IR 05000255/1987008
| ML18052B034 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/20/1987 |
| From: | Burgess B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052B031 | List: |
| References | |
| 50-255-87-08, 50-255-87-8, NUDOCS 8706020195 | |
| Download: ML18052B034 (12) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/87008(DRP)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Palisades Site, Covert, Michigan Inspection Conducted:
April 7 through May 4, 1987 Inspectors:
E. R. Swanson C. 0. Anderson cO~~vW~
Approved By:
B. L. Burgess, Chief Reactor Projects Section 2A Inspection Summary License No. DPR-20 Inspection on April 7 through May 4, 1987 (Re~ort No. 50-255/87008(DRP))
Areas Inspected:
Rowtine, unannounced inspec ion by resident inspectors of fol lowup of previo~s inspection findings; operational safety; maintenance; surveillance and reportable event The report also documents the April 24, 1987 Management meetin Results:
Of the areas inspected two violations were identifie The licensee fa1 led to implement a license change in a timely manner which caused Temporary Changes to be approved by individuals other than the appropriate Senior Manager The second violation consists of two examples of inadequate corrective actions:
appropriate compensatory actions were not taken for a fire door which was left open and an administratively inoperable radiation monito Although not a violation of requirements, the operational event discussed in Para9raph 3.d of unexpected dilution and overboration reflects poorly on the quality of operation Paragraph 3.e discusses situations where a nonconservative interpretation of requirements was made, resulting in questionable actions being taken when incore monitoring capability was lost. This issue is being tracked as an Unresolved Ite.
PDR ADoc~ 870522 G
05000255 PDR
...
DETAILS Persons Contacted Consumers Power Company (CPCo)
+F. W. Buckman, Vice President, Nuclear Operations
+J. F. Firlit, General Manager, Palisades
- D. P. Hoffman, General Manager, Palisades
+W. E. Garrity, Manager, Engineering, PE&C
+J. L. Kuemin, Licensing Engineer
- J. G. Lewis, Technical Director
- +R. D. Orosz, Engineering and Maintenance Manager
- D. W. Joos, Adm1nistrat1ve and Planning Manager
- C. S. Kozup, Technical Engineer
- D. J. Malone, Licensing Analyst
- R. E. McCaleb, Quality Assurance Director
- R. M. Brzezinski, Instrument and Control Superintendent
- K. M. Haas, Reactor Engineering Superintendent
- R. A. Fenech, Operations Superintendent
- S. C. Cote, Property Protection Supervisor
- G. W. Ford, Plant Safety Engineering NRC Personnel
+C. E. Norelius, Director, Division of Reactor Projects
+W. G. Guldemond, Chief, Projects Branch 2
+B. L. Burgess, Chief, Reactor Projects Section 2A
+E. R. Swanson, Senior Resident Inspector
+M. J. Virgilio, Director, PWR-B, NRR (by teleconference)
+T. V. Wambach, Project Manager, Palisades (by teleconferenc)
- C. D. Anderson, Resident Inspector
- Denotes those present at the Management Interview on May 4, 198 +Denotes those present at* the Management Meeting on April 24, 198 Other members of the Plant Operations, Maintenance, Technical, and Chemistry Health Physics staffs, and several members of the Contract Security Force, were also contacted briefl Followup on Previous Inspection Findings:
(Closed) Violation (255/84025-02):
Adequate corrective action was not taken to prevent recurrence of late reporting of excessive unidentified Primary Coolant System leakage conditions (refer to Inspection Report No. 255/85008(DRP)).
To prevent further recurrence, the licensee committed to increasing the frequency of emergency plan (EP) trainin Currently the operators attend simulator training twice each year which includes EP activation and classification. There have been no late reports of EP events, with the exception of the May 19, 1986 trip, during the past two year Inspection Report No. 255/86021(DRSS) addresses the exceptio The increased emphasis on EP activation appears adequate to prevent recurrenc,
(Closed) Open Item 255/85013-01:
The Palisades General Manager, Mr. J. F. Firlit, did not meet the ANSI Standard N18.l-1971 requirement for power plant experience. Since Mr. Firlit has resigned from this position to take one with another utility, this item is close Qualification of the new plant manager will be reviewed at a later dat Mr. D. P. Hoffman assumed the plant manager position on May 1, 198 (Closed) Open Item 255/85013-05:
The licensee has incorporated the documentation system for overtime approval into Administrative Procedure 1.0 The licensee does a monthly audit to ensure compliance with the procedur The inspector reviewed several recent approvals and audits and found them acceptabl (Closed) Violation 255/85027-02:
The licensee had failed to take timely corrective action when a fire protection audit identified that a fire suppression water system valve was not being checked as required by Technical Specification (TS).
Corrective actions included four Qua*lity Assurance Department procedures being revised to specifically state that the cognizant plant management must be informed immediately of a TS violatio In addition, a memorandum was sent to all managers and superintendents requesting this issue be discussed with their departments stressin9 the importance of takin9 appropriate corrective actions upon problem identification. Also, this subject was reviewed with all audit section personne No similar TS related problems have recurred during the recent pas An inspector concern remains relative to the apparent delay in corrective action from the time an audit team exits until the report is received by the licensee for non-TS related, but plant significant item (Closed) Open Item 255/85034-03:
LER 255/85028 documented a containment isolation caused by a construction electricia The purpose of this open item was to track the licensee 1s corrective action to develop a better method of controlling construction activities on plant installed engineered safeguards circuitr Upon further investigation, the licensee determined that the root cause was not lack of detailed steps in the work order, but failure to follow the The licensee 1s upcoming revision to this LER will include the new root cause determinatio Projects, Engineering and Construction has enhanced the 11 Equipment Control and Processing NOC Forms 11 procedure, 8-2.7, by requiring a briefin9 of the workmen, and work orders with sufficient detail specifying isolation points that minimize impact on other in-service equipment or system (Closed) Violation 255/86007-01:
The licensee failed to submit LERs for fire doors being open without compensatory measures on January 6 and 8, 1986, and for containment isolations on December 14 and 15, 198 LER 255/86009 was submitted on March 19, 1986, for the fire doors and LER 255/85032 was submitted on April 17, 1986, for the containment isolation The fire door reportability was incorrectly determined by the responsible Licensing Department individual. This is considered an isolated occurrenc All Licensing Department personnel have been informed of the incident and its consequence The failure to report
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the containment isolations was due to the Licensing Department individual construing that the isolations had been preplanned evolution The
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licensee response dated April 28, 1986, stated that written documentation is now required to consider an evolution preplanne The Licensing Department clarified 11written documentation 11 to be a procedur This should prevent similar failures to repor (Closed) Open Item 255/87006-02:
A Confirmatory Action Letter (CAL) was issued by the NRC on March 27, 1987, to allow startup and testing of the Palisades plant under NRC supervision with certain condition All commitments were fulfilled and a Safety Evaluation of the Service Water operability limit of 80 degrees F was completed allowing recision of the CAL on May 1, 198 No new violations or deviations were identifie.
Operational Safety The inspectors observed control room activities, discussed these activities with plant operators, and reviewed various logs and other operations records throughout the inspectio Control room indicators and alarms, log sheets, turnover sheets, and equipment status boards were routinely checked agains~ operating requirement Pump and valve controls were verified to be proper for applicable plant condition On several occasions, the inspector observed shift turnover activities and shift briefing meeting During this inspection period, the events described in sub-paragraphs d, e and f below initiated concerns regarding operating experience by licensed operators whose primary job responsibilities are outside the control room environmen Review of these events by the inspector reenforced this concern and highlighted the need for a response by the licensee specifically addressing these event This request is included in the cover letter to this repor Tours were conducted in the turbine and auxiliary buildings, and central alarm station to observe work activities and testing in progress and to observe plant equipment condition, cleanliness, fire safety, health physics and security measures, and adherence to procedural and regulatory requirement The inspectors made observations concerning radiological safety practices in the radiation controlled areas including:
verification of proper posting; accuracy and currentness of area status sheets; verification of selected Radiation Work Permit (RWP) compliance; and implementation of proper personnel survey (frisking) and contamination control (step-off-pad) practice Health Physics logs and dose records were routinely reviewe The inspectors observed physical security activities at various access control points, including proper personnel identification and search, and toured security barriers to verify maintenance of integrit Periodic observation of access control activities for
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vehicles and packages and activities in the Central and Secondary Alarm Station were also conducte Two inspector identified security vial at ion_s ar~ docljmented__ in_ I_11$pection Report No. 255/87009(DRSS).
During this inspection period, the inspectors conducted extended control room and plant inspection coverage on all shifts during power ascensio The results of this inspection are documented in Inspection Report N /87005(DRP)~
An ongoing review of all licensee corrective action program items at the Event Report l~vel was performe The inspectors conducted an ongoing review of all new, revised and temporarily changed procedure At the Management Interview, the inspector discussed the potential misuse_ of the editorial change proces During a walkdown of the turbine and controls on the evening of April 20, 1987, an engineer identified a problem with the Turbine Overspeed Trip Test device which could have resulted in an inadvertent turbine tri Operating procedures had required the isolation valves to be opened 1/2 turn from the fully closed positio This resulted in 16 of the 40 pounds hydraulic pressure required to trip the overspeed trip being indicated on the test gag Although it was not clear that the condition would have resulted in a turbine trip, the trip device was tested and the system was properly isolated. - Licensee investigation and resolution of the problem is in progres Early identification of the problem with this device is a direct result of the _Palisades System Engineer Progra At 10:17 a.m. on April 21, 1987, while operating at 98% power a high Safety Injection Tank (SIT) level alarm occurred which rendered the SIT inoperable under the Technical Specifications (TS).
The licensee drained the tank, restoring the level and obtained a sample which was analyzed for boron concentratio The one hour LCO expired at 11:17 a.m. and the licensee commenced a power reduction at 6% per hour to comply with the action requirements of TS 3. The result of the boron sample was determined to be within specification and not diluted as suspecte The licensee then terminated the Unusual Event at 11:22 a.m. on April 21, 1987, with the reactor power at 97.5%.
The licensee has postulated that heatup of the containment during power acceleration, which raised the temperature 15 degrees, coupled with the lack of temperature compensation on the level indication instrumentation system resulted in a tank level indication 10% lower than actua This indication error led the operators to leave the SIT level higher than actually desired following the last monthly sampling evaluatio Since the separate SIT level switch is not affected by temperature -change, it accurately alarmed on high level when a slight expansion in the level took plac There was no indication that the high level was due to the in-leakage problems previously experience *)
Proposed corrective actions include the replacement of the SIT level instruments with instrumentation not susceptible to containment temperature, SIT pressure, or SIT in-leakage induced error * On April 24, 1987, at 8:20 p.m., a power transient occurred from approximately 100% power when a purification demineralizer (T-518),
which deborated the primary coolant, was placed in servic The demineralizer was not at a known boron concentration prior to valving it in to the Chemical and Volume Control syste Average coolant temperature and power increased until T-518 was bypassed after approximately 30 minutes in servic Power increased to 101.6%.
The total time that reactor power was greater than 100%
was approximately 10 minute Control rods and boron were used to control power, though the excessive amount of boron used caused power to decrease to approximately 90%.
T-518 had been placed in service prior to receiving the boron sample results due to low Volume Control Tank leve While the inspector acknowledged that procedural weaknesses may exist, it is expected that an operator would be in full control of reactivity changes by being aware of the expected borating or deborating effect of a demineralizer and also be able to accurately compensate for this effect using batch additions or dilutions of boro The procedure was verified to include an appropriate caution concernin9 deboration and guidance on compensation for an unborated demineral1ze The guidance did not include a requirement to sample the demineralizer. This event was discussed at the management meeting (Paragraph 10) regarding the above concern The licensee indicated that they would address the NRC concerns in their review of this even During full power operation on April 27, 1987, the results of a routine surveillance test showed that the excore nuclear detectors did not meet the acceptance criteria for measaring quadrant power tilt or monitoring linear heat rat The determination was made at 4:19 At 5:58 p.m., the incore monitor was declared inoperable due to a plant computer failure during input of new incore alarm point Under the Technical Specifications (TS) 3.23.l power operation may continue if power is below 85% and manual monitoring of the incore detectors is performed every two hour Not being aware that the power level should be less than 85% in two hours, the Operations Superintendent directed that power be reduced at a slower than usual rate due to recent indications of failed fuel cladding (iodine spiking).
The computer was declared operable at 9:00 on the same date and power reduction was stopped at 93%.
The excore detectors which provide backup indication to the incores had previously been declared unusable since they were not within acceptance limits for use.
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TS 3.23.1 for Linear Heat Rate (LHR) is applicable above 50% power.
Required monitoring is performed by incore detectors through the plant (PIP) computer, or excores if they-are properly calibrated to the incore Absent these two means of monitoring LHR, certain actions are specified in the T The licensed operators in reading the TS interpreted 11Action 3 11 as not having any time constraint on being less than 85%.
However, a historical review of TS and the Safety Evaluation indicate that the last sentence of 11Action 2 11 was intended to be applicable in directing a power reduction below 85%
when neither monitoring system was operabl Although confusing, a conservative reading of the entire TS would have alerted the operators to the time requiremen As part of the corrective actions, the licensee plans on submitting a TS change request to clarify the requirement Failure to reduce reactor power below 85% within two hours was considered by the licensee to be a violation of the action requirement of Technical Specification 3.23.1 on the morning of April 28, 198 A one hour non-emergency 10 CFR 50.72 report was made at 8:10 on April 28, 1987, as a result of the discovered action requirement violation. Subsequent review of the situation by the licensee has raised doubt on their part as to whether a violation exist The resolution of this issue and the licensee action to submit a TS revision will be tracked as an Unresolved Item (255/87008-0l(DRP)).
At 3:25 p.m. on April 29, 1987, the licensee opened the East Safeguards Room air damper while the associated noble gas activity monitor RIA 1810 was administratively inoperabl RIA 1810 had been declared inoperable on April 27, 1987, for calibration and it was returned to service, though not declared operable, on April 29, 198 The Shift Supervisor had tested it and considered it functional, but the surveillance paperwork was still being held by the Instrument and Control Department pending consideration of additional maintenance, therefore, it was not declared operabl By opening the associated air damper, reliance is placed on the process monitor RIA 1810 to provide the isolation signal for a high radiation conditi-0 Technical Specification (TS) 3.16 establishes the required instrument setting for the isolation but does not address what is to be done if the monitor can not provide the isolation
- functio The basis of TS 3.16 describes the need for isolation so as to maintain acceptable dose levels at the site boundar TS Table 3.24-2 requires that an alternate method of monitoring be initiated (discussed below) but does not address isolation capabilit On January 22 and 30, 1984, Engineered Safeguards Rooms 1 noble gas monitors RIA 1811 and RIA 1810, respectively, were inoperable while their associated dampers were ope Corrective action document E-PAL-84-014 describes actions to preclude repetition of the event and includes the issuance of a Standing Order (SO) describing how the dampers are to be operated when the associated radiation monitor is inoperabl SO 53 was written July 23, 1984, specifying that the associated dampers must be closed if RIA 1810 or 1811 are inoperabl.. / *
The SO does not explicitly state that the RIA must be declared operable prior to opening the damper Common practice at Palisades is to prove operability of a component and declare operability
subsequent to the necessary administrative requirements prior to relying on its functio Alarm and Response Procedure 8, step 64 also states that if RIA 1810 or 1811 are inoperable, their associated dampers shall be close A similar event occurred on November 8, 1986, as documented in Licensee Event Report (LER) 255/8603 Liquid Radwaste Effluent Line Monitor RIA 1049 was administratively inoperable during a release and the compensatory measures of TS Table 3.24-1 were not take Similarly, the instrument had been tested to verify its alarm and trip function and had not been declared operable, but was being relied upon to perform its TS required functio LER 255/86038 states that the occurrence was reviewed with the Shift Supervisors and no further corrective actions were necessar The corrective actions taken following these two events were ineffective in precluding the April 29, 1987, event where an administratively inoperable component was relied upon to perform its functio This repeat event is considered a violation of 10 CFR 50, Appendix B,
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Criterion XVI, 11Corrective Action 11 (255/87008-02a(DRP)).
The SO will be revised to prevent an interpretation that would allow the dampers to be reopened after repair, but prior to declaration of operabilit The licensee is also considering proposin9 a change to TS to explicitly include an isolation function operability statement and an associated action statement for inoperabilit The inspector also discovered that the licensee has no documented preplanned alternate methods to meet TS Table 3.24-2, Action 3 With less than the minimum number of operable Radioactive Gaseous Effluent Monitoring Instrumentation Channels listed in TS Table 3.24-2 3.d, 5.a and 6.a, Action 38 requires that initiation of a preplanned alternate method of monitoring the appropriate parameter occur within 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> This TS has been in place since November 9, 198 The licensee has committed to proceduralize the alternate method and this will be tracked by Open Item 255/87008-03(DRP).
There are no known instances where the licensee has failed to take appropriate actio As of April 30, 1987, the licensee had not implemented or incorporated the March 23, 1987, Technical Specification (TS)
Amendment 103. This amendment changes TS 6.8.3 to require that the appropriate senior department manager approve temporary procedure change The licensee indicated that they were waiting until the implementing procedure, Administrative Procedure 10.41, was revised to incorporate the T The procedure was revised and issued on May 6, 198 Seventeen Temporary Changes (TCs) had been approved in the interim by individuals other than senior department manager This is considered a violation as set forth in the Notice of Violation (255/87008-04(DRP)).
The licensee is currently having the subject TCs approved by the appropriate senior manager * On May 4, 1987, two events occurred where fire protection features were rendered inoperable without the required compensatory actions being take The first event started at 6:29 a.m. when Operations isolated the sprinklers for the cable spreading room and the IC switchgear room to permit repair of a firewater flow switc As required by Technical Specification (TS) 3.22.3.1 and the proposed revision to the TS, a firewatch with backup suppression was provided for the cable spreading room but not for the switchgear roo The violation was identified by a plant welder assi9ned to the work who was aware of the system desig TS action requirements were met by 8:30 a.m. on May 4, 198 The isolation valve name tag nomenclature (MV-127FP 11 Cable Spread SPR Shutoff 11 ) may have contributed to the error since it did not indicate that it isolated the IC switchgear roo However, plant drawing M-216, Sheet 2 clearly shows that isolating valve MV-127FP results in isolation of sprinklers to both room Licensee personnel evidently did not refer to the system drawing in preparing the tagout for the work or they would have been alerted to the impact of closing the isolation valve on the other room 1s sprinkler Although clearly a violation of fire protection requirements, the NRC has not yet amended the Palisades TS to reflect the inclusion of the IC switch9ear room under the requirements of Section 3.22.3. Since the violation was identified and will be reported by the licensee, no recent similar events have occurred, and corrective action was taken and is planned to prevent recurrence, no citation of the violation is planned at this tim Until licensee corrective action to prevent recurrence are completed this will be tracked as an Unresolved Item (255/87008-03(DRPJ).
The second event on May 4, 1987, was caused by a maintenance welding activity where welding cables were strung through a firedoor from 8:30 a.m. through 11:18 a.m. when the lack of a firewatch was discovered by a Security Office As required by TS 3.22.5.1, all fire barrier penetrations not intact shall have either a continuous firewatch posted or an hourly inspection performed if there is an operable fire detector inside the safety related are The above violation is identical to the two examples cited in Inspection Report No. 255/86003 where cables and hoses blocked open the East Safeguards room and the Auxiliary Feed Pump room fire door As required by the licensee 1s corrective action program and 10 CFR 50 Appendix B Criterion XVI, corrective 11 *** measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition~
The above failure to take effective corrective action is violation as set forth in the Appendix (Violation 255/87008-02b(DRP)).
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On March 25, 1987, a quarterly Fire Protection Surveillance was performed by operators and it was determined that the fire water flow switch (WFS-2G2) to the sprinklers in the 1-2 Diesel Generator room was inoperabl With operable fire detection in the room, Technical Specification 3.22 requires that an hourly fire tour be establishe On April 20, 1987, at 11:25 a.m. while preparing to release work order FWS-24701737 for repair of the flow switch, it was discovered that no fire tours were being conducte The operators performing and reviewing the surveillance were not aware of the operability and fire watch requirements. Corrective actions to commence hourly fire tours were implemented,when the event was discovered on April 20, 198 Further evaluation and closeout review of this event will be conducted after the licensee submits a Licensee Event Repor Two violations (one with two examples) and no deviations were identifie.
Maintenance The inspector reviewed and/or observed the following selected work activity and verified whether appropriate procedures were in ef~ect controlling removal from and return to service, hold points, verification testing, fire prevention/protection, radiological controls, and cleanliness where applicable:
Federal Industrial Sealing of body to bonnet leak on feedwater recirculation valve CV-0710 (WO CDS 24702106).
No violations or deviations were identifie.
Surveillance The inspectors reviewed surveillance activities to asce~tain compliance with scheduling requirements and to verify compliance with requirements
- relating to procedures, removal from and return to service, personnel qualifications, and documentatio The following test activities were inspected: DW0-1 SH0-1 Daily Control Room Surveillance Operators Shift Surveillance No violations or deviations were identifie.
Licensee Event Reports Through direct observations, discussions with licensee personnel, and review of records, the inspectors examined the following reportable events to determine whether:
reportability requirements were met; immediate corrective action was accomplished as appropriate; and.
corrective action to prevent recurrence had been accomplished per the Technical Specification (Closed) LER 255/85012:
The licensee failed to perform Technical Specific~tion (TS) required surveillances on five containment isolation check valve An enforcement conference was held October 2, 1985, and a no response violation issued in Inspection Report No. 255/85023(DRP).
The licensee completed a review of TS versus surveillance procedures to ensure that all required surveillances are being performe Also during this review, administrative and editorial discrepancies were note Several of these, such as incorrect references, have not yet been correcte Thou9h not considered a major problem, these should be corrected in a timely manne (Closed) LER 255/86040 Revision 2:
The root cause of the Control Rod Drive seal housing cracking was updated after receipt of Combustion Engineering 1s evaluatio Potassium contamination was identified as the cause of the observed transgranular stress corrosion crackin No likely source of the contaminant was identified, although it was presumed to have been introduced during the manufacturing process. Defect reporting under 10 CFR 21 was not required since Palisades received the entire manufacturing lot of thre (Closed) LER 255/87008:
During Reactor Protection System (RPS) Matrix Relay testing an inadvertent reactor trip occurred on March 11, 1987, at 3:15 a.m.. The purpose of the testing was to verify that control rod clutch control power supplies could be interrupted for each channel in the RPS Matrix, such that upon RPS actuation all control rod~would be release The reactor was in hot shutdown with all rods fully inserted and the RPS rese The RPS Matrix test switch apparently failed allowing all four clutch power supplies to deenergiz A repeat of the testing sequence could not duplicate the even The Matrix test switch apparently failed due to dirty contacts which were then restored by their self-wiping featur The test had not been conducted during the preceding nine months due to the outag No prior problems with these switches had been experienced, likely due to more frequent us The test procedure was revised to require exercising of the test switches prior to actual test performanc The licensee also plans to replace the switches due to normal wear and age of these component Completion of this will be tracked as an open item (255/87008-05(DRP).
No violations or deviations were identifie.
Management Meeting A management meeting was held between Consumers Power Company, represented by Dr. F. W. Buckman, Mr. J. F. Firlit and staff as identified in Paragraph 1, and the NRC represented by Mr. C. E. Norelius, Dr. C. J. Paperiello and staff on April 24, 198 The licensee presented their Proposed Configuration Control Program including discussion of the purpose, methodology, organization and scop The Plant Maintenance
- Manager also discussed Preventive Maintenance Program development, implementation goals and current status, plant trending and other future plan No formal conclusions or decisions were made by the NRC as a result of this meetin.
Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspectors, and which involve some action on the part of the NRC or licensee or bot Open items disclosed during the inspection are discussed in Paragraphs 3.f and.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviation An Unresolved Item disclosed during the inspection is discussed in Paragraph.
Management Interview A management interview was conducted on May 4, 1987, at the end of the inspection and again on May 8, 1987, to update licensee mana~ement on resolution of certain item The scope and findings of the inspection were discusse The inspector also discussed the likely information content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspectio The licensee did not identify any such documents/processes as proprietary.
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