IR 05000302/2008007
| ML081500347 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/22/2008 |
| From: | Vias S Division Reactor Projects II |
| To: | Young D Progress Energy Florida |
| References | |
| IR-08-007 | |
| Download: ML081500347 (24) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
May 22, 2008
SUBJECT:
CRYSTAL RIVER UNIT 3 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 050000302/2008007
Dear Mr. Young:
On April 25, 2008, the NRC completed a team inspection at the Crystal River Nuclear Plant, Unit 3. The enclosed report documents the inspection findings which were discussed on April 25, 2008, with you and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of plant equipment and activities, and interviews with personnel.
On the basis of the samples selected for review, the inspectors concluded that in general, your corrective action program processes and procedures were effective; thresholds for identifying issues were appropriately low; and problems were properly evaluated and corrected within the problem identification and resolution program (PI&R).
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document
FPC 2 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/
Steven J. Vias, Chief Technical Support Branch Division of Reactor Projects Docket No. 50-302 License No. DPR-72
Enclosure:
Inspection Report 05000302/2008007 w/Attachments: Supplemental Information
_________________________
OFFICE RII:DRP RII:DRP RII:DRP RII:DRP RII:DRP SIGNATURE DXM /RA/ RCT /RA/ LXG /RA/ RJR /via email/ SJV /RA/
NAME DMerzke RTaylor LGarner RReyes SVias DATE 05/22/2008 05/22/2008 05/22/2008 05/22/2008 05/22/200/
E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO
FPC 3
REGION II==
Docket No: 50-302 License No: DPR-72 Report No: 05000302/2008007 Licensee: Progress Energy Florida - Florida Power Corporation Facility: Crystal River Unit 3 Location: 15760 West Power Line Street Crystal River, FL 34428-6708 Dates: April 7-11 and April 21-25, 2008 Inspectors: D. Merzke, Senior Project Inspector, Team Leader L. Garner, Senior Project Engineer R. Taylor, Senior Project Inspector R. Reyes, Resident Inspector Approved by: Steven J. Vias, Chief Technical Support Branch Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS IR 05000302/2008007, 04/07/2008-04/11/2008 and 04/21/2008-04/25/2008; Crystal River Nuclear Plant, Unit 3; Identification and Resolution of Problems.
This inspection was conducted by two senior project inspectors, a senior project engineer, and a resident inspector. 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 4, dated December 2006.
Identification and Resolution of Problems The team concluded that in general, problems were properly identified, evaluated, prioritized, and corrected within the licensees corrective action program (CAP). Evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant adverse conditions were comprehensive and detailed. Overall, corrective actions developed and implemented for issues were effective in correcting the problems. However, the team identified a few examples where corrective actions have not been entirely effective.
The team determined that thresholds for identifying issues were appropriately low. Nuclear Assessment Section audits and departmental self-assessments were effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the CAP and addressed.
Based on discussions and interviews conducted with plant employees from various departments, the inspectors did not identify any reluctance to report safety concerns. The team concluded that the employee concerns program (ECP) was functioning as intended.
A. NRC Identified Findings No findings of significance were identified.
B. Licensee Identified Violations No findings of significance were identified.
Enclosure
Report Details 4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution The team based the following conclusions, in part, on issues identified during the period, July 1, 2006 (the last biennial problem identification and resolution inspection) to the end of the inspection on April 25, 2008. In addition, the team reviewed problems for selected systems, which were identified outside this assessment period whose significance may be age-dependent.
a. Assessment of the Corrective Action Program (1) Inspection Scope The inspectors reviewed the licensees corrective action program (CAP) procedures which described the administrative process for initiating and resolving problems primarily through the use of nuclear condition reports (NCRs). The inspectors reviewed selected NCRs, and attended meetings where NCRs were screened for significance to determine whether the licensee was identifying, accurately characterizing, and entering problems into the CAP at an appropriate threshold.
The inspectors selected NCRs for review which involved issues covering the seven cornerstones of safety identified in the NRCs Reactor Oversight Process (ROP). The selected samples involved various licensee classified severity levels and site departments. The inspectors also conducted a detailed review of NCRs for several risk significant systems which were selected based on risk insights from the licensees probabilistic safety assessment. The systems selected for review were the Emergency Diesel Generators (EGDGs) and Diesel Fuel Tanks; Decay Heat Removal, Decay Heat Closed Cycle (DC); Raw Water (RW); Service Water (SW); and Emergency and Auxiliary Feedwater systems. The inspectors reviewed NCRs, maintenance history, completed work orders (WOs) for the systems, and reviewed associated system health reports. These reviews were performed to verify that problems were being properly identified, appropriately characterized, and entered into the CAP. Items reviewed generally covered a two-year period of time; however, in accordance with the inspection procedure, a five-year review was performed for selected systems for age-dependent issues.
The inspectors conducted plant walkdowns of equipment associated with the selected systems to assess the material condition and to look for any deficiencies that had not been entered into the CAP. Control room operator logs and site observation items were also reviewed to verify that issues identified were properly entered into the CAP.
The inspectors reviewed NCRs, including root and apparent cause evaluations, site and department trend reports, and observed other activities to verify that the licensee appropriately prioritized and evaluated problems in accordance with their risk significance. The inspection was intended to verify that the licensee adequately Enclosure
determined the cause of the problems, including root cause analysis where appropriate, and adequately addressed operability, reportability, common cause, generic concerns, extent of condition, and extent of cause.
The review included the appropriateness of the assigned significance, the timeliness of resolutions, the level of effort in the investigation, and the scope and depth of the causal analysis. The review was also performed to verify that the licensee appropriately identified corrective actions to prevent recurrence and that those actions had been appropriately prioritized.
The inspectors reviewed a sample of selected licensee effectiveness reviews and work orders initiated to resolve NCRs to verify the licensee had identified and implemented timely and appropriate corrective actions to address problems. The inspectors verified that the corrective actions were properly assigned, documented, and tracked to ensure completion. The review was also conducted to verify the adequacy of corrective actions to address equipment deficiencies and maintenance rule (MR) functional failures of risk significant plant safety systems.
The inspectors attended various plant meetings to observe management oversight functions of the corrective action process. These included plan of the day meetings, a Self-Evaluation Board (SEB) meeting, and a system review meeting. Documents reviewed are listed in the Attachment.
Furthermore, the inspectors verified that issues identified by internal and external operating experience, licensee audits and self-assessments, and the employee concerns program were entered into and dispositioned by the CAP, as appropriate. The team also reviewed corrective action packages related to previously issued non-cited violations and licensee event reports.
(2) Assessment Identification of Issues: The team determined that the licensee was generally effective in identifying problems and entering them into the CAP. There was no threshold for entering issues into the CAP and employees were encouraged to initiate NCRs for any reason. Trending was generally effective in monitoring equipment performance.
However, the team did recognize that there have been a significant number of NCRs initiated in 2008 as a result of NRC resident inspectors identifying issues during plant walkdowns that could have been captured by licensee personnel. The licensee identified this trend and initiated NCR 272132 to take corrective action. In addition, during a plant walkdown, the team identified scaffolding and shielding that was blocking Appendix R emergency light illumination. Subsequent to observations and conversations with the NRC, the scaffolding was moved; however no NCR was initiated to evaluate the changes. The licensee later captured this issue in NCR 274711.
Prioritization and Evaluation of Issues: In general, the team determined that problems were adequately prioritized and entered into the CAP consistent with the licensees CAP guidance. Each NCR written and priority level assigned was reviewed during the plan of the day meeting which was chaired by the superintendent shift operations and attended Enclosure
by upper management and department heads. Management reviews of NCRs were thorough and adequate consideration was given to system or component operability and associated plant risks. Additionally, the inspectors reviewed meeting minutes from several Nuclear Safety Review Committee meetings and concluded that additional quality was added to the licensees process by the committee. The inspectors concluded that evaluation of issues was generally comprehensive and technically adequate. Formal root cause evaluations for issues classified as significant adverse conditions were comprehensive and detailed. However, the team identified examples where problem evaluations were not thorough or were found to be incorrect:
- The incore monitoring (PAM) exceeded the functional failure limit without generating an NCR documenting the maintenance rule 10 CFR 50.65(a)(1) evaluation and goal setting in accordance with their procedure. The licensee captured this issue in NCR 274599.
- For NCR 257782, the maintenance rule evaluation and the investigation dispositions did not agree with each other. The licensee captured this issue in NCR 275017.
- Although the apparent cause that was determined for the leakage through valve MUV-187 was incorrect, the corrective actions taken by the licensee to correct the leakage were appropriate and effective. The licensee captured this issue in NCR 275695.
Effectiveness of Corrective Actions: The inspectors determined that overall, corrective actions were effective in correcting plant problems. The effectiveness of corrective actions was correlated to good material condition of the systems reviewed. The inspectors identified that most corrective actions implemented by the licensee were appropriate for the severity and risk significance of the problem identified. However, the team noted the below listed examples where the licensee had determined that corrective actions had not been completely effective:
- NCR 264012 on dropped objects prevention was initiated following the most recent refueling outage. The investigation stated that corrective actions previously put into effect were not being utilized.
- NCR 206464 on Plant Status Control had ineffective corrective actions to prevent recurrence, i.e., NCRs 218895, 258438, and 235991 were subsequently written since September 2006, identifying adverse trends in human performance. However, the station did identify that the corrective actions to prevent recurrence were ineffective, and has continued to implement additional corrective actions.
(3) Findings No findings of significance were identified.
Enclosure
b. Assessment of the Use of Operating Experience (1) Inspection Scope The inspectors examined licensee programs for reviewing industry operating experience, reviewed the licensees operating experience database, and interviewed the Operating Experience Coordinator, to assess the effectiveness of how external and internal operating experience data was handled at the plant. In addition, the inspectors selected operating experience documents (e.g., NRC generic communications, 10 CFR Part 21 reports, licensee event reports, vendor notifications, and plant internal operating experience items, etc.), to verify whether the licensee had appropriately evaluated each notification for applicability to the Crystal River plant and whether issues identified through these reviews were entered into the CAP. Documents reviewed are listed in the Attachment.
(2) Assessment The team determined that the licensee was effective in screening operating experience for applicability to the plant. The inspectors verified that the licensee had entered those items determined to be applicable into the CAP and taken adequate corrective actions to address the issues. Internal operating experience was adequately utilized and considered as part of formal root cause evaluations for supporting the development of lessons learned and corrective actions for CAP issues. However, one example was identified where no evaluation for prioritization was performed for an industry lesson learned concerning single point vulnerabilities.
(3) Findings No findings of significance were identified.
c. Assessment of Self-Assessments and Audits (1) Inspection Scope The inspectors reviewed licensee Nuclear Assurance Section (NAS) audits, NAS quality reports, and department self-assessments, including those which focused on problem identification and resolution, to verify that findings were entered into the CAP and to verify that these findings were consistent with the NRCs assessment of the licensees CAP.
(2) Assessment NAS audits and departmental self-assessments were effective in identifying issues and directing attention to areas that needed improvement. Licensee identified weaknesses and issues in self-assessments were appropriately entered into the corrective action program and addressed. The team determined that the self-assessments and audits were critical, insightful, and persistent at identifying issues and entering them into the corrective action program. Based on the weaknesses and recommendations identified Enclosure
by the licensee, the team determined the self-assessments were thorough and comprehensive. However, the team determined that the documentation of the self-assessments lacked sufficient detail to adequately evaluate the effectiveness of the assessments. The licensee initiated NCR 274514 to address this issue. Effectiveness reviews for root cause evaluations were usually comprehensive, detailed, and correctly identified CAP implementation deficiencies.
(3) Findings No findings of significance were identified.
d. Assessment of Safety-Conscious Work Environment (1) Inspection Scope The team randomly interviewed on-site workers regarding their knowledge of the corrective action program at Crystal River and their willingness to write NCRs or raise safety concerns. Additionally, during technical discussions with members of the plant staff, the inspectors conducted interviews to develop a general perspective of the safety-conscious work environment at the site. The interviews were also conducted to determine if any conditions existed that would cause employees to be reluctant to raise safety concerns. The inspectors reviewed the licensees employee concerns program (ECP) and interviewed the ECP manager. Additionally, the inspectors reviewed a select number of completed ECP reports to verify that concerns were being properly reviewed and identified deficiencies were being resolved and entered into the CAP as appropriate.
(2) Assessment Based on this inspection and the NCR reviews, the inspectors determined that licensee management emphasized the need for all employees to identify and report problems using the appropriate methods established within the administrative programs, including the CAP and ECP. These methods were readily accessible to all employees. Based on discussions conducted with a sample of plant employees from various departments, the inspectors determined that employees felt free to raise issues and felt that management wanted issues placed into the CAP for resolution. The inspectors did not identify any reluctance on the part of the licensee staff to report safety concerns.
(3) Findings No findings of significance were identified.
4OA6 Exit Meeting On April 25, 2008, the inspectors presented the inspection results to Mr. Dale Young and other members of his staff who acknowledged the results. The inspectors confirmed that proprietary information was not provided or retained following the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION Enclosure
SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee personnel:
M. Annacone, Plant Manager W. Brewer, Manager, Maintenance T. Burnett, Supervisor, Self Evaluation Unit S. Cahill, Manager, Engineering P. Dixon, Manager, Nuclear Assessment B. Foster, Supervisor, Engineering J. Franke, Director of Site Operations D. Herrin, Acting Supervisor, Licensing J. Holt, Manager, Operations R. Hons, Manager, Training M. Rigsby, Superintendent, Radiation Protection J. Stephenson, Supervisor, Emergency Preparedness I. Wilson, Manager, Outage and Scheduling D. Young, Vice President, Crystal River Nuclear Plant NRC personnel:
T. Morrissey S. Vias ITEMS OPENED, CLOSED AND DISCUSSED Opened, Closed and Discussed None Attachment
LIST OF DOCUMENTS REVIEWED Procedures ADM-NGGC-0101, Maintenance Rule Program, Rev. 20 ADM-NGGC-0104, Work Management Process, Rev. 30 ADM-NGGC-0107, Equipment Reliability Process Guideline, Rev. 8 CAP-NGGC-0200, Corrective Action Program, Rev. 19 - 21 CAP-NGGC-0201, Self-Assessment and Benchmarking Programs, Rev. 11 CAP-NGGC-0202, Operating Experience Program, Rev. 12 CAP-NGGC-0204, Human Performance Program, Rev. 1 CAP-NGGC-0205, Significant Adverse Condition Investigations, Rev. 5, 6 CAP-NGGC-0206, Corrective Action Program Trending and Analysis, Rev. 2 OPS-NGGC-1305, Operability Determinations, Rev. 1 MNT-NGGC-0001, Maintenance Rework Program, Rev. 22 NCRs Priority 1 139589, 152691, 173854, 183116, 206464, 210023, 211171, 214165, 214698, 218852, 223337, 233789, 250154, 252450, 257797, 258560, 261079, 261226, 264799, 265765, 265766 NCRs Priority 2 137983, 162050, 173722, 182701, 183919, 185120, 188885, 190986, 191084, 192649, 194236, 196736, 198289, 201597, 201944, 204234, 205229, 205952, 206535, 207901, 212789, 214397, 214771, 215863, 216312, 217536, 218572, 219138, 220386, 221602, 221784, 227266, 227539, 227594, 227784, 228216, 228294, 228445, 228565, 231678, 232237, 233116, 236093, 236290, 236294, 237842, 238613, 239508, 243938, 244022, 247908, 248036, 251060, 253517, 253738, 254044, 254189, 254250, 254283, 254367, 254610, 254982, 256015, 256703, 256721, 257426, 257562, 257602, 257782, 257785, 259764, 260238, 260803, 261788, 263645, 264012, 264111, 264479, 265002, 266059, 269125, 269400, 272132 NCRs Priority 3 188606, 199372, 213215, 225082, 228944, 231002, 235798, 244045, 249790, 251080, 251346, 255006, 256022, 262448, 265064, 266575 NCRs Priority 5 205565, 229102, 251116 Work Orders 00651965, 00830714, 00970053, 00976734, 00980242, 00992881, 01014030, 01042026, 01127659, 01164492, 01279634, 01309060 Attachment
Self-Assessments Assessment Number 170712, Nuclear Assessment Section Adverse Condition Investigation Quality, November 2006 Assessment Number 173867, Self-Assessment of the Corrective Action Program and the Operating Experience Program, August 2006 Assessment Number 261775, Self-Assessment of the Corrective Action Program and the Operating Experience program, March 2008 Benchmark 208108, Florida Power & Light, August 2007 C-EC-07-01, Environmental and Chemistry Assessment, August 9, 2007 C-EP-07-01, Emergency Preparedness Assessment, February 27, 2007 C-ES-07-01, Engineering Assessment, March 22, 2007 C-FP-07-01, Fire Protection Assessment, May 10, 2007 C-OM-07-01, R15 Outage Assessment C-OP-07-01, Operations Assessment, February 2007 C-RP-07-01, Radiation Protection Assessment, May 30, 2007 C-SC-07-01, Security Assessment, August 23, 2007 C-SP-07-01, In-Service Inspection/In-Service Testing and Special Processes, September 18, 2007 Drawings FD-302-082, Emergency Feedwater Sheet 3 of 3, Rev. 30 FD-302-082, Emergency Feedwater Sheet 2 of 3, Rev. 18 FD-302-082, Emergency Feedwater Sheet 1 of 3, Rev. 62 Other Documents 4th Quarter 2007 CAP Rollup & Trend Analysis 4th Quarter 2007 Decay Heat Closed Cycle Cooling System Health Report 4th Quarter 2007 Decay Heat System Health Report 4th Quarter 2007 Emergency Diesel Generator System Health Report 4th Quarter 2007 Emergency Feedwater System Health Report 4th Quarter 2007 Nuclear Service Water Closed Cycle Cooling System Health Report 4th Quarter 2007 Nuclear Services & Decay Heat Sea Water System Health Report Electrical / I&C System Walkdown Checklist, Rev. 9 Enhanced DBD for the Emergency Feedwater, Rev. 17 Enhanced DBD for the Emergency Diesel Generator System, Rev. 11 Enhanced DBD for the Decay Heat System, Rev. 23 Formal Benchmark Report Robinson Nuclear Plant, October 2005 Formal Benchmark Report CAPOG Summer Meeting, August 2006 Generic Letter 89-13 Program Review Meeting, December 2006 Mechanical System Walkdown Checklist, Rev. 9 Lesson Decay Heat Closed Cycle Cooing System, Rev. 4 Lesson Nuclear Services Closed Cycle Cooling System, Rev. 7 Lesson Nuclear Services and Decay Heat Raw Water System, Rev. 7 Licensee Event Report 50-302/2006-001-00 Licensee Event Report 50-302/2006-002-00 Attachment
Licensee Event Report 50-302/2007-001-00 Licensee Event Report 50-302/2007-002-00 Non-cited Violation 5000302/2007002-03 Non-cited Violation 5000302/2007006-02 Observation Details Report, January 2008 OE Item Evaluation forms for OEs 21316, 25124, 26525, 26531Operating Experience Program Health Report, February 2007, August 2007, February 2008 OPS-4-037, Emergency Feedwater System Lesson Plan, Rev. 7 OPS-4-06, Emergency and Alternate AC Diesel Generators, Rev. 6 Safety Evaluation of Florida Power Corporation Proposed Emergency Action Level Change for Crystal River Unit 3, dated September 21, 1999.
Self-Evaluation Board (SEB) Meeting Minutes, March 27, 2008 System Review Meeting EC-EFIC, EF Report System Review Meeting SW Report, May 2007 System Review Meeting DC Report, March 2006 System Review Meeting RW Report, June 2007 Nuclear Safety Review Committee Meeting Minutes August 22, 2006 November 7, 2006 February 20, 2007 June 19, 2007 August 28, 2007 November 13, 2007 Attachment
Request for Items for the Crystal River PI&R Inspection April 7-11 & April 21-25, 2008 Note: Unless otherwise noted, please provide documents from July 2006 1. Copies of the corporate and site level procedures and sub-tier procedures associated with the corrective action program. This should include procedures related to: 1)
corrective action process, 2) operating experience program, 3) employee concerns program, 4) self-assessment program, 5) maintenance rule program and implementing procedures, 6) Operability Determination process, 7) Degraded/non-conforming condition process (e.g., RIS 2005-20), 8) System health process, or equivalent Equipment Reliability Improvement Programs, 9) PM deferral and NCR extension process.
2. List of top ten risk significant systems, components, and operator manual actions.
3. List of all NCRs initiated since July 1, 2006, sorted by the following responsible plant departments. In each department grouping, please provide the following information sorted by NCR #: a) NCR #, b) Priority, and c) NCR Title.
a) Emergency Preparedness; b) Health Physics; c) Chemistry; and, d) Security.
4. List of all NCRs initiated since July 1, 2006, sorted by Priority, with the following information: a) NCR #, b) Priority, and c) NCR Title.
5. List of outstanding corrective actions with a brief description, priority level, initiation date, and due date.
6. List of control room deficiencies with a brief description and corresponding NCR and or work order number.
7. List of all currently extended NCRs or overdue, sorted by initiation date, with the following information: a) NCR #, b) Priority, and c) NCR Title.
8. List of all NCRs that have been voided or cancelled since July 1, 2006. Please sort by NCR #, with title or description of problem, and reason voided or cancelled.
9. List of all structures, systems, and components (SSC) which were classified as (a)(1) in accordance with the Maintenance Rule since July 1, 2006. Include applicable procedures for classifying systems or components as (a)(1), date and reason for being placed in (a)(1), and actions completed and current status. Also, provide a copy of any self-assessment of the Maintenance Rule program conducted since July 1, 2006.
Attachment
10. List of Maintenance Preventable Functional Failures (MPFF) of risk significant systems since July 1, 2006. Include actions completed and current status.
11. Copies of latest System Health Reports. Copies of system design basis documents, system description information, P&IDs, etc.
12. Corrective action closeout packages for all NRC findings and licensee identified violations since July 1, 2006.
13. Corrective action closeout packages for all LERs issued since July 1, 2006.
14. List of all NRC generic communications (e.g., Information Notices, Generic Letters, etc.)
and industry operating experience documents (e.g., Part 21 reports, vendor information letters, information from other sites, etc.), evaluated by the site for applicability to the station, regardless of the determination of applicability, since July 1, 2006.
15. Copies all quality assurance audits and/or assessments issued since July 1, 2006, including the last two audits/assessments of the corrective action program. Also, any self-assessment of the site safety culture conducted since July 1, 2006 should be provided.
16. Copies of all department self-assessments since July 1, 2006.
17. List of corrective action documents that have resulted from the Employee Concerns Program since July 1, 2006.
18. Copy of the most recent integrated plant trend report, departmental trend report(s), and corrective action trend report, including any human performance and equipment reliability trends.
19. Copy of the latest Corrective Action Program statistics (if exists) such as the number initiated by department, human performance errors by department, and others as may be available.
20. Copies of any minutes of meetings by the offsite safety review boards/groups since July 1, 2006.
21. List of NCRs related to equipment aging issues of risk significant systems since January 1, 2002 (e.g., system erosion and/or corrosion problems; electronic component aging or obsolescence of circuit boards, power supplies, relays, etc.; environmental qualification).
Please sort by NCR # with the following information: a) NCR #, b) priority, and c) NCR Title.
22. If performed, results from safety culture survey.
Attachment
23. Copies of corrective action program documents related to cross-cutting issues (human performance, problem identification and resolution, and safety conscious work environment) identified via trending, self-assessments, safety review committee, or other oversight methods.
24. List of all root cause evaluations with a brief description.
Attachment