IR 05000483/1985016

From kanterella
(Redirected from ML20138A708)
Jump to navigation Jump to search
Safety Insp Rept 50-483/85-16 on 850625-0903.Violation Noted:Lack of Operator Attention Where Allowable Axial Flux Difference Exceeded
ML20138A708
Person / Time
Site: Callaway Ameren icon.png
Issue date: 09/24/1985
From: Suermann J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138A698 List:
References
50-483-85-16, NUDOCS 8510080616
Download: ML20138A708 (12)


Text

!

'

.

!

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/85016(DRP)

Docket No. 50-483 License No. NPF-30 Licensee:

Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, M0 63166 Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Steedman, M0 Inspection Conducted: June 25 through September 3, 1985 Inspectors:

B. H. Little C. H. Brown R. L. Nelson 9[J4/87 Approved By:

J. F. Suey c

Reactor Projects Section 2A Date Inspection Summary Inspection on June 25 through September 3, 1985 (Report No. 50-483/85016(DRP))

Areas Inspected:

Routine unannounced safety inspection by the resident inspectors of licensee event reports, licensee events, regional requests, Technical Specifications, and plant tours.

The inspection involved a total of 294 inspector-hours by three NRC inspectors including 64 inspector-hours onsite during off-shifts.

Results:

One violation was identified involving the lack of operator attention where the allowable Axial Flux Difference was exceeded as described in Paragraph 3.b.

One unresolved item was identified during the inspection of Licensee Event Report No.85-028, where a potential generic problem exists with the failure of the wide range gas monitor pump diaphragm as described in Paragraph 2.

The licensee was actively involved in an Event Reduction Program and has implemented a comprehensive maintenance planning and scheduling program.

8510080616 850927 ADOCK 0 % 3 DR

---

._..

.

..

- - - -. - -. _ _ - _ -

_ _ _.

. -... -

-

.--...

_

t

.

.

'

i DETAILS

,

!

,

I t

1.

Persons Contacted

  • S. E. Miltenberger, Manager, Callaway Plant

D. F. Schnell, Vice President - Nuclear r

!

  • D. C. Poole, Assistant Manager, Operations and

Maintenance

[

  • R. L. Powers, Assistant Manager - Quality Assurance

'

M. E. Taylor, Operations Superintendent J. E. Davis, Compliance Superintendent J. C. Gearhart, Supervisory Engineer - QA

>

  • P. T. Appleby, Assistant Manager, Support Services J. R. Veatch, Supervisory Engineer - QA

!

J. T. Patterson, Assistant Superintendent Operations

C. D. Naslund, Superintendent, Instrumentation and

.

Control

'

l

  • J. V. Laux, Supervisor - QA
  • W. A. Norton, Engineer - QA

'

  • A. P. Neuhalfen, Assistant Manager - Administrative

,

i

  • W. R. Robinson, Compliance Supervisor s
  • Denotes those present at one or more exit interviews.

!

l In addition, a number of equipment operators, Reactor Operators, Senior Reactor Operators, and other members of the Quality Control (QC),

'

i Operations and Maintenance staffs were contacted.

!

!

!

!

2.

Licensee Event Report (LER) Followup i

Through direct observations, discussions with licensee personnel, and

.

i 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 accomplished.

t (Closed) LER 84-045:

Feedwater Isolation Signal (FWIS).

On September 30, l

1984, due to the omission of a switch position in the reactor trip bypass l

breaker surveillance procedure, a FWIS was generated.

The procedure was i

revised and successfully performed the following day.

The need for i

specifying pretest status in procedures was emphasized to the system i

engineers.

The inspector has no further questions in this matter.

This j

item is considered closed.

e l

i -

I

!

.

4

-, ~ -


mm-

.

.,,--,-- - ~ nae-vv w ~

e.,,-e

-,---,vaem=-en,-.--

,.n

,e.

-,c-w.

-. -., - -,- --- -, - -

. - - -,

- - -,

r,

-,---en.

,-

-

.

,

'

.

(Closed) LER 84-049-01:

Technical Specification Violation.

In the month of October 1984, two occurrences were noted of an out-of-specification reading being logged without the appropriate action being taken.

The plant was in Mode 2, at 10-8 amps at the time of the events.

In both cases this resulted in being outside the Limiting Conditions for Operations as the applicable bistables were not tripped within one hour.

Corrective action included addition of a seminar on data documentation to the requalification program and requiring that an Equipment Out of Service log number be written on the bottom of the Reactor Operator Log for each out-of-specifi-cation entry.

The training was completed in February 1985.

No citation was issued since under the Enforcement Policy this was considered a Severity Level IV Technical Specifications violation which was identified and satisfactorily corrected by the licensee, and no further violations of a similar nature have occurred.

This item is considered closed.

(Closed) LER 84-059:

Reactor Trips Upon Loss of Service Air.

This LER covers two reactor trips that occurred due to loss of service air supply to feedwater control valves.

On November 5, 1984, the plant tripped from 45% power due to 10-10 steam generator level which was caused by the

'

feedwater control valve failing closed due to loss of air supply when an air line connection failed.

On November 6,1984, during the trip recovery, an air line ruptured to a feedwater recirculation valve resulting in a steam generator high level main turbine trip, and the resulting steam generator level shrink caused a reactor trip.

A design modification changed the air line fabrication material and provided supports for the air lines to the feedwater valves.

This item is considered closed.

(Closed) LER 84-060:

Reactor Trip and Engineered Safety Features (ESF)

Actuation.

A reactor trip and engineered safety features actuation occurred on November 14, 1984, as a manual turbine runback was being performed in response to decreasing condenser vacuum. A circulating water pump received an auto trip signal causing the decreasing condenser vacuum. The turbine runback resulted in steam generator (SG) level oscillations ending in a hi-hi level SG turbine trip-reactor (greater than 50% power) trip.

The auto trip on the circulating water pump was found to be unnecessary and was, therefore, converted to an alarm-only function eliminating the possibility of an unnecessary reactor trip and ESF actuations.

This item is considered closed.

(Closed) LER 85-002:

Reactor Trip and Turbine Trip. On January 7, 1985, the reactor was tripped from 50% power due to a turbine trip initiated by a spurious high vibration signal.

The turbine high vibration circuitry was modified to provide an alarm-only function to the control room. The turbine trip from high vibration was disabled to prevent unnecessary challenges to the reactor protection systems. The inspector has no further questions in this matter. This item is considered closed.

,

-

.

(Closed) LER 85-005 and LER 85-038:

Reactor Protection System Actuation.

On January 31, 1985, a reactor trip occurred from 100% power.

The trip was caused by a loss of field to the main generator which resulted in a turbine trip.

The apparent cause of-the loss of the generator field was a momentary open circuit in the auto voltage regulator rheostat for the generator field.

The rheostat was cleaned and the automatic voltage regulator operated satisfactorily until August 20, 1985, when the voltage regulator again experienced an intermittent failure which caused a turbine trip / reactor trip.

The licensee replaced the suspect potentiometer and printed circuit card and instituted a weekly preventive maintenance procedure to exercise the potentiometer through full travel.

The inspector has no further question in this matter.

This item is considered closed.

(Closed) LER 85-006:

Inadvertent Control Room Ventilation Isolation Signal (CRVIS).

On January 22, 1985, an inadvertent CRVIS occurred while troubleshooting an iodine monitor.

The spike was apparently transmitted back through the power supply into other monitors causing the isolation.

Corrective action included bypassing the apprcpriate ESF channel before similar work is initiated.

This item is considered closed.

(Closed) LER 85-012:

Inadvertent Engineered Safety Features Actuation.

On February 22, 1985, a turbine trip, feedwater isolation signal, steam generator blowdown isolation signal, and auxiliary feedwater actuation signal resulted from a hi-hi level signal on steam generator "D".

The reactor was at 7% power and feedwater control was in manual.

The steam generator "D" level recorder was not functioning properly which resulted in overfeeding of the Steam Generator.

This overfeeding in combination with expansion of the cold feedwater (feedwater not being preheated)

resulted in the hi-hi level, turbine trip, and isolations.

The recorder was repaired and extra precautions were provided to the feedwater control station operator when feeding the steam generators with cold feedwater.

This item is considered closed.

(Closed) LER 85-014:

Inadvertent Engineered Safety Features Actuation.

The licensee's troubleshooting, which included review of system perfor-mance, sample flows, and radiation levels, could not identify a cause for the actuation.

The licensee classified this as a spurious actuation.

This item is considered closed.

(Closed) LER 85-018:

Inadvertent Diesel Generator Start. On March 29, 1985, "B" diesel generator was inadvertently started during the perfor-mance of a surveillance procedure.

The technician depressed the incorrect pushbutton which simulated an undervoltage condition.

The technician was reminded to remain attentive while performing surveillance.

In addition, identifying name plates were installed on the panels.

This item is considered closed.

,-

-

.

.

-

.

.

-

-

--

..

.-.

_.

t

-

.

(Closed) LER 85-019:

Low Steamline Pressure Safety Injection Actuation.

,

On March 30, 1985, an inadvertent safety injection actuation (reactor shutdown) occurred from a low steamline pressure signal.

An unusual Event was in effect for about 20 minutes.

The low steamline pressure signal was due to cooling down with the steam dumps when steam pressure was near

,

the safety injection setpoint.

The small steam pressure decrease as

,

amplified by the-rate compensation was sufficient to cause an ESF actua-l tion.

To prevent recurrence a caution note was added to the cooldown procedure, alerting operators of the possibility of initiating safety injection. This item is considered closed.

(Closed) LER 85-028:

Technical Specification Violation.

This report documents three Technical Specification Violations which occurred as the result of maintenance performed on the Unit Vent Vide Range Monitor System

(WRGM) GT-RE-218.

On May 29, 1985, troubleshooting and maintenance was

,

performed on the unit vent monitoring system.

The work was performed by the licensee's Instrument and Control (I&C) technicians in response to an observed system flow control deficiency.

Following the maintenance i

!

activities, the wide range monitor sample line was inadvertenty left disconnected, yet post maintenance testing was performed and the system was declared operable.

On June 11, 1985, the licensee discovered the j

disconnected sample line, properly restored the system to an operable status, documented the violation, and reported the event to the NRC.

The disconnected line resulted in the wide range monitor sampling the auxiliary building atmosphere rather than the unit vent during the period May 29 through June 11, 1985, and resulted in the following T/S Violations.

T/S 3.3.3.6 Action c. - Not performed as required for an inoperable

.

accident monitoring instrumentation channel.

  • T/S 3.3.3.10 Action b. - Not pe'rformed as required for an inoperable

.

radioactive gaseous effluent monitoring instrumentation channel.

T/S 3.11.2.1 - Surveillance requirements for sampling and analysis

.

following the reactor trip which occurred on June 7, 1985, were performed but were invalid due to the disconnected sample line.

NRC Inspection Report No. 483/85017(DRSS) addressed the Notice of Violation

for the above T/S Violations, and,-in addition, provides a discussion of j

Health Physics (HP) procedural deficiencies identified during that inspection.

Consequently, the inspector has no further questions with

'

regard to the T/S Violations, nor in the related HP area.

An inspection i

of matters relating to the cause of this event was performed to assess the adequacy of, and adherence to, the licensee's procedures for the

-

control of maintenance activities.

The inspection included interviews

with HP, I&C and Operations personnel and a review of the following documents:

'

'

<

.

-

.

.. - -

-

- _ _. -- -. _

.. -.

..

. _... _.,. _

.

..

,

.

.

Equipment Out of Service Log E0L No.85-538

-

Shift Supervisor's Log - May 29, 1985

-

I&C Functional Test Surveillance Procedure ISF-GT-OR21B (Rev. 2

-

and 3) and related Surveillance Task Sheets Workmen's Protection Assurance and Caution Tagging

-

(APA-ZZ-00310)

Work Request Processing (PDP-ZZ-00003)

-

I&C Work Request No. 46234 (Generic Troubleshooting)

-

I&C Work Request No. 44600 (Troubleshooting and repair low range

-

pump manual control)

Incident Report No.85-253 (Discovery of disconnected sample line)

-

Licensee Event Report No.85-028 (Technical Specification Violation)

-

The inspector determined that the event (inoperable monitoring

-

system) resulted from a combination of personnel error, procedure deficiency, and system design deficiency.

These items are discussed separately as follows:

Personnel Error During troubleshooting activities using I&C generic Work Request (WR)

No. 46234, an I&C technician disconnected the sample inlet line and removed the WRGM pump head.

The activity was contrary to the WR attachment 1, which states, " Entry into any fluid system is not allowed by this work request." Additionally, the work performed on this WR was not documented; i.e., the " repair action taken/ corrective action" block on the WR form contained only " Pump has a broken diaphragm. 2 techs 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." Restoration of the pump was performed using WR 44600 on the following shift.

The disconnected sample line was overlooked.

Licensee's review of the above errors determined that the technician's understanding of " Fluid System" referred to

" liquid" not air or gas.

The licensee has discussed the technician's misunderstanding of the WR restriction on entry into fluid systems and the need for documenting actual work performed.

.

Procedure Deficiency WR No. '44600 specified ISF-GT-OR21B, Section 6.2, as the system functional retest method to determine system operability.

The specified functional test was performed and the WRGM system was returned to service.

The licensee's review following the event determined that the functional test procedure was deficient in

-

-

+

m

.

'

that the test procedure failed to ensure sample line integrity.

The licensee has issued Revision 3 to ISF-GT-0R21B which corrects the deficiency.

System Design Deficiency The licensee's Incident Report No. IR-85-0253 documents that the WRGM system pump diaphragm rupture is the second occurrence of this nature.

The first pump diaphragm rupture occurred on May 8, 1984.

With a diaphragm failure, the pump continues to move air through the WRGM detector and mass flow meter.

This results in the auxiliary building atmosphere (pump perimeter) being monitored instead of the unit vent sample.

The licensee has issued Callaway Modification Request (CMR) No.

85-312A.

This request for a design change would enable the WRGM system to detect a pump diaphragm failure or loss of suction line integrity.

The licensee has discussed this matter with the pump vendor (GA Technologies) and is currently evaluating the generic aspects of this type of failure.

This matter remains unresolved pending further NRC review of the generic aspects.

Unresolved Item No. 483/85016-01(DRP).

The inspector determined that matters relative to the Technical Specification Violations have been thoroughly evaluated and corrected by the licensee.

This includes the issuance of a CMR, revision of the functional test procedure and the indoctrination and training of involved personnel.

LER 85-028 is considered closed.

One unresolved item, no violations, and no deviations were identified.

3.

Inspection of Licensee Events a.

Possible Tampering On July 29, 1985, during performance of the Containment Spray (CS)

Train "B" Surveillance Test OSP-EN-P001B, two CS pump trips occurred on Phase "C" instantaneous overcurrent.

The licensee's initial inspection determined the following:

(1) The relay sealing wire used on the relay case was not properly installed.

(2) The face of the relay cover had a corner broken and a hand screw missing.

(3) The instantaneous overcurrent setting locknut was very loose.

A subsequent calibration check of the relay determined that the as found setting was 19.6 amps as opposed to the specified setting of 40.0 amps.

c

,

.

Based on the initial findings, the licensee took additional security measures, notified the NRC Senior Resident Inspector, Region III and Headquarters personnel, and conducted a thorough investigation.

The licensee's follow-up investigation determined that the lead wire seal had been improperly installed and that the plastic cover of the relay box had been previously reported with a WR; the repair was awaiting replacement parts.

The most probable causes of the incorrect relay setting were initial setting error or that the setting changed over time because of a loose locknut.

The licensee reviewed this event with plant personnel encouraging their awareness and reporting events of this nature, reviewed test procedures relating to relay settings, and instructed technicians in the proper installation of seals.

This matter is documented in Licensee Security Report No.85-012.

The inspector's review of this matter determined that the licensee's investigation was prompt and thorough and both conclusions and corrective measures were appropriate.

The inspector has no further questions in this matter.

Licensee Security Report No.85-012 is considered closed.

b.

Technical Specification Violation (Exceeding Axial Flux Difference (AFD) Limits)

On August 17, 1985, while at 100% reactor thermal power, the reactor was operated beyond the allowable AFD target band for an accumulated time of 141 minutes.

Technical Specification 3.2.1 Action a. states the following:

"With the indicated AFD outside of the above required target band and with THERMAL POWER greater than or equal to 90% of RATED THERMAL POWER, within 15 minutes, either:

1.

Restore the indicated AFD to within the above required target band limits, or 2.

Reduce THERMAL POWER to less than 90% of RATED THERMAL POWER."

At the time the licensed reactor operator noted the AFD condition, 135 penalty points (minutes) had accumulated, exceeding the allowable action time.

An additional six (6) penalty points accumulated during the subsequent power reduction.

The reactor thermal power was reduced to approximately 46% power and maintained there for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> deleting the penalty points.

Inspection in this matter included a review of computer printouts, operating logs and Incident Report No. IR 85-340, interviews with operating crews and discussion of the event with plant management.

,

-

.

The computer printouts indicate that the allowable AFD band was exceeded by approximately one percent.

The licensee and Westinghouse Core Design and Nuclear Fuels Division personnel reviewed the AFD data. They concluded that the event posed no technical safety problem and that remaining below 50% power for the specified time provided adequate pre-conditioning of the fuel.

Four channels of power range flux difference, an NIS Recorder and CRT display are provided on the control room " front panel", which provides AFD conditions. This event indicates a lack of operator attention and resulted in exceedi.ig the allowable Axial Flux Difference.

Failure to satisfy the associated Action Statements within the specified time is a violation of Technical Specification 3.2.1 (483/85016-02(DRP)).

The inspection disclosed that, once identified by the licensee, action was promptly taken to correct the violation, the event was appropriately documented, and was reported to the NRC.

Corrective action to prevent recurrence includes instructions to shift super-visors which specify immediate definitive action relating to personnel accountability, procedure adherence, and upgrading of watchstanding practices including greater attention to plant parameters and conditions.

Additional action to prevent recurrence included the installation of the AFD monitor alarm in the control room and the CRT display indicating, in red, the AFD values which exceed limits.

The inspector has no further questions in this matter, and under the provisions of the Enforcement Policy no reply to this violation is required.

LER No.85-037 is considered closed.

One violation and no deviations were identified.

4.

Followup on Regional Requests a.

Documenting and Reporting of Events During this inspection period, the inspector assessed the licensee's overall performance and threshold of documenting and/or reporting of events in order to ascertain licensee compliance with NRC require-ments (10 CFR 50.72 and 50.73) regarding notifications to the NRC Operations Center and reporting of events in LERs. The inspection included a review of 28 Incident Reports (irs) selected from IR Nos.85-125 through 85-261, a review of operating logs and LERs, and interviews with operations and compliance department personnel.

The inspector determined that five of the 28 irs reviewed resulted in LERs or were declared potential LERs by the licensee. The remaining 23 irs documented minor procedure, personnel and/or hardware deficiencies.

This review indicated that the licensee has a conservative threshold for documenting deficiencies on Incident

,

.

Reports and that significant events receive a thorough evaluation, are corrected, and are appropriately reported to the NRC.

However, during this review the inspector questioned the licensee disposi-tion of Incident Report No.85-137.

This Incident Report was written to document a QA audit finding that the Technical Specification Boration Control - Shutdown Margin Surveillance 4.1.1.1.2 was not performed in the specified time interval (prior to exceeding 60 Effective Full Power Days (EFPD)).

The core reactivity data was obtained at approximately 45 EFPD; however, the data was not used to adjust (normalize) the predicted reactivity values to correspond to the actual core conditions until approximately 64 EFPD.

This item was reviewed by the licensee's Onsite Review Committee (ORC) and the Nuclear Safety Review Board.

Based on these reviews, the licensee determined that the Technical Specification was not violated.

The basis for this determination was that T/S Surveillance 4.0.2 states, "Each surveillance requirement shall be performed within the specified time interval with:

A maximum extension not to exceed 25% of the surveillance interval..."

.

The inspector has discussed this matter with Messrs. Virgilio (NRR),

Moon (NRR), and Brinkman (I&E).

Based on these discussions, the inspector determined that in this specific case the licensee's position, e.g., "T/S 4.1.1.1.2 was not violated", was found acceptable.

Consideration was given that, in a broad sense, 60 EFPD after each fuel loading, could be accepted as a " time interval" and also that the T/S did not exclude the allowable extension contained in T/S 4.0.2.

The inspector has no further questions in this matter.

No violations or deviations were identified.

b.

Licensee Events / Reactor Trips The inspector evaluated the nature, cause and frequency of licensee events and reactor trips.

The inspector determined that although there has been an overall reduction in the frequency of both LERs and reactor trips during 1985, there has been an increasing trend in these events occurring since June 1985 attributable to personnel errors.

For example, during the first five months of this year, nine reactor trips occurred; all appeared to have resulted from random equipment failures.

During the past three months, six reactor trips occurred and three were the result of personnel errors.

The personnel errors appeared to be " isolated" events but can be related to operator / technician attentiveness.

The inspector determined that the events and trips received prompt licensee attention, causal factors were evaluated, and corrective measures were applied.

This matter was discussed with the licensee during a recent NRC Region III management site visit and during routine NRC resident inspector / licensee meetings.

The licensee's attention and involve-ment toward the reduction of events / trips is evident.

In addition to the immediate corrective measures taken, the licensee is performing a

-

-.--- -. -

- - - - -

-- --

-- -.

..,.

. -

__

._

_ - _.,

.

_

__

. _ _

-

.

common element analysis to determine both specific and generic corrective action, and is developing an overall Incident Reduction Program.

These actions are expected to bring about improvement in this area.

The NRC will closely monitor the licensee's effectiveness in this matter.

No violations or deviations were identified.

c.

Operations and Maintenance Overview

!

At the request of NRC Region III, the Senior Resident Inspector from the Kewaunee Plant performed an onsite inspection at the Callaway

'

Plant during the week of June 24, 1985.

The inspection included observations of operations, the implementation of the maintenance planning and scheduling program, radwaste processing, plant housekeeping, and interviews with licensee personnel.

The NRC inspector determined that control room activities were being performed in a professional manner.

The planning and scheduling program was comprehensive and effectively implemented.

Personnel who were interviewed were very responsive and projected a positive attitude toward their responsibilities.

i No violations or deviations were identified.

)

5.

Compliance with Callaway Plant Technical Specifications Through in plant inspections of system line-ups, control room valve and breaker indications, the review of chemistry logs, calibration data and

,

plant cecords, the inspector verified compliance with the following l

Technical Specifications.

!

Technical Specifications:

i 3.2.1 Axial Flux Difference

!

3.3.3.5 Remote Shutdown Instrumentation l

3.4.7 Reactor Coolant System Chemistry i

3.5.1 ECCS Accumulators j

3.6.1.4 Containment Systems - Internal Pressure

  • 3.6.3 Containment Isolation Valves

3.7.3 Component Cooling Water System 3.7.5 Ultimate Heat Sink i

  • 3.7.10 Fire Suppression Systems 3.8.1.1 AC Sources j
  • Sample inspection performed.

No violations or deviations were identified.

!

i,

!r__

_ -. -

.-

-

-

. - -.

.

.

-

- -

-

-

.

.-

~

- -. - -

.,

~

.

'

6.

Plant Tours The inspector toured plant areas frequently during this inspection period to observe housekeeping conditions and practices, plant operations, control room activities, and maintenance and surveillance testing activities.

The inspectors reviewed control room logs and observed shift turnovers.

Plant tours were also performed by the Region III management personnel i

and regional inspectors.

Housekeeping in general was determined to be

'

very good to excellent.

I&C surveillance and ongoing maintenance activities were adequately scheduled and supervised, and procedures were adhered to.

Control room behavior continues to be excellent.

Control room activities are performed in a business-like and disciplined manner.

No violations or deviations were identified.

7.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations.

An unresolved item disclosed during the inspection is discussed in Paragraph 3.b.

8.

Exit Iqterview The inspector met with licensee representatives (denoted under Persons Contacted) at intervals during the inspection period.

The inspector summarized the scope and findings of the inspection.

The licensee representatives acknowledged the findings as reported herein.

The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.

The licensee did not identify 'any such documents / processes as proprietary.

. - _....

.

-