IR 05000445/1990014
| ML20034B891 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/27/1990 |
| From: | Chamberlain D, Joel Wiebe NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20034B890 | List: |
| References | |
| 50-445-90-14, 50-446-90-14, NUDOCS 9005010127 | |
| Download: ML20034B891 (14) | |
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l U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report 50-445/90-14 l
50-446/90-14-Dockets: 50-445 Unit 1 Operating License:
50-446 Unit 2 construction Permit CPPR-127 Expires August 1, 1992 e
Licensee:
TU Electric
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Skyway Tower i
400 North Olive Street
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Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES),
Units l'and 2 Inspection At:
Comanche Peak Site, Glon Rose, Texas
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i Inspection Conducted:
April 10 through April 12, 1990
Team Leader:
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D. D.VChamberlain, Ch,ef Date Project Section B, Region IV Team Membara:
A. T. Howell, Resident Inspector, Operations W. F. Smith, Senior Resident Inspector, Waterford Steam Electric Station, Unit 3 T. Taylor, Senior Resident Inspector, Braidwood
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K. M. Jenison, Senior Resident Inspector, Sequoyah S. D. Bitter, Resident Inspector, Operations Reviewed by:
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J S. Wiebe, Senior Project Inspector
'/Datp
I 9005010127 900427 i
{liR ADOCK 05000445 l
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Inspection Summary (
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Inspection conducted: April 10 throuch April 12, 1990 (Report 50-445/90-14 50-446/90-14)
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Areas Inspected:
Special, announced team inspection of control room observations, shift turnover observations, plant tours, maintenance
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observations, surveillance observations, safety system walkdowns, licensee open items review, operator staffing, management oversight of
operational activities, administrative / technical support to operations, and operability assessments for identified deficiencies.
Results:
The NRC review of the licensee's operational activities indicate that the licensee's operations staff is staffed by professional and competent personnel.
The NRC findings from this i
inspection are not indicative of an overall generic problem in any area.
The minor deficiencies noted did not affect system operability.
It is the team's conclusion that the licensee's performance was satisfactory to assume full-power operation.
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The team identified a number of strengths and a couple of potential weak areas.
These include:
a.
Strenoths l
System status controls (paragraph 2).
Operations staff conduct and professionalism (paragraphs 2 and 3).
Management involvement in operational activities (paragraph 10).
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Six crew shift rotation (paragraph 9).
Control of maintenance backlog (paragraph 8).
plant cleanliness (paragraph 4).
Automated tagging system for scheduled, repetitive tasks (paragraph 4).
b.
Weaknesses conduct of nonsafety-related maintenance (paragraph 5.c).
Control of doors (paragraph 4.e.).
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DETAILS
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1.
Persons Contacted
- W.
Cahill, Executive Vice President, Nuclear, TO Electric
- A.
Scott, Vice President, Nuclear Operations, TU Electric
K. Apple, Unit 1 Supervisor, TU Electric T. Bain, Shift Supervisor, TO Electric T. Beaudin, Shift Supervisor, TU Electric
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D. Corbit, Manager, Administrative Services, TU Electric M. Cornell, Reactor Operator, TU Electric T. Daskam, Shift Supervisor, TU Electric C. Davis, Reactor Operator, TU Electric
- D. Davis, Manager, Technical Support, TU Electric D. Goldwin, Shift Technical Advisor (STA), TU Electric J. Goode, Technical Support / Compliance, TU Electric
- J. Donahue, Operations Manager, TU Electric
- W. Guldemond, Manager of Site Licensing, TU Electric R. Henslee, Operations Surveillance Test Coordinator,
TU Electric
- C.
Hogg, Chief Engineer, TU Electric-
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C. Homan, Site Work Control Center, Westinghouse
- T.
Hope, Site Licensing, TU Electric
- A. Husain, Director, Reactor Engineering, TU Electric D. Knox, Auxiliary Operator, TU Electric G. Lytle, Work Control Operations Supervisor, TU Electric T. Marsh, Shift Supervisor, TU Electric
- D.
McAfee, Manager, QA, TU Electric
- E. Ottney, Project Manager, CASE
- H.
Phillips, Consultant, CASE A. Pietrovich, System Engineer, TU Electric B. Poteate, Operations Duty Manager, TU Electric
- M.
Riggs, Plant Evaluation Manager, Operations, TU Electric W. Rosette, Operations Support, TU Electric
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- W.
Sly, Instrumentation and Control, TU Electric
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M. Smith, Shift Supervisor, TU Electric M. Sullivan, Site Health Physics (HP) Supervisor, TU Electric N. Terrel, Supervisor, NSSS Systems, TU Electric
- C.
Terry, Manager of Projects, TU Electric G. Thatcher, Auxiliary Operator, TU Electric P. Uselton, Reactor Operator, TU Electric S. White, Instrumentation & Control, TU Electric
- B.
Wieland, Manager, Maintenance, TU Electric The NRC team also interviewed other licensee employees during this inspection period.
- Denotes personnel present at the April 12, 1990, exit meeting.
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NRC personnel present at April 12, 1990, exit meeting.
l S. D. Bitter, Resident Inspector, Comanche Peak Project Division,
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D. D. Chamberlain, Chief, Project Section B, Region IV-
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T. P. Gwynn, Deputy Director, Division of Reactor Projects, j
Region IV A. T. Howell, Resident Inspector, Region IV
K. M. Jenison, Senior Resident Inspector, Sequoyah, Region II
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W. F. Smith, Senior Resident Inspector, Waterford-3, Region IV T. Taylor, Resident Inspector, Braidwood,. Region III
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R. F. Warnick, Assistant Director for Inspection Programs, Comanche Peak Project Division, NRR
2.
Control Room Observations (93806)
The_ team observed control room activities during both day and
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evening shifts.
The activities were observed to be handled in a
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competent and professional manner.
Control room professionalism
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promoted safe operation of the plant.
This was considered a strength by the team.
The operators were knowledgeable, attentive, and aware of plant conditions including the reasons
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for alarms.
The Unit 1 reactor operator logs were reviewed
periodically by the team and the entries were appropriate and
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informative.
The operators appeared to have control of plant activities as evidenced by the team observation of response to a failure of the rod control system on April 10, 1990, and a plant shutdown on April 11, 1990.
Tagging, maintenance authorizations, and surveillance authorizations were conducted in accordance with approved procedures.
Effective operation's management
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involvement was evident.
Operation's management was conscientious and knowledgeable of plant conditions and problems.
Management was also active with the planning of activities and resolution of problems.
System status was well maintained through use of procedures, l
computerized clearances, conduct of recent valve lineup checks on i
key safety system flow paths, and by marking up plastic laminated l
system diagrams which were maintained in the control room.
The inspectors reviewed Procedure No. ODA-410, Revision 1, " System Status Control," and noted that the systems to be statused were listed,-and that tasks and responsibilities for statusing these systems was delineated. System status controls in effect at CPSES were viewed by the inspectors as a strength.
The licensee's Shift Advisor Program appeared to enhance the operation of the plant during these early stages.
There were three individuals rotating on twelve hour shifts.
One was a senior reactor operator (SRO) from Commonwealth Edison, one was a SRO from Duke Power, and the third was a contractor that had been
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a SRO at Plant Vogtle.
There was a good working relationship
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l No violations or deviations were identified in this area.
3.
shift Turnover Observations (93806)
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V The team witnessed.both the morning, afternoon, and night shift turnovers.
The inspectors' observations of the shift turnovers
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indicated that the turnover process was effective.
Shift
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briefings and review of logs and other records were performed
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I such that the operators u7derstood the condition of the plant
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prior to taking the watch.
Adequate information was disseminated at the turnover briefings to give the operators and shift
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supervisor knowledge about plant conditions, ongoing work, upcoming work and planned evolutions.
Input was also received from other station organizations such as health physics, i
chemistry, quality assurance, and maintenance..The turnover j
process was considered another example of professional conduct by the operations staff.
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No violations or deviations were identified in this area.
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4.
Plant Tours (93806)
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l The team conducted' plant tours during day and evening shifts to
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assess plant and equipment conditions.
The plant was toured to determine whether
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General plant conditions were satisfactory;
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Equipment was being maintained in proper condition, without excessive fluid leaks and excessive vibration; Plant housekeeping and cleanliness practices, including fire hazards and the control of combustible material, were adequate;
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Portable gas cylinders were properly stored to prevent possible missile hazards; and
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O Tagout of equipment was performed properly.
During the tours of the plant, the team noted the items listed below
a.
Luminescent striping on 6.9kv safeguard switchgear was inconsistent between the two trains..On the basis of conversations with auxiliary operators, the use of this striping was also not clear.
This issue will remain open pending-further inspection followup (445/9014-0-01).
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b.
Unmarked yellow polyethylene catch bags were used to collect f
potentially contaminated liquids.
In addition, clear
_ plastic sleeving was used to direct liquid to floor drains -
The control of potentially contaminated fluids was discussed with the site Radiological Controls manager who outlined an
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existing program to identify, tag, and track these receptacles.
c.
An electrical conduit for residual heat removal (RNR) flow control valve FCV-618, RHR heat exchanger bypass flow
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control, was loose and did not appear to have proper support.
d.
Some water tight doors are-not able to be unlocked from i
inside the pump-rooms.
The licensec was aware of this
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condition and has established adequate corrective actions,
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including not locking the doors until modifications are complete, e.
Tornado door Sl-37X was'found to'be blocked open on two occasions because the lock was apparently difficult to operate.
Control of doors was considered a potential
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weakness by the team.
The licensee was in the process of developing a computer database j
which will automatically generate'an appropriate tagout for any
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scheduled repetitive task (mostly preven'tive maintenance or surveillance items).
The system was already printing the tagout
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verification sheets and the tags themselves.
This system was being set up to establish " routine" clearances for repetitive tasks, thus eliminating errors.
The program also automatically provided valve and breaker descriptions _and locations for all clearances.
This was considered a strength.
On the basis of the plant tours and the few deficiencies that were noted, the team considered the overall material condition of i
the plant to be good, and the overall level of plant cleanliness to be excellent.
Plant cleanliness-was considered a strength by
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the team.
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No violations or deviations were identified.
5.
Maintenance Observations (93806)
The team reviewed and observed selected station maintenance activities (both safety and nonsafety related) to verify the maintenance was conducted in accordance with the applicable procedures and requirements, i
The team reviewed and observed the following maintenance
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activities:
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Work Order (WO) C90-2802, Revision 1 was issued to replace power range detector assembly, 1-NI-0042A.- The team noted j
.that this work order was well planned and executed.
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team was concerned, however, that no lanyards were used on
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small hand tools to prevent them from being dropped.into the detector well.
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Wo C90-2469, Revision 1 was issued to obtain control rod l
current traces to determine why one particular control rod (P8) was not maintaining proper alignment with the others in
its group (c).
The team reviewed various activities-l associated with this maintenance activity, and found them to
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be well performed.
The-team did note, however, that the troubleshooting of the rod control system was performed while the system was in operation during a reactor shutdown even though Procedure ICA-102, Revision 0, " Instrumentation and Control Troubleshooting Activities," requires, in part, that troubleshooting can be performed only on systems that are inoperable.
Discussions with licensee personnel i
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revealed that it was not clear what the intent of the word
" inoperable" was (i.e., inoperable'in the context of the Technical Specifications or some broader definition applicable to both safety-related and nonsafety-related.
systems and components).
This issue will remain open pending further inspection followup (445/9014-0-02).
c.
WO 90-1910 was issued to reassemble a mainsteam dump valve.
The weaknesses listed below were observed by the team, The procedure was not routinely referenced throughout t
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the reassembly process.
Procedure steps that were already signed as complete were referenced during the observed reassembly of the valve.
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Quality Control (QC) hold points were marked N/A without written justification in the work order.
Channel lock pliers were used on valve stem nuts.
The stem was initially bound during reassembly which required disassembly of the upper portion of the valve mechanism.
The reason for the binding was not documented.
When the valve body was lifted, the valve stem was realigned and the binding eliminated.
l Torquing values were changed from the standard stud size values to those generic values recommended by the vendor.
Justification for this decision was not documented in the WO.
However, on the basis of discussions with the technicians, the team determined that this decision was made by mechanical maintenance supervision.
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The torquing pattern used by the technicians was not
described in the procedure and was not a standard
crossing pattern.
Although the team witnessed only a few maintenance activities, it
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i appeared that nonsafety-related maintenance activities were not as well planned or executed as safety-related activities.
Discussions with senior licensee management revealed that it was
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the licensee's intent to conduct both safety-related and
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nonsafety-related maintenance activities in a:similar manner.
At
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the April 12, 1990, exit meeting, licensee senior management
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stated that a review of maintenance policies and practices a
governing safety-related and nonsafety-related maintenance would
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be conducted.
Nonsafety-related maintenance activities will be
reviewed during future NRC inkpections.
No violations or deviations were identified.
6.
Surveillance observations (93806)
The team observed the performance and documentation of selected
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surveillance activities on safety-related systems and components.
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The following surveillances were observed:
a.
OPT-303A, " Reactor Coolant System Water Inventory."
The team reviewed the completed data and performad i
independent calculations to verify the results.
7uring the review, the team noted that the input data on the official
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record copy of the completed test was not raw data and in two instances (reactor coolant drain tank (RCDT) temperature and RCDT leakage flow) the raw data was incorrectly transcribed from the raw data printout to the official data sheet.
Using the raw data, which the licensee did not.
t include as part of the completed work package, the team was able to calculate results that were in agreement with the licensee's results.
In addition, a negative unidentified leakage (-0.1687 gpm) value was obtained and accepted,
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because the acceptance criterion was less than 1 gpm.
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to the accuracy of instruments read, this is possible when
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leak rates are low, but the procedure did not establish how negative the results can become before a problem may exist.
The team believed that this surveillance could be improved by establishing a tolerance for action with negative reactor coolant system (RCS) leak rate results, and by including the raw data printout in the record copy of the completed surveillance packane.
This was discussed with the licensee who indicated the intent to review this matter.
This area
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is monitored during routine resident inspection activities.
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ODA-301-37, Revision 2, " Reactor operator Log Sheet."
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OPT-102A-02, Revision 1, " Shiftily Surveillance."
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OPT-102A-07, Revision 4, " Local Shiftily Surveillance."
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EGT-108.1, Revision 0, " Control / Indicating Circuit Functional for Feedwater Regulation Valves."
l The inspector identified that this test did not have acceptance criteria identified in it and did'not refer to
another document for acceptance criteria.
The technician
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who performed the test stated that-the acceptance criteria l
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was taken from Comanche, Peak Technical Requirements Manual.
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The team believed that this area could be improved by i
referencing the source document and by documenting the
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acceptance criteria along with the data recorded.
The licensee stated the intent to review this area for potential
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improvements.
The team had no further questions, j
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INC-7384A, " Channel Calibration of Neutron Flux Source Range
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l Channel 32, High Flux at Shutdown."
The team noted that there was some confusion between the technician and the STA with respect to the manner that the source range nuclear instrumentation scaler was to be placed back in normal operation.
This scaler was used to obtain source range calibration data.
After some discussion, the STA placed the scaler back into operation.
Correct data was obtained for the source range calibration and the team had no further questions.
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No violations or deviations were identified.
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7.
Safety System Walkdowns'(93806)
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The team performed a walkdown of selected safety-related systems
to determine whether as-built conditions matched drawings and procedures.
The team found that valves and electrical breakers
observed were in the correct position for normal system operability.
The following systems were inspected:
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Component Coolina Water (CCW)
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The followdng minor observations were made on the CCW systems (1)
Valve ICC-101 was leaking slightly.
(2)
CCW Pump No. 1 outboard seal was leaking about 40 drops per minute.
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Safety Injection (SI) System'
'The following minor observations were made on the SI nystem:?
(1)
Oil!1evel was low on the TBS-SIAPSI-02_SI pump.
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Valve 1-8802B was leaking slightly.
t (3)' Flow Element FE-918 flanges were leaking.
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d-(4)
TBX-SIAPSI-02 suction andLdischarge-pressure, gages.wereL i
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'not labeled.
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(5)
Maintenance work tags for.old work:were not removed a
(e;g.', WO 57543).
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(6)
The room cooler for SI Pump TBX-SIAPSI-01 wasidripping-and had rust on the inlet and outlet flanges and bolts.
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There was minor corrosion.on the oil pump base for SI Pump-TBX-SIAPSI-01.
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No violations or' deviations were identified..The minor q
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observations noted did not affect system operability.
All of the minor observations were given to the licensee during the
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inspection and the licensee initiated" actions to correct them immediately.
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Licensee-Open Items (93806)
The team reviewed the manner in which-the~ licensee controlled i
open items.
The team found that the' licensee had reduced the-
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total amount of open' items from approximately 21,200'itemsiin?
October 1989 to approximately 1800. items as of-April 1990.
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the 1800'openLitems, approximately 1275 are. corrective ~
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maintenance work requests / orders.
The. team, sampled approximately i
100 open work. orders'and found them to be_ acceptable for
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post-full-power. license deferral.
The control of maintenance backlog was considered'a strength by the team.
No violations or deviations were identified in this area.
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Operator Staffing (93806)
The team reviewed the Unit 1 licensed operator complement to determine if staffing-met Technical Specification requirements.
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-The team considered the six crew rotation to be a strength,
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i Licensed operator-work hours were controlled by Station Administrative Procedure STA-615, Revision 3, " Staff Work Hours."
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The team found.that licensed operator overtime was not excessive l
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-were controlled in accordance with the governing procedure.
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No violations'or deviations were identified in'this area.
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Management Oversicht of Operational Activities (93806)
Management oversight was: evident for activities observed during this inspection.
Plan-Of-The-Day meetings were conducted each
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morning, and'were' chaired by the plant manager where plant status
and problems were openly discussed.: Senior-level management also
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participated and management probing of issues and knowledge.of.
problem areas were demonstrated during these meetings.
Matters.
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requiring management interface and resolution were-expeditiously
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addressed-at these meetings.
During control room and shift turnover' observations, effective management involvement was also observed.
Management was
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knowledgeable of plant conditions and problems, and was active-r with the planning of activities and-resolution of problems.
The team also assessed the licensee's use of shift advisors and-duty managers during this inspection.
Shift advisors were effectively interfacing with the operating crews and shift i
management in an advisory-capacity to provide' enhanced experienced oversight of operational activities.- -The duty managers were providing shift coordination and were functioning in an advisory capacity,to the shift supervisor and other
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licensee management.- The team believed that the use of shift
advisors and duty managers was an effective tool tx) enhance management oversight of operational activities.
Overall, the team concluded that management oversight of operational activities was effective-and would provide the necessary oversight for power ascension testing of Unit 1 at CPSES.
Management oversight was considered a strength by the l
team.
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11.
Administrative / Technical Support to Operations (93806)
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The following administrative / technical support systems affecting the conduct of operations were reviewed for adequacy:
Temporary Modifications (STA-602);
Changes to Procedures (STA-205); and U
Drawing Control and System Status (PAS 2.13-01,.-02; ODA-410).
The team'found that the procedures governing these activities met applicable requirements'and were of sufficient detail to
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effectively control such activities.
Generally,-the
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implementation effectiveness of the above listed programs was
good.
Relatively few temporary modifications (about_20)1wcre in effect at the time of the-inspection.
Of approximately 50 procedures reviewed by the team (system operating, abnormal operating, initial,startup testing,' operations work instructions, etc.), all were found to have been changed-in accordance with the s
governing procedure.
The teamLalso sampled 66 vital station drawings (VSD).at two VSD i
stations (Technical Support Center and Control Room). lAll of these-drawings. reflected 1the most: current ~ revision.
TheLteam
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'also reviewed these same drawings-which are also governed by Operations: Department' Administrative-Procedure ODA-410,-
Revision 6,?" System Status Control."
The-distribution control
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for these drawings is not performed by the Document Control'
Center.
ODA-410 does, however, require that the drawings-be-reviewed weekly in order to ensure that the drawings reflect.the most current as-built system configuration as well as-system-
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status.
The team found that four drawings had been updated'to-the most current revision while the team.was onsite even though
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the most current revisions of the' subject drawings had been.
effective for several weeks, and in one case-for several months.
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The team considered these instances in-which.the. drawings were
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not updated in a timely manner to be isolated. examples, and found-that the weekly audit of.the system. status drawings was generally effective in ensuring that actual plant-status is reflected by.
-the drawings.
The-team reviewed two of eight licensee Technical Specification (TS) interprutations, which were issued to' clarify the application of certain TS to plant conditions:.
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001 - TS 4.0.4
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005 - TS 3.3.3.4
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These interpretations were discussed with the licensee, NRR representatives, and the NRC site staff.
It' appeared on the
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surface that these two interpretations may.have been-nonconservative.
The interpretation for'TS 4.0.4: allowed time in addition to the TS limiting condition for operationc(LCO) time to perform required surveillance when plant conditions allow the-
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surveillances to be performed.
The interpretation for TS 3.3.3.4
defined the term " operating" very narrowly and~ allows hydrogen and oxygen analyzers to be inoperable during certain waste gas
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compressor operations.
The NRC site staff will. review the
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existing TS interpretations with the licensee to assure that'they
are appropriate and routine resident inspections will monitor licensee use of TS interpretations.
No violations or deviations were identified in this area.
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12. - Review of Operability Assessments for Identified Deficiencies
(93806)
g This area offinspection was conducted to review the-licensee's
. process for evaluating-system operability when a; deficiency or adverse condition is identified.
At CPSES, this is controlled by
Procedure _STA-422, " Processing of Operations Notification and
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Evaluation _(ONE) Forms."
This. procedure provides for-the administration, screening for operability-and reportability, e
' identification of corrective action type resolution, and closure j
of potential = adverse conditions documented on.ONE Forms.
Upon receipt of.an initiated ONE Form, the shift supervisor is responsible for performing a prompt: review for operability and a
reportability.
If the condition reported on the ONE Form affects the ability of-the plant to operate within the constraints of1the
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Technical Specification, the Shift Supervisor shall take i
appropriate corrective actions.. If the condition reported on the'
ONE Form, results in a conclusion that' equipment-operability is indeterminate, the Shift Supervisor will enter that information in the comments block of the ONE Form along with a description =of any immediate corrective action.taken.
The Duty Manager is then notified to coordinate an engineer
Ovaluation to determine would be performed t
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Engineering evaluat
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support to the Shift
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l Supervisor for operability determ12x.
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The team attended ONE Form meetings conducted each morning by the licensee.
The ONE Form meetings were chaired by the Duty Manager and included representatives from various~ departments.
During these meetings, ONE Forms initiated during the previous 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period were reviewed for reportability and assignment of corrective action.
Technical evaluations for previous ONE Forms were also assessed for adequacy.
From a review of the ONE Form.
procedure, the team could not fully determine the_ attendance, authority and responsibility requirements for the ONE Form meeting participants.
This was discussed with licensee management during the inspection and again during the exit interview.
The licensee stated the intent to review this matter and evaluate changes to the procedure for the ONE Form' committee as appropriate.
The team reviewed-initial operability assessments made by the licensee for the ONE Forms listed below:
FX 90-1239 Train A Auxiliary Feedwater/ Safety Injection i
Actuation.
FX 90-1270 High Limit Voltage Left at 9.860.
FX 90-1295 Pressurizer Safety Valve Setpoint.
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FX 90-1320 Orifice Plate not Evaluated for Maximum Differential Pressure.
L FX 90-1327-Deficiencies Found During Closeout Evaluation of OQUAT-170.
FX 90-1330 Control Room Air-conditioning Unit Valve.
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FX 90-1332
. Test Exception Generated During ISU-021A.
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FX 90-1349 Inadequate Test Equipment.
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FX 90-1371 Pipe Plug and. Pilot DrillLFell into Line-During-Work Activity.
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FX-90-1374
' Monthly. Diesel Run Documentation Not Completed Properly.
q FX-90-1383-Plant-operated in a Condition That May Have Been outside Licensing Basis.
FX 90-1399 Improper Installation of Pipe Caps.
FX 90-1400 Drawing Error' Identified.
FX 90-1402 Inadequate Technical Specification Implementing
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Procedure.-
The team concluded that-the licensee's. process for operability determinations provides for the.necessary support to the shift supervisor and no problems were noted with the initial operability determinations reviewed.
13.
Open Items Open items are matters which have been discussed with the licensee,'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 paragraphs 4.a. and 5.b.
14.
Exit Meeting-(30703)
The team met with the licensee personnel denoted in paragraph l_
on April 12, 1990.
No written material was provided to the licensee by the inspectors during this reporting period.
The licensee did not identify as proprietary any of the materials i
provided to or reviewed by the inspectors during this inspection.
At this meeting, the team summarized the1 scope of the inspection and the findings.
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