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| issue date = 10/11/2017
| issue date = 10/11/2017
| title = Evaluations of Changes, Test, and Experiments Baseline Inspection Report 05000346/2017010
| title = Evaluations of Changes, Test, and Experiments Baseline Inspection Report 05000346/2017010
| author name = Daley R C
| author name = Daley R
| author affiliation = NRC/RGN-III/DRS/EB3
| author affiliation = NRC/RGN-III/DRS/EB3
| addressee name = Bezilla M
| addressee name = Bezilla M
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE RD. SUITE 210 LISLE, IL 60532-4352 October 11, 2017 Mr. Mark Bezilla Site Vice President FirstEnergy Nuclear Operating Co.
{{#Wiki_filter:UNITED STATES ber 11, 2017


Davis-Besse Nuclear Power Station 5501 N. State Rte. 2, Mail Stop A-DB-3080 Oak Harbor, OH 43449-9760
==SUBJECT:==
 
DAVIS-BESSE NUCLEAR POWER STATION EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000346/2017010
SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000346/2017010


==Dear Mr. Bezilla:==
==Dear Mr. Bezilla:==
On September 22, 2017 the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments inspection at your Davis-Besse Nuclear Power Station. The enclosed inspection report documents the inspection results which were discussed on September 22, 2017, with you and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.
On September 22, 2017 the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments inspection at your Davis-Besse Nuclear Power Station. The enclosed inspection report documents the inspection results which were discussed on September 22, 2017, with you and other members of your staff.


The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The NRC inspectors did not identify any findings or violations of more than minor significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.


Sincerely,/RA/
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
Robert C. Daley, Chief Engineering Branch 3


Division of Reactor Safety Docket No. 50-346 License No. NPF-3
The NRC inspectors did not identify any findings or violations of more than minor significance.


===Enclosure:===
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
IR 05000346/2017010 cc: Distribution via LISTSERV


Letter to Mark Bezilla from Robert C. Daley dated October 11, 2017
Sincerely,
/RA/
Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-346 License No. NPF-3


SUBJECT: DAVIS-BESSE NUCLEAR POWER STATION EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000346/2017010 DISTRIBUTION: Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMDavisBesse Resource RidsNrrDirsIrib Resource Cynthia Pederson
===Enclosure:===
IR 05000346/2017010


James Trapp
REGION III==
Docket No: 50-346 License No: NPF-3 Report No: 05000346/2017010 Licensee: FirstEnergy Nuclear Operating Company Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: September 18-22, 2017 Inspectors: J. Bozga, Senior Reactor Inspector (Lead)
J. Benjamin, Senior Reactor Inspector J. Gilliam, Reactor Inspector N. Khan, Electrical Engineer (Observer)
Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure


Richard Skokowski Allan Barker Carole Ariano
=SUMMARY=
 
Inspection Report 05000346/2017010; 09/18/2017-09/22/2017; Davis-Besse Nuclear Power
Linda Linn
 
DRPIII DRSIII ROPreports.Resource@nrc.gov
 
ADAMS Accession Number: ML17286B124 OFFICE RIII RIII NAME JBozga:cl RDaley DATE 10/5 /17 10/11/17 OFFICIAL RECORD COPY
 
Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50-346 License No: NPF-3 Report No: 05000346/2017010 Licensee: FirstEnergy Nuclear Operating Company Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: September 18-22, 2017 Inspectors: J. Bozga, Senior Reactor Inspector (Lead) J. Benjamin, Senior Reactor Inspector J. Gilliam, Reactor Inspector
 
N. Khan, Electrical Engineer (Observer) Approved by: Robert C. Daley, Chief Engineering Branch 3
 
Division of Reactor Safety


2
Station; Evaluations of Changes, Tests, and Experiments.


=SUMMARY=
This report covers a 1-week announced evaluations of changes, tests, and experiments baseline inspection. The inspection was conducted by Region III based engineering inspectors.
Inspection Report 05000346/2017010; 09/18/2017-09/22/2017; Davis-Besse Nuclear Power Station; Evaluations of Changes, Tests, and Experiments. This report covers a 1-week announced evaluations of changes, tests, and experiments baseline inspection. The inspection was conducted by Region III based engineering inspectors.


The NRC's program for overseeing the safe operati on of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 6, dated July 2016.
The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 201


===NRC-Identified===
===NRC-Identified===
and Self-Revealed Findings No findings were identified.
and Self-Revealed Findings No findings were identified.


===  
===Licensee-Identified Violations===


Licensee-Identified Violations===
No violations were identified.
No violations were identified.
3


=REPORT DETAILS=
=REPORT DETAILS=
Line 78: Line 66:
==REACTOR SAFETY==
==REACTOR SAFETY==


===Cornerstone:===
===Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity===
Initiating Events, Mitigating Systems, and Barrier Integrity
{{a|1R17}}
{{a|1R17}}
==1R17 Evaluations of Changes, Tests, and Experiments==
==1R17 Evaluations of Changes, Tests, and Experiments==
Line 90: Line 77:
* the safety issue requiring the change, tests or experiment was resolved;
* the safety issue requiring the change, tests or experiment was resolved;
* the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and
* the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and
* the design and licensing basis documentation was updated to reflect the change. The inspectors used, in part, Nuclear Energy Institute 96-07, "Guidelines for 10 CFR 50.59 Implementation," Revision 1, to determine acceptability of the completed evaluations, and screenings. The Nuclear Energy Institute document was endorsed by the U.S. Nuclear Regulatory Commission in Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments," dated November 2000. The inspectors also consulted Part 9900 of the U.S. Nuclear Regulatory Commission Inspection Manual, "10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments." This inspection constituted 30 samples of evaluations, screenings, and/or applicability determinations as defined in Inspection Procedure 71111.17-05.
* the design and licensing basis documentation was updated to reflect the change.
 
The inspectors used, in part, Nuclear Energy Institute 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The Nuclear Energy Institute document was endorsed by the U.S. Nuclear Regulatory Commission in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the U.S. Nuclear Regulatory Commission Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.
 
This inspection constituted 30 samples of evaluations, screenings, and/or applicability determinations as defined in Inspection Procedure 71111.17-05.


====b. Findings====
====b. Findings====
Line 106: Line 97:
====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==


===.1 Exit Meeting Summary===
===.1 Exit Meeting Summary===
On September 22, 2017, the inspectors presented the inspection results to Mr. M. Bezilla, Site Vice President, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff. ATTACHMENT:
 
On September 22, 2017, the inspectors presented the inspection results to Mr. M. Bezilla, Site Vice President, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.
 
ATTACHMENT:  


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 116: Line 110:
==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==


Licensee  
Licensee
: [[contact::M. Bezilla]], Site Vice President  
: [[contact::M. Bezilla]], Site Vice President
: [[contact::G. Wolf]], Regulatory Compliance Supervisor  
: [[contact::G. Wolf]], Regulatory Compliance Supervisor
: [[contact::D. Blakely]], Engineering Analysis Supervisor  
: [[contact::D. Blakely]], Engineering Analysis Supervisor
: [[contact::J. Sturdavant]], Regulatory Compliance Specialist  
: [[contact::J. Sturdavant]], Regulatory Compliance Specialist
 
==LIST OF ITEMS==
==LIST OF ITEMS==
OPENED, CLOSED AND DISCUSSED Opened, Closed and  
 
===OPENED, CLOSED AND DISCUSSED===
 
Opened, Closed and  
===Discussed===
===Discussed===


None LIST OF ACRONYMS USED CFR Code of Federal Regulations  
None LIST OF ACRONYMS USED CFR             Code of Federal Regulations


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a list of documents reviewed during the inspection.
 
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.
: CFR 50.59 EVALUATIONS
: Number Description or Title Date 13-04680 Containment Vessel Analysis 01/24/2014
: 13-04372 Containment Vessel Analysis 01/24/2014
: 13-04729 36 Inch Main Steam Line Break Rm 601/602 01/24/2014
: 14-03427
: ECP 12-0270, Replacement of the Control Rod Drive (CRD)
system with a Digital Contro
l Rod Drive Control System (DCRDCS), and
: ECP 15-0370, AQ Requirements for Digital
: CRD Replacement 
: 2/11/2016
: CFR 50.59 SCREENINGS
: Number Description or Title Date 13-04729 36 Inch Main Steam Line Break Rooms 601/602 01/15/2014 14-03200 Battery Room Heaters 05/27/2015
: 14-04107 Spent Fuel Pool Cooling Malfunctions 12/08/2014
: 14-04284 Technical Specification for Station Blackout Diesel Generator System 12/19/2014 15-00312 Decay Heat Pump Recirculation Line Support Changes 05/18/2015
: 15-00409 Technical Specification for Self-Cleaning Service Water Strainer 02/16/2015
: 15-00664 Standing Order:
: Restrictions on Use of an EDG to Supply Nonessential 4160 V Busses
: 2/27/2015 15-00807 Pipe Stress Analysis for Decay Heat Coolers and Attached DH/LPI and CCW Piping and Pipe Stress Analysis for Decay Heat Flush Piping for 10"
: GCB-1
: 05/19/2015 15-00915 Emergency Feedwater System 09/16/2016 15-01313 Modify Hanger 5-GBD-2-H16 04/23/2015
: 15-01708 Pipe Stress Analysis Sump Pump Piping 09/24/2015
: 15-03646 Pipe Stress Analysis 01/06/2016 16-01379 Install Freeze Seal on Demineralized Water line 4"
: HCD-4 to Facilitate
: WO 200610327
: 04/25/2016 16-01483 Serious Station Fire Procedure 05/04/2016 16-02041 Install Temporary Modification to Defeat EDGs Crank Case Pressure Trip
: 06/21/2016 16-02042 Compensatory Action - Preclude EDG Crank Case Pressure Trip during Tornado Watch
: 06/16/2016 16-00616 Backing Plates for Unused Instrument Locations on Cabinet
: C5718 03/07/2016 16-01189 Pipe Stress Analysis Report 04/12/2016 16-02566 Permanently Disable EDGs Crank Case Pressure Trip 08/23/2016 16-02882 Pressurizer Operating Procedure 09/19/2016 16-02967 Spent Fuel Storage System Incorporation 12/28/2016 
: 10
: CFR 50.59 SCREENINGS
: Number Description or Title Date 17-01485 Modify Integrated Control System (ICS0 Steam Generator Operate Range High Level Limit from 90% to 96%
: 05/11/2017 17-01851 Security Event or Threats 06/12/2017 17-02024 Adjusted Minimum Level for Emergency Diesel Generator Day Tanks 06/22/2017 17-02210 Reactor Vessel Head Drop Analysis 07/19/2017 17-02263 Station Blackout Diesel Generator Operating Procedure 07/24/2017
: CALCULATIONS
: Number Description or Title Revision 51 Pipe Stress Analysis Report 20 51 Pipe Stress Analysis Report 20, Addendum A01
: C-CSS-
: 049.02-066 Pipe Stress Analysis for Decay Heat Flush Piping for 10"
: GCB-1
: 84C Pipe Stress Analysis 11
: C-CSS-049.02-064 Pipe Stress Analysis for Decay Heat Pump P42-2 Recirculation Piping 0 C-CSS-049.02-065 Pipe Stress Analysis for Decay Heat Pump P42-1 Recirculation Piping 0 C-NSA-060.05-010 Containment Vessel Analysis 7
: C-NSA-060.05-010 Containment Vessel Analysis 8
: C-CSS-020.12-004 Pipe Stress Analysis Sump Pump Piping 1
: C-CSS-020.12-007 Pipe Stress Analysis Sump Pump Piping 0
: C-CSS-062.01-025 Reactor Vessel Head Drop Analysis 2, Addendum A01
: C-CSS-
: 099.16-064 Backing Plates for Unused Instruments on Cabinets C5718 &
: C5720 2, Addendum A02
: CORRECTIVE ACTION PROGRAM DOCUMENTS INITIATED DURING INSPECTION
: Number Description or Title Date 2017-09668 2017
: NRC 10CR50.59: Design Evaluation for Pressurizer Spray Piping to Pressurizer Nozzle and Cold Leg Nozzle Does Not Use Latest Piping Loads"
: 09/20/2017
: CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
: Number Description or Title Date 2013-06458 Low Margin for the Battery Room Minimum Temperature 04/24/2013 2014-00239 NRC Identified Low Temperatures in Battery Room B 01/07/2014 2014-16898 2015 CDBI SA: Service Water Strainer Maximum Flowrate 11/11/2014 2016-03257 AREVA Customer Service Bulletin 16-01 03/09/2016
: 2017-02971 OTSG Monitoring - Cycle 20 Level Trending 03/16/2017
: DRAWINGS Number Description or Title Revision
: OS-045 Operational Schematic Primary and Demineralized Water System 49
: OTHER DOCUMENTS
: Number Description or Title Date B&W
: 58007800 Casualty Analysis for Toledo Edison Control Rod Drive Electrical System
: 06/1973 M-237Q Digital Control Rod Drive Control System Performance Test
: RAD 14-04107 Spent Fuel Pool Cooling Malfunctions 12/08/2014
: RAD 14-04284 Technical Specification for Station Blackout Diesel Generator System
: 2/19/2014
: RAD 15-00664 Standing Order:
: Restrictions on Use of an EDG to Supply Nonessential 4160 V Busses
: 2/27/2015
: RAD 15-00915 Emergency Feedwater System 09/13/2016
: RAD 16-01483 Serious Station Fire Procedure 05/04/2016
: RAD 16-02041 Install Temporary Modification to Defeat EDGs Crank Case Pressure Trip
: 06/21/2016
: RAD 16-02042 Compensatory Action to Remove EDGs Crank Case Pressure Trip during Tornado Watch
: 06/16/2016
: RAD 16-02566 Permanently Disable EDGs Crank Case Pressure Trip 08/23/2016
: RAD 16-02882 Pressurizer Operating Procedure 09/19/2016
: RAD 16-02967 Spent Fuel Storage System Incorporation 12/28/2016
: RAD 17-01851 Security Events or Threats 06/12/2017
: RAD 17-02024 Adjusted Minimum Level for Emergency Diesel Generator Day Tanks
: 06/22/2017
: RAD 17-02263 Station Blackout Diesel Generator Operating Procedure 07/24/2017
: RAD 13-04729 36 Inch Main Steam Line Break Rooms 601/602 01/15/2014
: PROCEDURES
: Number Description or Title Revision
: NNOBP-LP-4003A FENOC 10
: CFR 50.59 User Guidelines 8
: DB-OP-02012 STM GEN/SFRCS Alarm Panel 12 Annunciator 18
}}
}}

Latest revision as of 10:01, 19 December 2019

Evaluations of Changes, Test, and Experiments Baseline Inspection Report 05000346/2017010
ML17286B124
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 10/11/2017
From: Robert Daley
Engineering Branch 3
To: Bezilla M
FirstEnergy Nuclear Operating Co
References
IR 2017010
Download: ML17286B124 (13)


Text

UNITED STATES ber 11, 2017

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000346/2017010

Dear Mr. Bezilla:

On September 22, 2017 the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments inspection at your Davis-Besse Nuclear Power Station. The enclosed inspection report documents the inspection results which were discussed on September 22, 2017, with you and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The NRC inspectors did not identify any findings or violations of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket No. 50-346 License No. NPF-3

Enclosure:

IR 05000346/2017010

REGION III==

Docket No: 50-346 License No: NPF-3 Report No: 05000346/2017010 Licensee: FirstEnergy Nuclear Operating Company Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: September 18-22, 2017 Inspectors: J. Bozga, Senior Reactor Inspector (Lead)

J. Benjamin, Senior Reactor Inspector J. Gilliam, Reactor Inspector N. Khan, Electrical Engineer (Observer)

Approved by: Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000346/2017010; 09/18/2017-09/22/2017; Davis-Besse Nuclear Power

Station; Evaluations of Changes, Tests, and Experiments.

This report covers a 1-week announced evaluations of changes, tests, and experiments baseline inspection. The inspection was conducted by Region III based engineering inspectors.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 201

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, and Experiments

.1 Evaluation of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed 4 evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59, to determine if the evaluations were adequate and that prior NRC approval was obtained as appropriate. The inspectors also reviewed screenings and applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

  • the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;
  • the safety issue requiring the change, tests or experiment was resolved;
  • the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and
  • the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The Nuclear Energy Institute document was endorsed by the U.S. Nuclear Regulatory Commission in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the U.S. Nuclear Regulatory Commission Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection constituted 30 samples of evaluations, screenings, and/or applicability determinations as defined in Inspection Procedure 71111.17-05.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed several corrective action process documents that identified or were related to 10 CFR 50.59 evaluations. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On September 22, 2017, the inspectors presented the inspection results to Mr. M. Bezilla, Site Vice President, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Bezilla, Site Vice President
G. Wolf, Regulatory Compliance Supervisor
D. Blakely, Engineering Analysis Supervisor
J. Sturdavant, Regulatory Compliance Specialist

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

Opened, Closed and

Discussed

None LIST OF ACRONYMS USED CFR Code of Federal Regulations

LIST OF DOCUMENTS REVIEWED