IR 05000247/1982028
| ML20028F168 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/10/1983 |
| From: | Foley T, Kister H, Koltay P, Wen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20028F160 | List: |
| References | |
| 50-247-82-28, NUDOCS 8301310200 | |
| Download: ML20028F168 (18) | |
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DCS Nos.: 50247-F21029 U.S. NUCLEAR REGULATORY COMMISSION
Region I Report No. 82-28 Docket 'lo. 50-247 License No. DPR-26 Priority Category C
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Licensee: Consolidated Edison Company of New York, Inc.
4 Irving Place l
Facility Name:
Indian Point Nuclear Generating Station, Unit 2 Inspection at:
Buchanan, New York Inspection conducted: December 1,1982 to January 3,1983 Inspectors:
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//fl81 T. Foley, Senior ResTdent Inspector
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' date
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//f/LI P. Koltay,eRefsicent Inspector
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~ date 7c A nttL &
tho/ra P. Wen, Reactor Inspector date Approved by:
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H. Kist'ef, Chief, Reactor Projects Section IC, Cate DPRP Inspection Sumary:
Inspection on December 1, 1982 to January 3, 1983 (Inspection Report 50-247/82-28)
Areas Inspe::ted: Routine onsite, regular and backshift inspection including licensee ac;1on on previously identified inspection findings; plant operations review; operational safety verification; operability of engineered safeguard features; rafueling activities; surveillance; facility maintenance; physics acceptance testing; comitments prior to startup; emergency plan exercise; review of monthly and periodic reports; licensee event reports followup; regional office followup; and, physical security. The inspection involved 215 inspector hours by the resident inspectors and one regional inspector.
Results: One apparent violation was identified in one area.
(Failure to control access to a vital area, paragraph 15.)
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0301310200 830110 PDR ADOCK 05000247
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DETAILS 1.
Persons Contacted
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D. Army, Maintenance Engineer J. Basile, General Manager Nuclear Power Generation M. Blatt, Acting Director, Regulatory Affairs A. Brescia, I&C Supervisor K. Burke, General Manager, Adninistrative Services J. Cullen, Rad Waste Manager J. Curry, Chief Operations Engineer W. Ferreira, Radiation Protection Adninistrator R. Gauny, General Manager, Environmental Health and Safety J. Higgins, Chemistry Manager C. Jackson, Vice President Nuclear Power J. Mooney, Electrical Engineer H. Morrison, Operations Superintendent A. Nespoli, Major Projects Manager J. Quirk, Test and Performance Engineer M. Skotzko, Security Adninistrator M. Smith, Acting General Manager, Technical Support The inspectors also interviewed other licensee employees including members of the operations, health physics, technical support, maintenance, con-struction, corporate engineering staff, and security personnel.
2.
Licensee Action on Previously Identified Inspection Findings (Closed) Unresolved Item (247/79-03-01) Procedures and documents CI-290-3, CI-240-1 and GE-0P-19, addressing drawing control, are inconsistent resulting in insufficient modification drawing controls. The licensee issued revised Procedure CI-290, " Obtaining As-Constructed Drawings," and Procedure SA0122,
" Drawing Controls," Revision 3.
The inspector verified that the licensee has developed an acceptable drawing control program which reflects the require-ments of the Quality Assurance Manual, CI-240-1.
(Closed) Infraction dated October 4, 1979 (247/79-09-02) Containment Isolation Valve Leak Rate Test, conducted during the 1979 fuel outage did not include containment isolation valve PCV 1190. The inspector verified that the valve was tested by the licensee on August 21, 1979. The valve was also tested in accordance with Procedure PT-R27, Revision 7, during the 1982 refueling outag.,.
-3-l (Closed) Unresolved Item (247/79-10-01) " Check Off List Discrepancies identified by the inspector on COL-12, Safety Injection System, and COL-25, Diesel Generators." The inspector verified that the licensee
updated the COL's and corrected the identified discrepancies. The inspec-tor noted that one item identified in the finding, missing valve tags, has
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been brought to the licensee's attention during subsequent inspector find-ings. The inspector noted that a problem still exists in this area. The licensee agreed to replace missing valve tags as they are identified by plant operators.
(Closed) Unresolved Item (247/79-12-02) The licensee experienced several reactor coolant pump (RCP) lagging fires, after it became saturated with oil.
In order to eliminate the problem, the licensee replaced the lagging with a canned / mirrored material which prevents oil saturation of the lagging.
(Closed) Unresolved Item (247/79-12-01) During startup, after the 1979 re-fueling outage, the Metal Impact Monitoring System (MIMS) identified a loose object in the reactor vessel. The Station Safety Committee concluded that the plant can safely operate with the loose object in the vessel. During the 1980-81 outage, contractors removed the loose object from the vessel.
However, during startup, there were additional indications of loose ob-jects including a 1/2 inch long bolt, and several smaller objects that were subsequently recovered. The licensee believes that no loose objects that would cause concern, remain in the reactor vessel.
(Closed) Unresolved Item (247/80-04-01) Emergency lockers located in the control room did not include all items listed on the inventory. The inspec-tor verified that the emergency lockers contain all required equipment. The
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licensee conducts monthly inventory and calibration checks.
(Closed) Inspector Follow Item (247/80-04-02) Review of the licensee's evalua-tion of an emergency drill held on May 7,1980. The inspector reviewed avail-able data on the emergency drill.
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Plant Operations Review A.
Control Room Tour i
Daily, the reside.?t inspectors reviewed, on a sampling basis, the control room logs, records, annunciators, and instruments for signi-ficant changes or trends in plant parameters, to ascertain that re-quirements for the mode of operation at the time were being met, i
including equipment status, plant chemistry, connunication ability,
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control room manning and turnover, and general control room manner of operation and conduct of events.
No inadequacies were identified.
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Plant Tours i
During the course of the inspection period, the inspectors made i
multiple tours of all accessible areas within the facility.
During these tours, the inspectors ascertained that adequate controls were being implemented for the following:
Radiation Protection Controls
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Plant Housekeeping
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Fire Protection
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Equipment Control
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Tagging Controls
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Pipe Support and Seismic Restraint
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Fluid Leaks
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Instrumentation Controls
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Inspection Findings:
1) On December 6, 1982, during an inspection of the construction activities on the 53 ft. elevation, outside the Unit I control room, the inspector noted that the Unit I control room boundary wall teminated approximately 6 feet below the 20 foot high
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ceiling.
Further examination identified a 6 foot high and approximately 15 foot wide opening in the south boundary of the Unit 1 control room between the hallway and the locker room ~
area. Another opening, approximately 2 ft. by 3 ft., was ob-served between the hallway and the control room proper.
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openings had ventilation ducts routed through thon. The li-censee estimated that the openings were made during a con-struction modification of Unit I at a time when Unit I was
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operational. During nomal operations, an aluminum dropped ceiling is installed in both the locker room and the hallway
which concealed the openings. The problem was brought to the
licensee's attention and as a compensatory measure, the li-censee stationed a guard in the control room.
l The licensee, in accordance with 10 CFR, Section 73.71(c)
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, reported the abo'te described condition as a potential degradation of physical security effectiveness. The inspector noted that access into the control room through the openings was prevented by a 14 foot high wall and a dropped ceiling.
The licensee reviewed the effectiveness of fire barriers en-closing the control room, and detemined that during periods of power operations, the wall foming the south boundary of the hallway and fire doors providing access into the hallway pro-vided the required fire barrier boundaries around the control room. During the maintenance / refueling outage, the fire doors were blocked open by scaffolding. The licensee took imediate corrective action by closing the fire doors.
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-5 On December 9, the inspector verified that the licensee com-pleted proper corrective action by closing the openings using
bricks as the structural material.
On December 17, subsequent to the repair of the openings in the
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control room wall, the licensee completed a control room habitability test.
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The results of the test are being evaluated by the licensee.
2) On December 27, 1982, during an inspection of control room
cabinets, the inspector observed cracking in a fire barrier j
penetration seal in the control room floor. An inspection of additional penetration seals inside the control room cabinets identified that most seals exhibited cracks up to 1/4 inch wide and extended through the 1/4-1/2 inch thickness of the
"F1amemastic Coating" material.
The degraded condition of the electrical penetration seals was brcught to the licensee's attention. The licensee ini-tiated an inspection and repair program of all control room floor penetrations. The inspector noted that similarly de-graded penetration seals located in the cable tunnel and the primary auxiliary building were identified previously, and brought to the licensee's attention.
This item remains unresolved pendir.g review of the licensee's corrective actions. (82-27-01)
4.
Operational Safety Verification Using a unit specific daily and biweekly checklist, the inspector routinely verified the following attributes:
Proper control room manning and access control;
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Operators adhering to approved procedures for ongoing activities:
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Adherence to limiting conditions for operations observable from
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the control room; No abnonnalities on instrumentation and recorder traces;
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Nuclear instrumentation and other reactor protection systems
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are operable; Control rod insertion limits are in confonnance with technical
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I specification requirements;
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Containment temperature and pressure indications were in con-
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l formance with technical specification requirements;
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No abnomalities indicated on radiation monitor recorder traces;
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and, Onsite and offsite emergency power sources available for auto-
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matic operation.
The inspector reviewed the control room log, shift supervisor's log, refueling log, tagout log, operating orders, significant occurrence reports, shift turnwer check sheet, and diesel operability log to obtain infomation concerning operating trends and activities, ar.d to note any out-of-service safety systems.
During routine entry and egress from the protected (PA), the inspectors verified:
Access controls are in confomance with security plan requirements
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for personnel, packages and vehicles; The required number of guards are present and alert;
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Gates in the PA barriers are closed and locked if not attended;
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Isolation zones are free of visual obstructions and objects that
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could aid an intruder in penetrating the PA; and, Personnel radiation monitoring equipinent is operable, and that
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equipment and materials are being monitored prior to release for unrestricted use.
Findings:
One inadequacy was identified and is discussed under the paragraph en-titled " Security" in this report.
5.
Operability of Engineered Safeguard Features The inspector verified through direct observation, and procedural re-view, the operability of the emergency diesel generators and the
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component cooling water system.
The inspection criteria included:
t A walkdown of the accessible portions of selected system;
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System lineups checked against plant drawings;
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Verified hangers and supports were operable;
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Cleanliness of breakers, instrumentation cabinets;
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Valves in proper position, power available, locked and
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sealed, as required by checkoff lists; and,
. Local and remote control positions correctly established.
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No violations were identified.
6.
Refueling Activities During the reporting period, the plant was initially in the cold shutdown mode with the new Core 6 entirely installed.
The reactor was completely assembled without incident. Housekeeping and Quality Controls around the reactor vessel and spent fuel pool were evident. Much of the activity during this period was surveillance testing, in preparation for startup.
Surveillance testing is covered in another section of this report. The inspectors witnessed repairs and functional testing of the containment sump pumps and ructor vessel cavity sump pumps. Problems wi;h these pumps were identified in inspection report 50-247/82-23.
The inspectors also toured the containment and portions of the Primary Auxiliary Build-ing including containment sumps.
Specific coments on housekeeping were presented to the licensee who initiated appropriate corrective action.
On December 29, 1982, the plant achieved criticality and comenced low pour physics acceptance testing. On January 2,1983, the generator was synchronized to the grid and low power testing continued through the end of the reporting period.
Physics acceptance testing is covered in another
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section of this report.
7.
Surveillance A.
The licensee's surveillance equipment and program provides assurance that required pumps, fans, valves, and other instrumentation will perform their required functions.
I The inspector's verification of the licensee's surveillance program includes:
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Review of surveillance procedure for conformance to tech-
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nical specification requirements, and verify proper licensee review / approval; Verification of test instrumentation calibration;
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Observations of portions of system removal from service.
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Confirmation that LC0's are met when operational mode re-quirements are specified;
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Observation of portions of the conducted surveillance test;
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Observation of portions of the system's restoration to
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service; Review test data for accuracy and completeness.
Independent-
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ly calculated selected test results to verify accuracy;
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Confimation that surveillance test documentation is reviewed
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and test discrepancies are rectified;
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Verification that test results meet technical specification j
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requirements;
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Verification that testing was done by qualified personnel;
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Verification that surveillance schedule for this test was met.
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The following surveillance test was witnessed:
PTR-5A Safety Injection Electrical Load Test, Revision 7 l
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During the simulated loss of offsite power to safeguards
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busses, safety injection (SI) pump #23 failed to start, and simultaneously, the RHR pump #22 started, then tripped off the line. The cause of the SI pump failure was traced
to a switch improperly reset, while the RHR pump problem was
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mechanical in nature.
Repairs and testing of the RHR pump i
are addressed under the maintenance paragraph in this report.
PTR-14 was repeated by the licensee on December 10, 1982 with all loads properly sequenced on the diesel generators.
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Additional Surveillance Test Verification Portions of the following surveillance tests were witnessed. by the inspector to verify that tests were:
Scheduled in accordance with the TS, where applicable;
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Procedures were being followed;
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Testing was perfomed by qualified personnel;
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LC0's were met, when applicable; and,
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Restoration of systems was correctly accomplished.
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The tests witnessed were:
PTR-2A-2B - Reactor Cavity Sump Pump;
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Central Control Room Ventilation System Test;
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PTR-22A, Revision 1 Steam Driven Auxiliary Boiler Feed Pump
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Full Flow Test; PTR-7A, kevision 1 Mohr Driven Auxiliary Boiler Feed Pump
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Full Flow Test; and, PT-V3 and PT-V9, Revisic. 7 Reactor Coolant System Hydro and
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Leakage Test.
No violations were identified.
8.
, facility Maintenance The inspector reviewed portions of safety-related corrective and pre-ventive maintenance, and detennined through observations and reviews of records that:
The maintenance activity did not violate limiting conditions for
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operation; Redundant components are operable, if required;
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Required administrative approvals, and tagouts were obtained
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prior to initiating the work, if required; Approved procedures were being used, where required;
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The procedures used were adequate to control the activity;
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The activities were being accomplished by qualified personnel-
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Replacement parts and materials being used are properly certified;
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Preventive Maintenance Program is functioning in accordance with
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approved procedures; Radiological controls are proper, and that they are being
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properly implemented; Ignition / fire prevention controls were appropriate, and were
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implemented, where. required;
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QC hold points were observed, and provided independent verifi-
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cation of specific points, if required; and, Equipment was properly tested prior to return to service.
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Portions of the following maintenance activities were observed and reviewed:
Residual Heat Removai Pump #22 During the performance of PTR-14, Safety Injection Electrical Load Test, RHR pump #22 tripped off the line. Several attempts to restart the pump failed. The licensee's inspection of the pump detemined that the pump impeller separated from the shaft msulting in three loose parts in the system, a washer and two nuts. One of the nuts and a washer was recovered.
The licensee's quality assurance group radiographed all suspected locations, but was unsuccessful in locating the remaining loose part in the system.
Containment isolation valves, elbows, and the system piping were radio-graphed.
i The licensee maintains a loose parts monitoring system which monitors j
the Reactor Coolant System (RCS) for items such as loose nuts. The li-censee has detemined that with full flow through the core, the loose
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part(s) within the RCS are not significantly vibrating and have, therefore,
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lodged somewhere in the RHR system. The RHR heat exchanger would prevent the nut from entering the core region. Visual inspection of the reactor vessel is perfomed each refueling outage, and any foreign objects are
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removed.
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The Station Nuclear Safety Connittee (SNSC) detemined that the loose part does not present a safety problem. The inspector reviewed MWR 6134, Maintenance Procedure 2CM-7.23, and PMT-18, RHR pump functional test.
i No other problems were identified.
The inspectors conducted sample reviews of maintenance and construction packages, including steplists, maintenance procedures and drawings, and witnessed, in part, mi.intenance activities conducted by the licensee in
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the following areas:
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Installation of weir dump valves;
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Installation of auxiliary boiler feed pumps;
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Installation of recirculating sump pump and containment
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stanp level transmitters; and, Incore thermocouple connectors repair.
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No violations were identified.
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9.
Physics Acceptance Testing During the reporting period, the licensee brought the reactor critical on December 29, 1982, and comenced low power physics testing. The inspector witnessed portions of the startup physics tests including initial criticality, zero power test range determination, reactivity computer checkout, control rod worth measurement, and low level flux mapping.
The inspector reviewed the following documents:
a)
Indian Point Nuclear Plant, Unit 2, Cycle 6, Reload Safety Evaluation b) The Nuclear Design and Core Management of the Indian Point Plant, No. 2, Cycle 6 (WCAP-10151)
c)
Indian Point Unit No. 2, Cycle 5, Startup Physics Test Report d) Test Procedures:
RE-7 Initial Criticality, Revision 3
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RE-8 Isothemal Temperature Coefficient, Revision 3
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RE-9 Control Rod Worth Measurement, Revision 3
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RE-13 Startup Physics Test Program, Revision 4
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l RE-16 Low Level Flux Map, Revision 2
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Findings:
The zero power test program was implemented in accordance with the test
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proceduresequence(RE-13, Attachment 2).
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Instructions for test procedures were provided, including Precautions,
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Limitations, and Acceptance Criteria in conformance with the require-ments of the Technical Specifications.
Methods and calculations were clearly specified and tests were perfomed
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accordingly Results:
End Point Boron Concentrations Configuration Measured (PPM)
Design (PPM)
Acceptance All Rods Out 1398 1348
+ 50 PPM D In 1298 1248
[50 PPM
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Control Rod Bank Integral Worth Measured Worth Design Worth Bank (PCM)
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Acceptance D
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C 688 704 10%
Isothemal Temperature Coefficients Measured Design Configuration (PCM/or)
(PCM/or)
Acceptana All Rods Out-2.2-2.8 1 3 PCM/op D In-4.2-4.7 1 3 PCM/op The inspector also reviewed the reactivity computer checkout data and verified that the response of the reactivity computer was acceptable. The test was conducted in accordance with the procedure RE-7, Rev. 3. Appendix A.
" Operational Checkout of Reactivity Computer."
10. Comitments Prior to Startup As a result of a recent Indian Point Probabilistic Safety Study (IPPSS),
and review of the IPPSS by Sandia National Laboratories, a contractor of the NRC, the NRC required the licensee to take certain precautionary measures to reduce the probability of occurrence of certain significant events. These events were detennined by the IPPSS.
The events are described below:
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a) Control Building Shock Absorbers The inspectors witnessed the in-progress and completed installation control building shock absorbers "Controiroom Bumpers." The NRC is currently evaluating the design of the shock absorbers.
b) Shutdown System Modification In order to satisfy alternate safe shutdown requirements, the licensee installed alternate power supplies "hard wired" to the following equip-ment:
No. 24 Service Water Pump
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No. 23 Charging Pump
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No. 21 Auxiliary Boiler Feed Pump
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No. 23 Component Cooling Water Pump
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l The alternate power supply to the above equipment is provided from the 13.8KV normal outside power through Unit I switchgear,12RW3 and 12FD3.
If normal offsite power is not available, all of the above equipment can be energized using any one of the three available gas turbines.
Operator actions required to place the equipment in service are detailed in Procedure S0P 27.1.9, Rev. 2, " Safe Shutdown System Operations."
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-13-The licensee also provided alternate power supply from the previously
described sources to local tennination boxes in the safety injection pump area, residual heat removal pump area, and No. 27 motor control center area. These installations enable the licensee to provide an
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alternate power source to No. 21 safety injection pump, No. 21 residual heat removal pump, and No. 27 motor control center.
The inspector verified that all of the above equipment has been tested in accordance with Procedure PT-017, Rev. O, "Startup Verification of Alternate Safe Shutdown Equipment." All equipment functioned as intended.
c) Control Roon' Ceiling Modification The licensee has plans to secure the present egg crate ceiling fixture in place so as to catch the upper ceiling if it fell as a result of a seismic event. This modification is scheduled to be complete by
February, 1983.
d) Containment Building Soil / Structure Interaction Study The licensee plans to provide an evaluation of interaction between the containment back fill soil and the containment structure. This evalua-tion is scheduled to be complete and provided to the NRC by the Spring
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of 1983.
e) Hurricane Wind Conditions
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The licensee has submitted a pmposed change, and the NRC has approved and issued a license amendnent which requires the reactor to be in a cold shutdown condition upon arrival of a hurricane at the site.
The inspectors have reviewed hurricane procedure which requires the plant to be placed in cold shutdown when arrival of a hurricane is eminent.
No violations were identified.
i 11.
Emergency Plan Exercise On December 8, 1982, the licensee conducted the Indian Point Unit 2 Annual Emergency Response Field Exercise. The purpose of this exercise was to
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demonstrate that the IP-2 Site Emergency Response Plan and procedures, and l
Consolidated Edison Corporate Emergency Response Plan and procedures could
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be effectively implemented.
The Federal Emergency Management Agency (FEMA), the State of New York, and local comunities did not participate in, or observe the exercise. However, the licensee did make initial notifications to the appropriate groups in accordance with the emergency plan. The NRC resident inspectors from Units 2 and 3 observed the licensee's activities in the control room, the Technical Support Center, and Emergency Offsite Facility.
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_14 The drill scenario provided the operators with conditions which resulted in:
(a) a loss of offsite power, (b) failed fuel, (c) a steam tube rupture, (d) a stuck open main steam safety valve and, (e) generator saturated conditions in the core. These conditions resulted in an offsite release and declaration of a General Emergency.
The inspectors attended the drill critique conducted the following day, and provided their specific observations at a separate meeting with the emergency plan coordinators. The principal observations were regarding the acceptability of corrective actions required to be taken in response to the NRC Emergency Preparedness Appraisal, Inspection Report 50-247/
81-06, and reappraisal conducted February 8,1982.
These concerns will be evaluated duri:g the emergency exercise currently scheduled for March, 1983, when the state, local, and federal agencies will participate in the exercise.
No violations were identified.
12.
Review of Monthly and Periodic Reports
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During this period, the inspectors reviewed the Monthly Operating Report relating to Indian Point Unit 2 for the month of November. The report was reviewed pursuant to Technical Specifications, and verified to deter-mine that the statistics had been accurately reported, and that the narrative summaries of the operating experiences were contained therein.
No violations were identified.
13.
Licensee Event Reports Followup Through direct observations, discussions with licensee personnel, and review of records, the following event reports were reviewed to determine that reportability requirements were fulfilled, imediate cer:ective action was accomplished, and corrective action to prevent reoccurrence had been accomplished in accordance with Technical Specifications.
LER 82-044/03L-0 High initial failure rate of tested snubbers.
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During the 1982 refueling maintenance outage, the licensee tested all snubbers listed in the Technical Specifications. The test identified 102 failures out of 252 snubbers tested. The licensee reinstalled 40 snubbers which passed the test.
The remainder were replaced with new snubbers.
LER 82-046/03L-0 A 15 gallon spill of borated water in the
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primary auxiliary building was contained in-side the building.
LER 82-047/03L-0 Laboratory testing of pressurizer safety valves
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identified two valves to be outside the Technical Specification required tolerance. This item was discussed in Section 8 of NRC Report 50-286/82-23.
No violations were identified.
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-15-14. Regional Office Followup During the reporting period, public concerns were received at the NRC
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Regional Office from private citizens regarding various aspects of the licensee's operation. These concerns were investigated by the resident inspectors as described below:
a) Quality Control _ Inspector's Qualifications The resident inspectors reviewed certifications, resumes and quali-
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fications of several quality assurance inspectors from three of the licensee's contractor groups. The inspector interviewed several quality control inspectors, and verified the validity of the quali-fication records and resumes by questioning personnel. The inspectors compared the qualifications to the requirements of the American Nuclear Society Instruction (ANSI) N45.2.6, and the requirements of the Society of Nondestructive Testing (SNT) TC-1A. The qualifications of a total of eighteen inspectors were reviewed, and each of the inspectors met or exceeded the minimum requirements stated above.
b) Deficiency Reports The inspectors detemined that the licensee uses the quality assurance
inspection services of five different contractors during the outages.
Each of the contractors has a supervisor who reports to a licensee's construction quality assurance supervisor. The inspectors reviewed i
deficiency reports generated by the contractor's inspectors, and routed through the contractor's supervisor to the licensee's quality assurance group.
Deficiency reports appear to be properly acted upon and resolved in a timely manner. No personnel interviewed were aware of violations
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of construction standards that were not resolved or in the process of being resolved.
c) Themocouple The inspectors queried the Unit 2 and Unit 3 operation departments re-garding the placement of thermocouples within the core.
No descrepancies were noted by either licensee.
However, in conversation with Unit 3 personnel, it was determined that a minor problem did exist concerning the arrangement of flux thimbles within the Unit 3 core.
The inspectors queried Unit 2 personnel, and determined that the licensee had previously initiated a Quality Control Audit, QCIR 82-2-243, dated December 12, 1982, that concludes that all flux thimbles are aligned in their intended locations within the Unit 2 core.
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-16-d) Threats or Acts of Violence During conversation with several persons interviewed from the Consolidated Edison, Crouse, and Universal Testing Laboratories organizations, no acts of violence or threats were mentioned. Several people were specifically asked if they had heard of such acts either on or off site. No one had heard of any such acts related to quality control inspectors.
The validity of the allegations could not be substantiated with the information available.
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-19-16. Unresolved Items An item about which more information is required to detennine whether it is acceptable, or a violation is considered unresolved.
Paragraph 3.B(2)
contains an unresolved item.
17.
Exit Interview At periodic intervals during the course of the inspection, meetings were held with senior facility management to discuss the inspection scope and findings.
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