ML20211L109

Insp Rept 50-322/86-10 on 860416-0531.No Unacceptable Conditions Identified.Major Areas Inspected:Previous Insp Items,Facility Operations,Lers & Followup of IE Notices, Bulletins & Generic Ltrs

ML20211L109
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/24/1986
From:	Strosnider J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20206M800	List: IR 05000322/1986010 ML20206M794 ML20211L109
References
50-322-86-10, GL-83-28, IEIN-85-030, IEIN-85-30, NUDOCS 8607010291
Download: ML20211L109 (13)

See also: IR 05000322/1986010

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l U.S. NUCLEAR REGULATORY COMMISSION

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REGION I .

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! REPORT N0. 50-322/86-10

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l DOCKET NO. 50-322

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I LICENSE NO. NPF-36

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l LICENSEE: Long Island Lighting Company

P. O. Box 618

i Shoreham Nuclear Power Station

i Wading River, New York 11792

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j INSPECTION AT: Wading River, New York

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{ INSPECTION CONDUCTED: April 16-May 31, 1986

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i INSPECTORS: John A. Berry, Senior Resident Inspector

i Clay C. Warren, Resident Inspector

APPROVED: ~

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! J. R. Strosnider, Chief, Reactors Projects 6 ate Signed  ;

, Section IB, Division of Reactor Projects

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j SUMMARY: During the period covered by Inspection Report 86-10, April 16,

j 1986 through May 31, 1986, 290 hours0.00336 days <br />0.0806 hours <br />4.794974e-4 weeks <br />1.10345e-4 months <br /> of direct inspection were

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performed by the Senior Resident Inspector, Resident Inspector

I and one region-based inspector.

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} No unacceptable conditions were identified during the

j inspections described in this report.

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i 9607010291 860625 ,i

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PDR ADOCK 05000322

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j 1. Status of Previous Inspection Items

] 1.1 Closed 86-08-03: Inadequate Local ~ Leak Rate Testing of BWR Vacuum ,

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Relief System Valves (IE Notice 86-16)

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i Shoreham has a different Containment design than the plants in the

i subject information notice (i.e. no Torus or Torus to Secondary

j vacuum breaker systems). However, SNPS has had similar problems with

l simulating the Integrated Test direction in Local Tests. The most

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similar case at SNPS to those in the Information Notice are the Con-

j tainment Purge and Vent lines-T46. The test frequency for valves in

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these lines has been increased per the present Technical Specifica-

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tions for reverse testing of these valves. They are also tested in

the Integrated test direction per the Appendix J schedule as recom-

i mended in the Information Notice using a blank flange inside Contain-

l ment. This adequately addresses possible leakage paths for these

valves. Another possible concern are flanged connections at valves <

j in the Appendix J test program. These are addressed by a special

i maintenance bolting procedure SP35.121.02 to assure proper flange

! tightness.

This item is closed.

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j 1.2 Closed 86-08-05: Failure of _ Automatic Sprinkler System Valves to

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Licensee review of the facility fire suppression systems showed that

no ASCO valves of the same type listed in IE Notice 86-17 are in-

stalled at Shoreham.

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j This item is closed.

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1.3 Closed 84-29-01: Bahnson Air Handling Units

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i I&E Information Notice 85-30 was provided to inform licensees of

j potentially significant discrepancies in record keeping and material

j defects identified on heating, ventilation, and air conditioning

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(HVAC) equipment manufactured by the Bahnson Company (a division of

i Flakt, Inc.) of Winston-Salem, North Carolina. Millstone 3 and

Shearon Harris have found discrepancies in record keeping and ma-

i terial defects. It was found that factory NDE liquid penetrant in-

{ spections were incomplete and undocumented. Millstone 3 units had

low strength carbon steel fasteners substituted for the required

ASTM-A449 fan motor anchor bolts and self-tapping stainless steel

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screws for the required ASTM-A193-GRB8 cooling coil mounting bolts.

Shearon Harris units had welds with cracks, lack of fusion, and

i undercut exceeding 1/64 inch. There were also missing welds and

i welds not made in accordance with the design drawings.

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As a result of these findings, Board Notification 84-006 (2/9/84)

was made by NRR for the Shoreham Nuclear Power Station.

The Shoreham Station uses four safety-related air conditioning units

(ACUS) supplied by Bahnson (shipping date 9/75-5/76). These units

(S&W Mark Nos. IX61*ACU-007A&B) supply cooling air to the control

room and relay room, respectively.

Upon issuance of the Board Notification and IE Information Notice,

the licensee initiated an inspection of all accessible areas of each

ACU's internal / external structures. These inspections resulted in

the following LILCO Deficiency Report (LDRs):

Equipment

LDR No. Date Mark No. Service

2167 03/07/84 1X61*ACU-007A&B Cantrol Room (CB E1. 63')

2168 03/07/84 IX41*ACV-014A&B Relay Room (CB El. 44')

2470 08/06/84 1X41*ACU-0148 Re1ay Room (CB E1. 44')

2471 08/06/84 1X41*ACU-014A Relay Room (CB El. 44')

2472 08/06/84 1X61*ACU-007A Control Room (CB E1. 63')

2473 08/06/84 IX61*ACU-007B Control Room (CB El. 63')

2537 11/05/84 IX61*ACV-007A Control Room (CB El. 63')

Typical nonconformances identified in the above LDRs were: weld

splatter, discontinuity, undercut, excessive convexity and lack of

fusion on structural members; cooling coil / air filter support braces

missing; various weld detail discrepancies with design drawings;

lower-strength bolting substitutions made on the inlet bell and its

support attachments. While these inspections were limited to

external welds and internal welds which were readily accessible, the

engineering disposition would address the adequacy of the remaining

welds without further inspections required.

In a follow-up to the licensee's corrective actions on the Bahnson's

HVAC equipment deficiencies, NRC Inspections 50-322/84-50 and 85-02

were conducted by the Resident Inspector. Unresolved Item 84-29-01

was identified to permit NRC review of the seismic structural

calculations prepared by Corporate Consulting, Ltd. (CCL) for

Bahnson/Flakt to address the LDR-specific deficiencies for both the

welds inspected "as-built" as well as the inaccessible, " hidden",

welds.

Unresolved item 84-29-01 was updated in NRC Inspection Report

50-322/85-02. The inspector reviewed the LDR's and expressed a con-

cern over the engineering disposition. The concern related to the

fact that because of the relatively small number of welds inspected,

and the high number of deficiencier found, that either 1) the remain-

ing welds should be inspected or 2) satisfactory justification should

be provided for why further inspection is not necessary. The item

remained unresolved pending NRC review of the licensee's final engi-

neering dispositions and seismic calculations.

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The licensee reviewed the disposition of the LDR's and concluded

that upon satisfactory completion of the LDR reworks, the structural

integrity of Shoreham's Bahnson ACUS will not be compromised in

performing its intended safety function under design basis loads.

That conclusion was based upon additional calculations performed in

response to the inspectors concerns expressed in NRC Inspection

Report 85-02, as well as previous calculations.

The seismic calculations were performed assuming that the " hidden"

welds did not exist. The calculations showed that with this assump-

tion the ACOs would still perform their intended safety function.

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Non-conforming bolting material was replaced under LDR rework. Based

on the inspectors eview of the seismic calculations, and the LDR

i rework, this item is closed.

1.4 Closed 84-29-06: Generic Letter 83-28, Salem ATWS Event

NRR review of Licensee Actions in response to Generic Letter 83-28

acknowledges that the facilities response to the NRC's concerns were

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adequate. A letter dated April 9, 1986 from Walter R. Butler, BWR

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Project No. 4 Directorate, Director Division of BWR Licensing to

John D. Leonard, Vice President Nuclear Operations, LILCO, documents

this satisfactory Licensee response.

This item is closed.

2. Review of Facility Operations

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2.1 Plant Status Summary

During the period covered by inspection report 86-10 the facility

remained in a shutdown condition while the licensee plugged

! condenser tube leaks (See Section 9.0) and performed 18 month

surveillance activities.

2.2 Operational Safety Verification

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The inspector toured the control room daily to verify proper shift

manning, use of and adherence to approved procedures, and compliance

with Technical Specification Limiting Conditions for Operation.

Control panel instrumentation and recorder traces were observed and

the status of annunciators was reviewed. Nuclear instrumentation

and reactor protection system status were examined. Radiation

monitoring instrumentation, including in plant Area Radiation

monitors and effluent monitors were verified to be within allowable

limits, and observed for indications of trends. Electrical

distribution panels were examined for verification of proper lineups

of backup and emergency electrical power sources as required by the

Technical Specification. .

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The inspector reviewed Watch Engineer and Nuclear Station Operator

logs for adequacy of review by oncoming watchstanders, and for proper

entries. A periodic review of Night Orders, Maintenance Work

Requests, Technical Specification LCO Log, and other control room

logs and records were made. Shift turnovers were observed on a

periodic basis.

The inspector also observed and reviewed the adequacy of access

controls to the Main Control Room, and verified that no loitering by

unauthorized personnel in the Control Room Area was permitted. The

inspector observed the conduct of Shift personnel to ensure

adherence to Shoreham Procedures 21.001.01, " Shift Operations" and

21.004.01, " Main Control Room - Conduct for Personnel".

The inspector noted that on-shift personnel conducted themselves in

a dedicated and professional manner, and that watchstanding

personnel were fully aware of plant status and ongoing activities.

No unacceptable conditions were identified.

2.3 Plant and Site Tours

The inspector conducted periodic tours of accessible areas of plant

and site throughout the inspection period. These included: the

Turbine and Reactor Buildings, the Rad Waste Building, the Control

Building, the Screenwell Structure, the Fire Pump House, the

Security Building, and the Colt Diesel Generator Butiding.

During these tours, the following specific items were evaluated:

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Fire Equipment - Operability and evidence of periodic

inspection of fire suppression equipment;

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Housekeeping - Maintenance of required cleanliness levels;

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Equipment Preservation - Maintenance of special precautionary

measures for installed equipment, as applicable;

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QA/QC Surveillance - Pertinent act'vities were being surveilled

on a sampling basis by qualified QA/QC personnel;

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Component Tagging - Implementation of appropriate equipment

tagging for safety, equipment protection, and jurisdiction;

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Personnel adherence to Radiological Controlled Area rules,

including proper Personnel frisking upon RCA exit;

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Access control to the Protected Area, including search

activities, escorting and badging, and vehicle access control;

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Integrity of the Protected Area boundary.

! No unacceptable conditions were identified.

2.4 Administrative Matters

2.4.1 Review of Operations Committee (ROC)

Several Review of Operations Committee Meetings were

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attended by the inspector during the inspection period.

During these meetings, the inspector verified the required

Technical Specification composition and quorum for the

committee. The inspector also verified that appropriate

reviews of safety evaluations and issues were presented.

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No unacceptable conditions were identified.

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2.4.2 Plant Organizational Changes

During this inspection period, the following organizational

changes occurred:

. Mr. Jeffrey L. Smith was appointed as Corporate

Director of Training, responsible for both nuclear

and fossil training.

. Mr. Brian McCaffrey was appointed Manager, Nuclear

Operations Support Department, replacing Mr. Smith.

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j . Mr. Chuck Daverio was appointed Assistant to the Vice

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President-Nuclear Operations, replacing Mr.

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McCaffrey.

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! . Mr. Doug Crocker was appointed Section Head, Offsite

1 Emergency Preparedness Section, replacing Mr. W.

{ Renz, who resigned.

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1 . Mr. Gary Krieger was appointed Section Head, Onsite

Emergency Preparedness Section, replacing Mr.

Crocker.

. Mr. Dennis Spencer, Section Head, Drill Scenario-and

Development Section, Emergency Preparedness Division,

resigned.

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. Mr. Mark Potkin was appointed as Modification

Engineer, Outage and Modifications Division,

replacing Mr. R. Gutman who was previously promoted

to the position of Manager, Nuclear Contracts &

Material Control Division.

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3. Licensee Reports

3.1 In Office Review of Licensee Event Reports

The inspector reviewed Licensee Event Reports (LERs) submitted to

the NRC to verify that details were clearly reported, including

accuracy of the cause description and adequacy of corrective action.

The inspector determined whether further information was required

from the licensee, whetner generic implications were involved, and

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whether the event warranted onsite follow-up. The following LERs

were rcviewed:

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86-17 Source Leak Test not performed on a sealed source prior to

being put in use.

86-18 Unmonitored discharge of non-radioactive water (less than

minimum detectable activity) from the condensate storage

tank sump.

No unacceptable conditions were noted.

4. Monthly Surveillance and Maintenance Observation

4.1 Surveillance Activities

The inspector observed the performance of various surveillance tests

to verify that; the surveillance procedure conformed to technical

specification requirements, administrative approvals and tagging

requirements were reviewed and approved prior to test initiation,

testing was accomplished by qualified personnel, current approved

procedures were used, test instrumentation was currently calibrated,

, limiting conditions for operation were met, test data was accurately

and completely recorded, removal and restoration of affected '

components was properly accomplished, and tests were completed

within the required Technical Specification frequency.

In the area of surveillance testing, the facility conducted an

extensive program to complete a large number of 18 month tests that

would have come due during the next three months. This licensee

effort was conducted to ensure that no shutdowns would be necessary

to perform surveillances once the low power testing program is

resumed.

The bulk of the 18 month surveillances were performed on the

Emergency Diesel Generators including operating emergency diesel

lockout feature test, operating emergency diesel load reject test

from both rated and partial load, operating emergency diesel loss of

offsite power test, operating emergency diesel loss of offsite power

test with emergency core cooling system actuation and operating ,

emergency diesel generator 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> full load run.

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In addition to 18 month diesel generator testing, the licensee also

conducted 18 month manual and automatic initiation tests of both

loops of the Core Spray, Low Pressure Coolant Injec. tion Mode of the

Residual Heat Removal System and Reactor Building Service Water

Pumps.

The inspectors monitored the performance of the following surveil-

lance items to ensure procedural compliance, system performance,

procedural adequacy and Technical Specification satisfaction:

24.307.01 Electrical Power Systems /AC Sources-Operating Emergency

Diesel Generator Load Test

24.307.02 Electrical Power Systems /AC Sources-Operating Emergency

Diesel Generator Test Mode Override Verification -

24.307.03 Electrical Power Systems /AC Sources-Operating Emergency

Diesel Generator Load Reject Test

24.203.04 Electrical Power Systems /AC Sources-Operating Emergency

Diesel Generator Loss of Offsite Power with Emergency Core

Cooling System Actuation

24.307.02 Electrical Power Systems /AC Sources-Operating Emergency

Diesel Generator 24 Hour Run Test

24.203.04 Plant Systems / Reactor Building Service Water Automatic

Pump Start Operability Test

24.203.04 Plant Systems / Reactor Building Service Water Automatic

Valve Accident Signal Operability Test

No unacceptable conditions were identified.

4.2 Maintenance Activities

The inspector observed the conduct of various maintenance activities

throughout the inspection period. During this observation, the in-

spector verified that; maintenance activities were conducted within ,

the requirements of the plant's administrative procedures and techni-

cal specifications, proper radiological controls were implemented and

observed, proper safety precautions were observed, and tnat activities

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which have the potential to impact plant operations are properly co-

ordinated with the control room.

During the inspection period the following maintenance activities

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Main condenser tube leak repairs,

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Repair to plant exhaust ventilation radiation monitor,

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Electro-hydraulic control system pump removal, ins,allation and

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M-50 system chiller condenser tube cleaning

No unacceptable conditions were noted.

5. Review and Followup of I&E Notices, Bulletins and Generic Letters

5.1 I&E Notices

The inspector reviewed notices issued by the Office of Inspection and >

Enforcement during the inspection period. Review was to determine;

if the subject of the notice was applicable to the Shorcham Nuclear

Power Station, and if followup of the licensee's action was required

by the inspector.

The following IE Information Notices were received during the period

covered by Inspection Report 86-10:

IE Notice No. 86-23: Excessive Skin Exposure Due to

Contamination with Hot Particles.

IE Notice No. 86-24: Respirator Users Notice: Increased

! Inspection Frequency for Certain Self-

contained Breathing Apparatus Air

Cylinders.

IE Notice No. 86-25: Traceability and Material Control of

Material and Equipment, Particularly

Fasteners.

IE Notice No. 86-26

Potential Problems In Generators

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Manufactured by Electrical Products

Incorporated.

IE Notice No. 86-27: Access Control at Nuclear Facilities.

IE Notice No. 86-29: Effects of Changing Valve Motor-Operated

Switch Settings.

IE Notice No. 86-30: Design Limitation of Gaseous Effluent

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Monitoring Systems.

IE Notice No. 86-31: Unauthorized Transfer and Loss

of Control of Industrial Nuclear Gauges.

IE Notice No. 86-32: Request for Collection of Licensee

Radioactivity Measurements Attributed to

the Chernobyl Nuclear Plant Accident.

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IE Notice No. 86-34: Improper Assembly, Material Selection and

Test of Valves and Their Actuators.

IE Notice No. 86-35: Fire in Compressible Material at Dresden

Unit 3.

IE Notice No. 86-36: Change in NRC Practice Regarding Issuance

of Confirming Letters to Principal

Contractors.

IE Notice No. 86-37: Degradation of Station Batteries.

IE Notice No. 86-38: Deficient Operator Actions Following Dual

Function Valve Failures.

IE Notice No. 86-39: Failures of RHR Pump Motors and Pump

Internals.

IE Notices 86-26, 86-31, 86-36 and 86-39 are not applicable to

Shoreham. Shoreham was the subject of IE Notice 86-34 and has

satisfactorily completed action to resolve the problems identified

in the notice. Licensee response to all remaining notices will be

reviewed as part of future routine resident inspections.

6. Survey of Licensee's Response to Selected Safety Issues

The inspectors reviewed the licensee's response to selected safety issues

in response to Temporary Instruction 2515/77. Licensee response to

recommendations on reliability of high pressure coolant injection / reactor

core isolation cooling systems and on biological fouling of cooling

water heat exchangers were reviewed. The licensee has adequately

addressed the recommended actions. The inspector had no further questions.

7. Annual Review of Licensee Radiological Environmental Monitoring Program

The inspector reviewed the licensee's Radiological Environmental

Monitoring Program annual report for 1985. This report summarizes the

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results of the sampling and analyses of environmental media to determine ,

the radiological impact of station operations. These environmental media

include air, water, vegetation, and aquatic plants and animals. In

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addition, direct radiation is monitored by-placement of thermoluminescient

i dosimeters at various locations around the station,

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As a result of this review, the inspector determined that the licensee has

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generally complied with its environmental Technical Specification require- 1

ments for sampling frequencies, types of measurements, analytical sensi-

tivities, and reporting schedules. Exceptions to the sampling and analysis

program were adequately explained, e.g., low air sample volume analyzed

due to sample pump power failure. The report included summaries of the

laboratory quality assurance program and of the land use survey.

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The analyses of environmental samples indicated that doses to humans from

radionuclides of station origin were negligible.

8. Licensee Response to CAL 86-05 Dated March 21, 1986

In response to CAL 86-05 the licensee issued a 30-day letter dated April

18, 1986 outlining actions taken to correct deficiencies identified in

Special Inspection 50-322/86-03. This letter (SNRC-1249) provides

information requested by Item 4 in CAL 86-05 and is outlined below.

8.1 Vice President Nuclear Operations / Plant Manager Activities

Meetings were held between the Vice President Nuclear Operations,

Plant Manager and Local 1049 IBEW Representatives to emphasize the

importance the licensee places on the concept of personal

accountability and responsibility.

j The Vice President Nuclear Operations and Plant Manager held a

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meeting with facility foreman and line supervisors to encourage open

communication on matters effecting quality of safety. A meeting

emphasizing the same matters was also held with plant section heads.

The licensee has taken a more aggressive attitude in the personnel

recruitment area in an attempt to reduce the number of contractor

personnel filling supervisory positions. Results of this effort are

not yet conclusive but a positive trend appears to be developing.

This is evidenced by the licensee's recruiting and hiring qualified

personnel to fill three supervisory positions within the

i Radiochemistry Department. In addition to filling these supervisory

positions the licensee has been able to successfully recruit five

technicians to fill vacant positions.

Plant Manager directives have been issued in an effort to increasing

management attention and responsiveness to quality assurance audit

findings, improving administrative control over personnel training

and qualification programs, establishing a personnel resources

, report that will enable the plant manager and Vice Fresident Nuclear

Operations to be better appraised of vacancies and personnel

transfers, and improving observations of work being performed in the

plant by division managers and section heads.

8.2 Quality Assurance Actions

! In the Quality Assurance area, an action plan has been developed

instituting programmatic changes, audit actions and quality

assurance training improvements designed to remedy the problems

identifi J by Inspection 86-03 of the radiochemistry area.

Programmatic changes have been made within the Quality Assurance ,

process to ensure a timely resolution of quality concerns. At the

direction of the Quality Assurance Manager changes were instituted

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to increase the distribution of QA Audit Reports to all department

managers regardless of the audit area, in an attempt to increase

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interdepartmental attention. Format changes in the Quarterly Trend

Analysis Report, Quarterly Audit Finding Summary and Quality

, Assurance Open Item List have been made to increase the usefulness

of these reports. These changes should assist management in keeping

abreast of outstanding Quality Assurance Open Items, timeliness of

response, response acceptability and potential for adverse trend.

The licensee contracted an independent assessment of the facility

Quality Assurance Program. The audit assessment report was

j presented to the Nuclear Review Board on April 18, 1986.

In the audit area, two audit related actions have taken place in

response to Special Inspection 86-03. A Quality Assurance audit of

the Health Physics Section was performed and findings have been

discussed with the lead auditor, the Health Physics Engineer and the

Radiological Controls Division Manager. The results of this audit

report can be found in Inspection Report 86-07. In addition to the

above audit the QA Division Manager moved up scheduled Nuclear Review

Board Training Audit and QA Training Audits to April from their

originally scheduled dates. The Training and Qualification audit

was conducted by a twelve man audit team that expended over 1,000

man hours in audit preparation and conduct. The audit indicated

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proper qualification of personnel with no problems similar to the

qualification deficiencies identified in the radiochemsitry area

(See Inspection Report 86-03 for further details). However, the

audit report did result in 35 audit findings and 19 observations

spanning all areas from program / procedure development through record

keeping. As a result of these findings the audit report recommended

further management attention be applied in the training and

qualification area to assure timely resolution of these audit

findings and observations.

Actions have been or will be taken in the QA training area to enhance

4 the activities of Quality Assurance personnel conducting audits.

, QA auditors will receive or have already completed training in Health

Physics, Radiochemistry, Operations and Radwaste operations. This

training should enable the Quality Assurance auditors to improve

their technique in these areas.

8.3 Training Actions

The Vice President Nuclear Operations ordered an immediate update of

all qualification and training records in response to findings in

Special Inspection 86-03. As part of this effort all qualification

file folders have been updated and a qualification matrix performed.

In the future these files will be updated on a monthly basis until

software changes can be made to allow training records to be placed

in a computer data base at which time updating will be maintained

continually.

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This inspector has no further questions.

9. Condenser Tube Leaks

During late April the licensee noted a gradual increase in condensate

system conductivity and chloride concentration, indicative of condenser

seawater inleakage. Further investigation using installed conductivity-

elements indicated inleakage in three of four condenser quadrants with

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only the 'B' quadrant showing no indication of leakage.

The facility opened the waterboxes that indicated leakage and performed

soap tests on the tubesheets. Soap bubble testing indicated that the 'A'

quadrant had 10 leaks, the 'C' quadrant had 28 leaks and the 'D' quadrant

had 22 leaks. The leaks were found to be at the tube /tubesheet interface

and all leaking tubes were characterized by a small bulge or bubble on

the inner tube surface. The bulges appeared uniform in size and shape

being approximately one-eighth inch high, one-third inch wide and three-

quarter inch long.

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A complete mapping of all tubes indicated approximately two hundred tubes

had the same bulge formation and all were subsequently plugged to stop

known leaks and preclude any further leaks from bulged tubes.

In an attempt to identify the cause of the bulging a tube was cut to

determine if a chemical reaction was occurring between the titanium tubes

and the munz metal (admiralty brass) tube sheet. There was no evidence

of corrosion at the tube /tubesheet interface and this mechanism has been

eliminated. One additional tube was removed, with the bulge intact, and

shipped to an independent metallurgical laboratory in hopes of

determining the mechanism by which the bulges are formed. The results

of that analysis are not yet available.

j The condenser is currently in service and no additional tube leakage is

evident.

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10. Management Meetings

At periodic intervals during the course of this inspection, meetings

were held with licensee management to discuss the scope and findings

of this inspection.

Based on NRC Region I review of this report, and discussions with

licensee representatives, it was determined that this report does

not contain information subject to 10 CFR 2.790 restrictions.

The inspectors also attended entrance and exit interviews for

inspections conducted by region-based inspectors during the period.

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