IR 05000313/2009006

IR 05000313-09-006 and 05000368-09-006, on 01/19/2009-02/20/2009, Arkansas Nuclear One, Units 1 and 2, Biennial Baseline Inspection of the Identification and Resolution of Problems

ML090930276
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/03/2009
From:	Greg Werner NRC/RGN-IV/DRS/PSB-2
To:	Mitchell T Entergy Operations
References
IR-09-006
Download: ML090930276 (25)

Text

April 3, 2009 Mr. Timothy Vice President Operations Arkansas Nuclear One Entergy Operations, Inc. 1448 S.R. 333 Russellville, AR 72802-0967

SUBJECT: ARKANSAS NUCLEAR ONE - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000313/2009006 AND 05000368/2009006

Dear Mr. Mitchell:

On February 20, 2009, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at Arkansas Nuclear One. The enclosed report documents the inspection findings, which were discussed on February 20, 2009, with Brad Berryman, General Manager Operations, Acting Site Vice President, and other members of your staff.

The inspection examined activities conducted under your license as they relate to identification and resolution of problems, safety and compliance with the Commission's rules and regulations and with the conditions of your operating license. The team reviewed selected procedures and records, observed activities, and interviewed personnel.

The International Atomic Energy Agency conducted an Operational Safety Review Team Evaluation at Arkansas Nuclear One from June 15 through July 2, 2008. The Operational Safety Review Team's review included an evaluation of your corrective action program which is documented in a report (ADAMS Accession Number ML083440148) which is accessible from the NRC Web-site at www.nrc.gov/reading-rm/adams.html. Nuclear Regulatory Commission personnel closely monitored the team's activities and deemed it appropriate to assess a 50 percent credit for the baseline problem identification and resolution inspection in accordance with the guidance provided in Inspection Manual Chapter 2515, "Light-Water Reactor Inspection Program-Operations Phase," Section 08.05.

Based on the samples selected for review, the team concluded that the implementation of the corrective action program at Arkansas Nuclear One, Units 1 and 2, was effective. The inspectors determined that Arkansas Nuclear One staff had a low threshold for identifying problems and issues were prioritized and evaluated commensurate with their safety significance. Corrective actions were typically implemented in a timely manner and addressed the identified causes of problems. Lessons learned from industry operating experience were reviewed and usually applied when appropriate. Audits and self-assessments were critical with UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125 Entergy Operations, Inc. - 2 -

appropriate actions recommended; however, there were several examples where licensee management did not evaluate the validity of the recommendations and closed out the item without taking any actions.

Based on the results of this inspection, no findings of significance were identified. However, one licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as a noncited violation, consistent with Section VI.A.1 of the NRC Enforcement Policy. If you contest this noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 East Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Arkansas Nuclear One , Units 1 and 2, facility. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web-site at www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/ Larry T. Ricketson for Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety Dockets: 50-313; 50-368 Licenses: DPR-51; NPF-6

Enclosure: Inspection Reports 05000313/2009006 and 05000368/2009006 w/Attachments: 1. Supplemental Information 2. Information Request Senior Vice President Entergy Operations, Inc. P. O. Box 31995 Jackson, MS 39286-1995

Entergy Operations, Inc. - 3 -

Senior Vice President & Chief Operating Officer Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Vice President, Oversight Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Manager, Licensing Entergy Operations, Inc. Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Associate General Counsel Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety & Licensing Entergy Operations, Inc. P. O. Box 31995 Jackson, MS 39286-1995 Chief, Radiation Control Section Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Section Chief, Division of Health Emergency Management Section Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 David E. Maxwell, Director Arkansas Department of Emergency Management Bldg. 9501 Camp Joseph T. Robinson North Little Rock, AR 72199

Entergy Operations, Inc. - 4 -

Pope County Judge Pope County Courthouse 100 West Main Street Russellville, AR 72801 Entergy Operations, Inc. - 5 -

Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector (Alfred.Sanchez@nrc.gov) Resident Inspector (Jeffrey.Josey@nrc.gov) Branch Chief, DRP/E (Jeff.Clark@nrc.gov) Senior Project Engineer, DRP/E (George.Replogle@nrc.gov) ANO Site Secretary (Vicki.High@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)

K. S. Fuller, RC OEMail Resource Senior Enforcement Specialist (Mark.Haire@nrc.gov) Only inspection reports to the following: DRS STA (Dale.Powers@nrc.gov)

OEDO RIV Coordinator, Primary (Shawn.Williams@nrc.gov) OEDO RIV Coordinador, Backup (Eugene.Guthrie@nrc.gov)

ROPreports

File located: SUNSI Rev Compl. x Yes No ADAMS x Yes No Reviewer Initials JFD Publicly Avail x Yes No Sensitive Yes x No Sens. Type Initials JFD RIV: RI:DRP/E RI/DRP/E SRI/DRS/PSB2 C:DRS/PSB2 C:DRP/E Z. Bailey J. Josey J. Drake G. Werner J. Clark

/RA/ /RA/ /RA//RA//RA/ 4/3/09 4/3/09 4/3/09 4/3/09 4/2/09 C:DRS/PSB2 G. Werner

/RA/ 4/3/09 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 50-313 and 50-368 License: DPR 51 and NPF 6 Report: 05000313/2009006 and 05000368/2009006 Licensee: Entergy Operations, Inc.

Facility: Arkansas Nuclear One, Units 1 and 2 Location: Junction of Hwy. 64W and Hwy. 333 South Russellville, Arkansas Dates: January 19 to February 20, 2009 Team Leader: James F. Drake, Senior Reactor Inspector Inspector:

Accompanied by: Jeffery Josey, Resident Inspector, Plant Support Branch E Zachary Bailey, Reactor Inspector, Plant Support Branch E Approved By:

Gregory E. Werner, Chief Plant Support Branch 2 Division of Reactor Safety

- 2 - Enclosure

SUMMARY OF FINDINGS

IR 05000313/2009006 and 05000368/2009006; 01/19/2009-02/20/2009; Arkansas Nuclear One, Units 1 and 2, "Biennial Baseline Inspection of the Identification and Resolution of Problems."

This inspection was performed by one regional inspector and one resident inspector. No findings of significance were identified during this inspection. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609, "Significance Determination Process". Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG 1649, "Reactor Oversight Process," Revision 3, dated July 2000. Identification and Resolution of Problems The inspectors reviewed approximately 300 condition reports, work orders, engineering evaluations, root and apparent cause evaluations, and other supporting documentation to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The inspectors reviewed a sample of system health reports, self-assessments, trending reports and metrics, and various other documents related to the corrective action program. The inspectors concluded that the licensee effectively identified, evaluated, and prioritized corrective actions for conditions adverse to quality. The inspectors concluded that the licensee implemented timely, effective corrective actions.

With minor exceptions, the licensee appropriately evaluated industry operating experience for relevance to the facility and had entered applicable items in the corrective action program. The licensee used industry operating experience when performing root cause and apparent cause evaluations. The licensee performed effective quality assurance audits and self-assessments, as demonstrated by self-identification of poor corrective action program performance and identification of ineffective corrective actions.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

The inspectors evaluated one licensee-identified violation of very low safety significance. Corrective actions taken or planned by the licensee have been entered into the corrective action program. This violation and condition report numbers are listed in Section 4OA7 of this report.

REPORT DETAILS

4OA2 Problem Identification and Resolution

a. Assessment of Corrective Action Program Effectiveness

(1) Inspection Scope

The inspectors reviewed the procedures describing Arkansas Nuclear One's corrective action program. The licensee identified problems for evaluation and resolution by initiating condition reports in their condition reporting system. The inspectors evaluated the methods for assigning and tracking issues to ensure that issues were screened for operability and reportability, prioritized for evaluation and resolution in a timely manner commensurate with their safety significance, and tracked to identify adverse trends and repetitive issues. In addition, the inspectors interviewed plant staff and management to determine their understanding of and involvement with the corrective action program.

The inspectors reviewed approximately 300 condition reports including associated root, apparent, and direct cause evaluations, from the approximately 14,000 condition reports that were issued between March 2007 and February 2009, to determine if problems were being properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The inspectors evaluated the licensee's efforts in identifying and establishing the scope of problems by reviewing selected logs, operability determinations, work requests, self-assessments results, audits, system health reports, action plans, and results from surveillance tests and preventive maintenance tasks. The inspectors attended the licensee's Condition Review Group screening committee meetings and Corrective Action Review Board meetings to assess the reporting threshold, prioritization efforts, and significance determination process, as well as observing the interfaces with the operability assessment and work control processes. The inspectors' review included verifying that the licensee considered the full extent of cause and extent of condition for problems, as well as how the licensee assessed generic implications and previous occurrences. The inspectors assessed the timeliness and effectiveness of corrective actions, completed or planned, and looked for additional examples of similar problems. The inspectors conducted interviews with plant personnel to identify other processes that may exist where problems may be identified and addressed outside the corrective action program.

The inspectors also reviewed condition reports that addressed past NRC-identified violations to ensure that the corrective actions addressed the issues as described in the inspection reports. The inspectors reviewed a sample of corrective actions closed to other corrective action documents to ensure that corrective actions were still appropriate and timely.

The inspectors considered risk insights from the NRC's and Arkansas Nuclear One's risk analyses to focus the sample selection and plant tours on risk significant systems and components. The corrective action review was expanded to five years for evaluation of the Unit 1 120 Vac vital power system and fire protection systems and administrative controls. The inspectors conducted a walkdown of these systems and the plant to assess whether problems were identified and entered into the corrective action program.

(2) Assessments

(a) Assessment - Effectiveness of Problem Identification The inspectors determined that licensee personnel were effective at identifying conditions adverse to quality and entering them into the corrective action program in accordance with station procedures and NRC requirements. The inspectors determined that licensee personnel were usually identifying problems at a low threshold; although, there were nine examples identified where condition reports were not promptly initiated when warranted. For example, the inspectors identified that condition reports had not been initiated for the tripping of the primary pump or auto starting of the secondary pump during operations or maintenance for the component cooling water and the control rod drive cooling pumps on several occasions where plant operations had not been impacted. The inspectors also identified that contrary to licensee management's expectation, condition reports were not initiated on several occasions when multiple barriers in the tagout process failed.

(b) Assessment - Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, licensee personnel appropriately prioritized and evaluated issues commensurate with the safety significance of the issue. Condition reports were screened for operability and reportability, categorized by significance (A through D), and assigned to a department for evaluation and resolution. The Condition Review Group appropriately considered human performance issues, radiological safety concerns, repetitiveness, and adverse trends in their reviews.

During their review, the inspectors identified four condition reports where the licensee had failed to appropriately recognize and classify repetitive component performance issues as repeat conditions in a timely manner. These associated issues were not coded as repeat conditions in the corrective action program and as a result, this affected the station's ability to trend issues and raise station awareness. For example, the inspectors noted that the reactor building spray Pump B suction pressure transmitter (PT-2428) had a history of indicating lower than actual pressure. Specifically, this pressure transmitter had an 18-month calibration periodicity, and during every scheduled calibration from 2000 to 2007, the as-found reading had been out-of-tolerance low. Additionally, on two occasions during this time, Transmitter PT-2428 had required corrective maintenance between calibrations due to low readings. The inspectors determined that this transmitter was only used to perform in-service testing of the pump, and had been properly calibrated prior to use. Subsequently, the station identified this issue as repetitive and the transmitter was replaced in November 2008 to correct the problem. The inspectors found that the cause analyses reviewed were thorough and appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors determined that the reviews conducted by the Corrective Action Review Board were detailed and ensured that corrective actions addressed the identified causes. For significant conditions adverse to quality, the Corrective Action Review Board identified appropriate corrective actions to prevent recurrence.

(c) Assessment - Effectiveness of Corrective Action Program The inspectors determined that the licensee usually developed appropriate corrective actions to address problems. However, the inspectors did identify several exceptions that included: one condition report where the corrective action was not implemented in a timely manner, one condition report had two corrective actions that lacked specific actions to address the contributing causes, and two condition reports where the causes were attributed to ineffective communications, for which the licensee has been taking extensive actions to correct. Specifically:

• The licensee failed to implement a corrective action to ensure that a solenoid valve design that had been determined to be inadequate in January 2006 was controlled and not issued for use or installation. The correct design solenoid valve was purchased and entered into the warehouse with the identical part number as the incorrect design. The incorrect valve design was not deleted from the stock, nor were any administrative holds placed on the parts to prevent issuance. As a result, the incorrect design solenoid valve was issued and installed in the plant. This issue is addressed in Section

4OA7 as a licensee identified violation.

• The licensee identified in Condition Report ANO-2-2007-313 that, "Policy guidance/management expectations were not well defined or understood as it relates to when a procedure would be required to perform a task or when skill-of the-craft can be used." The licensee's corrective action added a step in Procedure COPD-001, "Operations, Expectations, and Standards", (Rev 030) referencing EN-WM-100, "Work Request Generation, Screening, and Classification", for the definition of "Skill of the Craft." The team considered this corrective action inadequate since the definition of skill of the craft in Procedure EN-WM-100, "Work Request Generation, Screening, and Classification", is the same now as it was when the incident occurred and there was no documentation of additional training regarding management expectations pertaining to the use of skill-of the-craft. The only action was to reference Procedure EN-WM-100, "Work Request Generation, Screening, and Classification", in Procedure COPD-001, "Operations, Expectations, and Standards". Since Procedure COPD-001, "Operations, Expectations, and Standards", is an administrative procedure, it is not required to be reviewed or referenced prior to or during work.

• The licensee identified in Condition Report ANO-2-2007-313 (FIN 05000368/2007003-04, AComplete Loss of Component Cooling Water Flow During Maintenance Operations,@) that, "Written Communications PJB [pre-job brief] Form is too Generic." The corrective action was, "Establish guidance in COPD-001 for pre-job brief that will trigger additional rigor in evaluating high risk significant activities." The inspectors found that no additional guidance was inserted into the COPD-001, "Operations, Expectations, and Standards", pre-brief checklist. Only in the main body of COPD-001, "Operations, Expectations, and Standards", was additional guidance provided, but the procedure is marked as administrative, so it is not required to be reviewed prior to a pre-job brief.

• In Condition Report ANO-2-2007-0313, (FIN 05000368/2007003-04, AComplete Loss of Component Cooling Water Flow During Maintenance Operations

@), the licensee identified that the system engineer had changed the scope of the job and not effectively communicated this information to the operations and maintenance personnel on the subsequent shifts. The licensee also identified that although the System Engineer was aware of increased leak rates from the heat exchanger due to the removal of the tube plugs, this information was not communicated to operations and maintenance personnel as a potential concern. This resulted in a loss of component cooling water and an unplanned manual trip of the reactor plant.

• In Condition Report ANO-2-2008-1634, which detailed a fuel oil day tank overflow, the licensee determined that there had been a missed opportunity to prevent this event, which dealt with inadequate communications. Specifically, the licensee determined that instrumentation and controls technicians attempted to communicate to the control room operators that the fuel oil day tank level transmitters were to be isolated. However, this communication was determined to be ineffective and, as a result, contributed to the event occurrence. This resulted in the fuel oil transfer pump auto starting and overflowing the fuel oil day tank and spilling fuel oil to the environment.

.3 Findings

No findings of significance were identified.

b. Assessment of the Use of Operating Experience

(1) Inspection Scope The inspectors examined the licensee's program for reviewing industry operating experience, including reviewing the governing procedure and self-assessments. The inspectors reviewed 12 operating experience notifications to assess whether the licensee had appropriately evaluated the notifications for relevance to the facility. The inspectors then examined whether the licensee had entered these items into their corrective action program and assigned actions to address the issues. The inspectors reviewed a sample of root cause evaluations and corrective action documents to verify if the licensee had appropriately included industry-operating experience.

(2) Assessment The inspectors found that operating experience information was appropriately considered for applicability, and corrective and preventive actions were taken as needed. Site operating experience coordinators screened issues from various sources for applicability and initiated condition reports for additional reviews and corrective actions as necessary. Operating experience information has been integrated into routine activities, such as pre-job briefs, procedures, and training material. The inspectors noted several positive examples in which plant personnel considered operating experience information in addition to material provided by the operating experience program. However, in a few cases the inspectors found that site-specific operating experience was not effectively utilized because operating experience reviews were not required to be completed for lower significance (Cat C and D) condition reports.

(3) Findings No findings of significance were identified.

c. Assessment of Self-Assessments and Audits

(1) Inspection Scope The inspectors reviewed a sample population of 20 out of 80 audits and self-assessments, including the most recent audit of the corrective action program, corrective action program trend reports, quality assurance audits, departmental self-assessments, and assessments conducted by independent organizations. A specific list of documents reviewed is included in the attachment to this report. These reviews were performed to determine if problems identified through these assessments were entered into the corrective action program, when appropriate, and whether corrective actions were initiated to address identified deficiencies. The effectiveness of the audits and assessments was evaluated by comparing audit and self-assessment results against self-revealing and NRC identified findings and observations made during the inspection.

(2) Assessment The inspectors observed that, overall, audits and self-assessments were critical and, in most cases, appropriate actions were taken to address identified issues. However, in some cases, the inspectors found that management failed to evaluate the validity of the recommendations/observations made for issues identified during assessments. For example, the inspectors noted that in Condition Report ANO-C-2008-1311, quality assurance personnel indicated a concern with potential inadequate oversight of contractor personnel. After management review and evaluation, this condition report was closed based on the determination that the level and type of supervision being used for contract workers was sufficient and in line with standard industry practices. Subsequently, the inspectors noted that Condition Report ANO-C-2008-2565, written several months later, identified inadequate oversight of contractor personnel as a contributing cause for continuing problems with fire watches and control of combustible materials. The inspectors noted that the basis for this determination was that contract supervisors were not as familiar with station procedures and processes as compared to licensee supervisors.

.(3) Findings No findings of significance were identified.

d. Assessment of Safety Conscious Work Environment

(1) Inspection Scope A limited assessment of the licensee's safety culture was conducted during this inspection based on the significant assessment of the status of the safety-conscious work environment that was performed as part of the Operational Safety Review Team evaluation with no issues of significance being identified. The inspector did not conduct interviews

(2) Assessment The inspectors noted from discussions with plant personnel, that the staff were aware of the importance of a strong safety conscious work environment and a willingness to raise safety issues. None of the plant employees had experienced retaliation for safety issues raised or knew of anyone who had been retaliated against for raising issues. All persons interviewed had an adequate knowledge of the corrective action program and engineering action request program. The threshold for entering concerns in the Employees' Concern Program was appropriate and the program administrator willing accepted not only safety concerns but also other work place concerns. Additionally, the resident inspectors had not identified any concerns of a safety conscious work environment. The licensee periodically monitored the safety conscious work environment and the results were consistent with the NRC observations. Based on these reviews and interviews, the inspectors concluded there was a safety conscious work environment.

(3) Findings No findings of significance were identified.

4OA6 Meetings, Including Exit

On February 20, 2009, the inspectors presented the inspection results to Mr. Brad Berryman, General Manager Operations, Acting Site Vice President, and other members of the staff, who acknowledged the findings. The inspectors confirmed that no proprietary information reviewed during the inspection was retained by the inspectors nor was any included in this report.

4OA7 Licensee Identified Violations

The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncited violation.

Title 10 CFR Part 50, Appendix B, Criterion XV, "Nonconforming Materials, Parts, or components," requires, in part, that measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition, and notification to affected organizations. Contrary to the above requirement, the licensee failed to ensure that a solenoid valve design that had been determined to be inadequate in January 2006 was controlled and not issued for use or installation. This resulted in a subsequent failure of decay heat cooler 'A' bypass valve (CV-1433) because of the inadequate solenoid valve. This finding was determined to have very low safety significance because the condition did not result in the actual loss of any component, train, or system. This issue was entered into the licensee's corrective action program as condition reports ANO-1-2008-2525, ANO-1-2008-2578 and ANO-1-2008-2625.

ATTACHMENTS:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

B. Berryman, General Manager Operations, Acting Site Vice President

D. James, Director, Nuclear Safety Assurance

P. Williams, Manager, Design Engineering

R. Eichenberger, Manager, Corrective Actions and Assessments

M. Chisum, Manager, Planning, Scheduling, and Outages

R. Dodds, Manager, Maintenance

C. Reasoner, Director, Engineering

J. Smith, Manager, Quality Assurance

E. Blackano, Supervisor, Components

J. Sigle, Assistant Manager, Operations

P. Higgins, Supervisor, Training

F. Van Buskiak, Licensing Specialist

D. Moore, Manager, Radiation Protection

R. Schiede, Licensing Specialist

D. Bice, Acting Manager, Licensing

NRC personnel

T. Pruett, Deputy Director, Division of Reactor Safety

J. Clark, Branch Chief, E, Division of Reactor Projects

A. Sanchez, Senior Resident Inspector, Arkansas Nuclear One

Attachment 1

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened

None

Closed

None

Discussed

None

Attachment 1