ML17321A484

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Insp Repts 50-315/84-23 & 50-316/84-25 on 841222-850211. Noncompliance Noted:Repetitive Failure to Collect & Analyze Compensatory Grab Samples in Required Time Limit
ML17321A484
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 02/27/1985
From: Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17321A482 List:
References
50-315-84-23, 50-316-84-25, NUDOCS 8503190133
Download: ML17321A484 (17)


See also: IR 05000315/1984023

Text

~

~

U. S.

NUCLEAR REGULATORY CON>iISSION

REGION III

Reports

No. 50-315/84-23(DRP);

50-316/84-25(DRP)

Docket

Nos

~ 50-315;

50-316

Licenses

No. DPR-58;

DPR-74

Licensee:

American Electric Power Service Corporation

Indiana

and >iichigan Electric Company

1 Riverside Plaza

Columbus,

OH

43216

Facility Name:

Donald C.

Cook Nuclear

Power Plant, Units

1 and

2

Inspection At:

Donald C.

Cook Site,

Bridgman, HI

Inspection Conducted:

December

22,

1984 through February

11,

1985

Inspectors:

B. L. Jorgensen

J.

K. Heller

Approved By:

G.

C. Wright, Chief

Reactor Projects. Section

2A

gl7 gS

Date

Ins ection

Summar

Ins ection on December

22

1984 throu h Februar

11

1985

Re orts

No. 50-315 84-23

DRP '0-316

84-25(DRP

Areas Ins ected:

Routine unannounced

inspection

by the resident

inspectors

of

licensee

actions

on previous inspection findings; operational safety; reactor

trips; surveillance;

Licensee Event Reports;

maintenance;

and independent

inspection activities.

The inspection involved a total of 242 inspector-hours

by two NRC inspectors

including 30 inspector-hours off-shift.

Results:

Of the seven

areas

inspected,

no items of noncompliance

or deviations

were identified in six areas;

one item of noncompliance

was identified in the

remaining area (failure to collect and analyze

compensatory

grab samples

within required time limits - Paragraph

6).

8503

Cg 050003 1 5

190i33 850227

l

PDR

A

PDR)

A

DETAILS

1.

Persons

Contacted

-W.

E.

o'rB

YP,

K.

>A.
  • J

>C.

G. Smith, Jr., Plant Manager

L. Townley, Assistant Plant Manager

A. Svensson,

Assistant

Plant Manager

A. Kriesel, Technical Supervisor,

Physical

Sciences

R. Baker, Operations

Superintendent

A. Blind, Technical Superintendent-Engineering

F. Stietzel,QC Supervisor

E. Murphy, Production Supervisor

The inspectors

also contacted

a number of licensee

and contract

employees

and informally interviewed operation, technical

and maintenance

personnel

during this period.

2.

>'<Denotes personnel

attending exit interview on February

19,

1985.

Licensee Action on Previous

Ins ection Findin s

(Open) Noncompliance

(315/81-28-01;

316/81-32-01

and 315/82-11-01;

316/82-11-01):

Noncompliance

315/81-28-01;

316/81-32-01

documented

that the controls for maintaining the "N" List as

an up-to-date,

reliable

reference

were inadequate.

Noncompliance

82-11-01 documented that while

verifying the adequacy of the updated

"N" List, the Divider Barrier Seal

(covered by Technical Specification 3/4.6.5.9

and considered to be safety

related)

was not listed.

This resulted in purchasing the seal

as

a non-

safety related item from a non-approved

vendor.

To correct these

items of

noncompliance the licensee

committed to review the "N" List for complete-

ness

and accuracy

and to make the required actions to make the list an

up-to-date

document.

The review and updating were scheduled to be com-

pleted by December

31,

1982.

While reviewing these

items the inspectors

were unable to find documentation that the review and updating had been

completed by December

31,

1982.

The licensee

was requested

to provide

documentation prior to the close of the next inspection report.

(Closed) Unresolved Item (315/82-15-07;

316/82-15-02):

This item ques-

tioned the Fire Protection Coordinator's practice of finding nonconforming

conditions

and using word-of-mouth to correct them.

Through discussion

with the Fire Protection Coordinator

and review of condition reports,

the

inspectors

found that nonconforming conditions are currently being identi-

fied on Condition Reports.

In addition, this item documented that findings

from the monthly

QC surveillance

housekeeping

reports

are not subject to

the condition reporting system.

Through discussion with the Quality Con-

trol Supervisor

and the Plant Manager,

the inspectors

were informed that

the housekeeping

Quality Control Surveillance reports

are reviewed by the

Plant Manager

who initiates corrective action.

(Closed)

Noncompliance

(315/82-22-04;

316/82-22-04):

The Plant Nuclear

safety Review Committee

(PSNRC) did not document that determination of an

unreviewed safety question

was

made for violations of Technical Specifica-

tions.

The inspectors verified the licensee action as stated in their

response

dated Narch 22,

1983.

No items of noncompliance or deviations

were identified.

0 erational

Safet,

Verification

The inspectors

observed control room operations,

including manning, shift

turnover,

approved procedures

and

LCO adherence,

reviewed applicable logs,

and conducted discussions

with control room operators

during the inspection

of December

22,

1984 through February

11,

1985.

Observations of control

room monitors, indicators,

and recorders

were

made to verify the operabil-

ity of emergency

systems,

radiation monitoring systems,

and nuclear

and

reactor protection systems.

Reviews of surveillance,

equipment condition,

and tagout logs were conducted.

Proper return to service of selected

components

was verified.

Tours of the auxiliary building, turbine building,

Unit

1 containment,

and screenhouse

were made to observe accessible

equip-

ment conditions,

including fluid leaks, potential fire hazards,

and control

of activities in progress.

By observation

and direct interview the inspectors verified that the physi-

cal security plan was being implemented in accordance

with the station

security plan.

The inspectors

observed Unit 2 loose parts monitoring activities following

receipt of an alarm on the monitoring instrumentation during startup

on

January

3,

1985.

The licensee

and vendor

(Westinghouse)

evaluation indi-

cated the likelihood that broken split pin parts,

as found in other plants,

were the cause of the condition.

The plant was cooled down, the steam

generators

opened,

and small split pin parts were found and retrieved

as

expected.

The licensee

subsequently

provided

NRC Region III a special

report on this matter, including a safety evaluation in support. of the

licensee's

review pursuant to

10 CFR 50.59.

During a tour of the Unit 2 cable spreading

room, the inspectors

noted two

fire extinguishers

without current operability check tags attached.

Inde-

pendent

records verified the proper checks

had been performed

and current

tags were affixed to the subject extinguishers.

Unit 2 pressurizer

spray valve NRV-163, which contributed to a reactor

trip/safety injection on November

11,

1984 due to excess

leakage,

once

again became

suspected

of leakage despite intervening maintenance

and

tagging of the valve controller to maintain the valve in "manual" and

closed.

This was identified only after considerable

investigative effort

on the pressurizer

heaters

as

a potential source of pressure

control

problems - a situation contributed to by placement of the aforementioned

tag such that the valve controller was partially obscured.

The tag was

placed to the side of the controller and

a manual "closed" signal given

to the valve, which may have drifted slightly off its seat.

Several matters

came to the attention of the inspectors for which Licensee

Event Report's

(LERs) are anticipated.

These matters will be reviewed fully

in evaluation of the

LER information.

They include: for Unit 2 - identifi-

cation of a cold leg RTD installed with components

not all environmentally

qualified; for Unit 1 - concurrent inoperability during Mode 5 of both the

AB emergency diesel

and the

CD station battery without restoration of con-

tainment integrity within eight, hours; for both Units - identification of

multiple Rockwell RTD loop bypass isolation valve failures,

and; for both

Units - ice condenser

door testing to erroneous criteria such that surveil-

lance test failures were not identified and appropriate

LCO Action State-

ments

complied with.

Except for the Rockwell valve failure matter,

these

items

may have

NRC enforcement

action implications'his

was discussed

at

the Management

interview.

In review of preliminary information concerning concurrent inoperability

of the

AB diesel

and the

DC battery identified above,

the inspectors dis-

covered

a Technical Specification "interpretation" by the Plant Nuclear

Safety Review Committee

(PNSRC) involving LCO actions for inoperable

station batteries.

This interpretation

(No.

12 dated July ll, 1978)

appears

contradictory to Technical Specification 3.8 '.3, at least insofar

as no cross-reference

is made to Specification 3.0.3 for contemplated

cross-

tieing of the batteries

when one or the other battery is "inoperable".

This situation developed with Unit 2 in Mode

1 on January

30,

1985 when the

batteries

were cross-tied

under the provisions of 3.0.3 while a faulty cell

in one battery was jumpered.

An LER is forthcoming, on this matter,

which

will be reviewed further.

Concerning the

PSNRC interpretation,

the licen-

see

agreed to re-examine

the matter.

This was discussed

at, the Management

Interview.

Routine inspector review of Unit

1 logs identified an apparent

concurrent

inoperability of two engineered

safety feature fans, contrary to Technical

Specification requirements.

Further evaluation

and discussion with licen-

see personnel

established

that Specifications

had been met,

appearances

to

the contrary being

a consequence

of imprecise log entries.

The log entries

were corrected.

Observations

of the plant housekeeping/cleanliness

conditions

and the

implementation of the radiation protection program

and controls were made.

These reviews

and observations

were conducted to verify that facility oper-

ations were in conformance with the requirements

established

per Technical

Specifications,

10 CFR,

and Administrative Procedures.

No items of noncompliance or deviations

were identified.

Reactor Tri s

Following the plant trips discussed

below, the inspectors

ascertained

the

status of the reactor

and safety systems

by observation of control room

indicators and/or by discussions

with licensee

personnel.

The inspectors

verified the establishment

of proper communications

and reviewed the

corrective actions

taken by the licensee.

Unit 2 tripped from about 2/ power on January

12,

1985 when steam generator

lo-lo level developed

from a combination of steam

demand control difficulty

at low power and level shrinkage

due to increased

cold auxiliary feedwater

flow in response

to these difficulties.

System

responses

to the trip were

normal and the reactor

was

made critical at

1928 hours0.0223 days <br />0.536 hours <br />0.00319 weeks <br />7.33604e-4 months <br />.

Unit 2 tripped from about 96/ power on January

26,

1985 when power was lost

to a control room instrument panel

(GRID III) due to an internal computing

capacitor short circuit.

This caused

an indicated loss of reactor coolant

flow on one loop, tripping the reactor.

Subsequent

to the trip, the Tur-

bine Driven Auxiliary Feedwater

Pump

(TDAFP) failed to auto-start

on steam

generator lo-lo level.

Investigation revealed the

TDAFP would not stay

latched.

A governor linkage maladjustment

was corrected

and several

TDAFP

start tests,

including start

on the lo-lo level signal,

were performed

successfully.

Internal components of GRID III were replaced.

The Plant

Nuclear Safety Review Committee

(PNSRC) reviewed the circumstances

of the

trip and the findings concerning

GRID III and the TDAFP; restart

was

approved.

The reactor

was

made critical at 0241 hours0.00279 days <br />0.0669 hours <br />3.984788e-4 weeks <br />9.17005e-5 months <br /> the following day.

No items of noncompliance

or deviations

were identified.

Monthl

Surveillance Observation

The inspectors

reviewed Technical Specifications

required surveillance

testing on the systems listed below and verified that testing was performed

in accordance

with adequate

procedures,

that test instrumentation

was cali-

brated, that limiting conditions for operation were met, that removal and

restoration of the affected

components

were accomplished,

that test results

conformed with Technical Specifications

and procedure

requirements

and were

reviewed by personnel

other than the individual directing the test,

and

that deficiencies identified during the testing were properly reviewed

and

resolved by appropriate

management

personnel.

The following surveillance activities were observed/reviewed:

2

OHP 4030 STP.017

Auxiliary Feedwater

System Test

1

OHP 4030 STP.032

Quadrant

Power Tilt Ratio Calculation

12 THP 4030 STP.227

Multiple Entry Personnel Air Lock Leakage

Surveillance Test.

12 THP 4030 STP.204

Personnel Air Lock Leakage

and Interlock

Surveillance Test.

12 THP 6040 Per.091

1

OHP SP.032

RTD Bypass

Loop Flow Verification

Special Test of the Turbine Driven

Auxiliary Feedwater

Pump

No items on noncompliance or deviations

were identified.

6.

Licensee

Event

Re orts

Through direct observation,

discussions

with licensee

personnel,

and review

of records,

the following event reports

were reviewed to determine that

reportability requirements

were fulfilled, immediate corrective action was

accomplished,

and corrective action to prevent recurrence

had been

accom-

plished in accordance

with Technical Specifications.

The following LERs

are considered

closed:

Unit

1

RO 83-026/03L-0

RO 83-098/01T-0

and

1

RO 83-121/01T-0

Hole found in fire seal.

Incorrect data used for Cycle

7 Ep (z)

Backup sampling for vent stack monitor

not done.

RO 83-125/03L-0

RO 83-128/03L-0

T-Average exceeded

570

F.

AB Diesel Generator

inoperable

due to

defective electronic tachometer circuit.

RO 83-130/03L-0

Steam generator

blowdown isolation

valve inoperable.

RO 84-001-0

Reactor trip January

23,

1984 during reactor

coolant loop flow instrument calibration.

An

incompletely closed equalizing valve on

Channel

3 (Instrument

NFP-222 which was in

"trip" for calibration)

reduced the pressure

differential across

associated

instruments

(common hi pressure

side tap) resulting in

apparent

low flow on a second

channel

( 2 of

3 to trip).

Plant response

was normal - see

IE Report 315/84-02.

Appropriate modifica-

tions were made to the subject calibration

procedures

(1 THP 6030.IMP.099 thru .101) to

ensure proper equalizing valve closure.

RO 84-002"0

On initial use of Rev.

11 of

1

OHP 4030

STP.005,

the Unit Supervisor discovered

an

error which could have rendered

both

RHR

trains inoperable,

in that the quarterly

portion of the test called for isolation of

one loop at a point in the procedure

where

the other loop was already isolated by the

monthly portion of the test.

The procedure

error was corrected.

RO 84-005-0

and

84-030-0

Required grab samples

were not taken within

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per Table 3-13,

Item l.a, Action No.

30 when the auto gas analyzer

was inoperable.

In both cases

repairs

were started without

first obtaining

a grab sample,

and were in-

complete

(and preventing grab sampling)

when

the 12-hour time limit expired.

RO 84-026-0

and

84-029-0

Required grab samples

were not taken within

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> per Table 3-13,

Item 3.a, Action No.

28 when the auxiliary building vent monitor

was inoperable.

In accordance

with NRC enforcement policy,

a licensee-identified

noncompli-

ance which should have been prevented

by corrective action for a previous

similar occurrence,

is subject to enforcement

action.

RO 84-029-0

and

RO 84-030-0 are each repeat

examples of previous similar occurrences

as

discussed

above;

and both represent

failure to comply with Technical Speci-

fication 3 '.3.10 '

in that required actions of Table 3.3-13

(ACTION 28 and

ACTION 30 respectively)

were not preformed within the times allowed.

Thus,

failure to collect and analyze required grab samples

in compensation

for

inoperable monitors

as described

above

and in RO 84-029-0

and

RO 84-030-0

is considered

an example of noncompliance with the referenced Technical

Specification for which a Notice of Violation is being issued with this

report.

(315/84-23-01

and 316/84-25-01).

RO 84-016-0

Motor driven auxiliary feedwater

(MDAFM)

pump handswitches

were in "neutral" during

Mode 3, making them incapable of responding

to selected

emergency auto-start signals.

A

noncompliance

(Item 325-84-18-02)

and esca-

lated enforcement

action (Civil Penalty)

relating in part to this matter,

have been

issued.

Corrective

and preventive actions

will be examined in followup of the noncom-

pliance.

RO 84-017-0

MDAFW pumps started automatically

as designed

when the single operating main feed

pump was

lost during startup.

Manual steam generator

level control involving both an operator

and

a trainee resulted inadvertently in high S/G

No.

4 level.

RO 84-019-0

The turbine driven auxiliary feedwater

pump

governor valve position was left in a condi-

tion per instructions of a surveillance

such

that it was not capable of meeting design

pressure

and flow requirements.

This item

was part of a noncompliance

(Item 315/84-18-

03 and 316/84-20-01)

and escalated

enforce-

ment (Civil Penalty).

Corrective

and preven-

tive actions will be examined in followup of

the noncompliance citation.

RO 84-024"0

Spent fuel exhaust ventilation dampers did

not initially respond to input of a high

alarm on radiation monitor R-5 during a test.

No system problem could be found; the dampers

responded

properly on subsequent

tests

(the

event could not be repeated)

and were left

"operable" after testing.

RO 84-025-0

System walkdowns being conducted

under the

D.

C.

Cook Regulatory Performance

Improvement

Program identified mislabeled firewater ring

header valves

as such required testing was

being applied to the wrong valves.

Proce-

dures

were corrected

and the correct valves

were tested satisfactorily.

Unit 2

RO 83-042/03L-0

RO 83-069/03L-0

l

Hydrogen sampling system inoperable

Component cooling water pump discharge valve

inoperable

RO 83-102/03L-0

Non essential

service water valve from lower

containment, ventilation Unit No.

3 closing

time.

RO 83-117/03L-0

Number

1 Steam Generator

blowdown sample

valve inoperable

due to a damaged actuator.

RO 84-001/0

A boron injection tank (BIT) was diluted

when, following maintenance,

the system line-

up restoration did not address

the valve

which had been worked on and it was left

partially open.

The

LCO Action Statement

(1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> restoration)

was met.

RO 84-012-0

Inadvertent

Node

6 Safety injection signal

(no injection) due to insufficient specific

test procedure instructions for sequence

of

returning components

(solid state protection

system) to service.

The procedure

was

corrected.

RO 84-013-0

This was

a voluntary licensee report concern-

ing the

AB battery 60-month capacity

(discharge) test,

which showed the battery

had reached

the end of its useable life.

The

battery was replaced

and the new battery

tested

and placed in service.

RO 84-014-0

Both RHR pumps were inoperable in diode

5 for

about

25 minutes

when operators

switching

from one

pump to the other started the second

pump before stopping the first while in "half-

loop" operation.

Both pumps

became

airbound

and had to be vented before being returned

to service.

The procedure

was revised to

clarify that restrictions

on two-pump opera-

tions apply even during the brief switching

process.

RO'84-015-0

RO 84-017-0

'urveillance

requirements

of Technical Speci-

fication 4.0.2.6 were not met when

a required

RCS boron sample

was analyzed

35 minutes late.

The technicians

involved were not adequately

informed concerning either the sample loca-

tion or the deadline.

They were reinstructed

and the sample

frequency

was increased to

prevent recurrence.

Shiftly channel

checks of the intermediate

range excore detectors

were not performed

in accordance

with Technical Specification

Table 4.3-1 (asterisked notation) for a

condition other than Nodes

1 or

2 with the

reactor trip breakers

closed

and the rod

drive system

capable of rod withdrawal.

The

surveillance procedure

(2

OHP 4030 STP.030)

was revised to include the asterisk notation

requirements.

RO 84"018"0

Control rods B-8 and K-10 indicated

14 and

13

step misalignments,

respectively,

from their

group demand positions

- the limit being

12

steps.

The applicable Action valuation indi-

cated the secondary coil stack measurements

used for position determination

had not yet

stabilized following thermal cycling associ-

ated with the post-refueling

low power physics

testing in progress

at the time.

Thus, the

"misalignments" were likely an indication

error.

The rods indicated proper alignment

on withdrawal the following day.

RO 84-019-0

and

84-019-1

When a reactor coolant loop was

removed from

service

and T-avg maintained

above

541

F,

associated

loop bistables

were not tripped

within one hour per Technical Specification 3.3.2-1, Table 3.3-3,

Item 4d.

This matter

was inspector-identified

and

a noncompliance

citation (Item 316/84-14-02)

issued.

Correc-

tive action will be reviewed in followup to

the noncompliance citation.

4t

RO

RO

RO

RO

84-024-0

84-025-0

84-031-0

84-032-0

These reports all involve Unit 2 low power

or zero power

RPS actuations

(trips) which

have been previously reviewed

- the first

two in IE Report 316/84-21,

the other two

in IE Report 316/84-24.

One item of noncompliance

was identified involving a repetitive failure

to collect timely compensatory

samples

when automatic

equipment

was

inoperable.

7.

Inde endent

Ins ection Activities

Licensee Condition Reports

were routinely reviewed to provide an on-

going and current perception of the effectiveness

of the licensee's

corrective action program.

Selected

reports

were reviewed in more

detail on the basis of their potential implications or the particular

interest of the inspectors.

Condition Report, 2-12-84-2641

discussed

lifting of an

RHR safety valve during Unit 2 airsweeps

on December

23,

1984.

Procedure

2

OHP 4021.002.001

was used in a manner

(higher

RCS

'ressure)

not contemplated

and,

as such, this event could be consid-

ered

a consequence

of violating an approved safety-related

procedure.

Condition Report 1-12-84-2598

involved "E" motor driven auxiliary feed-

water

pump emergency leakoff valve inoperability as

a consequence

of

violating procedural controls

on lifted leads.

Under

NRC Enforcement

Policy, minor violations of this type identified and corrected

by the

licensee

are not subject to NRC Enforcement Action.

b.

The licensee's

response

to IE Bulletin 8'g-03 "Refueling Cavity Mater

Seal"

was subjected to preliminary review.

Copies of this response

distributed to the site were apparently transmitted without an oath

or affirmation statement,

though the copy sent to

NRC Region III had

such

a statement.

The inspectors

requested

a copy of the affirmation

statement

be transmitted to the site.

NUREG-0737,

Item II.B.l "Reactor Coolant System Vents" and

10 CFR 50.44 (c)(3)(iii) provided for installation and operability (including

procedure preparation

and operator training) of RCS vent systems for

use in controlling potential noncondensable

gas accumulation in the

reactor coolant system.

The licensee installed the vent system

as

discussed

in IE Report 315/84-20

and 316/84-22,

leaving "open" the

completion of surveillance testing,

procedure revisions, training,

and

conversion of the systems to full operability, pursuant to newly

issued Technical Specifications.

During unit outages for each of the respective units during this

inspection period, the licensee verified or performed current sur-

veillance testing

and energized

and declared

the respective

vent

systems

"operable".

Procedure

revisions covering system operation

were approved

and issued

(TP-1 to Rev.

1 dated

May 15,

1984 of Proce-

dures

1 and

2

OHP 4023.001.015) prior to the operability declarations.

Operator training was performed after installation of the actual modi-

fications with a refresher

memorandum to the shifts

(October

19,

1984)

relating to final elevation of the systems

to full operability under

the Technical Specifications.

10

The inspectors,

having no further questions

concerning this item, con-

sider this item closed.

d.

The inspectors

discussed

internal

NRC information potentially appli-

cable to D. C.

Cook with appropriate

licensee representatives.

On

January

12,

1985,

a reactor trip breaker at Sequoyah Unit 2 did not

open automatically

on demand

due to a printed circuit board short

(i.e., the breaker did not "fail safe").

The licensee

was provided

with available information and asked to review the matter for appli-

cability.

On a separate

matter, the licensee

was requested

to review

his records for possible historical procurement of safety-related

com-

ponents

from a vendor (Familian Northwest) under investigation for

falsification of material certifications.

The licensee

review indi-

cated this vendor has not supplied safety-related

components to

D.

C. Cook.

No items of noncompliance or deviations

were identified.

8.

Mana ement Interview

A management

interview (attended

as indicated in Paragraph

1) was conducted

at the completion of the inspection.

The following items were discussed:

a.

The inspectors

summarized the scope

and findings of the inspection

as

described in these details.

b.

The apparent

item of noncompliance (partially affecting both Units)

was specifically identified and discussed

(Paragraph

6).

c.

Events for which LERs (or supplemental

information thereto)

are anti-

cipated

and which may have

NRC enforcement

action implications were

identified and discussed

(Paragraph

3).

d.

A questionable

PNSRC Technical Specification "interpretation" concern-

ing cross-tieing station batteries

was discussed

- the licensee

agreed

to re-examine

the matter

(Paragraph

3).

e.

The TMI Action Item (NUREG-0737 Item II B.l) involving reactor coolant

vents

was identified as "closed" on the basis of this inspection

(Paragraph 8.c).

The inspector

asked the licensee

representatives

whether they

considered

any of the matters

discussed

to contain proprietary

information or other information exempt

from disclosure pursuant to

10 CFR 2.790.

No such information was identified.

11

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