IR 05000333/2019002

Integrated Inspection Report 05000333/2019002

ML19225B240
Person / Time
Site:	FitzPatrick
Issue date:	08/12/2019
From:	Erin Carfang NRC/RGN-I/DRP/PB5
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Carfang E
References
IR 2019002
Download: ML19225B240 (17)

Text

ust 12, 2019

SUBJECT:

JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2019002

Dear Mr. Hanson:

On June 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On July 25, 2019, the NRC inspectors discussed the results of this inspection with Mr. Joseph Pacher and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors documented one finding of very low safety significance (Green) in this report. The finding did not involve a violation of NRC requirements.

The inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; and the NRC Resident Inspector at FitzPatrick. 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/

Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Docket No. 05000333 License No. DPR-59

Enclosure:

As stated

Inspection Report

Docket Number: 05000333 License Number: DPR-59 Report Number: 05000333/2019002 Enterprise Identifier: I-2019-002-0051 Licensee: Exelon Generation Company, LLC Facility: James A. FitzPatrick Nuclear Power Plant Location: Oswego, NY Inspection Dates: April 1, 2019 to June 30, 2019 Inspectors: E. Miller, Senior Resident Inspector C. Highley, Acting Senior Resident Inspector G. Stock, Resident Inspector L. Dumont, Reactor Inspector Z. Hollcraft, Senior Resident Inspector P. Ott, Operations Engineer R. Rolph, Resident Inspector Approved By: Erin E. Carfang, Chief Reactor Projects Branch 1 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at James A. FitzPatrick Nuclear Power Plant in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Licensee-identified non-cited violations are documented in report sections: 71111.15.

List of Findings and Violations Exposure Greater Than 50 Percent of the Estimate Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.5] - Work 71124.02 Radiation Safety FIN 05000333/2019002-01 Management Open A self-revealed Green finding was identified because Exelon did not follow their as low as reasonably achievable (ALARA) procedure during the most recent refueling outage.

Specifically, Exelon did not follow procedure RP-AA-401, ALARA Planning and Controls, to conduct a work-in-progress review when they encountered an expanded work scope that was not accounted for in contingent dose, and could not be accommodated in the existing dose estimate. The expanded work scope caused the accumulated dose to be greater than 50 percent of the estimate for safety relief valve work.

Additional Tracking Items None.

PLANT STATUS

FitzPatrick began the inspection period at rated thermal power. On May 22, 2019, operators reduced power to 65 percent to repair a condenser tube leak and to perform turbine valve testing and a rod pattern adjustment. The unit was returned to rated thermal power on May 23, 2019, and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Seasonal Extreme Weather Sample (IP Section 03.02)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal hot temperatures for the 'A', 'B', 'C', and 'D' emergency diesel generators; the 'A' and 'B' residual heat removal service water systems; and the 'A' and 'B' emergency service water systems.

71111.04 - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) High pressure coolant injection system on April 4, 2019

(2) 'B' and 'D' emergency diesel generators on April 17, 2019

(3) 'B' station battery on April 24, 2019

(4) 'A' and 'B' standby liquid control systems on May 15, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Recirculation motor generator set room, fire area MG-1 on April 17, 2019

(2) Refuel floor reactor building elevation 369', fire area RB-1A on April 22, 2019

(3) Battery room complex, fire area BR-4 and BR-5 on May 17, 2019

(4) Reactor building elevations 272', 300', 326', and 344', fire area RB-1A on May 20, 2019

71111.06 - Flood Protection Measures Inspection Activities - Internal Flooding (IP Section 02.02a)

The inspectors evaluated internal flooding mitigation protections:

(1) Review of Operating Experience Smart Sample FY2007/02, Analysis of Flooding Vulnerabilities, Revision 3 on May 23, 2019

71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance Requalification Examination Results (IP Section 03.03)

(1) The inspectors reviewed and evaluated the licensed operator annual requalification examination results on June 5, 2019.

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) The inspectors observed and evaluated licensed operator performance in the control room during control rod exercising and operability testing on June 1, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed the annual reactor operator requalification exam which included a loss of a 354 kilovolt breaker, a trip of a control rod drive pump, a loss of the T-5 4 kilovolt to 600 volt transformer, reactor scram with a failure of the reactor protection system to actuate requiring the use of the alternate rod insertion system, and a loss of coolant accident inside primary containment requiring an Alert declaration on April 30, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Review of the maintenance rule a(3) periodic assessment on May 31, 2019

(2) Area radiation monitors on June 26, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Unplanned maintenance on the reactor core isolation cooling outboard steam admission valve, 13-MOV-131, on April 5, 2019

(2) Planned maintenance on the 'C' emergency diesel generator on April 16, 2019

(3) Elevated plant risk due to severe weather on May 19, 2019

(4) Planned maintenance on the 'B' emergency diesel generator on June 6, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Reactor building closed-loop cooling spring can bottomed out in the recirculation motor generator set room on May 8, 2019

(2) 'B' station battery with small gap in structural supports on May 23, 2019

(3) Control room air conditioning system with through wall leak on control room chiller service water inlet isolation valve, 70PCV-100A1, on June 28, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following permanent modification:

(1) Engineering Change Package 625160 - Install New RADCAM Camera System in JAF Drywell, on May 9, 2019

71111.19 - Post-Maintenance Testing Post Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) ST-9BA, EDG A and C Full Load Test and ESW Pump Operability Test, for 'C' emergency diesel generator, following maintenance window on April 11, 2019

(2) ST-24J, RCIC Flow Rate and Inservice Test, following reactor core isolation cooling outboard steam admission valve, 13-MOV-131, packing replacement on April 11, 2019

(3) MP-046.03, Twin Basket Strainers, 46STR-5A(B) and 10S-5A(B), following 'B' emergency service water strainer cleaning and inspection on June 6, 2019

(4) ST-9BB, EDG B and D Full Load Test and ESW Pump Operability Test, following 'B' emergency diesel generator maintenance window on June 7, 2019

(5) MP-059.60, Anchor Darling Pressure Seal Gate and Globe Valve (ISI), following reactor core isolation cooling outboard steam admission valve, 13-MOV-131, poppet replacement on June 14, 2019

(6) OP-55B, Control Room Ventilation and Cooling, following troubleshooting and repair of 'A' control room emergency ventilation system on June 20, 2019

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Inservice Testing (IP Section 03.01)

(1) ST-3PB, Core Spray Loop B Quarterly Operability Test, on April 8, 2019

(2) ST-4N, HPCI Quick-Start, Inservice, and Transient Monitoring Test, on May 30, 2019

Surveillance Tests (other) (IP Section 03.01) (2 Samples)

(1) ST-9BB, Emergency Diesel Generator B and D Full Load Test and Emergency Service Water Pump Operability Test, on May 6, 2019

(2) ST-18, Main Control Room Emergency Fan and Damper Operability Test, on May 29, 2019

71114.06 - Drill Evaluation Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)

(1) The inspectors evaluated the conduct of a routine emergency planning drill on May 21,

71124.01 - Radiological Hazard Assessment and Exposure Controls High Radiation Area and Very High Radiation Area Controls (IP Section 02.05)

(1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

71124.02 - Occupational ALARA Planning and Controls Radiological Work Planning (IP Section 02.01)

The inspectors evaluated the licensees radiological work planning.

(1) The inspectors selected the following radiological work activities based on exposure significance for review:

JF-1-18-00506, DW Scaffold Activities, Revision 0 JF-1-18-00510, DW Main Steam Safety Relief Valve Activities, Revision 0 JF-1-18-00516, DW Recirc Pump, Seals, and Motor Activities, Revision 0 JF-1-18-00541, DW 12RWC-46 and 12MOV-15 Activities, Revision 1 JF-1-18-00901, FF Outage Reactor Disassembly/Reassembly Activities, Revision 2 For each of these activities, the inspectors reviewed ALARA work activity evaluations, exposure estimates, exposure reduction requirements, results achieved (dose rate reductions, actual dose), person-hour estimates, results achieved, 50 percent and 80 percent work in progress reviews and post-job reviews that were conducted to identify lessons learned.

Verification of Dose Estimates and Exposure Tracking Systems (IP Section 02.02) (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

(1) The inspectors reviewed the current annual collective dose estimate, basis methodology, and measures to track, trend, and reduce occupational doses for ongoing work activities. The inspectors evaluated the adjustment of exposure estimates, or re-planning of work. The inspectors reviewed post-job ALARA evaluations of excessive exposure.

TEDE ALARA Evaluation for RWP JF-1-18-00901, dated September 10, 2018 TEDE ALARA Evaluation for RWP JF-1-18-00906, dated September 10, 2018

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls (IP Section 02.01)

The inspectors evaluated airborne controls and radioactive monitoring.

(1) The inspectors reviewed operability and use of both permanent and temporary ventilation systems, and the adequacy of airborne radioactivity radiation monitoring in the plant based on location, sensitivity, and alarm set-points.

Self-Contained Breathing Apparatus for Emergency Use (IP Section 02.03) (1 Sample)

The inspectors evaluated self-contained breathing apparatus program implementation.

(1) The inspectors reviewed the status and surveillance records for three self-contained breathing apparatus staged in-plant for use during emergencies, FitzPatrick's self-contained breathing apparatus procedures, maintenance and test records, the refilling and transporting of self-contained breathing apparatus air bottles, self-contained breathing apparatus mask size availability, and the qualifications of personnel performing service and repair of this equipment.

Use of Respiratory Protection Devices (IP Section 02.02) (1 Sample)

The inspectors evaluated the licensees use of respiratory protection devices by:

(1) The inspectors reviewed the adequacy of FitzPatrick's use of respiratory protection devices in the plant to include applicable ALARA evaluations, respiratory protection device certification, respiratory equipment storage, air quality testing records, and individual qualification records. The inspectors verified the qualifications of three individuals and observed them don, doff, and functional check various respirators.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

BI02: RCS Leak Rate Sample (IP Section 02.11) ===

(1) April 1, 2018 through March 31, 2019 MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (1 Sample)

(1) January 1, 2018 through March 31, 2019

71152 - Problem Identification and Resolution Semiannual Trend Review (IP Section 02.02)

(1) The inspectors evaluated a sample of condition reports generated over the course of the fourth quarter of 2018 and first quarter of 2019 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified that these issues were addressed within the scope of the corrective action program or through department review.

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.15 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: FitzPatrick Technical Specification 5.4.1(a), Procedures, requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of NRC Regulatory Guide 1.33, dated 1972. NRC Regulatory Guide 1.33 recommends procedures for the control of the maintenance, repair, replacement, and modification of safety-related equipment. Exelon procedure MA-AA-716-010, Maintenance Planning, Revision 28, directs maintenance planners to prepare work packages to resolve reported deficiencies to ensure completion within the established deadlines and schedules. Contrary to the above, following identification and evaluation of localized wall thinning of the B emergency service water strainer by engineering in October 2016, the deadline established for reevaluation or repair of October 2017, based on engineering evaluation of the wall degradation, was lost when transferring the work request information into the associated work order. Because the engineering evaluated deadline was lost, the wall thickness was allowed to fall below American Society of Mechanical Engineers code minimum wall thickness requiring the invocation of American Society of Mechanical Engineers code case N-513-2 and additional non-destructive evaluations to maintain 'B' emergency service water operability.

Significance: Green.

Corrective Action References: IRs 04220485, 04235651, 04245272, 04252851, 04254085, 04259691 Exposure Greater Than 50 Percent of the Estimate Cornerstone Significance Cross-Cutting Report Aspect Section Occupational Green [H.5] - Work 71124.02 Radiation Safety FIN 05000333/2019002-01 Management Open A Green self-revealed finding was identified because Exelon did not follow their ALARA procedure during the most recent refueling outage. Specifically, Exelon did not follow procedure RP-AA-401, ALARA Planning and Controls, to conduct a work-in-progress review when they encountered an expanded work scope that was not accounted for in contingent dose, and could not be accommodated in the existing dose estimate. The expanded work scope caused the accumulated dose to be greater than 50 percent of the estimate for safety relief valve work.

Description:

The purpose of the safety relief valves is to prevent overpressurization of the reactor coolant system. One of the tasks during the most recent refueling outage was a modification of the safety relief valves, including the replacement of eight nitrogen accumulators. The activity had an estimated exposure of 12.534 person-rem.

Following the completed modification of the safety relief valves, the safety relief valves were tested. A solenoid within a safety relief valve failed during this testing. The solenoid was disassembled, and foreign material was found. The foreign material in the safety relief valve was determined to be from the nitrogen accumulator work upstream of the solenoid. The scope of the work was expanded to remove, blow down, and reinstall the 11 safety relief valves to verify that foreign material did not exist in the lines.

Procedure RP-AA-401, ALARA Planning and Controls, Section 4.2.4 states, in part, if a task is not proceeding as planned with a greater than anticipated dose accrual, or an expanded scope that is not accounted for in contingent dose, and cannot be accomplished in the existing estimate, conduct a work-in-progress review and update radiation work permit estimates per the work-in-progress results. Upon discovery of foreign material in the safety relief valve and subsequent expanded scope to ensure the other safety relief valves did not contain foreign material, Exelon did not conduct a work-in-progress review with updated exposures. The exposure at the end of the task was 23.161 person-rem, which was 10.627 person-rem over the estimated exposure of 12.534 person-rem.

Corrective Actions: Exelons immediate corrective actions included reviewing the lessons learned in the post-job review following the work and entering the issue into their corrective action program.

Corrective Action References: IR 4243309

Performance Assessment:

Performance Deficiency: Exelon failed to follow their ALARA procedure to conduct a work-in-progress review after they encountered an expanded work scope that was not accounted for in contingent dose and could not be accommodated in the existing dose estimate.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone. Additionally, this finding is similar to IMC 0612, Appendix E, Example 6.i. Specifically, the actual collective dose exceeded 5 person-rem and exceeded the planned, intended dose by more than 50 percent.

Significance: The inspectors assessed the significance of the finding using Appendix C, Occupational Radiation Safety SDP. The inspectors assessed the significance of the finding using IMC 0609, Appendix C, Occupational Radiation Safety - Significance Determination Process.

Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Exelon's ALARA work-in-progress review process was not controlled and executed following an expanded scope of work activities associated with the safety relief valve accumulators. This expanded scope caused the accumulated dose to be greater than 50 percent of the estimate for the task.

Enforcement:

Inspectors did not identify a violation of regulatory requirements associated with this finding.

Observation: Semiannual Trend Review 71111.52 The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Exelon staff for potential trends at a low threshold, and resolved within the scope of the corrective action program. The inspectors noted minor adverse trends identified by Exelon staff associated with out of tolerance maintenance and testing equipment and foreign material exclusion. There were no safety consequences as a result of these low-level trend issues.

Based on the overall results of the semiannual trend review, the inspectors determined that Exelon had properly identified adverse trends at FitzPatrick before they became more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On July 25, 2019, the inspectors presented the quarterly integrated inspection results to Mr. Joseph Pacher and other members of the licensee staff.

On April 25, 2019, the inspectors presented the radiation protection inspection results to Mr. Joesph Pacher and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04 Calculations JAF-CALC- Determination of Float and Equalize Voltage for Station 1

ELEC-02551 Batteries 71SB-1 and 71SB-2

Drawings FM-21A Standby Liquid Control Flow Diagram System 11 37

FM-25A Flow Diagram High Pressure Coolant Injection System 23 75

FM-25B Flow Diagram High Pressure Coolant Injection Lube Oil 34

System 23

Miscellaneous DBD-023 Design Basis Document for the High Pressure Coolant 12

Injection System

Procedures OP-AA-108-117 Protected Equipment Program 5

71111.05Q Fire Plans PFP-PWR20 Reactor Building East Elevation 272' Fire Area Zone IX/RB-

1A

PFP-PWR23 Motor Generator Set Room/Elevation 300 Ft Fire Area/Zone 5

1A/MG-1

PFP-PWR24 Reactor Building East Elevation 300' Fire Area Zone IX/RB-

1A

PFP-PWR26 Reactor Building Elevation 326' Fire Area Zone IX/RB-1A

PFP-PWR27 Reactor Building West Elevation 344' Fire Area Zone IX/RB-

1A

PFP-PWR28 Reactor Building West Elevation 369' Fire Area Zone IX/RB-

1A

PFP-PWR28 Reactor Building Elev. 369' Fire Area Zone 9 RB-1A 008

PPFP-PWR04 Battery Room Complex Elevation 272', 282' Fire Area/Zone 02

IV BR-4, XVI/BR-5

Procedures CC-AA-211 Fire Protection Program 8

OP-AA-201-008 Pre-Fire Plan Manual 4

OP-AA-201-009 Control of Combustible Material 22

71111.11Q ST-20B Control Rod Operability for Partially Within Control Rods 4

ST-20C Control Rod Operability for Fully Withdrawn Control Rods 30

71111.12 Corrective Action 04158874

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 04161715

04165321

04175570

04183635

04188108

206271

209692

247972

Miscellaneous Exelon Corporation James A. FitzPatrick Nuclear Power 0

Plant 10 CFR 50.65 (a)(3) Periodic Assessment, November

2015-March 2019

Maintenance Rule System Basis Document, System 18, June 24,

Area Radiation Monitoring System 2019

71111.13 Procedures AOP-13 Severe Weather 35

ER-AA-600-1042 On-Line Risk Management 11

WC-AA-104 Integrated Risk Management 25

71111.15 Corrective Action 04235651

Documents 04242812

243161

245107

245272

252851

254085

258826

259691

Drawings FB-35E Flow Diagram Control Room Area Service and Chilled 38

Water, System 70

FM-46A Flow Diagram Service Water, System 46 92

FM-46B Flow Diagram Emergency Service Water, System 46 and 15 57

71111.18 Engineering EC 625160 Install New RADCAM Camera System in JAF Drywell 0

Changes

Procedures IS-E-02 Moisture Sealing of Terminal Boards for Safety-Related 6

Components

Inspection Type Designation Description or Title Revision or

Procedure Date

Work Orders 04818415-23

04818415-24

04896434-01

04896434-04

71111.19 Corrective Action 04257834

Documents

Procedures MP-046.03 Twin Basket Strainers, 46STR-5A(B) and 10S-5A(B) 21

OP-55B Control Room Ventilation and Cooling 37

ST-24J RCIC Flow Rate and Inservice Test (IST) 16

ST-9BA EDG A and C Full Load Test and ESW Pump Operability 17

Test

ST-9BB EDG B and D Full Load Test and ESW Pump Operability 16

Test

Work Orders 04803630

04865820

04932856

212182

71111.22 Calculations JAF-CALC-12- Gas Void Venting Acceptance Criteria January 12,

00001 2012

Corrective Action 04198505

Documents 04252351

252355

252357

252619

252625

71151 CR-JAF-2014-

06498

Corrective Action 04254986

Documents

Resulting from

Inspection

71152 Corrective Action 04179908

Documents 04180073

Inspection Type Designation Description or Title Revision or

Procedure Date

04180548

04191862

04191905

211069

212905

239944 Trend Review

71153 Procedures AP-16.14 Hazard Barrier Controls 7

14