IR 05000483/1985002

Notifies That Insp of Concerns Noted in 850205 Ltr Re Certification of Level III Inspectors Completed & Documented in Paragraph 4 of Encl Insp Rept 50-483/85-02.Info Deleted

ML20134A625
Person / Time
Site:	Callaway
Issue date:	07/15/1985
From:	Weil C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	AFFILIATION NOT ASSIGNED
Shared Package
ML20134A622	List: IR 05000483/1985002 ML20134A620 ML20134A628 ML20134A632 ML20134A636
References
FOIA-85-655 NUDOCS 8511070439
Download: ML20134A625 (1)

Text

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July 15, 1985

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On February 5,1985, you provided the U. S. Nuclear ~ Regulatory Comission with information concerning the cert,ification of Level III inspectors at the Callaway fiuclear Plant. Our irispection into your concerns has been completed and documented in Paragraph 4 of the enclosed Inspection Report.

Your cooperation with the 11. S. Nuclear Regulatory Comission was greatly appreciated.

Sincerely, Origir.a1 signed by Charles'il. Fleil Charles H. k'eil Investigation and Compliance Specialist

Enclosure:

Inspection Report tio. 50-483/85002 Ati 350togD5ay '

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AMS fio. RIII-85-A-0021 Docket tio. 50-483

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Docket No. 50-453 .

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Union Electric Company ATIK: Mr. Donald T. Schnell Vice President - Nuclear

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Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen: *

This refers to the routine inspection conducted by Messrs. B. H. Little and C. E. Brown of this office on January 20 through March 9, 1985, of activities at Callaway Nuclear Plant authorized by NRC Operating License No. NFP-30 and to the discussion of our findings with Mr. Steve E. Miltenberger at the con-clusion of the inspection.

The enclosed copy of our inspection report identifies areas exacined during the inspection. k'ithin these areas, the inspection consisted of a selective exacination of procedures and representative records, observations, and inter-views with personnel.

No itees of noncompliance with NRC requirements were identified during the course of this inspection.

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REGION III t ~

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Report No. 50-463/85002(DRP)

Docket No. 50-483 . License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166

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, Facility Name

Callaway Plant, Unit 1

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Inspection At: Callaway Site,'Steedman, MO 65077 Inspection Conducted: January 20 through March 9,1985  !

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Inspectors

E. H. Little

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l C. H. Erown

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7 p Approved By: V. L. Forn y, ief /8 Reactor Projects Section 1A Date

, , Inspection Su=mery i

! Inspection on January 20 through March 9, 1985

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(Recort No. 50-483/85002(DRP))

Areas Inspected: Routine unannounced safety inspection by the resident inspec-tors of licensee event reports, SER and open items, allegations, regional I

requests, licensee events, cold weather protection, compliance with Technical

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Specifications, routine licensee activities and plant tours. The inspection i involved a total of 196 inspector-hours by two NRC inspectors including" 58 ,

l inspector-hours onsite during off-shif ts.

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Results: No items of noncompliance or deviations were identified.

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DETAILS

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1. Persons Contacted

• S. E. Miltenberger, Manager, Callaway Plant D. F. Schnell, Vice President - Nuclear -

• D. C. Poole, Assistant Menager Operations and  ;

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Maintenance

• R. 1.. Powers, Assistant Manager - Quality j Assurance

M. E. Taylor, Operations Superintendent -

j R. F.. Leuther, Maintenance Superintendent

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J. E. Davis, Compliance Superintendent E. L. Wickes, Instrumentation and Control Supervisor

J. C. Gearhart, Supervisory Engineer - QA t l

l *P. T. Appleby, Assistant Manager (SS)

J. R. Vestch, Supervisor Engineering - QA -

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J. T. Patterson, Assistant Superintende.t Operations

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C. D. Naslund, Superintendent, Instrumentation and

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Control

• J. V. Laux, Supervisor - QA l *V. A. Norton, Engineer - QA

{ *A. P. Neuhalfen, Assistant Manager - Administrative

• 0. E. DuBois, Engineer Consultant - QA f

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• V. R. Robinson, Compliance Supervisor

• Denotes those present at one or more exit interviews, ,

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In addition, a number of equipment operators, Reactor Operators and Senior

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Reactor Operators, and other members of-the QC and Operations and Mainten-ance staffs were contacted.

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i 2. Licensee Event Report Follovun

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l Through direct observations, discussions with licensee personnel, and i

review of records, the following event reports were reviewed to determine l'

that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been acco=plished.

(Closed) LER 84-046 - Inadvertent Engineered Safety Features Actuation:

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On October 5, 1984, a reactor trip was initiated by low level signals from j th* "E" steam eenerator (S/G). The trip was due to one channel being in .

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(Closed) LER 84-047 - Unplanned Reactor Trip: On Octob,er 6, 1964, an 1&C technician was performing maintenance on the Source Range Nuclear Instru-mentation power supply cables and removed both instrument and control power

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fuses to the Source Range high voltage power supply. This caused .a trip as the plant had just changed modes. Procedure APA-ZZ-00320, " Initiating and Processing Work Requests", has been revised effective November 16, 1984, to provide an attachment to the work documents to better inform work groups and operations personnel of the consequences of a work ar.tivity.

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(Closed) LER 84-051 - Unexpected Steam Dump Operation Causing a Feedwater Isolation Signal (FWIS): On October 14, 1984, (plant at 3% in Mode 3) a

FVIS was generated by level " swell" in the S/G (hi-hi level) due to the i steam dump velves going from 20% to 40% flow. The FWIS did not actually occur as the plant was in Mode 2 at 3% power and auxiliary feed was

, supplying the S/G at the time. A dynamic steam dump control test was perforced satisfactorily and the problem has not reccurred.

(Closed) LER 84-053 - Technical Specifications Violations: The Technical Specification 3.3.3.10(b), Action 42, requires a grab sample to be taken from the Water Gas Holdup System every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> if the outlet oxygen

monitor on a hydrogen recombiner is inoperable. On October 17, 1984, the sample was taken outside the required time period. The oxygen concentra-tion of the sa=ple was found withir. specifications. The chemistry techni-cians were retrained on the required samples, and the use of the status board has been clarified.

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. (Closed) LER 84-054 - Inadvertent Engineered Safety Features Actuation:

Two sicilar events caused actuation of these features from fluctuations in the S/G water levels due to adjustment on the Power Range Nuclear Instrumentation made on Octcber 19, 1984, and October 21, 1984. One

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adjusteent was an increase in gain and the other was when the gain was

. - reduced. The procedure was revised to allow putting the level controllcrs

, in manual while the gain of power range instrumentation was being adjusted.

Additional training wa,s provided to the operators on the S/G level con-troller system.

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(Closed) LER 84-055 -- Unplanned Actuation of Engineered Safety Features:

On October 21, 1984, a hi-hi level on S/G "A" actuated the engineered safety features. The hi-hi level resulted f rom incomplete review of the consequences of calibrating the level control system without taking the feedwater controller out of automatic control. The work control procedures

, have been revised to make the consequence of maintenance activities one of

, the points of consideration prior to initiating the work activity.

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(Closed) LER 84-056 - Inadvertent Engineered Safety Features Actuation:

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Licensee action to prevent recurrence included revising plant procedures OTN-AC-00001 (Main Tbrbine and Generator Systems) and OTG-ZZ-00003 (Plant Startup Less Than or Equal to 5% to 20% Power). The revised procedures restrict rolling of the main turbine for periods of longer than one hour and at power levels greater than 10% reactor power.

(C1'osed) LER 84-057 - Inadvertent Engineered Safety Features Actuations:

On October 27, 1984, a reactor trip and ESF actuation occurred as a result of a low level in S/G "A". The event occurred during the transfer of feedwater flow control from the bypass valve to the main control valve.

The main feedwater control valve failed due to a blown fuse.

Although considered to be a single random f ailure, the licensee revised plant procedure OTN-AE-00001 (Feedwater System) which specifies that

. during valve transfer the main control valves be opened manually per-mitting the bypass valves, in automatic, to close maintaining S/G 1evel.

(Closed) LER 84-058 - Inadvertent Engineered Safety Features Actuation:

On October 30, 1984, with the plant'in Mode 1 at 301 power, an ESF actua-tion was initiated by a high level on S/G "B". The event resulted from S/G level oscillations following a spurious (vibration) trip of -the main turbine and faulty operation of the steam dump valves (T-ave Mode).

The licensee's review of this matter, identified a wiring terminatien deficiency which disabled the steam dump permissive (C-7) and prevented automatic operation of the steam dump valves. Vork Request No. 035944 was issued to correct the wiring deficiency and to perform e functional test of the steam dump valve operation. This work was completed on October 31, 1984 (Closed) LER 84-061 - Reactor Trip and Tbrbine Trip- On November 29, 1984,

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a reactor trip occurred while in Mode 1 at 801 reactor power as a result

, of a main turbine trip. The event occurred when a nonsafety-related transformer tripped on overcurrent due to excessive loading of two electrical buses, which ware supplying power to the main turbine Electro-hydraulic Control (EHC) oil pumps. .

The licensee has completed a review of bus loading on systems with the tie breaker in use. Based on that review, plant procedures OTN-NG-00001, OTN-PE-00001 and OTN-PG-00001 were revised to provide loactng restrictions when tie breakers are to be closed.

(Closed) LER 84-062 and 84-067 - Inadvertent Engineered Safety Features Actuations: On December 7 and 30, 1984, and on January 9, 1985, Contain-ment Purge Isolations and Control Room Ventilation Isolations occurred as i

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IEC technicians found a loose fuse clip to RM-80. This condition could have caused the initial blown fuse and the following event on December 30, 1984. The fuse clip was tightened and the unit returned to service.

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(Cdbsed) LER 84-064 - Reactor Trip During a 50% Load Reduction Test: On December 17, 1984, a reactor trip was received on rapidly decreasing pressurizer pressure,(rate sensitive). At the time of the event, a 50%

load reduction test (ETT-ZZ-07120) was in progress. The test was being

, performed with the PORV' block' valve closed due to excessive PORV leakage.

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The load reduction resulte'd in-an increase in plant pressure." When pressure approached the PORV setpoint, the reactor operator opened the PORV block valves. This action in conjunction with the pressurizer spray valves being fully open csused a rapid decrease in pressure and reactor trip.

Examination of the high speed recorder trace for pressurizer pressure

- showed that, although the RO acted correctly by unblocking the PORV's when it became obvious they would be challenged, the pressure had already peaked at approximately 2340 psig and had started decreasing. The total clapsed time f rom initiation of transient to reactor trip was 28.5 seconds and the minimum pressure encountered was approximately 2220 psig.

The licensee revised test procedure ETT-ZZ-07120 to require the PORV block valves to be open prior to' initiation of the load reduction. The test was co=pleted successfully on December 19, 1984.

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(Closed) LER's84-065 and 85-001 ' Reactor Trips Due t'o 'Feedwater Valve Deficiencies: On December 17 and 18,1984, and January 2, 1985, reactor trips were initiated by lo-lo S/G 1evels. Tbc first event resulted from a failed current-pressure (I/P) converter, the second event was caused by steam generator level oscillations which operators were unable to control due to a partially open main f eed regulating valve (AE-FCV-530). The third

,, event occurred when a failed solenoid in the valve control circuit caused

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a feedwater isolation valve to fast close.

The failed components, (1/P) converter, and solenoid were replaced. Plant procedure ITG-ZZ-FX023 was revised which specifies that feedwater isola-tion valves be correctly positioned during e.onverter calibration.

(Closed) LER 85-006 - Inadvertent Control Room Ventilation Isolation: On i January 25, 1985, a Containment Purge 1 solation'and Control Room Ventila-tion were actuated from a signal on the containment process monitor GT-RI-31. The containment was not being purged at the time of the event and did not result in a release of radioactivity.

Licensee review of the event determined that a small increase in gaseous arrie4 v ==v h a .. nees,er.A uhan the PORV hinck valves were stroke tested.

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Operations Department Night Orders issued January 25, 1965, directed that the containment process monitors GT-RE-31 and GT-RE-32 be placed in " bypass" when not purging the containment. This action was taken to reduce the number of engineered safety features actuations which have occurred from-spurious signals from the process monitors.

The inspector reviewed Technical Specification 3.3.3.1, Table 3'.3-6 and Action Statement 26. The Technical Specification permits continued opera-tions with the above monitors bypassed (inoperable) provided.that the containment purge valves are maintained closed.

No ite=s of noncompliance or deviations were identified.

3. Insoection of SER/Open Items .

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(Closed) Open Item (483/8t,.-32-07): Install correctly scaled paper for recorders GN-PR-934 and GN-PR-938 (GN-PR-938 was incorrectly identified in Inspection Report 84-32 as GN-PR-936). The lack of correctly scaled paper for the control room recorders was identified as a human engineering discrepancy during the NRC onsite audit on February 28 and 29, 1984. The inspector performed a control room walkdown and verified that the licensee has installed correctly scaled paper in the containment pressure recorders GN-PR-93.". and GN-PR-938.

(Closed) SER Item (4S3/83-32-34): The Radiation Protection Manager (RPM)

has participated in at least one refueling at another plant prior to fuel load.

The RPM training commitment to NRR was documented by a Ictter to NRR from the licensee dated September 9, 1983, and a letter to the licensee from NRR dated November 23, 1983. The resulting new co=mitment required the

.. Health Physics Superintendent (RPM) and the Health Physics Operations

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Supervisor to participate in only one refueling outage. To satisfy this commitcent, the health Physics Superintendent and the Health Physics Operations Supervisor participated in a refueling outage at the McGuire Nuclear Station. From discussions with the Health Physics Superintendent,

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the inspector determined that this on-the-job experience satisfied the co=miteent.

No items of noncompliance or deviations were identified. .

4 Followuo on A11egetions (Closed) Allegation RIII-85-A-0021: Procedures Not Followed-in the Certi-fication of Quality Control (QC) Inspectors (Level III). On February 5,

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pressing work assignment the inspector would meet with the resident inspec-tor the following day for further discussion. During the next meeting (February 6,1985), the QC inspector, in response to the resident inspec-tor's questions, stated that the inspector had not documented the above procedure violation nor had the inspector discussed this matter wit'h the Quality Assurance (QA) Department; however, the inspector knew that other QC inspectors had contacted QA personnel regarding this matter. With the QC inspector present and with his concurrence, the resident inspector con-tacted (by phone) the QC inspectors identified as having contacted QA.

These inspectors confirmed' that they had discussed the proced6re violation and the qualification concern of those recently certified.

On February 6, following the above meeting, the resident inspector inter-viewed members of the licensee's QA Department to assess QA response in

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this matter. The inspector was advised that on February 4,1985, QC inspectors had informed QA of the specific procedure violation and had expressed concerns regarding the qualifications of the QC Level III inspectors that had been recently certified. On February 5, 1985, the QA Supervisor (Operations) had initiated a QA surveillance in this matter.

The scope of the surveillance included not only QC inspectors' concerns but also a review of each QC inspector's qualifications and certifications and UENO-QC program administrative matters.

On February 8, 1985, QA issued a Request for Corrective Action (RCA)

No. P85-02-028 which documented the procedure violation and substantiates the QC inspector's allegation which was made to the NRC.

On February 22, 1985, QA issued Surveillance Report No. 850209 (Review of Certifications of UENO Quality Control Inspectors). This report identified additional deficiencies which have been documented on the following RCAs:

,. RCA No. Descrintion

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P-6502-034 Insufficient Records to Support QC Certifications P-8502-035 QC Inspectors Don't Have Needed Experience P-8502-039 Certification / Qualification Progra=

Deficiencies

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The inspector interviewed QA engineers during the performance of the QC surveillance, reviewed the QA surveillance report,.and the associated RCAs.

The inspector is satisfied that the QA department's response to the QC inspe ctors ' allegation and concerns was both prompt and thorough.

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No itees of noncompliance or deviations were identified. .

5. Followun on Regional Reouests a. Licensee Event Reports (LERs)

An inspection in this area was performed to assess the licensee's overall performance and threshold of documenting and reporting LERs, and to ascertain licensee' compliance with NRC reouirements (10 CFR 50.72 and 50.73) regarding notifications to the NRC Operations Center and reporting of events in LERs. The inspection included a review of 45 Incident Reports (irs) selected from IR Nos.84-894 through 85-112, a review of operating logs and LERs, and interviews with operations and compliance department personnel.

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In review of this matter the inspector found that 24 of the 45 irs resulted in LERs or'were declared potential LERs by the licensee.

Tne remaining 21 irs documented minor procedure and/or hardware deficiencies. " Multiple failures" were not identified during this review; however, the inspector found that the nature of deficiencies documented on irs indicate a low threshold of deficiency reporting and that reports to the NRC Operations Center included safety system response / performance.

This matter was discussed with the licensee during a routine exit meeting on March 1, 1985. The inspector stressed the intent of both 10 CFR 50.72 and 50.73 relating to the reporting requirements of cultiple failures in safety systems.

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Failure of Rockwell International Globe Valves (IE Information Notice St.-48)

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IE Inforcation Notice 84-48 alerted licensees of a potential defici-ency (separation of valve disc from valve stem) of valves used in loep RTD bypass lines. The inspector reviewed this matter to ascer-tuin the status of licensee's review of the subject Information Notice.

Tne licensee's review determined that Rockwell Globe valves were not installed in the loop RTD bypass lines at Callaway; however, the valves are installed in the reactor vessel level indicator system (RVLIS) and in nonsafety system applications. This is not a concern for the RVLIS since it is a static (no flow system).

No items of noncompliance or deviations were identified, i

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found that a discrepancy existed between the flow rates specified in

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the Technical Specification Section 3.7.6 (2000 cubic -f eet per minute (cfm) +/- 10%) and the system design flow (2200 cfm + 10% -0%). Work Requests (WRs) Nos. 36553 and 36554 were issued to measure the CREVS flow rates of the "A" and "B" trains and, if required, establish system total flow rate between 1980 and 2200 cfm. - -

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'The HVAC technicians, .during -the performance. of the VRs, noted that floe restricting plat,estthought ;to be required.on both trains were missing. Based on this belief : plant Incident.. Report,(IR) No.85-083 was issued. At 1645 on February 15, 1985, upon receipt of the IR, the shift supervisor declared both trains of the CREVS inoperable, placing the plant in the Technical Specification 3.0.3. Action Statement.

Subsequent system flow tests determined that the "B" train flow rates were within Technical Specification requirements, and the "A" train

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flow rates exceeded Technical Specification requirements.

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• Ibe "as f ound" data is as follows: -

A Train - Fan Speed 4150 rpm Filter Floe 624 cfm

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Cleanup T10w 2150.cfm .

Total System Flow 2774 cfm E Train - Fan Speed . ~.: .

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Filter Flow 509 cfm....;.;; . .

Cleanup Flow . .

1506 cfm .

Total System Flow . :2015 cfm VR No. 36553 was performed on the "A" train which reestablished the flow rates as required by the Technical Specification and the system

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was declared operable at 1630 on February 15, 1985.

The licensee's review determined that the excessive "A" train flows

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resulted from the removal of a flow restricting orifice plate which had been installed during system acceptance testing (co=pleted on April 6, 1984). The orifice plate was not_ documented on the con-trolled drawing (Bechtel Drawing No. M-618.3-0005) and subsequent system walkdowns and acceptance reviews did not detect the missing plate.

The licensee issued a Request for Resolution (RTR) No. 00743 to Bechtel to evaluate if the excessive system flows resulted in an unreviewed safety question. Bechtel evaluated various system flow ratas un to 300G cfm total flow and 1000 cfm filter flow. The safety L__---_------------

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Valkdown of all "Q" HVAC systems to verify placement of flow restricting plates and diffuser plates and that no unauthorized plates / orifices were installed.

• Reverified all preoperational test data used to satisfy Tech-nical Specification Surveillance requirements which have not

' been previously v.erified by performance of a plant surveillance procedure. ,,

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• Reverified all he'chnica'l Specification ventilation system flow rates by performance of the appropriate sections of permanent plant surveillance procedures.

The above action was completed on March 1, 1985. No ddditional system

- deficiencies were identified..

The inspector revieced the plant operating logs and Incident Reports Nos.85-082 and 85-083 which document the event and the Technical Specification violation and interviewed operations, compliance and site engineering personnel. The inspector verified that the violation as identified by the licensee was appropriately documented and reported to the NRC and that the licensee had taken pro =pt corrective action to prevent recurrence.

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b. Unusual Event - Lo'ss of Power (Electrical Busses PA01 and PA02)

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On February '22, 1985', the plant experienced a loss of electrical power to busses PA01 and PA02. This resulted in e loss of power to the reactor coolant pumps and rod drive motor generator sets: At the time of the event, the reactor was at 0.3% power. In response to the reactor operator's inability to move control rods, the unit was

.- canually tripped and the licensee declared an unusual event.

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The less of power to the two PA busses was the result of the startup

transformer tripping on a deluge system actuation. The deluge system

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actuation was caused by water. entering the outside hand pull switch. .

The licensee is processing a Callaway Modification Package (CMP) which l

will codify the deluge actuation scheme such that the main and startup transformers would have to be off line before the deluge system would activate. The-licensee plans to implement the CMP during the next scheduled shutdown.

The resident inspector was in the control room at the time of the event and observed plant system and operator performance until the

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7. Cold Weather Protection In January 198' 5 , an inspection was performed to ascertain that the licen-see's cold weather protection program had been implemented and maintained.

i The inspection included a review of IE Bulletin No. 79-24 (Frozen Lines),

Callaway Plant Procedure APA-ZZ-00302 (Cold Weather Preparation), and cold weather inspection checklists. The inspector performed in-plant and out-4 plant walkdowns to d' etermine that adequate protective measures were implace for safety-related process. instrument and sampling lines. Areas inspected i

included the essential service pump rooms, condensate storage and refueling water storage tank areas, RHR, emergency diesel generators and radwaste areas.

The inspector found that line and tank insulation, heat tracing and space heating were being maintained.

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, No items of noncompliance or deviations were identified.

i i E. Compliance with Callaway Plant Technical Specifications J

l Through in plant inspections of system line-ups, control room valve and  ;

i breaker indications, the review of chemistry logs, calibration data and

plant records, the inspector verified compliance with the following i Technical Specifications.

Technical Specifications

r 3.1.1 Boration Control Shutdown '

Margin - T-AVG More Then 200 degree F 3.2.1 Axial Flux Difference 3.2.4 Quadrant Power Tilt Ratio 3.3.3.5 Remote Shutdown Instrumentation *

3.4.7 Reactor Coolant System Chemistry

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ECCS Accumulators

, 3.5.2 ECCS Subsystems Average Temperature Above 350 degree F

3.7.3 Component Cooling Water System i 3.7.5 Ultimate Heat Sink 3.8.1.1 AC Sources

' The inspector reviewed Technical Specification 3/4.1 (Reactivity Control Systems Surveillance Requirements), 4.1.1.1.1, 4.1.1.1.2, the licensee's supporting documents, and operating logs. This included a review ~of Sur-veillance Task Sheet No. 0004270 and the supporting engineering evaluation which were done based on the overall core reactivity balance. The pre-dicted reactivity values were normalized to correspond to the actual core condition prior to exceeding 60 EFPD.

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s. Fire team response to a fire alarm (2000 ft. level reactor auxiliary building). There was no fire - grinding in area had set of f a smoke detector.

Emergency Diesel Generator (NE02).

b. Preventive maintenance of the "B" Operability checks on NE01 and the operability surveillance performed on NE02 prior to declaring the unit in serv. ice were observed.

c.

16C Surveillance"I'S'F-BB-OP'458 '(Funct ional Test ; Pressurizer Pressure) .

d. Radiological Emergency Response Drill (January 30, 1985).

e. Removal of Temporary Modification No. 84-3-167 Work Request No. 4899 (Install Parts in NE107). Operability checks on Emergency Diesel

- Generator (NE02) were observed.

The inspector reviewed also'ciated work documents and procedures and veri-fied that the Technical Specifications were met and/or licensee adminis-trative controls were adhered to.

No ite=s of noncompliance or deviations were identified.

10. Plant Tours The inspector toured site and plant areas frequently during this inspection period to observe housekeeping conditions and practices , ' plant operations, control room activities, and maintenance and surveillance testing activi-ties. Tne inspector reviewed control room logs and observed shif t turnovers.

No items of noncompliance or deviations were identified.

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11. Open Ite=s

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Open itecs are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 4.

12. Exit Int e rview ~

The inspector met with licensee representatives (denotedThe under Persons inspector Contacted) at intervals during the inspectic period.

sum =arized the scope and findings of the ir.=pect ion . The licensee repre-sentatives acknowledged the findings as reported herein. The inspector

- - 4 s - . * 4 -a a l enntent of the inspection report i

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