IR 05000454/1993013

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Safety Insp Repts 50-454/93-13 & 50-455/93-13 on 931001-31.No Violations Noted.Major Areas Inspected: Operational Safety Verification,Matl Condition,Security, Housekeeping & Plant Cleanliness & Radiological Controls
ML20058G061
Person / Time
Site: Byron  Constellation icon.png
Issue date: 12/01/1993
From: Farber M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058G047 List:
References
50-454-93-13, 50-455-93-13, NUDOCS 9312090090
Download: ML20058G061 (13)
v • d • e


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U.S. NUCLEAR REGULATORY COMMISSION

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REGION 111 i

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Reports No. 50-454/93013(DRP); 50-455/93013(DRP)  !

Dockets No. 50-454; 50-455 Licenses No. NPT-37; NPT-66 ,

Licensee: Commonwealth Edison Company l Executive Towers West III  !

1400 Opus Place ,

Downers Grove, IL 60515 facility Name: Byron Station, Units I and o i inspection At: Byron Site, Byron, Illinois ,

inspection Conducted: October 1 - 31, 1993 '

.t inspectors: H. Peterson l C. H. Brown i R. B. Landsman J. G. Guzman '

Approved By: & 3

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Martin J. fp{6er, Chief ' Date

Reactor ProYects Section lA l inspection s Summarv

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Inspection from October 1 throuah 31. 1993 (Reports No. 50-454/93013(DRP): 50-455/93013(DRP)). -l Areas Insnected: Routine, unannounced safety inspection by the resident I inspectors of previous inspection findings, operational safety verification, ,

material condition, housekeeping and plant cleanliness, radiological controls, security, safety assessment / quality verification, maintenance activities, surveillance activities, and engineering and technical suppor :

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R J sults: In the ten areas inspected, no violations or deviations were  ;

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identified. . The following is a summary of performance during this inspection  !

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Plant Operations Performance in this area was considered good. During this inspection period, {

u Unit 2 was started up following-a refueling outage. The outage was originally i

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scheduled to last 60 days; however, the licensee successfully completed the l outage in 52 days. During the Unit 2' reactor startup the licensee experienced  !

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some difficulties, including problems with the speed control (governor) l l

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9312090090 931201 i PDR ADDCK 05000454  ;

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modification to the 2B turbine-driven main feedwater pump, safety injection  :

relief valve lifting, and back leakage of safety injection and residual heat  !

removal check valves (paragraph 6). The licensee's response to these items l was satisfactor l

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i Personnel errors were aggressively addressed during this inspection period. A l

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high level of attention to detail was continuously encouraged by the i 1 management. Station management and staff throughout the plant maintained a - i heightened awareness of all levels of plant activities and responsibilitie l t

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Safety Assessment /Ouality Verification  !

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Performance in this area was considered good. The inspectors observed the  !

d effectiveness of field monitoring activities associated with temporary lif t of j out-of-service tagouts (paragraph 4). Concerns were immediately brought to j management's attention by the On-Site Quality Verification group and were j quickly corrected, j

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Maintenance and Surveillance ,

i Performance in this area was considered good. Major activities during the  !

Unit 2 outage were effectively controlled, resulting in early completion of j the refueling outage. A summary of major work items is noted in paragraph 3c  ;

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Engineerino and Technical Support i

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Performance in this area was considered good. The engineering organization t jl faced several challenges and satisf actorily solved each problem. Activities i included: installation of temporary / portable N u monitors on Unit I due to  !

the steam generator tube leak event at Braidwood station; safety injection and  :

residual heat removai check valve back leakage; identification and repairs to i
the Unit 2 control rod drive shaft funnel problem; and seismic design concerns  ;
associated with plant scaffolding (paragraph 6). l;

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i DETAILS .l f

I Persons Contacted i

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Commonwealth Edison Company (Ceco)

K. Schwartz, Station Manager i

  • T. Tulon, Operations Manager  ;

D. St. Clair, Site Engineering Construction Manager  ;

  • P. Johnson, Technical Service Superintendent

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  • E. Campbell, Support Services Director
  • M. Snow, Work Control Superintendent
  • D. Brindle, Regulatory Assurance Supervisor
  • T. Gierich, Maintenance Superintendent  ;

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  • T Schuster, On-Site Quality Verification Director i W. Grundman, On-Site Quality Verification Superintendent  !
  • C. Bontjes, On-Site Quality Verification Inspector  !

- A. Javorik, Technical Staff Supervisor r

  • E. Zittle, Security Administrator j

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. *P. Enge, NRC Coordinator R. Wegner, Shift Operations Supervisor j W. Dijstelbergen, Site Engineering Modification Supervisor

  • K. Passmore, Site Engineering Support Supervisor W. Kouba, Long Range Work Control Superintendent l
  • E. Bendis, Admin Operating Engineer  ;

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  • Denotes those attending the exit interview conducted on November 1, i 199 The inspectors also had discussions with other licensee employees as !

, necessary, including members of the technical and engineering staffs; !

j reactor and auxiliary operators; shift engineers and foremen; and j

electrical, mechanical and instrument maintenance personnel; and }

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contract security personne !

i i Action on Previous Inspection Findings (92701. 92702) l f

I (Closed) Unresolved item 454/455-92015-03 (DRP): Apparent i falsification of rounds. This item was a generic issue addressed !

l by the NRC in Information Notice (IN) 92-30, " Falsification of l l Plant Records," issued on April 23, 1992. Following this action, l the NRC found potential instances of inaccurate documentation of !

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round The licensee then performed a review of records and j identified some potential records at Byron as incomplete or J; inaccurate. Follow up actions by the licensee were determined to i be adequate to prevent recurrence. Subsequently, a no response !

violation was issued by the Region III Regional Administrator via !

letter dated October 15, 1993. This item is considered close l

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'l (Closed) Inspection Followuo Item 454/455-93012-04 (DRP): Two :

separate pressurizer transients occurred during the Unit 2 l shutdown on September 3 and 5, 1993. These transients posed ,

questions associated with exceeding the departure from nucleate l boiling (DNB) pressure limits, and pressurizer cooldown limit l Following further investigation, it was determined that one of the j transients was the result of inadequately following plant 1 procedures. The September 5 event was caused by shift operator's l attempt to better cool the pressurizer by securing all the l heaters. This action was a violation of station procedure 2BGP l 100-5, " Shutdown and Cooldown," which states in part that attempts ;

should be made to maintain a continuous _outsurge condition by ;

maintaining pressurizer backup heaters on with spray flow, and i that these heaters are to remain on until reactor coolant system - .

solid conditions are established. This apparent violation of ;

procedures occurred during the same time frame as the cited ;

violation for failure to follow procedures during the last _ i

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inspection report, 454/455-93012-02 (DRp). This event will be tracked and considered as another example of the same violation; ;

therefore, this follow up item will be considered close )

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! 3. Plant Operations Unit 1 operated at power levels up to 100% in the load following mode throughout the report perio ;

Unit 2 was in a refueling outage at the start of the report period. On October 24, 1993, a reactor startup was initiated. On October 25, 1993, -l at 1:41 p.m. the generator was synchronized to the grid. Although-originally scheduled for 60 days, the refueling outage was completed in 52 days, Operational Safety Verification (71707. 93702)

The inspectors verified that the facility was being operated in conformance with the licenses and regulatory requirements, and that the licensee's management control system was effectively carrying out its responsibilities for safe operatio On a sampling basis, the inspectors verified proper control room staffing and coordination of plant activities; verified operator adherence with procedures and technical specifications; monitored control room indications for abnormalities; verified that electrical power was available; and observed the frequency of plant and control room visits by station managemen Following the September events associated with personnel errors, which led to a cited violation in inspection report 93012 for lack of following procedures, the licensee's level of awareness and attention have been elevate Root cause investigation and long l- term corrective actions are still in progress; however, the I licensee has initiated actions to resolve concerns over personnel

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l attention to details. These actions included required reading of ,

the violation, added review and attention of high level activities  :

by upper management, and periodic discussions with the staf J

Unit 2 Reactor Startup l'

l During the second week of October, having completed refueling activities, including the unexpected repairs on the control rod  ;

drive funnel (paragraph 6), the licensee successfully transitioned l out of Mode 6. The inspectors observed the licensee's subsequent I mode change onsite review meetings, checklists, and startup activities. Mode change activities were performed satisfactorily, j and the Unit 2 startup was initiated on October 24, 1993. The l

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licensee's performance during the Unit 2 startup was good;  ;

I however, a few equipment problems were identified. For example, j l during the mode changes and subsequent startup surveillance 1

testing, the 2A and 28 safety injection pump discharge relief i l' valves lifted and had to be repaired (paragraph 6); the 2A reactor j coolant pump developed a seal leak; and the modification >

associated with the speed control unit for the 28 main feed pump caused too much speed oscillation. All anomalies were well i managed and corrective actions were satisfactorily made by the licensee. Overall, the startup progressed satisfactorily and was j completed without any major complications on October 25, 199 j i i b. Enoineered Safety Feature (ESF1 Systems (71710) 1 I

During the inspection, the inspectors selected accessible portions  ;

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of several ESF systems to verify status. Consideration was given  ;

to the plant mode, applicable technical specifications,-limiting  ;

conditions for operation action requirements (LC0ARs), and other applicable requirement Various observations, where applicable, were made of hangers and supports; housekeeping; whether freeze protection, if required, was installed and operational; valve position and conditions; potential ignition sources; major component labeling, lubrication, cooling, etc.; whether instrumentation was properly installed and l functioning and significant process parameter values were l- consistent with expected values; whether instrumentation was calibrated; whether necessary support systems were operational; and whether locally and remotely indicated breaker and valve positions agree During the inspection, the accessible portions of the diesel driven auxiliary feedwater (AFW) Pumps IB and 28 systems were walked dow No operability concerns were identified; however, one minor item was identified. During the system walkdown, it was -

identified that the installation of two valves, on the suction

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line of the condensate storage tank for the 2B AFW pump, were-I swapped, when compared to the other three pairs of valves for'the AFW system. Locked open manual isolation suction valve, 2AF0028,

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AFW system. Locked open manual isolation suction valve, 2AF002B, i was installed upstream of the suction check valve, 2AF001B, vice i downstream of the check valve. The P&ID correctly shows the !

unusual configuration of the two valves for the 2B AFW syste i The licensee's engineering group investigated with Sargent and ,

Lundy, and determined that it was constructed this way and does !

not propose a safety system operability concern, t

c. Unit 2 Refuelino Outage Summary j i

On October 25, 1993, Unit 2 generator was synchronized to the ;

grid, marking the completion of a 52 day refueling outage-(B2R04). l This outage was originally scheduled for 60 days. The licensee's {

work control and planning were well managed. Furthermore, the 1 effective performance of maintenance activities added  !

significantly to the early completion of the refuel outag l Overall, the licensee's performance during the refuel outage was good. The station ccmpleted the outage below budget and the total l person rem performance was estimated at 185 rem. Work items ;

ranged from routine preventive maintenance to major equipment ;

repairs. The following lists some of the major work items- ;

performed during the B2R04 refuel outage:  ;

  • Refueling Activities (loading 88 new fuel assemblies; emergent repair of control rod drive thermal sleeve funnel)
  • Turbine / Generator Work (HP and LP turbine general !

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inspection, with B LP turbine rotor removal)

  • 2A and 2B Diesel Generator 18 Month Teardown and Inspection (replaced 20 fuel injector pumps with new design and ,

replaced 9 cylinder liners and pistons)  !

  • Steam Generator Work - Sludge Lancing and Tube Plugging i (total of 285 lbs. of sludge removed from the secondary; ,

total of 36 steam generator U-tubes plugged)

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  • Motor Operated Valves Static and Differential Pressure l Testing ,
  • System Auxiliary Transformer Work

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pump D 5 year inspection; pumps A, B, and D seal ,

replacement; and replaced lower guide bearing on pump D) l I

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In addition to good outage performnce, the licensee performed a

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self critique on ways to improve tcture refueling outages. Two :

improvement items were identified i'or the Fall 1994 Unit I refuel j outage (BIR06)

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  • Implement the work control task force recommendations which !

include developing a work control cente ,

  • Closely monitor Braidwood's spring 1994 outage to see what ;

items can be learned from the alliance with Westinghous ;

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d. Current Material Condition 3

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The inspectors performed general plant walkdowns, as well as ];

selected system and component walkdowns to assess the general and specific materici condition of the plant, to verify that Nuclear l Work Requests (NWRs) had been initiated for identified equipment problems, and to evaluate housekeeping. Walkdowns included an assessment of the buildings, components, and systems for proper j identification and tagging, accessibility, fire and security door i integrity, scaffolding, radiological controls, and any unusual '

conditions. Unusual conditions included, but were not limited to water, oil, or other liquids on the floor or equipment; 1 indications. of leakage through ceiling, walls or floors; loose I insulation; corrosion; excessive noise; unusual temperatures; and abnormal ventilation and lightin Subsequent to the Unit 2 refueling outage, the general material condition of the plant was considered satisfactory. However, )

there were still some areas of clutter, corroded valve stems, and loose tools and equipment at the end of this inspection perio The licensee was aware of all the material discrepancy and was actively pursuing corrective action e. Housekeepina and Plant Cleanliness The inspectors monitored the status of housekeeping and plant cleanliness for fire protection and protection of safety-related l equipment from intrusion of foreign matte In general, housekeeping and plant cleanliness have-improve At the conclusion of the Unit 2 outage, the inspectors performed containment close out inspections along with the licensee and only i identified a few housekeeping items. Overall, containment close- )

out cleanliness was goo !

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' Radiolooical Controls i

The inspectors verified that personnel were.following health  !

physics procedures for dosimetry, protective clothing, frisking, j posting, and randomly e.,2 mined radiation protection l instrumentation for operability and calibratio :

i Radiological controls continue to be good. Radiation protection i personnel continue to be very responsive to the needs of the .;

plant. Good implementation and adherence to the ALARA program by  ;

the staff resulted in aggressive reduction of personnel  ;

contamination and dose. At the completion of the Unit 2 refuel  !

outage, an estimate of the total person rem was calculated to be l 185 re j r

. Security Each week during routine activities or tours, the inspectors i monitored the licensee's activities to ensure that observed  !

actions were being implemented according to the approved security  !

plan. The inspectors noted that persons within the protected area _ '

displayed proper photo-identification badges and those individuals  !'

requiring escorts were properly escorted. The inspectors also verified that vital areas were locked and alarmed. Additionally, i the inspectors also observed that personnel and packages entering .

the protected area were properly searched by utilizing appropriate  !

equipment and/or by han l J

Station security personnel continue to be responsible and perform t

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their respective duties in a very professional manner. This

- includes the enforcement of exit portal monitoring at the exit gate house. in one situation, an individual was exiting the plant j when he alarmed the exit portal monitor. The individual assumed ,

it was an erroneous alarm and did not stop to repeat _ the  :

monitoring, as required by station policy. The security guard l stopped the individual and ensured that he perform the radiation  !

personnel monitoring again. The individual re-entered the portal 3 monitor and was satisfactorily surveyed. No alarms were

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No violations or deviations were identifie . Safety Assessment /0uality Verification (40500. 90712. 92700)  ;

i The inspectors evaluated the scope and effectiveness of the_ station self i assessment an_d quality assurance programs during the refueling outag j This included the review of the On-Site Quality Verification (SQV) field '

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monitoring reports (FMR), to determine the effectiveness of the FMR  !

program, in particular, during review of out-of-services (00S), the SQV  !

inspector noted that three master MS cards were not placed in the a appropriate temporary lif t document. packages as required by station i administrative procedure BAP 331-1, " Administrative Requirements for l l

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Temporarily Lifting 005 Cards and/or Placing Equipment In Test." These concerns were immediately brought to the attention of the on-duty shift supervisor and were quickly corrected. The Shift Operations Supervisor-additionally issued a daily order to provide additional awareness of this concern. Also, during the Unit 2 outage, SQV inspectors.provided good coverage of-major work items and satisfactorily followed the reactor startup activities. The SQV department continues to identify concern areas and forwards the findings to the respective staff and management in a timely manne Station management continues to give high regard to the findings and recommendations of the SQV organization and takes appropriate actions to correct the deficiencies and prevent recurrenc No violations or deviations were identifie . Maintenance / Surveillance (62703. 61726) Maintenance Activities (62703)

Routinely, station maintenance activities were observed and/or reviewed to ascertain whether they were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with technical specification The following items were also considered during this review:

approvals were obtained prior to initiating the work; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; and activities were accomplished by qualified personne Portions of the following maintenance activities were observed and reviewed:

  • NWR 04644 Unit 2 N-32 (Startup Channel) Loss of Detector Voltage
  • NWR B05009 2B Feedwater Pump High Pressure Governor
  • NWR B02955 Replace Solenoid with ASCO Type on 2SX178 (SX Supply Valve for 2B AF Water Pump)

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  • NWR B02956 Replace Solenoid with ASCO Type on 2SX173 (SX l Return Valve for 2B AF Water Pump)

! Surveillance Activities (61726)  ;

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During the inspection period, the inspectors observed technical specification required surveillance testing and verified that .

testing was performed in accordance with applicable procedures, '

that test instrumentation was calibrated, that results conformed with technical specifications and procedure requirements and were i

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reviewed, and that any deficiencies identified during the testing were properly resolve The inspectors witnessed portions of the following surveillances:

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  • 2B05 8.1. A Diesel Generator Monthly Operability j

- IBVS 7.1. A Motor Driven Auxiliary Feedwater Pump Menthly i

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  • IBVS 5.2. A Safety Injection Pump ASME Requirements ;

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  • IBOS 3.1.1-20 1A Solid State Protection System Bi-Monthly -l
  • 1805 3.4.2.A-1 Turbine Valve Governor Valve Surveillance

- No violations or deviations were identifie ! Enoineerino & Technical Support (37700)  ;

The inspectors evaluated the extent to which engineering principles and r evaluations were integrated into daily plant activities. This was accomplished by assessing the technical staff involvement in non-routine t events, outage-related activities, and assigned technical specification -!

surveillances. Further evaluation was conducted, as necessary, by i observing technical staff involvement associated with on-going  !

maintenance work and troubleshooting, and reviewing deviation ,

investigations and root cause analysi l

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Safety Iniection Relief Valve' Problem and 'Subseouent Check Valve Back Leakaae i

on October 21 - 23, 1993, while performing Emergency Core Cooling System i

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(ECCS). Check Valve Testing in preparation of Unit' 2 startup, the 2A' and -

2B safety injection (SI) discharge relief valves-(2SI 8853 A and B)  :

lifte Engineering and Operations departments conducted investigations to determine the cause of the problem. The licensee concluded-that the l relief valve lifting was attributed to alignment af the SI system to . j portions of piping already at reactor coolant system pressure, it was i later verified that possibly one of the reactor coolant system (RCS)  !

cold leg check valves (SI 8948 A, B, C, or D) was leaking since_SI  !

discharge pressure was above normal discharge pressure. This

differential pressure condition was thought to have produced a pressure shock wave or possible water hammer which caused the relief valves to  :

lif In the following two days, the licensee took action to relieve l pressure upstream of the RCS and Si check valves (SI 8819 A, B, C, and j D), in attempt to seat the check valves by increasing the differential i pressure across the valves. The RCS check valves seated satisfactory; i however, the SI check valves continued to have a small back leakag !

Subsequent to the actions to seat the RCS and SI check valves, the 1 decreasing of the upstream pressure for the RCS check valves also j decreased the downstream pressure on the residual heat removal (RHR)

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cold leg check valves (SI 8818 A, B, C, and D). This resulted in a  !

minor back leakage into the RHR syste The licensee appears to have l taken all appropriate actions, including entering the limiting condition I for operation action requirement for ECCS. The relief valves were  !

satisfactorily repaired and the SI system was returned to operational-  !

condition. The RHR system continues to have a minor check valve back i leakage (approximately 30 gpd) from the SI accumulators; however, the i inspectors verified, with NRC headquarters technical branch, that no l safety system operability concerns existed. The RHR system pressure- t increases due to the SI accumulator pressure, which requires periodic -  ;

venting of the RHR system. The licensee has issued a daily order to  !

periodically vent the RHR system at approximately 250 psi. The '

inspectors will continue to monitor the licensee's activitie Follow Vn to the Steam Generator Tube Leak Event at Braidwood j On October 23, 1993, Braidwood Station experienced a steam generator ,

tube leak approximately 300 gpd and initiated a reactor shutdow Byron j station immediately rendered assistance and sent engineering' support )

personnel to Braidwood. The 300 gpd primary to secondary leak rate was 1 the administrative limit for both Byron and Braidwood stations. The "

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actual technical specification limit for a steam generator leak rate requiring mitigating actions is 500 gpd. Following the event, the >

licensee took conservative actions to decrease the administrative limit for primary to secondary steam generator _ leak rate.to 150 gpd, and f installed temporary / portable Nitrogen 16 radiation monitors on-two Unit I steam generator steam lines,' steam lines A and B. Byron 9 nit l'has  !

model D4 steam generators which are more susceptible to tube leakag !

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Control Rod Drive Shaft funnel Repair j

'i On October 8, 1993, while performing an underside inspection of the Unit i 2 reactor head the licensee identified an unusual shining object. Upon further inspection, it was found that one of the guide' funnels attached to the thermal sleeves to guide the control rod drive shafts .through the q reactor head was missing. The shining object was the portion of the i thermal sleeve where the funnel was to be attached. The licensee found- j the dislodged funnel on the upper internals encircling the B-8 position i drive shaft. The CRD guide funnels are threaded onto the thermal sleeve 1 and plug welded to the sleeve. The. licensee's engineering group and i Westinghouse initiated an investigation on the cause of how the funnel l came loose and what actions were necessary to repair the equipment. The  !

licensee took appropriate actions to reinstall the funnel to its . .!

original configuration utilizing the old funnel and plug welding it to the thermal sleeve. Root cause determination of the funnel failure  !

continues, with some speculation that the original plug weld was no !

correctly performed and did not adequately anchor the funnel' to the i thermal sleeve. The licensee conservatively verified that the remaining l CRD funnels were properly secured. The licensee took action to raise i this event as a potential generic issue and entered it into the nuclear  :

industry network. Also, questions were forwarded to Westinghouse as a  ;

i potential Part 21 issu i Seismic Desian Concerns Associated with Scaffoldina  ;

During a review of site requirements for erecting scaffolding, th inspector determined that the site was not adequately addressing seismic ,

requirements for scaffolding in safety-related applications, adjacent to or over operating or operable safety-related equipmen !

Site personnel indicated that the site has a general practice that

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scaffolding is not allowed adjacent to or over operating or operable safety-related equipment. It should be noted that.the licensee's corporate office had undertaken a project to provide improved.

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engineering analysis of scaffolding designs, as evidenced through draft technical information directives. The-licensee generated Nuclear j Tracking System Item 454-100-93-01300-01 and 02 to address the general l concerns on their overall scaffolding process. The areas to be covere !

include: 1) lack of training of personnel in seismic requirements (both  ;

Ceco and contractor crafts responsible for erecting scaffolding); and 2)  :

following scaffold erection, a review and sign-off block for a j structural (seismic) inspection for seismic requirements on the Scaffold i Inspection Tag required by scaffolding procedure BAP 499- j Consideration is being given to have both the training and inspection  ;

conducted by structural engineers from the SEC Departmen 'j i

No violations or deviations wera identifie i

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B i Report Review-During the inspection period, the inspector reviewed the licensee's i Monthly Performance and Monthly Plant Status Reports for September 199 j The inspectors confirmed that the information provided _ met the requi rerr- .s of Technical Specification 6.9.1.8 and Regulatory Guide ;

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No violations or deviations were identifie . Meetinas and Other Activities (30703)  ! J_nformational Tour by Illinois State Representatives On October 20, 1993, members of the Illinois State Government, i State Representatives Mssrs. Irvin Ronald Lawfer and David Wirsing, met with station management and toured the facility.

" Commonwealth Edison Board of Directors Nuclear Operations Committee Meetina On October 26, 1993, members of the Commonwealth Edison Board of Directors for the Nuclear Operations _ Committee met at the Byron Station. The members, including former NRC Chairman Lando Zech, met with selected staff, the station management, the Senior Resident inspector, and toured the facilit Annual Offsite Emeroency Response' Support Personnel Meetina On October 28, 1993, the inspectors attended the annual meeting of the offsite emergency response support personnel. The meeting was held at the Byron station training center. The licensee made a-general presentation and discussed the recent changes to the Emergency Preparedness Plan. The meeting was attended by several State and Local officials, including representatives from Ogle county, Illinois State Police, and Illinois Department of Nuclear Safet ' Exit Interview The inspectors met with the licensee representatives denoted in

- paragraph I during the inspection period and at the conclusion of the inspection on November 1, 1993. The inspectors summarized the scope and results of the inspection and discussed the likely content of this inspection report. The licensee acknowledged the information and did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur
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