ML17321A680
| ML17321A680 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/06/1985 |
| From: | Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| References | |
| 50-315-85-14, 50-316-85-14, NUDOCS 8506240659 | |
| Download: ML17321A680 (18) | |
See also: IR 05000315/1985014
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports
No. 50-315/85014(DRP);
50-316/85014(DRP)
Docket Nos.
50;315;
50-316
Licenses
No.
Licensee:
American Electric Power Service Corporation
and Michigan Electric Company
Columbus,
OH
43216
Facility Name:
Donald
C.
Cook Nuclear Power Plant, Units 1 and
2
Inspection At:
Donald
C.
Cook Site,
Bridgman,
MI
Inspection
Conducted:
April 23,
1985 through
May 20,
1985
Inspectors:
B.
L. Jorgensen
J.
K. Heller
C.
L. Wolfsen
JC.Ld
Approved By:
G.
C. Wrigh
Chief
Reactor Projects
Section
2A
c/c/Nf~
ate
Ins ection
Summar
Ins ection
on
A ril 23
1985 throu
h Ma
20
1985
Re orts
No. 50-315/85014
0-31
8 014
~A:
R
i
dt
p
i
tytd
id ti
p t
licensee
actions
on previous inspection findings; operational
safety; mainte-
nance;
surveillance;
and independent
inspection
areas.
The inspection involved
a total of 259 inspector-hours
by three
NRC inspectors
including 36 inspector-
hours off-shift.
Results:
Of the five areas
inspected,
no violations or deviations
were identi-
~fied
n three areas;
three violations were identified in the remaining two
areas
(improper storage of flammable liquids,
and failure to document reactor
coolant flow during reactor coolant boron reduction - Paragraph
3, failure to
follow battery surveillance
procedure - Paragraph
5).
850M40659 850606
ADOCK 050003%5
8
'
os
0
r
DETAILS
Persons
Contacted
"M. G. Smith, Jr., Plant Manager
"B. Svensson,
Assistant Plant Manager
T. Kriesel, Technical Superintendent-Physical
Science
A. Blind, Assistant Plant Manager
K. Baker, Operation's
Superintendent
"J. Stietzel, guality Control Superintendent
T. Beilman, guality Assurance
Superintendent
J. Allard, Maintenance
Superintendent
R. Tella, Maintenance
Engineer
T. Kossack,
Performance
Engineer
M. Tjader,
Maintenance
Foreman
A. Guzicki, Shift Supervisor
L. Boone, Shift Supervisor
L. Smith, Shift Supervisor
"L. Gibson,
Technical
Superintendent-Performance
"K. Murphy, Production Supervisor
The inspector also contacted
a number of licensee
and contract
employees
and informally interviewed operation,
technical
and maintenance
personnel
during this period.
"Denotes personnel
attending exit interview on May 23,
1985.
Licensee Actions on Previousl
Identified Items
(Closed)
Unresolved
Item (316/78-33-01):
The inspectors
were unable to
determine whether
each heat trace
channel for boron injection path
was
being energized at least
each
31 days
as required
by Unit 2 Technical
Specification 4. 5.4. 2. a.
The Unit 1 specification is the
same.
Review
in 1984 indicated that both requirements
are
implemented
by performance
of Procedure
12
OHP 4030 STP.023,
which specifies alternation of energized
channels
on the twelfth day of each month,
and includes appropriate
docu-
mentation
and review/signoff requirements.
(Closed)
Open Inspection
Items (315/80-20-05
and 316/80-16-03):
Policies
and procedures
on equipment return-to-service
needed
enhancement
to assure
appropriate
post-maintenance
testing
and verification of "operability".
This problem was identified in review of an
LER wherein
an
RHR pump was
not tested following maintenance
on an associated
heat exchanger
and .was
found airb'ound about three weeks later during routine surveillance testing.
Plant Manager's
Instructions
PMI-2110 "Clearance
Permit System"
now speci-
fies all Technical Specification
equipment shall
have operability verifi-
cation performed
by the Operation's
Department.
An SRO license holder
determines
restoration
requirements,
and is instructed
by PMI-2110 to
consider
not just the valve's,
breakers
or switches originally tagged,
but
all those
necessary
to "re-establish
the operability of the system or
component".
Restoration
not involving clearance
permits
remains
open
under the item discussed
below.
(Open) -Unresolved Item (315/83-01-06
and 316/83-01-06;
315/83-01" 07 and
316/83-01-07):
The first pair of items involves weakness
in PMI-2290,
"Job Orders", with respect to the determination of how equipment is to be
restored
and
how appropriate quality control functions (i.e.,
"hold points") are to be incorporated
when work is done without written
procedures;
the second pair of it'ems involves
a PMI-2290 weakness
in not
providing criteria and defining responsibility for determinin'g
when
written .procedures
are required.
The subject
PMI remains
unchanged.
Under the licensee's
Regulatory
Performance
Improvement
Program
(RPIP),
a revision is in progress,
but its completion is not anticipated until
September
1, 1985.
The specifics of the identified concerns relating to
PMI-2290 were discussed
with licensee
personnel
involved in the revision
process
(which is already overdue against the licensee's
original
RPIP
schedule)
who felt the concerns
were being addressed
in the revision being
considered.
The items remain
open pending
NRC review of the approved
revised procedure.
(Open) Noncompliance
(315/81-11-06A
and B, and 316/81-14-06A
and B):
Fire
resistance
ratings of certain doors could not be determined.
At the
request of a Region III Specialist the following were verified to be
UL
certified doors:
No.'s
323,
339,
325, 326,
324,
341,
373,
374, 385,
386,
388, 226, 227,
228,
and 229.
This information was provided to the Region
III Specialist with the expectation that this item will be closed in a
subsequent
inspection report.
(Closed)
Unresolved
Item (315/85009-02;
316/85009-01):
The weekly/quar-
terly surveillance
procedure for the 250 volt station batteries
did not
implement
a Technical Specification requirement that the electrolyte level
be maintained
between the minimum and maximum level marks
on the cells.
The current revision to the Surveillance
Procedure
requires
level
be .main-
tained between
these
marks.
From the time the problem was identified
until the appropriate
procedures
were revised,
the requirement to maintain
the electrolyte level between
the marks
was verified on the work orders
implementing these surveillances.
No
violat'ions or deviations
were identified.
0 erational Safet'erification
a 0
The inspector
observed control
room operation including manning,
shift turnover,
approved procedures
and
LCO adherence;
and reviewed
applicable
logs and conducted
discussions
with control
room operators
during the inspection period of April 23, through
May 20,
1985.
Observations
of the control
room monitors, indicators,
and recorders
were
made to verify the operability 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 veri-
fied.
Tours of the auxiliary building, Unit 1 containment,
and
screenhouse
were
made to observe
accessible
equipment conditions,
including fluid leaks, potential fire hazards,
and control of activi-
ties in progress.
b.
C.
d.
e.
By observation
and direct interview it was verified that the physical
security plan was being implemented in accordance
with the station
security plan.
During a tour of the Unit 1 upper containment
(top and intermediate
catwalks) the inspector
found coating delamination
ranging in size
from approximately
one square
inch to six square feet.
When dis-
cussed with site management
the inspector
was informed that
a program
was planned to recoat selected
areas
in the containment.
The inspec-
tor reviewed the coating repair program and found these
areas
and
many more were identified.
During a tour of the Auxiliary Feedwater
pump
rooms the inspector
found the retracting mechanism for Fire Doors
Nos.
226, 227,
228,
and 229 were loose or some of the screws
securing the retracting
mechanism
were loose.
This was identified to the Fire Protection
Coordinator.
This was also discussed
at the exit interview at which
time plant management
identified a generic review was being performed.
During a tour of the Unit 1 upper containment prior to fuel transfer
the inspector
observed
some foreign material
on the overhead
crane
rails.
This was identified to the accountability inspector stationed
at the access
to the refueling area.
A subsequent
inspection verified
'hat
the material
was
removed.
0
g.
During a tour of the 633 foot level of auxiliary building on May 15,
1985, at approximately
1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />,
the inspector
found three
UL/FM
approved
Flammable Liquid Storage
cabinets
located
near the Unit 1
auxiliary building control panel.
Stored in one cabinet were paint
cans with the lids removed.
Stored in another cabinet were
a couple
of small buckets of solidified paint.
Stored in the third cabinet
was
an uncovered pail (approximately
one gallon in size) with about
one inch of fresh paint.
Plant Manager',s Instruction 2271, "Control
of Combustible Material", at Paragraph
4.6.2 requires that all paint
shall
be stored in containers with tight fitting lids in either
a
UL/FM approved cabinet or the oil storage
room located
on 595 foot
elevation.
In addition, the empty containers will be stored in the
the approved paint storage
location or disposed of immediately.
The
inspector discussed
the violation of PMI-2271 with the Fire Protection
Coordinator
who issued
a Condition Report and took steps to resolve
the problem.
Unit 1 and
2 Technical Specification 6.8.l.f requires
that written procedures
shall
be implemented for the Fire Protection
Program.
Failure to comply with PMI-2271,
as described
above, is a
violation of Technical Specification 6.8.1.f. (Violation 315/85014"Ol;
316/85014-01) .
While observing the licensee fill the Unit 1 refueling cavity on
April 30, 1985, the inspector
asked the operators if the reactor
coolant boron concentration
was being reduced
and if it was,
how the
minimum flow requirement of Technical Specification 4. 1. 1.3 was
verified.
The Reactor
Coolant System boron concentration
was being
1
El
reduced
as evidenced
by earlier boron samples
of 2084 and 2295
ppm
and the last boron
samp'le of the refueling cavity makeup water which
was 2069
ppm.
A verification was
made to assure
the minimum boron
concentration of Technical Specification 3.9. 1 was met and would not
have
been violated.
After discussion with the licensee
the flow
requirement of Technical Specification 4. 1. 1.3 was verified, and
documented
in the Control
Room Logs.
Technical Specification 4. 1. 1.3 requires
the flow rate of the reactor
coolant to the reactor pressure
vessel
shall
be determined to be
greater
than 3000
GPM within one hour prior to the start of and at
least
once per hour during a reduction in Reactor Coolant System
concentration.
Failure to determine
the Reactor Coolant System flow
rate prior to and at least hourly during a b'oron reduction is a viola-
tion of Technical Specification 4.1.1.3.
(Yiolation 315/85014-02)
Unit 2 Control
Room Log (Book No. 37,
Page 88) for April 16, 1985,
at 0138 hours0.0016 days <br />0.0383 hours <br />2.281746e-4 weeks <br />5.2509e-5 months <br />,
documented that the Turbine Driven Auxiliary Feedwater
Pump
(TDAFP) throttle and trip (T/T) was verified closed.
The
T/T valve is normally closed;
however,
Procedure
1-OHP 4030.001.001
"Routine Plant Inspection Outside the Control
Room", requires verifi-
cation that the
TDAFP T/T valve was latched.
The log entries
from
the previous
and subsequent
shifts properly documented that the
TDAFP T/T was latched.
This inconsistency
in the log was discussed
with Operations.
On April 26,
1985, the licensee notified NRC of an apparent
Technical
Specification violation.
D.
C.
Cook Technical Specification 3.3.3. 1
requires radiation monitors
OPERABLE per Tab'1e 3.3-6.
That Table con-
tains
no requirements
applicable in Mode 5,
During Mode 6, however,
two of three specified monitors in each of Train A and Train
B are
required
ACTION 22 states
the
ACTION requirements
ofMech-
nical Specification
3. 9. 9 are to be complied with.
Specification
3.9.9,
which is identified as
APPLICABLE only during core alterations
or irradiated fuel movement in containment,
requires
the containment
purge
and exhaust isolation system to be
OPERABLE; if it is not, the
ACTION is to close purge and,exhaust
penetration to atmosphere.
When the licensee
changed
from Mode 5 (radiation monitors not
required - and they were "blocked" ) to Mode
6 at 1827 hours0.0211 days <br />0.508 hours <br />0.00302 weeks <br />6.951735e-4 months <br />
on
April 23,
1985, the radiation monitors were not restored
"OPERABLE".
The purge
system
was in continuous service thereafter with the radia-
tion monitor purge isolation inputs
BLOCKED until April 26,
1985 when
the distinction in APPLICABILITYbetween
Table 3.3-6
(Mode 6) and
Specification 3.9.0
(CORE ALTERATIONS) was noted.
At 2241 hours0.0259 days <br />0.623 hours <br />0.00371 weeks <br />8.527005e-4 months <br />
on
April 26, 1985, the radiation monitors were
UNBLOCKED and compliance
to both specifications
restored.
occurred at
any tHe during this period,
and the alarm functions of the monitors
were always available.
Operator
response
to the alarm,
by procedure,
would have
been to isolate purging.
No alarm occurred.
On April 29, 1985,
licensee
management
determined
the above
was
neither reportable
nor noncompliance,
as the Review Committee
had
evaluated this in 1984 as
an acceptable
condition.
At 1015 hours0.0117 days <br />0.282 hours <br />0.00168 weeks <br />3.862075e-4 months <br />
on April 29,
1985, the licensee
declared
an "Unusual
Event" per its emergency classification
when
a maintenance
worker
fell inside containment.
The individual was taken to Memorial
Hospital in St.
Joseph,
Michigan, with a
broken arm, broken leg
and possible
back injury.
The worker's anti-contamination clothing was not removed
due to
the suspected
back injury.
A radiation technician
accompanied
the
worker to the hospital in the Cook-site ambulance,
and subsequently
returned potentially contaminated
materials to the
D.
C.
Cook site.
k.
The licensee
declared
an Emergency
Plan "Unusual
Event" at 1021 on
April 27,
1985 when gaseous
hydrazine
was vented from feedwater
piping (in the
No.
feedwater gallery) which had
been cut open for maintenance.
A precautionary
evacuation
in parts
of the auxiliary building was conducted.
A temporary patch
was
installed
and the area ventilated.
When subsequent
sampling
showed
airborne levels
had been
reduced
below hazardous
levels,
the
"Unusual
Event" was secured at 1125.
A similar event occurred
May
14,
1985 at.1338
when 'the patch
began
leaking after auxiliary
was aligned upstream of the cut and Condensate
Storage
Tank (CST) hydrostatic pressure refilled the line back past
a
1'caking check valve, flushing out contaminants.
Containment ventila-
tion was secured
to avoid drawing gases
into the building, and no
containment
evacuation
was necessary,
though access
was restricted in
the feedwater gallery area.
This event
was secured
based
on satis-
factory air sampling results at 1850.
Two violations and
no deviations
were identified.
4.
Monthl
Maintenance
Observation
Station maintenance activities of safety related
systems
and components
listed below were observed
and/or reviewed to ascertain that they were
conducted
in accordance
with approved procedures,
regulatory guides
and industry codes or standards
and in conformance with Technical
Specifications.
The following items were considered
during this review: the limiting
conditions for operation
were met while components
or systems
were
removed from service;
approvals
were obtained prior to initiating the
work; activities were accomplished
using approved procedures.
.The following maintenance activities were:
a.
Observed
JO No.
94221
Remove
and machine
1CD
EDG main bearing
caps
per
RFC 2753 and 12
MHP 5021.001.H.
4
N
JO No.
97417
JO No.
76596
b.
Reviewed
JO No. 82723
Modify piping for cooling water to of] cooler
on
governor valve to TDAFP.
Repair to valve DO-121
18 month
1CD
EDG inspection
using
Procedures
12
MHP 5021.032.001L,
MHP 5021.
032.001M,
12
MHP 5021.032.001B,
MHP, 5021. 032. 001C,
MHP 5021. 032. 001H.
JO No.(s) 97016,
95080,
82734,
82731,
84877,
84876,
84858,
84857,
68200:
JO No. (s) 16793,
82412,
36296:
JO No.(s) 16768,
17732,
33972,
18006,
97758,
34363:
JO No. (s) 41851,
34488,
36300,
36291,
36288,
17900,
27967,
17965:
quarter]y inspection of the Unit 250 Volt
D.
C. Batteries
using 12
MHP 4030 STP.013.
quarter]y inspection of the Unit 2 AB
Battery using
2
MHP 4030 STP.035.
quarter]y inspection of the Unit 1 and
2
"N" Train Batteries
using 12
MHP 4030
STP. 023.
Weekly inspection of the Unit 2 "AB" and
"CD" Batteries
using 12
MHP 4030 STP.013.
No violations or deviations
were identified.
Month]
Surveillance Observation
The inspector
reviewed Technical Specifications
required surveillance
testing
on the systems listed below and verified that testing
was per-
formed in accordance
with adequate
procedures,
that,test instrumentation
was calibrated,
that .limiting conditions for operation
were met, that
removal
and restoration of the affected
components
were accomplished,
that test resu]ts
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.
"*12 THP 4030
PER.001
"S" Safety Injection
Pump
Fu]1 Flow Test.
""12 THP 4030 STP.211
Unit 1 Ice Condenser
Basket Weighing.
The inspector
reviewed selected
surveillance
and maintenance
pr'ocedures
for the 250 volt station batt'e'ries
to verify that the: Technical Specifi-
cations
are
imp]emented;
requirements/recommendations
of the "Exide" and
"C 8
D" battery vendor manuals
were implemented;
and,
recommendations
of
IEEE Standard
450 were implemented
as applicable.
The procedures
reviewed
were:
a.
12
MHP 4030 STP.013
Maintenance
Surveillance Test Procedure
For
Inspection of 250 Volt, 1CD,
and
2CD,
Batteries.
b.
12
MHP 4030 STP.014
Maintenance
Surveillance Test Procedure for
Plant Batteries
Emergency
Load Discharge
Test.
c.
2 MHP 4030 STP.023
d.
2
MHP 4030 STP.035
e.
2
MHP 4030 STP.036
250 Volt "N" Train Batteries.
quarterly Surveillance Test Procedure
For
Plant
2AB Battery.
Weekly Surveillance Test Procedures
For
Plant
2AB Battery.
The vendor for the
1AB, 1CD,
and
2CD 250 volt batteries
is "Exide", and
the vendor for the
2AB 250 volt and "N" Train batteries
is "C & D".
The
2AB batteries
were originally Exide batteries
but were replaced
in 1984
with C&D batteries.
The
C&D vendor manual specifies that minimum
applicable volts per cell is 2. 13 when the nominal cell specific gravity
is 1.210.
Unit 2 Technical Specification 4.8.2,3.2.b.1
and
2
MHP 4030
STP.035 at Step 7.33. 1 requires that each
connected cell shall
be greater
than 2. 10 volts.
The inspector questions if this value should
be changed
from 2. 10 volts to 2. 13 volts.
The lic'ensee
was requested
to review this
item and verify that the appropriate limit for minimum volt per cell is
specified.
(Open Item 316/85014-02).
Unit j. and 2 Technical Specification 4.8. 2. 3. 2. b.j. (250 volt D.
C. battery
banks)
and 4.8.2.5.2.6.1
("N" Train battery banks) requires verification
every 92 days that the voltage of each
connected cell has not decreased
more than 0.05 volts from the valve observed
during the original accept-
ance'est.
The inspector
reviewed
12
MHP 4030
STP. 013,
. 023,
and
. 025
and found that this requirement is restated
but the original acceptance
test results
are not in the procedure.
The inspector
was able to obtain
a copy of the original acceptance
test results
from a Maintenance
Engineer
but noted that the results did not appear to be controlled such that when
a cell is replaced the
new cell acceptance
c'riteria is available for
review.
The inspector
reviewed Condition Reports
and found that cell 108
for battery
1CD was replaced
on January
25,
1985.
The quarterly inspec-
tion (12
MHP 4030 STP.013)
was performed
on April 13,
1985.
The original
acceptance
test results that the inspector
was given had not been modified
to reflect acceptance
test results for the replacement
to cell 108.
This
item was discussed
with the Maintenance
Superintendent
with a request that
a review be performed to assure that the requirements
of Technical
Speci-
fication 4.8.2.3.2.6. 1 were performed during the quarterly surveillance
test.
(Unresolved
Item 315/85014-03).
The inspector
reviewed
random selections
of completed surveillance proce-
dures
and found three
examples (listed below) of failure to comply with
surveillance
procedures
of safety related
equipment.
These
were discussed
with the Maintenance
Superintendent.
a.
Procedure
12
MHP 4030
STP. 023, performed
on September
17, 1984, for
the Unit 2 "N" Train batteries
requires verification that the
voltage of each connected cell has not decreased
more than 0.05
volts from the values
recorded during the acceptance
test.
Com-
parison of the acceptance
test values obtained
from the Maintenance
Engineer
shows cell
6 had decreased
0. 06 volts from the value
recorded during the acceptance
test.
This is a failure to comply
with 12
MHP 4030 STP.023.
b.
Procedure
12
MHP 4030 STP.013,
performed
on December,
26,
1984, for
the U~it 1 AB batteries,
requires
the specific gravity be corrected
to 77 F. This is accomplished
in Step 7.4 by averaging the tempera-
ture of the selected cell and using this temperature
to determine
the specific gravity temperature
correction.
The data
documented
in
Attachment
2 contains
a math error which resulted in the use of the
wrong average
temperature
and the wrong correction factor.
This is
failure to comply with 12
MHP 4030 STP.013.
C.
Procedure
2
MHP 4030 STP,025,
performed
on April 10, j.985, for the
Unit 2 AB batteries,
requires
the -average cell temperature
be deter-
mined by averaging
the cell temperature
of every 6th cell (19 cell
total).
Table
1 shows the reading for cell 24 was not recorded
resulting in the total temperature for 18 cells being divided by 19
to obtain the cell average.
This is failure to comply with 12
MHP
4030
STP. 025
Unit 1 and
2 Technical Specification 6.8.2.c requires that written pro-
cedures
shall
be implemented covering surveillance
and test activities
of safety related
equipment.
Failure to comply with 12
MHP 4030 STP.013,
. 023,
and 025,
as described
above is a violation of Technical Specifica-
tion 6.8. 1. c.
(Violation 315/84014-04;
316/84014-03).
One violation,
and
no deviations
were identified.
6.
Inde endent Ins ection Areas
a e
In response
to a regional
request
regarding the
use of temporary
door restraints
on Ice Condenser
Lower Inlet Doors, the inspector
found that 24 temporary door restraints (in the form of tape)
were
used in Procedure
12
THP 4030 STP.207
Rev.
9, "Ice Condenser
Lower
Inlet Doors".
The temporary door restraints
were used to ensure that
the lower inlet doors were opened
one at a time, until the initial
door opening torque
was measured for each door.
The procedure
contained
steps to remove the 24 lower inlet door restraints after
the surveillance
was complete
and verification of removal
was
required
on a sign-off sheet.
In reviewing the procedure,
no
inadequacies
were found regarding the use of temporary door
restraints.
k
The inspector did identify minor inconsistencies
while reviewing
STP.207.
During a discussion with a Performance
Engineer, it was
determined that these
inconsistencies
had already
been identified
and changes
made.
b.
The inspector
was asked to review the licensees
action
on selected
safety issued
as defined in the Institute 'of Nuclear Power Operations
(INPO), Significant Operating Experience
Reports
(SOER),
and deter-
mine if the recommendations
of the
SOER were implemented.
The
selected
safety issues
reviewed were:
Steam Binding of Auxiliary
Pumps
(SOER 84-03),
and Mispositioned Control
Rod
(SOER 85-03).
The results of th'e review were sent to-Region III.on April
30,
1985 and
May 14, 1985.
No violations or deviations
were identified.
7.
~0ee
Items
Open Items are matters
which have
been discussed
with the license,
which
will be reviewed further, by the inspector,
and which involve some action
on the part of the
NRC or licensee
or both.
Open, Items disclosed during
this inspection are discussed
in Paragraph
5 above.
8.
Unresolved
Items
Unresolved
Items are matters
about which more information is required in
order to ascertain
whether they are acceptable,
violations, or deviations.
Unresolved
Items are discussed
in Paragraph
5.
9.
Mana ement Meetin
The inspector
met with the licensee
representatives
(denoted in Paragraph
1) at the conclusion of the inspection
on May 23,
1985 and summarized
the
scope
and findings of.'the inspection.
The inspectors
asked
those in attendance
at the meeting whether they con-
sidered
any of the matters
discussed
to contain proprietary information
or other 'information exempt, from disclosure.
No such information was
identified.
10
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