IR 05000282/2005009

IR 05000282-05-009(DRP), IR 05000306-05-009(DRP); 07/18/2005-08/05/2005; Prairie Island Nuclear Generating Plant, Units 1 & 2; Identification and Resolution of Problems

ML052500292
Person / Time
Site:	Prairie Island
Issue date:	09/06/2005
From:	Richard Skokowski NRC/RGN-III/DRP/RPB3
To:	Thomas J. Palmisano Nuclear Management Co
References
FOIA/PA-2010-0209 IR-05-009
Download: ML052500292 (29)

Text

ber 6, 2005

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000282/2005009(DRP); 05000306/2005009(DRP)

Dear Mr. Palmisano:

On August 5, 2005, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution team inspection at your Prairie Island Nuclear Generating Plant.

The enclosed report documents the inspection findings, which were discussed with you and other members of your staff on August 5, 2005.

This inspection focused on the effectiveness of your program to identify and resolve problems.

The inspection examined activities conducted under your license as they relate to safety and to 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.

On the basis of the samples selected for review, the inspectors concluded that, in general, problems were being properly identified, evaluated, and corrected. We noted that some weaknesses continued to exist, particularly with respect to the quantity, quality, and consistency of trending data entered into the program. This lack of data made effective early identification of trends difficult for your staff. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

R. Skokowski, Chief Branch 3 Division of Reactor Projects Docket Nos. 50-282; 50-306 License Nos. DPR-42; DPR-60

Enclosure:

Inspection Report 05000282/2005009(DRP); 05000306/2005009(DRP)

w/Attachment: Supplemental Information

REGION III==

Docket No: 50-282; 50-306 License No: DPR-42; DPR-60 Report No: 05000282/2005009(DRP); 05000306/2005009(DRP)

Licensee: Nuclear Management Company, LLC Facility: Prairie Island Nuclear Generating Plant Location: 1717 Wakonade Drive East Welch, MN 55089 Dates: July 18 through August 5, 2005 Inspectors: S. Ray, Senior Resident Inspector (Acting), Monticello D. Karjala, Resident Inspector, Prairie Island T. Bilik, Reactor Engineer Approved by: R. Skokowski, Chief Branch 3 Division of Reactor Projects

SUMMARY OF FINDINGS

IR 05000282/2005009(DRP), 05000306/2005009(DRP); 07/18/2005-08/05/2005; Prairie Island

Nuclear Generating Plant, Units 1 & 2; Identification and Resolution of Problems.

This report covers an announced baseline inspection on the Identification and Resolution of Problems. The inspection was conducted by a Senior Resident Inspector, the Resident Inspector, and a Region III Reactor Engineer. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

Identification and Resolution of Problems The team concluded that the licensee adequately identified, evaluated, and resolved problems within the requirements of the corrective action program (CAP). There were some problems with program implementation, but these problems had been identified by the licensee and actions were underway to resolve them. The team noted a number of observations, including:

• The initiation rate of issues entered into the CAP system has been relatively steady for the last two years. About half of the issues being entered were low priority items and were closed rapidly without further evaluation to actions taken, trending, or work orders being issued. This indicated that most issues, even minor ones, were being entered in the CAP.

• The quality of apparent cause evaluations and root cause evaluations had improved in the last two years.

• Trending of CAP data remained weak with essentially no improvement in the last two years despite the issue being identified by several organizations. Most of the electronic fields on the CAP documents useful for trending such as system, equipment number, process code, failure mode codes, and other predefined categories were not used in approximately 65 percent of the CAP items. The inspectors noted that most of the trends identified by the licensee in the last year had only been identified within the last two weeks through recent emphasis placed on department roll up meetings. There was little evidence that any trends had been identified by electronic sorting of CAP items using the coded fields.

• Corrective actions for several issues focused more on detecting inadequacies rather than preventing them. For example, the corrective actions relied on activities like management reviews, operator rounds and score sheets to catch the problems after they occurred, rather than preventing them from occurring in the first place.

REPORT DETAILS

4OA2 Identification and Resolution of Problems

.1 Effectiveness of Problem Identification

a. Inspection Scope

The inspectors reviewed items selected from the seven cornerstones of safety to determine whether the licensee was effective in identifying problems and entering them into its corrective action program (CAP). The inspectors reviewed selected plant procedures, interviewed plant personnel, attended various station meetings, and reviewed various assessments to determine if problems were being identified at the proper threshold, characterized appropriately, and being entered into the CAP.

The inspectors primarily reviewed documents associated with the CAP covering the period from September 2003 through July 2005, the period since the last Problem Identification and Resolution (PI&R) Inspection. The inspectors selected a number of CAP documents and other records from that period for a more in-depth review of selected issues. These issues included licensee-identified findings, NRC-identified findings, and issues from industry operating experience.

To assess trending, maintenance rule implementation, and to identify items that the licensee might have failed to enter into the CAP, the inspectors conducted walkdowns of selected risk-significant equipment and plant areas. This consisted of the cooling water system and areas where loose material might create tornado missile hazards or blockage of drain paths for internal flooding.

To assess the licensees ability to perform critical self-assessments, the inspectors reviewed selected Nuclear Oversight (NOS) reports and department self-assessments.

The inspectors also attended a department roll up meeting (DRUM) and the site DRUM integration meeting.

Specific documents reviewed that played a significant role in the inspectors assessments are listed in the Attachment.

b. Assessment No findings of significance were identified. The inspectors concluded that the licensee was generally effective in identifying problems and they appropriately characterized them. The significance threshold for entering issues into the CAP was appropriate and in accordance with the licensees CAP procedures. The program was relatively mature and stable with improvements noted in reducing the backlog of items to be closed.

Weaknesses in entering data into the CAP to enable electronic trending remained since the previous PI&R Inspection with essentially no improvement. However, licensee NOS and department self-assessments had already identified this and other minor weaknesses. Specific observations in this area are discussed below.

(1) Identification Threshold The rate of CAP initiation has remained steady since the last biennial inspection.

Approximately 400 CAPs per month were initiated with higher rates during outage periods. Approximately half of the CAPs were closed rapidly to trending, actions taken or work orders issued. This indicated a relatively low threshold was used in initiating CAPs and that the threshold has not changed significantly. Improvements have been accomplished since the last PI&R Inspection in the areas of backlogs of open CAPs, use of due date extensions for actions, and open CAP actions. Dramatic reductions in the backlog of open CAPs and open CAP actions were accomplished in the fall of 2003.

Specifically the CAP backlog was reduced from around 4000 to about 700 CAPs and the action backlog was reduced from about 1700 to 800 actions. Since that time, an additional reduction of about 10 percent has been accomplished in each of those areas.

(2) Trending Program The inspectors performed an examination of the licensees trending activities as a follow-on to an observation made in the previous PI&R Inspection. With respect to the quality of the trending program, the inspectors noted several observations as described below.

A number of the elements of the trending program remained weak or poorly implemented. The lack of systematic trending and analysis of CAP data was still a recognized problem. The NOS and department self-assessments repeatedly identified that the implementation of the trending program was less than adequate. In particular, there was a need to enter trend code data accurately and completely into the CAP system to be useful in order to identify existing or emergent adverse trends. The DRUM program, which was established in 2004 to improve department performance trending, initially met with limited success. There was recently a renewed effort by the licensee to focus on trending through DRUMs. Workshops on the DRUM process, DRUMs, and a DRUM oversight meeting were held in July and August of 2005, with an emphasis on completing the CAP data. While a number of trends were identified at the DRUMs, there was little evidence that any trends had been identified by electronic sorting of CAPs using coded fields. The effectiveness of these efforts through a review of the CAPs most recently written indicated that approximately two-thirds of the CAPs written continued to lack complete code information. While no violations of regulatory requirements were identified this was considered a weakness with the CAP.

(3) Nuclear Oversight Reports from NOS identified a number of issues with regard to a lack of effectiveness of the CAP. In particular, NOS noted that there had been a lack of improvement with the program. This included timeliness and effectiveness of corrective actions, approval of apparent cause evaluations (ACEs) by the corrective action review board (CARB),procedural adherence, and effectiveness of closure actions. In addition, NOS identified problems with low CARB meeting member attendance and preparedness. Finally, NOS identified problems with 10 CFR 50 Appendix B corrective actions being tracked outside the formal Appendix B programs as non-CAPs.

The inspectors noted that some improvements had been made. The backlog of open CAPs has been reduced, and actions had been initiated to prevent use of non-CAP programs for Appendix B corrective actions. However, the inspectors noted that the actions to prevent Appendix B corrective actions from being tracked outside of the CAP depended on reviews of items by management and supervisors in the daily CAP screening meeting to detect mistakes, rather than preventing improper tracking.

Regarding the CARB meeting attendance, the renewed focus on the DRUM program had improved the attendance at the CARB meetings.

(4) Department Self-Assessments Department self-assessments identified that the trending program implementation was less than adequate. The licensee noted that the quality and consistency of trending and follow-up on adverse trends needed improvement to help resolve lower level problems before they became consequential and that opportunities were being missed to improve equipment performance through the CAP. Trend code data was not easily obtainable or in a format that permitted simple trend identification. The licensee noted that trend coding was not being completed following root cause evaluations (RCEs), ACEs, and Human Performance Clock Resets. The licensee also noted in department self-assessments, that the closeout of corrective actions was less than adequate. The assessments stated that insufficient ownership of the CAP was impeding program improvements and causing corrective actions to be ineffective. The assessments observed that CARB membership attendance at meetings was low and appeared not to be considered a high priority. In addition, the assessments noted that some CAP initiators also desired more feedback on the disposition of CAPs, but there was no consistent feedback on CAPs that were closed to trend. The inspectors concluded that licensee department self-assessments had been effective in identifying most of the weaknesses in the CAP.

.2 Prioritization and Evaluation of Issues

a. Inspection Scope

The inspectors reviewed CAP documents to verify that issues were appropriately characterized and clearly described, attended CAP screening meetings to observe the assignment of CAP priorities and assignments, interviewed members of the licensees staff and attended CARB meetings to observe the licensees review of ACE and RCE reports.

The inspectors reviewed a sample of issues identified through the licensee review of operational events (OE) at other facilities and reviews of NRC Information Notices to verify that the licensee had evaluated the issues for applicability, entered those that were applicable into the CAP, and adequately evaluated and corrected the issues.

The inspectors conducted an independent review of a sample of recently completed ACEs and RCEs to assess the quality of the reviews, determination of the causes of issues, assessment of the extent of condition, and review of common cause possibilities.

The inspectors reviewed a sampling of CAP documents that were closed out to other documents and programs to verify that the original issue was carried through to the new documents with the proper priority. This included CAPs either closed to other CAPs, the work control process, engineering work requests, actions taken or trending.

Specific documents reviewed that played a significant role in the inspectors assessments are listed in the Attachment.

b.

Assessment No findings of significance were identified. The inspectors concluded that the licensee properly evaluated issues identified through OE, had made improvements in the quality of RCEs and ACEs, generally preserved the integrity of the issues in CAPs closed to other documents, and held effective screening and review meetings.

During the interviews, one concern expressed by some employees was that it was hard to apply the proper effort to significant issues of high priority when the due dates for actions of lower significance came first. A related concern was that there was a perceived pressure to take some token corrective action to close out even minor issues not important to safety or not related to quality. These issues were discussed with the stations management.

Additional observations in this area are discussed below.

(1) Issues Identified through OE The inspectors reviewed OE023894 which was initiated to address piston lip cracking in an emergency diesel generator at Calvert Cliffs. The Calvert Cliffs diesels were the same make as the D5 and D6 diesels at Prairie Island. The inspectors verified that the licensee implemented surveillance procedure changes to reduce the stresses on the pistons when reducing load on the diesel engines.

The inspectors reviewed OE028002 which was initiated to address NRC Information Notice 2003-15, Importance of Followup Activities in Resolving Maintenance Issues.

The inspectors verified that motor operated valve maintenance procedures were revised to address the motor pinion concerns described in the Information Notice.

(2) Quality of ACEs and RCEs The inspectors reviewed a number of ACEs and RCEs for quality. This had been an area of weakness in the previous PI&R Inspection. The inspectors concluded that the quality of the evaluations had improved. However, much of the improvement could be credited to supervisor and management reviews, CARB reviews, and the use of scorecards to grade the products. Several ACEs and RCEs were found by the licensee to be inadequate on first draft and were sent back to the writers for revision. Again, corrective action for this weakness focused more on detecting inadequate evaluations rather than preventing them.

The inspectors identified one ACE with a corrective action to prevent recurrence discussed in the text of the evaluation that had not been translated into a formal corrective action document. However, a discussion with the department supervisor indicted that the corrective action had been adequately evaluated.

Causes identified in most ACEs and RCEs were not coded back into the original CAPs to help with trend identification.

(3) CAPs Closed to Other Documents The inspectors reviewed numerous CAPs closed to other documents such as other CAPs, the work control process, and engineering work orders. The inspectors also reviewed CAPs closed to actions taken or trending.

The inspectors concluded that the original concern in CAPs was preserved in the documents the CAPs were closed to, and that the new documents were generally appropriately tracked. The licensee had identified a problem with some CAPs being inappropriately closed to non-CAP documents outside of the Appendix B system. The inspectors interviewed licensee CAP personnel regarding the resolution of this issue, which included the implementation of a new CAP software program, that may address the concern.

About half of the CAPs were of relatively low significance and priority and were closed rapidly to either actions taken or trending. The inspectors noted that about 65 percent of the CAPs closed to trending had no electronic trending codes assigned, so that there was no effective way to electronically search for trends. While no violations of regulatory requirements were identified, the lack of rigor in assigning trending codes was considered a weakness with the CAP.

(4) Effectiveness of CAP Screening Meetings and the CARB The inspectors observed two CAP screening meetings and concluded that CAPs were generally assigned an appropriate significance level and priority as specified by the licensees CAP procedures.

The inspectors observed two CARB meetings and reviewed CAPs associated with CARB issues. The CAPs were initiated to document meeting attendance and scheduling weaknesses. These have resulted in a backlog of evaluations to be reviewed. The inspectors reviewed the licensees recovery plan and found it acceptable.

The inspectors also noted that some evaluations were rejected because the evaluators did not understand the expectations for evaluation completion and documentation. In general, the evaluations that were approved by the CARB were of acceptable quality.

.3 Effectiveness of Corrective Actions

a. Inspection Scope

The inspectors selected sample issues documented in CAPs, NRC inspection reports (IRs), licensee self-assessments, NOS assessments, and other sources to evaluate the effectiveness and timeliness of corrective actions. Items selected from NRC inspection reports included NRC-identified findings and violations, self-revealing and licensee-identified findings and violations, weaknesses identified in the last PI&R Inspection, and a small sample of minor issues. For selected issues, the inspectors reviewed records going back for about five years instead of back to the last inspection.

Specific documents reviewed that played a significant role in the inspectors assessments are listed in the Attachment.

b.

Assessment No findings of significance were identified. In most cases, licensee corrective actions were adequate and effective. Some examples were identified where corrective actions were focused on detection of problems when they occurred, rather than preventing them from occurring. The licensee had made essentially no progress in improving the use of trend codes and other electronic sorting date entries in CAP documents. Specific observations in this area are discussed below.

(1) Issues From Last PI&R Inspection The inspectors reviewed licensee corrective actions for issues and findings identified in the previous PI&R Inspection, primarily focusing on the following:

• NCV [Non-Cited Violation] 05000282/2003007-01; 05000306/2003007-01; Inadequate Corrective Action to Prevent Recurrence for the Control of Material That Could Potentially Block Critical Drain Paths;

• Inconsistent use of Trend Coding;

• Weaknesses in ACEs; and

• Corrective Action Not Being Closed in Accordance With the Licensees Process.

For the NCV, the inspectors concluded that corrective actions were generally adequate to find and rapidly remove material that could block critical drainage paths. However, the licensee corrective actions were primarily focused on increased operator inspections to discover problems in a timely manner rather than preventing the problems from occurring.

The inspectors concluded that weaknesses in the trending program had remained essentially unchanged. The coding of CAP data remained inconsistent and incomplete among the station departments even though the stations coding and trending guidance manual was detailed. While there was an increased focus on addressing this issue via the DRUM program, a review of the most recently generated CAPs (following the DRUM workshops) indicated that the number of CAPs with incomplete code trending data remained at approximately 65 percent.

A review of a number of ACEs indicated that there has been improvement in the content and the extent of condition scope. ACEs and RCEs were generally well written and tended to be rigorous in determining the cause(s) of the deficiencies.

There were still a few examples of corrective actions not being closed in accordance with the licensees process. The significance of these issues were reviewed and determined not to be violations of regulatory requirements. Moreover, improvements had been accomplished since the last inspection in the areas of backlogs of open CAPs, use of due date extensions for actions, and open CAP actions.

(2) Corrective Actions for Previous NRC-Identified Findings The inspectors reviewed licensee corrective actions for several NRC-identified findings, primarily focusing on the following findings:

• FIN [Finding] 05000282/2004005-02; 05000306/2004005-02; Missile Hazards in the Switch Yard;

• NCV 05000282/2004008-01; 05000306/2004008-01; Failure to Promptly Identify and Correct Condition Adverse to Quality Associated with Multiple 121 Control Room Air Handler Failures; and

• FIN 05000282/2005004-01; 05000306/2005004-01; Failure to Identify and Remove/Secure Potential Tornado Missile Hazards.

For the second finding listed above, the inspectors concluded that licensee corrective actions were adequate. For the other two findings, the inspectors concluded that, although the corrective actions were adequate to detect and eliminate potential tornado missile hazards, the corrective actions were focused on detection of the problems through increased operator and supervisor inspections, rather than prevention.

Furthermore, a review associated with the control of potential tornado missile hazards completed by the licensee during the period of this inspection independently identified that the corrective actions taken up to that point had been ineffective in preventing recurrence. Several new corrective actions were proposed and entered into the CAP to help improve performance in this area. The inspectors concluded that the proposed corrective actions should improve prevention of the condition.

(3) Corrective Actions for Previous Licensee-Identified Findings The inspectors reviewed corrective actions for several licensee-identified findings of very low safety significance, primarily focusing on the following:

• IR 05000282/2004003; 05000306/2004003; Auxiliary Feedwater Pump Suction Pressure Switch Miscalibration; and

• IR 05000282/2004007; 05000306/2004007; Control Room Special Ventilation Radiation Monitoring Instruments Miscalibrated.

The inspectors concluded that licensees corrective actions for these issues were adequate.

(4) 5-year Review of Cooling Water Pump Shaft Bearing Supply Issue In addition to the findings discussed above, the inspectors selected one area with multiple findings for a more extensive review. The inspectors reviewed the CAP data base to evaluate the effectiveness of corrective actions during the previous five year history of the cooling water system. The NRC identified a finding in 2000 because the original design and installation of the three safety-related cooling water pumps did not have a safety-related supply of lubricating water for the bearings. The licensee installed a safety-related bearing supply as a temporary modification in late 2000 and early 2001. The safety-related supply was from the cooling water system (river water),which caused the filters to require frequent replacement due to silt.

In 2002, the licensee installed a modification that supplied well water (non safety-related) during normal use but would switch to the safety-related supply upon low well water pressure. Following the installation of the modification, 22 CAPs were initiated during the period from 2002 through 2004 due to problems with the modification, including loss of bearing flow, low flow alarms, flow switch sticking, three-way valve malfunctions, and frequent filter plugging. These CAPs resulted in four ACEs, eleven Condition Evaluations, and numerous corrective actions. Much of the corrective action depended on increased operator monitoring to detect plugging filters or flow problems. The inspectors noted that no RCE had been for this issue and there were few corrective actions to address the cause of the problem. However, on September 1, 2004, the modification was determined by the licensee to be ineffective to prevent recurrence and a request for a different modification was initiated.

The inspectors concluded that the corrective actions for the bearing water supply issues were not effective to prevent recurrence, but the licensee had identified this and had initiated action to resolve the concern. Further, the licensee implemented an action plan to comply with 10 CFR 50.65(a)(1), added the bearing water supply in the Top Ten Equipment Issues list, and added the frequent filter replacement on the Operator Work Around list. No violation of regulatory requirements occurred.

(5) Five-Year Review of Fan Coil Unit Isolation Valve Pressure Locking Issue Based on past system issues, the inspectors conducted a review of the history, going back about five years, of pressure locking and thermal binding problems on containment fan coil unit service water isolation valves. The inspectors concluded that the licensee had not been fully successful in permanently correcting this issue, and that interim corrective actions to use ice packs to prevent locking had not always been used.

However, the binding problem occurred only when attempting to return a fan coil to service following maintenance activities, and it was not considered an operational or safety concern. The licensee had initiated actions to correct the problem with permanent modifications, but had not progressed very far with the proposal at the time of the inspection. Since the issue was not risk significant, the timeliness was considered appropriate for the circumstances.

(6) Review of Licensee Actions Regarding Minor Issues The inspectors reviewed a sampling of minor NRC-identified issues brought to the licensees attention since the last PI&R Inspection to ensure that the licensee had entered the issues into its CAP, if appropriate, and that the issues were being addressed commensurate with their safety significance. No weaknesses were noted.

.4 Assessment of Safety-Conscious Work Environment

a. Inspection Scope

As part of the Identification and Resolution of Problems Inspection scope, the inspectors interviewed members of the plant staff to assess the establishment of a safety conscious work environment (SCWE) at the Prairie Island Nuclear Generating Plant. In this context, a SCWE refers to an environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation.

The interviews typically included questions similar to those listed in the Appendix, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R [Problem Identification and Resolution] Issues, to NRC Inspection Procedure 71152. During the conduct of interviews, document reviews, and observations of activities relevant to the PI&R Inspection, the inspectors looked for evidence that suggested plant employees may be reluctant to raise safety concerns.

The inspectors also reviewed a sampling of issues regarding nuclear safety that had been entered into the Employee Concerns Program (ECP) to ensure that they had been evaluated for operability concerns and entered into the CAP system with the appropriate priority and timeliness. The inspectors also reviewed the stations procedures related to the ECP and discussed the implementation of the program with the stations program coordinator. During interviews with plant personnel, their knowledge of and satisfaction with the ECP was discussed.

Specific documents reviewed that played a significant role in the inspectors assessments are listed in the Attachment.

b.

Assessment No findings of significance were identified. The inspectors concluded that, overall, a healthy SCWE existed at the Prairie Island Nuclear Generating Plant. All individuals interviewed indicated a willingness to raise safety concerns using the CAP process. All of the individuals interviewed indicated that they had previously initiated CAPs on issues. Individuals initiated CAPs related to their own and their departments activities, as well as other departments activities. The inspectors did not identify any evidence of retaliation against anyone who had raised a safety issue. Interviews with employees and reviews of CAPs indicated that issues were being identified by all department and a wide cross-section of personnel within those departments. In some cases, supervisors initiated most of the CAPs in the department because the employees were unfamiliar with the system. However, in those cases, employees were still not reluctant to bring up issues.

All employees interviewed indicated a familiarity with other options of raising safety issues, specifically the ECP and the NRC. Several of the employees stated that they had used the ECP and were generally satisfied with the results. The interviews indicated that confidentiality within the ECP was adequately maintained, and timeliness of investigations and actions were appropriate. The inspectors determined that nuclear safety issues brought up in the ECP had been appropriately entered into the CAP and evaluated for operability concerns in a timely manner.

In general, employees stated that their management was supportive of employees who raised safety concerns, and actively encouraged such activities.

4OA6 Meetings

.1 Exit Meeting

The inspectors presented the inspection results to Mr. T. Palmisano and other members of licensee management at the conclusion of the inspection on August 5, 2005. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

4OA7 Licensee-Identified Violations

None.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Palmisano, Site Vice President

L. Clewett, Plant Manager

J. Conners, System Engineer

C. Goranowski, Employee Concerns Program Manager

R. Graham, Director, Site Operations

J. Kivi, Senior Regulatory Compliance Engineer

M. Klee, Corrective Action Program Coordinator

E. Perry, NOS Supervisor

J. Wells, Performance Assessment Manager

R. Wirkkala, System Engineer

NRC

G. Wilson, Chief (acting), Projects Branch 3

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None.

Attachment

Prior to the inspection, the NRC requested a number of documents for inspector preparation.

Those documents were provided electronically by the licensee. A list of the documents requested is presented below. Specific documents from this list that played a significant role in the inspectors assessments are listed separately in the Attachment.

LIST OF INFORMATION REQUESTED 1. A copy of administrative procedure(s) for the corrective action process, trending program, quality assurance audit program, self-assessment program, corrective action effectiveness review program, and industry operating experience review program.

2. Scheduled date/time/location of all meetings associated with implementation of the corrective action program, such as CR screening meetings, corrective action review board meetings, etc.

3. A copy of nuclear quality assurance audits and self-assessments of the corrective action program completed since December 2003.

4. A chronological list of nuclear quality assurance audits and self-assessments completed for all departments since December 2003.

5. A chronological list of operability determinations initiated since July 2000.

6. A chronological list of all open apparent cause evaluations and root cause evaluations.

Include a description, date initiated, and whether there was an associated operability evaluation.

7. A chronological list of all closed root and apparent cause evaluations since July 2000.

Include a description, date initiated, date closed, and whether there was an associated operability evaluation.

8. A chronological list of condition reports initiated since December 2003 that involve inadequate or ineffective corrective actions. Include a brief description and status, whether open or closed.

9. A chronological list of in-service test or Technical Specification surveillance test failures since December 2003, with a brief description of the component/system which failed.

10. A copy of the latest corrective action program performance indicators.

11. Any performance indicators associated with backlog of corrective maintenance items.

2. A chronological list of operating experience documents received since July 2000 and any associated condition reports.

13. A chronological list of condition reports and work documents written since July 2000 associated with the Containment Fan Cooling Units and Emergency Diesel Generator Systems.

Attachment

14. A chronological list of condition reports associated with human performance errors since July 2000.

15. A chronological list of condition reports issued since July 2000 where the NRC was the identifying organization.

16. A list of condition reports associated with Non-Cited Violations from NRC Inspection Reports received since July 2000.

17. A chronological list of all Licensee Event Reports issued since July 2000, with a brief description of the affected components or systems.

18. Have available for review and use a copy of the Quality Assurance manual.

19. Have available for review and use a copy of the latest organization chart and phone listing.

Attachment