IR 05000348/1997007
| ML20211Q572 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/10/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211Q555 | List: |
| References | |
| 50-348-97-07, 50-348-97-7, 50-364-97-07, 50-364-97-7, NUDOCS 9710220353 | |
| Download: ML20211Q572 (27) | |
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U.S. NUCLEAR REGULATORY COMMISSION (NRC)-
reb!ON II'
Docket-Nos:
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50-348 and 50-364 Lit.ense Nos: NPF-2 and NPF-8 Report No: 50-348/97-07and50-364/97-07 Licensee: Southern Nuclear Operating Company. Inc. (SNC)
Facility: Farley Nuclear Plant (FNP) Units 1 and 2-Location: -7388. North State Highway.95 Columbia. AL 36319 Dates: August 25 - 29. 1997 Inspectors: B. Holbrook. Senior Resident Inspector -- Hatch-J. Bartley Resident Inspector R. Caldwell -Resident Inspector R. Carrion. Project Engineer _- .
-Approved by: P. Skinner.-Chief. Projects Branch 2-Division of Reactor Projects
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Enclosure 9710220353 971010 gDR ADOCK 05000348 PDR
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EXECUTIVE SUMMARY Farley Nuclear Power Plant. Units 1 and 2'
NRC Inspection Report 50-348/97-07, 50-364/97-07
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l This' routine announced inspection examined the licensee's corrective action
. program. _ including problem identification and resolution. operating experience
- feedback programs, self-assessment-activities, and commitment tracking.
- . Conclusions included the following:
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e -All Deficiency Reports and Maintenance Work Orders (MW0) reviewed by the
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inspectors were appropriately assessed for potential significance by the license Long term work items were appropriately tracked and categorized for unit outage work (Section 07.1).
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e The inspectors concluded that the licensee's MWO backlog was reasonable
- and that efforts made by the licensee to reduce it were satisfactory
! (Section 07.2).
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e There were several informal and non-proceduralized problem identification and tracking programs-that were not considered part of
- - the formal corrective actions programs. This resulted in low level
- . events or problems not being tracked in the corrective actions process.
F The data base maintained for operations procedure deficiencies provided
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a good vehicle to capture deficiencies. However, a weakness was identified for the overall. process and was based upon the large number
- - and duration of procedure deficiencies. There was a lack of management oversight and specific guidance-for maintaining the data base to ensure -
that the significance of the deficiencies was clearly understood and that appropriate corrective actions were completed in a timely manner
(Section 07.3).
e Although the licensee had taken actions to correct some NRC minor findings noted in Inspection Reports, the actions were generally narrow j in focus and were not always effective (Section 07.4).
, o Problem identification and corrective actions were effectively i
implemented in the. Emergency Preparedness area. Trending, tracking and 4 timeliness of corrective actions were appropriate for the identified
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3roblems that were reviewed by the inspectors. The " Emergency 3reparedness Punchlist" was not considered part of the formal corrective
! actions system and there was no specific procedural guidance to ensure
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that elements of this program were consistently implemented
- .(Section 07.5).
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Enclosure
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'2 e- _Until just 3rior to this .NRC-inspection, site personnel were taking no actions wit 1 respect to NRC inspectors identified Updated Final Safety Analysis Report (UFSAR) deficiencies. Site >ersonnel did not have procedures or a process in place to record tie deficiencies, assess their significance or track actions to ensure that corrective actions were appropriate and timely. Site personnel relied upon corporate Jpersonnel s review of NRC Inspection Reports to identify, track, and correct NRC Inspector identified UFSAR deficiencies-(Section 07.6).
- o Training feedback and evaluation 3rograms were effectively implemented for licensed operator training. Procedure requirements were met and the timeliness of corrective actions was satisfactory (Section 07.7).
e The self-assessment reviewed was a comprehensive evaluation of area "
responsibility. This self-assessment identified aspects of the various programs for improvement. The use of personnel from outside the plant
< as part of the self-assessment team was considered a strength. One maintenance assistant team leader was not aware that there was a
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- procedure for pre-job briefings or what management's expectations were for conducting pre-job briefings (Section 07.8).
-e- The Safety Audit'and Engineering Review'(SAER) Program satisfied the
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requirements of the UFSAR commitment Program implementation was adequate to keep licensee management informed of significant. developing problems-in the areas audited-(Section 07.9).
e The Plant Operations Review Committee activities met the requirements of the Operations Quality Assurance Manual. Appendix C and procedure FNP-0-AP-2. " Plant Operations Review Committee," Revision 17, (Section 07.10).
e Two periodic SAER sumary documents reviewed by the inspectors were of excellent quality and provided licensee management pertinent information to assess corrective actions. The operations department conducted self-assessments and operations management initiated actions to improve personnel performance (Section 07.11).
e .The Root Cause investigations were typically thorough. The Root Cause determinations reviewed were accurate and corrective actions were appropriate (Section 07.12), Occurrence report commitments were being closed in a timely manne . Poor tracking of Occurrence Report commitment due date extensions was
. identified as a weakness (Section 07.13)
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Enclosure
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o The Commitment Action Tracking Licensing Information Processing System was an effective tracking mechanism and aided the licensee in tracking open commitments. The root cause determinations and corrective actions for the Licensee Event Re> orts (LER) reviewed were detailed, accurate and timely. Reporting of _ERs was consistent with event reporting guidelines (Section 07.14).
e The Corrective Action Report process adequately tracked NRC violation Event cause analysis determinations, safety assessments, and effectiveness of ccrrective actions were generally satisfactor Reports were complete and comprehensive, with some minor administrative errors (Section 07.15).
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Enclosure
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Reoort Details I. Ooerations 07 Quality Assurance in Operations 07.1 Problem Identification and Resolution Insoection Scooe (40500)
The inspectors assessed the licensee's programs for identifying and correcting problems. The inspectors reviewed procedures FNP-0-ACP-5 " Equipment States Control and Maintenance Authorization." Revision (Rev.) 24. - FNP-0-ACP-52.2. " Work Order Development and Approval".
Rev. 3. and FNP-0-ACP-52.1. " Guidelines for Scheduling of On-line
. Maintenance." Rev. 2. The inspectors reviewed selected deficiencies submitted and work orders (W0) developed over a 2-week period to evaluate the ability to identify and characterize problems, Observations and Findinas When-deficiencies were identified, deficiency reports (DR) were generated and submitted to a dispatcher. A deficiency marker, generally a tag or sticker, was attached on or-near the deficient com>onent to-identify the fact that the deficiency had been reported. Tie dispatcher was responsible for the initial safety assessment and evaluation of the '
DR and informing the Shift' Supervisor (SS) if the deficiency affected operability or reliability of a function required by the Technica Specifications (TSs). The dispatcher was also responsible to assign-work' priority and the work need date. Work orders (W0s) were developed from the DR All individuals performing the functions of t' he dispatcher had -
significant experience. Most had current or formerly held a Senior-Reactor Operator licens The DRs and-W0s~ reviewed by the inspectors indicated that the dispatchers ap3ropriately-assessed the potential significance of the deficiency. T1e deficient conditions were either being worked. were scheduled for work in the near future, or tracked for unit outage wor 'The inspectors observed that the deficient-items were appropriately-tracked. The inspectors observed that the proposed corrective actions for. the deficiencies were approariate. The deficient items identified and tracked for unit outage wor ( were appropriate. Equipment failure history was maintained. The inspectors verified that some deficiency markers had been placed as. require Enclosure
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2 Conclusions All DRs and W0s reviewed by the inspectors were appropriately assessed
- for potential significance by the licensee. Long term work items were appropriately tracked and categorized-for unit outage wor .2 Review of Maintenance Work Order (MWO) Backloa and Corrective Actions Insoection Scone (40500)
The inspectors reviewed the licensee's backlog of MW0s for the period of June 1995 through July 1997 for timeliness of completion and to determine if backlogs were at reasonable levels, Observations and Findinas The inspectors reviewed a compilation of monthly totals of the plant MWO-backlog, divided into four components: mechanical, electrical, I & C, and com) uter support. The -inspectors noted that the backlog included outage W0s and that it had remained relatively stable until the fourth >
quarter of 1996, at approximately 1000 MW0s. An avcrage increase of over 200-MW0s was noted from that time to the present. The inspectors compared the results of July 1996 with those of July 1997-and noted that the largest increase from 1996 to 1997 was in the electrical groupin an increase of over 75% (from 175 in 1996 to 317 in 1997).
The inspectors discussed the MWO backlog with the licensee's maintenance manager, who identified the 1996 increase as being due essentially to-Kaowool issues being identified and added to the backlog at that tim He stated that the backlog was slowly being reduced and that each MWO averaged an exgnditure of approximately 50 man-hours to complet . Inefficiencies in scheduling the work had also prevented the backlog from being reduced more rapidly. In addition, plant management planned to-send some Farley personnel to support the com)any's other nuclear units during their upcoming refueling outages, t1ereby reducing qualified staff- for working off the backlog. The maintenance manager also stated that the sensitivity for writing deficiency cards was such that approximately 90% of them were for very minor items which had no effect on the safe operation of the plan Conclusions The inspectors concluded that the licensee s MWO backlog.was reasonable and thatiefforts made by the licensee to reduce it were satisfactor Enclosure
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07.3 Procedure Deficiency and Corrective Actions Review Insoection Scooe (405001 The inspectors reviewed procedures FNP-0-AP-1 "Develoxnent. Review and Approval of Plant Procedures." Rev. 35. FNP-0-AP-30. ") reparation and Processing of Occurrence Reports and Licensee Event Reports." Rev. 2 and FNP-0-AP-88 " Nuclear Safety Evaluation." Rev. 1. and assessed the licensee's disposition of identified procedure deficiencies. Some deficiencies required temporary procedure changes and others were characterized as minor administrative deficiencie Observations and Findinas The inspectors observed that the licensee did not write deficiency reports for procedural deficiencies. Procedure FNP-0-AP-52 identified a deficiency as any condition that deviates from the design condition or any com,inent that does not accomplish its intended function. The procedure did not specifically identify a procedure problem as a deficiency. The licensee depended upon the procedure user to identify procedure deficiencies and, if the deficiency resulted in difficulty in completing the assigned task, a temporary procedure change was to be implemented. The inspectors observed that, in general the temporary procedure change process was being satisfactorily implemented. The inspectors reviewed selected temporary procedure changes and verified that they were completed in accordance with the procedural requirement The inspectors observed that there were several informal and non-proceduralized problem identification and tracking programs that were not considered part of the formal corrective actions programs. This included actions for operations procedure deficiencies, maintenance procedure deficiencies, deficiencies in the Emergency Preparedness are and licensee actions for NRC-identified Untiated Final Safety Analysis Report (UFSAR) deficiencie The inspectors observed that the operations group had-an informal process to track procedural deficiencies. A computer data base was maintained by operations support personnel. When operations procedure problems were identified individuals reported the problems by phone or electronic mail. Operations support personnel documented the comments and recorded the comments in the data base. The inspectors observed that approximately 410 items were in the data base and some were identified as early as 1993. The data base included deficiencies for System Operating Procedures. Abnormal Operating Procedures. Surveillance Test Procedures. Fuel Handling Procedures. Emergency Implementing Proc Wures. Fire Surveillance Procedures, and Alarm Response Procedure The inspectors observed that many of the deficiencies were typographical errors or other similar minor discrepancies. These items were not
. included in any other site corrective actions tracking program and were not considered a part of the official corrective actions program. The Enclosure
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inspectors conducted a detailed review of selected deficiencies identified in 1993 and 1994 for System Operating Procedures and TS-required Surveillance Procedures. The following observations were made from the review:
s e On July 17. 1993, while returning a diesel generator air compressor to service, a procedure step identified that the oil pressure should be 25 as The individual identified that the vendor manual stated t1e oil pressure should be 18 to 20. The data base indicated that the problem was being researched in October 1996. The inspectors observed that the procedure step still indicated 25 psi and that the item was still open.
e On November 11. 1993 step 4.4 of procedure 2-SOP-1.4. which dealt with a reactor coolant leak test, was identified as being too vague. VT 2 examiners did not like the ambiguity of the step with respect to what action the examiners take. The inspectors observed that the procedural step had not been changed and that the item was still open.
e On January 7. 1994. Surveillance Procedure 1-STP-18.1. which dealt with a containment purge and exhaust isolation test, contained a note on page threa that directed the user to procedure step 5.1.10 instead of step 5.1.9. The inspectors observed that the note stated. "If check source level is NOT sufficient to trip High-High level alarm AJLD. damper isolation. THEN perform step 5.1.1 Otherwise proceed to step 5.1.11." The correct step was 5. not step 5.1.10. The inspectors observed that step 5.1.9 realired manual actions in order to meet the procedure's acceptance criteria. The inspectors also observed that the procedure was revised on June 19, 1995 and that this comment and correction were not include The inspectors discussed the deficiency list with operations support personnel, who maintained the informal data base, and operations management. The inspectors were informed that maintaining the data base was not proceduralized. There were no written instructions on what the expectations were for assessing significance of deficiencies timeliness of closing out items, or report generation for the status of the deficiencies. The inspectors were informed that there was little or no management oversight of the deficiency list and the data base had not been the subject of any formal or informal audit. Management personnel informed the inspectors that the intent of the data base was to document minor grammar or typographical errors that would be included in the next procedure revishn and was not intended to document deficiencies that may result in procedural misusage or items that required immediate temporary change Some management personnel suspected that the use of the data base may have evolved beyond its initial intentio Supervisory personnel informed the inspectors that they were considering changing the process to include more direct control and revie Enclosure
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5 i The inspectors did not identify any procedure deficiency that caused a violation of regulatory requirements, however, a vulnerability existed for procedural-usage error Conclusions The inspectors observed that there were several informal and non-proceduralized problem identification and tracking programs that were -
not consioered part-of the formal-corrective actions programs. This resulted in low level events or problems not being tracked in the i corrective actions process. The data base maintained for o)erations ;
procedure deficiencies provided a good vehicle to capture t1ese type of deficiencies. However.:a weakness was identified for the overall process. -The weakness was based upon the large number and duration of procedure deficiencies the lack of management oversight and specific guidance, and unclear expectations for maintaining the data base to-ensure that significance of the deficiencies and corrective actions were timely and appropriat .4 06eratina Exoerience Feedback. Review of Disoosition of Minor NRC Findinas InsDection Scoce-(40500)
The inspectors reviewed procedure FNP-0-AP-65. "FNP Operating Experience Evaluation Program." Rev. 7. and discussed with management personnel its-actions in response to NRC minor findings noted in Inspection Reports (irs). These findings were not violations, deviations, unresolved: items or inspector follow up items, i.e., they did not have an NRC report number designatio Observations and findinas During the ins)ectors' review of site procedures for DCs. Occurrence Reports and otler tracking or corrective action programs the inspectors did not identify procedures _that addressed licensee' actions in response .
to NRC minor findings' that were not assigned an IR number. The inspectors observed that procedure FNP-0-AP-65. also did not address minor NRC findings. The inspectors discussed this observation with licensee management and were informed that unnumbered items were not monitored-or tracked for resolution. These items were not included in any other site corrective actions tracking program and were not considered a part of the official corrective actions program. The inspectors were informed that if the NRC inspectors specifically discussed the minor finding with department personnel responsible for
.the deficiency, the department personnel generally would correct the proble Enclosure
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I The inspectors randomly selected three items to determine. licensee
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actions to address these items. The items were as follows:
e ;An observation. documented in IR 50-348. 364/96-09, that dealt with L minor discrepancies with installation drawings for design change-
-package S95-2-8982. The inspectors observed that the drawings were revised in a timely manner and the design package was
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complete e- An observation documented in IR 50-348, 364/96-15. that dealt with l non-licensed operator performance during plant tours that were not
effective in identifying problems. In this and previous report numerous examples were identified, of instances of degraded material conditions, poor housekeeping, inadequate lighting, and i
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- other deficient conditions. The inspectors observed that licensee management iad initiated some actlons such as coaching.
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- discussions and reviews of some problems at shift meetings. The inspectors observed that management actions generally focused on the departments that were directly affected and did not view the
)roblems as being generic Site Safety Assessment Engineering
- Review (SAER) audits and Licensee Self-Assessments conducted from about 1993 to the present identified that performance problems in i various departments still exist.
1 e IR 50-348, 364/96-02.- identified a minor discrepancy between a
plant practice and the UFSAR. Section 7.7.1 of the UFSAR directly implies that Tavg is controlled by rod movement. The plant practice is to control Tavg by diluting or borating the reactor
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coolant system. On August 29. 1997, this item was still open UFSARdiscrepanciesarediscussedinmoredetailinSectiond7.6
of-this report.
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The. inspectors concluded that, although the licensee had taken actions to correct some NRC minor observations. identified in irs. -the actions were generally narrow in focus and were not always effective.
1 07.5' Review of Problem-Identification and Corrective Actions in Emeraency Preoaredness 4-
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The inspectors reviewed procedure FNP-0-EIP-15. " Emergency Drills."
e Rev. 21. and assessed licensee corrective actions for problems that were
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7 Observations and Findinas The inspectors observed that section 5.6 of procedure FNP-0-EIP-15 requires that equi) ment, procedure, performance, training, drill, et deficiencies will ae summarized in a written critique format. The inspectors reviewed the list of identified deficiencies which was maintained on an " Emergency Planning Punchlist" The inspectors observed that the list contained 211 open items. Two items were identified in 1990 and one was identified in 1991. The data base indicated that the three items were classified as " implementation in progress" and were scheduled for closure in 1998. Most of the items were classified as " highly desirable" or " Comment" items. The inspectors observed that most items were being evaluated and had been assigned an estimated closure date. The inspectors observed that items listed in the " Emergency Planning Punchlist" were not included ir. any other site corrective actions tracking program and were not considered to be a part of the official corrective action progra The inspectors selected four items to review in deta' ~
assess licensee corrective actions. As part of the review, tne inspectors observed that procedure FNP-0-EIP-6.0. "TSC Setup and Activation,"
Rev. 30, was revised with the appropriate 10 CFR 50.59 review, to close a "punchlist" item. There were no deficiencies identified with three of the four items selected for review. One item, which was identified in December 1995 during an annual Emergency Preparedness (EP) exercise, dealt with security force members on posts and the roving patrols that could potentially be in the radiological contamination release pat Therefore they need access to dosimetry so that they can read an individual's current dose. This item was identified as close Licensee documentation indicated that part of the corrective actions were to evaluate having the roving patrol pick up dosimetry at the Emergency O personnel. perations Facility and deliver it to the appropriate The inspectors contacted security management >ersonnel to discuss the issue and to review the procedure chanaes. T1e inspectors observed that
, no security or other Emergency Implementing Procedure (EIP) had been revised to include the corrective actions. Security management provic:d a required reading training list, which documented that training was conducted as part of the corrective actions. The inspectors reviewed the required reading document and observed that it discussed the issue and provided specific directions for security personnel actions. The inspectors interviewed one security staff member who had just completed roving post duties to gain his understanding of what actions were required to obtain dosimetry for security members on roving patrol or stationed at other posts during emergency conditions. :he security staff member was not sure of what actions were required to be taken. As a result. security management re-issued the required reading training document as part of their immediate corrective actions to reinforce the requirements. Additionally, security management drafted a procedure Enclosure
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. revision to the EIPsf clearly identifying security member actions and Lrequirements to obtain dosimetry during accident conditions. The
= inspectors were-informed that a communication *s error and a lack of clear understanding of the corrective actions between EP and Security personnel resulted in the item being incorrectly closed out. The inspectors did not view this as significan The inspectors observed that maintaining the " Emergency-Planning Punchlist" was not proceduralized. There were no specific procedural
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. instructions for any aspect of the data base. The inspectors observed that emergency planning supervisory personnel maintained the data base and had established priorities, order of importance, description of comment, source of comment, assigned date (date item assigned to the responsible group) status, comments / disposition, and estimated closure date. The inspectors observed that the list was routinely routed to management personnel for their revie The inspectors reviewed documentation which indicated that SAER had-conducted at least one audit on the "punchlist." However. SAER management stated that the "punchlist" was not routinely audited but may be included as aart of other planned audits. The licensee did not consider this " Emergency Planning Punchlist" data base as part of the formal corrective action progra Conclusions Problem identification and corrective actions were effectively implemented in the Emergency Preparedness area. Trending, tracking and timeliness of corrective actions were appropriate for the identified problems that were reviewed. There were no procedures for clear guidance and expectations to ensure that the administrative aspects and other elements of-this problem identification and corrective actions-program were consistently implemente .6 - Review of Corrective Actions for NaC-Identified UFSAR Deficiencies Insoection Scoce (40500)
- The inspectors reviewed NRC-identified UFSAR deficiencies that were documented in NRC irs during 1996, and reviewed licensee actions to implement corrective action b; Observations and Findinas During the week of June 16, 1997, the inspectors visited the site to discuss material needs to com)lete the inspection activities scheduled -
-for the week of August 25. T1e inspectors requested a copy of licensee procedures that were used to track, evaluate, and correct NRC inspector-identified UFSAR deficiencies. The inspectors were informed that site personnel did not implement these corrective actions, and Enclosure
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currently site personnel were taking no action to correct identified problems. Tha licensee did not have site procedures or other processes in place to address these specific deficiencies. The inspectors were informed that the corporate review of the NRC 1Rs would detect the problems and corporate personnel should make the necessary changes to the UFSA During the week of the inspection, the inspectors were informed that site personnel had reviewed some NRC 1Rs and documented the UFSAR deficiencies the previous week. The deficiencies were being documented on an existing data base that corporate personnel used to document licensee identified UFSAR deficiencies. The inspectors observed that the deficiencies were being included on the Commitment Action Tracking Licensing Information Processing Syste The inspectors selected eight NRC identified UFSAR deficiencies identified in 1996, and discussed the items with site )ersonnel recently assigned to review the problem. Some type of actions lad been taken for four of the eight items. The licensee considered the four items closed, based upon !'FSAR revisions or pending UFSAR revisions. The remaining items were still being evaluated to determine what actions would be rec uired. it was apparent to the inspectors that cor) orate personnel hac taken some actions for the previously-identified JFSAR deficiencies, but it was not clear if all NRC-identified UFSAR deficiencies had been detected or assessed by corporate personne The inspectors were informed that site procedures had not been developed: out that develo) ment of procedures was being evaluated for site personnel to review NRC irs. to document and assess the significance of NRC-identified UFSAR deficiencies, and to ensure that corrective actions were a)propriate and timely. The NRC inspector identified UFSAl deficiencies were not included in any part of the site's formal corrective action program, Conclusion Until just 3rior to the NRC inspection, site personnel were taking no actions witi respect to NRC inspector-identified UFSAR deficiencie Site personnel did not have procedures or a process in place to record the deficiencies, assess their significance, or track actions to ensure that corrective actions were ennropriate and timely, Site personnel relied upon corporate personnei .; review of NRC 1Rs to identify, track, and correct NRC Inspector-identified UFSAR deficiencie Enclosure
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07.7 Review of Trainina Feedback and Evaluation Proarams Inspection Scone (40500)
The inspectors reviewed procedure FNP 0 TCP 1.0 "Feley Nuclear Plant Training Feedback and Evalunion Programs." Re',.16. and licensee actions taken in response to feedback, Observations and Findinas The inspectors selected eight feedback forms submitted following training conducted in August 1996. The inspectors reviewed licensee assessment of the f tems, actions taken in response to the feedback comments, and the timeliness of actions taken. The inspectors observed that some procedure changes had been implemented based upon comments received. The procedure changes were completed with the appropriate 10 CFR 50.59 evaluation. The licensee determined that for some comments, training changes were not needad. The inspectors observed that section 6.0 of procedure FNP-0 TCP-1.0. stated in aart. that if &ange actions were initisted as the result of feedback, tie training supervisor should inform the source of the feedback of the action taken. The intent was to close the feedback loop and keep trainees and supervisors informed of training's response to feedback. The inspectors observed that no form of feedback was required for items submitted that did not require a training change action. The inspectors discussed this observation sith management personnel, Conclusions Training feedback and evaluation )rograms were effectively implemented for licensed operator training. )rocedure requirements were met and the timeliness of corrective actions was satisfactor .8 Self- Assessments Insoection Scoce (40500)
The inspectors reviewed the licensee's documentation of a comprehensive self-assessment dated March 21. 199 Observations and Findinas The inspectors observed that the self-assessment was conducted by a team of nine individuals between February 10-19. 1997. The report was issued March 21. 1997. The assessment included personnel r.ot only from within the plant staff, but from other nuclear plants within the SNC organization. The assessment addressed the following areas:
Operations. Maintenance. and Engineering Support. The overall
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assessment was considered to be good. The assessment identified strengths and concerns, and offered comments. The self-assessment Enclosure
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document reviewed by the inspectors did not make specific recommendations for corrective actions, but identified general areas where programs or elements of programs could be improve The inspectors reviewed in detail a concern that was identified in the self-assessment to determine what corrective actions had been complete The item dealt with the quality of the pre-job briefings for maintenance activities. The inspectors were informed that as part of overall maintenance performance improvement activities, a maintenance job participation checklist had been recently issued to ensure that maintenance supervision routinely participated in work activitie The inspectors interviewed one maintenance team assistant team leader to discuss the items identified on the Maintenance Job Participation Checklist. Item 11 of the checklist was for pre-job briefings. The assistant team leader was not aware that the pre-job briefing was covered by a plant procedure. The inspectors also observed that some maintenancemanagement)ersonnelwerenotawarethatprocedure FNP-0-ACP-1 Pre-Jo) Brief." Rev. O. existed. The assistant team leader was not sure as to who was responsible for holding the pre-job briefing. to what detail the briefing should be conducted, or who should attend. The checklist also discussed whether or not industry experience was included in the pre-job briefing. The assistant team leader was not sure how to get industry experience information, and stated that he might get some industry experience information bu e-mail but generally industry events were not covered in the pre-job botefing. The assistant team leader demonstrated a good safety focus and was aware of the pre-job briefing card used by many personnel. These NRC observations were discussed with appropriate site management, Conclusions The self-assessment reviewed was a comprehensive evaluation of areas of responsibility. This self-assessment identified aspects of the various programs for improvemen The use of personnel from outside the plant as part of the self-assessment team was considered a strength. One assistant team leader was not aware that there was a procedure for pre-job briefings or what management's expectations were for conducting pre-job briefing .9 Review of Safety Audit and Enaineerina Review (SAER) Proaram Insoection Scone (40500)
The inspectors evaluated implementation of the SAER Program with regard to scope and responsibilities, position in the plant organization according to UFSAR Chapter 17.2. Operational Quality Assurance Progra licensee procedures and TSs. Selected SAER audits were specifically reviewe Enclosure
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b. Observations and Findinas The ins)ectors discussed the structure and specific responsibilities of the SAEl with licensee supervision to ensure that the program's implementation satisfied the requirements of the UFSAR, including independence from operational considerations. The inspectors reviewed the audit schedule for the current year for compliance with UFSAR-regt..ted subject audit areas and frequency. The audits had been predominately performance based for the past several years but had begun to shift their focus to first principles (e.9., items identified in the UFSAR, Appendix R, etc.). The inspectors selKhd the folbwing audits for review:
S96-069 (Audit 96 0A/41-1), Refueling Outage Activities S97-022 (Audit 97-0A/41), Refueling Outage Activities 596-046 (Audit 96-FP/12 1), Fire Protection S97-076 (Audit 97-FP/12 1), Fire Protection The ins)ectors determined that the audits were comprehensive and thoroug1. Audit findings were categorized into one of three items:
audit finding reports (AFRs), defined as conditions which did not meet s)ecific minimum conditions; comments, defined as an auditor's statement w11ch serves to call attention to, explain, or otherwise coment on matters relevant to the audit: and recommendations for correcting program deficiencies or impcoving the cuality assurance program. AFRs required a formal res)onse from the aucited group and were reviewed by the Vice President, w1o could accept or reject proposed corrective actions. These corrective actions were tracked by plant management until appropriate approved action was taken to resolve the findin These items were re-audited prior to closure. Comments required action to be taken and a response from the manager of the audited department, and were followed up during the successive audit to review the appropriateness of the action taken. Recommendations were treated as suggestions and no formal problem resolution was require The inspectors reviewed the handling of these different items, from original presentation in an audit to final resolution and disposition, and determined that they were appro)riately resolved in a timely manne Although Corrective Action Reports lad been established for the AFRs no significant work had been done on some of these because the audit had been comoleted cuite recently, within the previous two weeks. The (m inspectors notec that the reviewed audits were conducted within the UFSAR-required frequenc Enclosure
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The SAER staff consisted of six auditors and a supervisor. The auditors rotated from a given department for a period of between three to five years, at which time they returned to their original department. The current staff included three from operations, and one each from health physics maintenance, and general engineering. The inspectors interviewed one of the auditors concerning independence from normal plant operations. The auditor stated that there was no pressure put on him from his former department to "go easy" during an audit. He also stated that having a strong background and experience in a given department was an advantage because it gave him insights into the workings of the deaartment and its personnel not easily observed by a person without suc1 familiarity. He viewed his role as important to maintain the plant's overall performance, c.-- Conclusions The inspectors concluded that the SAER Program satisfied the requirements of the UFSAR and its implementation was adequate to kee)
licensee management informed of significant developing problems in tie areas audite .10 Review of Plant Ooerations Review Committee (PORC) Activities Insoection Scoce The inspectors reviewed the Operations Quality Assurance Manua Appendix C. Rev.13. Technical Specifications Section 6.5.1, and verified that the PORC met the a)plicable requirements. The inspectors reviewed Rev.17. procedure FNP-0-AP-2, and verified ")lant that selected Operations functions were Review Comittee."
appropriately performed in accordance with the procedur Observations and Findinas-The inspectors observed that section 7.6 of 3rocedure FNP-0 AP-2
. identified typical documents to be reviewed )y the PORC. The inspectors selected two periodic SAER sumaries, documents SAER 596 016. dated March 16. 1996, and SAER S97-079, dated August 14. 1997, of FNP non-compliances and _ verified that the PORC had fulfilled its requirement to conduct a review of the documents. The inspectors also observed that the PORC had conducted reviews for selected Licensee Event Report Corrective Action Reports and Occurrence Reports. The inspectors did not identify deficiencies with respect to membership, alternate designation, quorum, or frequency of meeting Enclosure
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! Conclusions ,
The inspectors concluded that the Plant Operations Review Committee activities met the requirements of the Operations Quality Assurance Manual. Appendix C. and procedure FNP 0-AP-2. " Plant Operations Review Committee." Rev. 17.
l 07.11 Review of SAER Periodic Reoorts
- Insoection Scone (40500)
The inspectors reviewed 3rocedures FNP-0-AP 2. "P; ant 0)erations Review Committee " Rev.17 and :NP-0-AP-7. " Corrective Action Reporting "
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Rev. 15. which describes periodic reports submitted for appropriate plant management corrective action review. The inspectors reviewed two periodic SAER summary documents. SAER 596-016. dated March 16, 1996, and SAER 597-079, dated August 14, 1997. to assess information presented to plant management for its review to ensure that sufficient action was proposed, that proper review and approval was provided and that the action was carried to completio Observation and Findinas The inspectors observed that both SAER documents presented a trend analysis of Operations Quality Assurance Findings. In combination, the documents ) resented data from 1993 through 1996. The data analyzed included NRC Inspection Report findings. LERs. SAER Audit findings, and corresponding Corrective Action Reports. The inspectors observed that the reports were very detailed. ) resented pertinent information to assess Corrective actions. and slowed both improving and declining trends. The findings were categorized into various plant groups snd each included cause codes. The report also contained a detailed breakdown of findings by subgroup for each department manage The August 14. 1997, report indicated that the majority (89%) of findings was attributable to personnel errors in 1996. The report also identified that the data reem)hasized the need for continued management efforts to improve personnel labits regarding self-verification and attention to detai SAER's summary of FNP Noncompliances, dated May 16, 1996. indicated that personnel errors were the causes of about 92% of all findings, especially in the area of maintenanc The inspectors observed that the majority of personnel errors occurred in the maintenance and operations areas. The inspectors reviewed the last two 1997 quarterly reports for Human Performance and observed that the reports svoported the personnel issues identified in the SAER reports. The human performance trend report observed that the significance level of errors has slightly decreased. but an overall upward trend occurred for personnel error <
Enclosure
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Operations has taken several initiatives to reduce the number of personnel errors. They conducted an extensive self-assessment in early 1997. As a result of the self-assessment, operations interviewed-personnel to gain a better understanding of why procedural usage and personnel error problems occurred. Several root causes and corrective actions resulted from the self-assessment. One initiative reviewed by the inspectors was a recent requirement for operations supervisors to conduct observations of assigned personnel. The requirement was part of procedure FNP-0-50P-0. " General Instructions for Operations Personnel."
Rev. 48. The procedure included various lists of expectations for items such as Annunciator Response. Pre-job Briefings. Communications etc.,
for supervisors to observe and make recommendations for improvemen The inspectors observed that many of the expectations were broad in scope and did not contain specific details. This was discussed with operations management which stated that the-procedures still needed to be improve The inspectors observed that procedure FNP-0-?P-6. " Procedure Adherence." Rev. 3 was undergoing a major revision. Additionally, a new procedure. FNP-0-ACP-11. Use of Procedures." was being develo more clearly define management's expectations t'or procedure usag The ped to inspectors observed that the new )rocedure was being developed per the requirements of procedure FNP-0-A)-1. " Development. Review and Approval of Plant Procedures." Rev. 3 Conclusions-Two periodic SAER summary documents. SAER 596 016 and SAER 597-079, were of excellent quality and provided management pertinent information to assess corrective actions. The ins)ectors observed that sufficient corrective actions were proposed tie corrective actions received proper ,
review and approval, and some corrective actions were being implemente The operations department conducted self-assessments and operations management initiated actions to improve personnel performanc ,12 Review of Root Cause Investiaations Insoection Scooe (40500)
The inspector reviewed the licensee's arogram for conducting root cause (RC) investigations as described by FN)-0 ACP-9.0, " Root Cause Program."
Rev.'2.-and FNP-0-ACP-9.1. " Root Cause Investigation." Rev. 1. The-inspectors reviewed nine RC investigations conducted since January 1995 and interviewed personnel involved in conducting those investigation .The inspector also reviewed the training provided to personnel performing RC investigation Enclosure i
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b. Observations and Findinas Procedures FNP-0-ACP-9.0 and FNP-0-ACP-9.1 provided detailed instructions on performing and documenting RC investigation The scope of the investigations was typically broad, with one exception. On June 11.1995. Unit 1 tripped due to the closure of a main steam isolation valve. The MSly went closed due to water intrusion into a junction box in the IB motor driven auxiliary feedwater pump room. As part of the broadness review. the team looked at 11 similar boxes (including the other MSIVs) for signs of water intrusion. Based on the fact that three of the 11 boxes had indications of previous water intrusion, the team opted to expand the scope of the investigation. The team requested Bechtel to provide a broader scope list of Appendix R safe shutdown junction boxes which were not environmentally qualified (EQi but were in E0 area The team inspected the larger sample for unsealed conduits and signs of water intrusion and found 25 of 33 boxes with at least one unsealed conduit and 3 of 33 with indicated yossible water intrusio The team did not expand the inspections furtier because their focus was on the signs of previous water intrusion instead of the potential for water -
intrusion due to unsealed conduit However, upon further review. there were only eight additional junction boxes that met the criteria of the q expanded scope that were not included in the inspection. All deficiencies identified in the inspections, i.e., unsealed penetrations into the junction boxes, were corrected as they were identified. The limited scope of this particular investigation was identified as a negative observation. However, the scope of other reviewed investigations, most of which were performed after this example. was adequat Procedure FNP-0-ACP-9.0. Section 2.8. described the composition of the RC team and stated that at least one person on the team would be trained-on RC investigation. The inspectors reviewed the training documentation for the RC training. There were two types of training provided. A 2-day Root Cause Analysis course taught in September 1992 and March 1993 anda1-daycoursetaughtinFebruary1995. The 2-day course contained detailed lectures on RL analysis techniques, however, the 1-day course only provided approximately three hours of a general RC analysis training. Also, the inspectors determined that the 1-day course was taught by an individual with no formal RC trainin The inspector reviewed the makeup of the RC teams for the selected investigations. In all cases. at least one member of the RC team had some RC analysis training. However in one case, the sole member of the team which had RC training only had the 1-day RC training. The use of the one day RC analysis course to satisfy the requirement of RC investigation training was considered to be a weaknes Enclosure
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17 Conclusions The Root Cause investigations were typically thorough. The determinations were accurate and corrective actions were appropriat .13 Occurrence Reoort Corrective Action Trackina Insoection Scooe (40500)
The inspectors reviewed the licensee's program for tracking Occurrence Report (OR) corrective actions as delineated by FNP-0-AP-3 " Preparation and Processing of Occurrence Reports and Licensee Event Reports." Rev. 22. The inspectors reviewed a selection of ors to verify that corrective actions were entered into the Occurrence Report Commitment Tracking Database and that corrective actions were completed in a timely manner, Observations and Findinas The inspectors determined that all corrective actions identified in the selected ors were entered into the data base. The corrective actions were ty)1cally closed in a timely manner. The inspectors noted that, while t1ere were procedural requirements for the responsible manager to approve changes in or deletion of corrective action commitments there were no procedural controls for extending corrective action completion dates. Changing a corrective action commitment required fillin form and formally obtaining the responsible manager's approval.g out a Changing a corrective action completion date only required a telephone call to the engineer managing the database. However, once the completion date was changed, there was no tracking mechanism to identify how many times the date had been changed or how much it had been extende The inspectors reviewed the licensee's list of overdue OR corrective action commitments for the weeks of August 1 and 22, 1997. On August 1-there were 36 overdue commitment The number of overdue commitments dropped to six by August 22. The inspector compared the list of overdue items on August 1 to the open item list (not overdue) as of August 26 and fo m d that of the apparent closure of 30 overdue commitments was, in fact a closure of 1 item and an extension of the commitment dates of the other 29. The )oor tracking of commitment date extensions was-identifled as a wea(nes The inspectors reviewed the list of open occurrence report commitments and determined that the commitments were being closed in a manner, commensurate with the item's significanc Enclosure
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18 Conclusions Occurrence report commitments were being closed in a timely manner. The poor tracking of Occurrence Report commitment due date extensions was identified as a weakr9s .14 Licensee Event Reports Insoection Scooe (40500)
The inspectors reviewed procedures. FNP-0-ACP-9.0, " Root Cause Program."
Rev. 2. FNP-0-ACP-9.1. " Root Cause Investigation." Rev. 1. FNP 0-AP-3 " Preparation and Processing of Occurrence Reports and Licensee Event Reports." Rev. 22. and NUREG 1022. " Event Reporting Guidelines 10 CFR 50.72 and 50.73." Additionally. the inspector reviewed four selected Licensee Event Reports (LER) from 1996 and 1997, with respect to root cause determinations, broadness reviews, safety assessments. and identification and im)lementation of corrective action Also, the licensee tracking metlodology was reviewed for accuracy and completeness. Licensee personnel involved with the LER process were interviewe Observations and Findinas The licensee used a computer database. the Commitment Action Tracking Licensing Information Processing System (CATLIPS). to track LER commitments. The commitments in each LER were identified and were assigned a specific NRC commitment number, due date, and responsible department The LERs received a high level of management attention and review. L5Rsandassociatedcorrectiveactionsweregenerally well-tracked, and licensee-generated due dates were generally me Corrective actions and root cause analysis were reviewed for LER 50-364/96-004-00. Manual Reactor Trip Due to Rod Control System Malfunction and LER 50-348/96-003-00. Actuation of Engineering Safety Feature Equipment Due to an Apparent Relay Contact Failure. The troubleshooting activities, root cause analysis, and broadness reviews were detailed, accurate and complete. Corrective actions were appropriately tracked. LER 50-348.364/96-004-00 was disenssed in detail in IR 50-348.364/96-1 The inspectors also reviewed the following LERs:
- LER 50-348/97-010-00. Motor Operated Valve Local - Remote Control Circuit Wiring Discrepancies: All corrective actions for the LER were considered complete by the licensee. The tracking database was current and documentation existed to demonstrate that corrective actions were complete. However, the LER safety assessment did not clearly address the result of these valves being out of service during a shutdown from the Hot Shutdown Panei Enclosure
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(HSDP). This observation was discussed with the Unit 1 Operations managemen The licensee conducted an initial review of the LER and stated that the safety assessment was not clear. Later, licensee supervision stated that a more detailed review of LER safety assessment would be required to determine if 10 CFR 5 Appendix R issues were fully evaluated. This LER will remain open for continued inspector's review of the safety assessment and corrective action * LER 50-348, 364/97-009-00. Lack of Missile Protection For Service Water Flow Switches: The corrective actions for the LER remained open and were accurately categorized and tracked in the CATLIPS database. The LER safety assessment and corrective actions to implement a design change and remove the flow switches from the system (and therefore remove the associated automatic function)
was being reviewed and assessed by the inspectors. This LER will remain open.
- Event descriptions, causes, and corrective actions were satisfactorily detailed in the LERs and transcribed, as appropriate, into the CATLIPS databas Conclusion The Commitment Action Tracking Licensing Information Processing System was an effective tracking mechanism and aided the licensee in tracking open comitments. The root cause determinations and corrective actions for the LERs reviewed, except for the deficiencies noted, were detailed, accurate and timely. The reporting of the LERs was consistent with the event reporting guideline .15 Corrective Action Effectiveness for Violations Insoection Scone (40500)
The inspectors reviewed the licensee's program for tracking the CARS which had been developed for NRC Violations, as described in FNP-0-AP-7,
" Corrective Action Reporting," Rev. 15. Eleven CARS and four Non-Cited Violations (NCVs), with associated site-generated Occurrence Reports (ors), written between 1995 to 1997, were reviewed. Specifically addressed were the event cause analysis determinations, safety assessments, and effectiveness of corrective actions. Additionally, the inspectors reviewed the licensee's tracking methodology for accuracy and completeness. The inspectors discussed the CAR process with personnel responsible for program implementatio Enclosure
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b. Observations and Findinas Licensee actions for Violation (VIO) 50-348, 364/97-05-03. Failure to Follow Multiple TS Surveillance Requirements, and associated CAR 2288, were reviewed. The event analysis was satisfactory and corrective actions were comprehensive and complete. The licensee appropriately identifled this problem as a generic issu The CAR procedure was followed and ensured adecuate management review of the issue. Licensee actions were complete anc resulted in a request for a TS amendmen Other corrective actions reviewed by the inspectors were satisfactor A review of VIO 50 348, 364/97-130-03014 Failure to Identify the Degraded Penetration Room Boundary, associated completed surveillances, and discussions concerning the condition of the Penetration Room Filtration (PRF) boundary with the system engineer were conducte Unit 2's PRF boundary had recently satisfied the operational check identified in FNP-2-STP-20.0, " Penetration Room Filtration System Train A(B) Quarterly Operability and Valve Inservice Test " Rev.16. The PRF boundary condition had teen significantly improved and the licensee had established a method of monitoring and repairing the boundary. The PRF boundary of Unit 1 had not yet satisfied the criteria established in FNP-1-STP-20.0. " Penetration Room Filtration System Train A(B) Quarterly Operability and Valve Inservice Test." Rev. 26 and therefor Maintenance Work Order (MWO) M-542559 was outstanding to correct this problem. The Unit 1 3rocedure was revised to incorporate a method to identify and correct )RF system boundary leakage. Although the Unit 1 PRF boundary has not yet satisfied the STP-20.0 criteria, the boundary conditions have been significantly im) roved since the violation was identified. The CAR system ensured tlat corrective actions were completed in a timely manner, and were brought to senior management's attentio The following CARS, ors, and licensee Audit Finding Reports (AFR) were reviewed, with regard to the generic issue of procedural adherence deficiencies:
e VIO 50-348, 364/95-18-05. Failure to Follow Procedures - Multiple Examples:
e 96-0A/41: AFR 97-24 Procedural adherence with regards to N/A*ing procedure step; e OR 2-96-372. associated with NCV 50-348, 364/96-15-01. Failure to Establish RCS Vent Path During Midloop:
e V10 50-348, 364/97-03-01, Multiple Examples of failure to Follow Procedure:
Enclosure
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e NCV 50-364/97-08-01. Failure to Foifow Procedure for the Penetration Room Filtration System: and e NCV 50-348, 364/97-08-05. Failure to Follow Fume Hood Procedur The root cause evaluation for VIO 50 348. 364/95-18-05 was detailed and comprehensive. Corrective actions were developed, implemented, and completed by March 27, 1996. On December 4. 1996, another )rocedural adherence problem occurred when the licensee failed to esta)lish a RCS vent path during midloop operations. The major cause category code for this event was personnel error with regards to procedural adherenc The corrective action for the December 4 problem was to stress procedural adherence during training. However, during management review of the corrective actions, management determined that adequate corrective actions were already in-place and no additional changes to the training were required. IR 50-348, 364/97-03, identified additional procedural adherence problems, which were documented as VIO 50 364/97-03-01. In addition, IR 50-348. 364/97-08 identified more procedural adherence problems, which were documented as NCVs 50-364/97-08-01 and 50-348, 364/97-08-05. Also licensee Audit Finding Report. AFR 97-24. dated June 18. 1997, identified a continuing problem
[ with respect to procedural adherence. During the analysis review for VIO 50-348. 364/97 03-01, the licensee identified that some corrective actions implemented for VIO 50-348, 364/95-18-05 were not as successful as desired. As a result, additional corrective actions were established to address the continued procedural adherence proble Occurrence Report (OR) 2-96-372, had corrective actions which included revising, for both units, the standard operating procedures for partial reactor coolant system drain and the unusual operating procedures concerning midloop operations. The corrective actions were not adequately transcribed into the OR corrective action database, in that the corrective action to update both the Unit 1 and Unit 2 midloop procedures was not entere Subsequently FNP-2-0MP-4.3. "Midloop Operations." Rev. 7, was not updated. Additionally, a corrective action to update a training lesson plan was closed out in the formal tracking system, based on its being tracked in an informal tracking syste These items were considered minor administrative error The following items were also reviewed by the inspectors to assess the licensee's corrective actions:
e Occurrence Report 1-97-006. which concerned NCV 50-348, 364/96-15-02. Inadequate Procedure Guidance For Freeze Protection, was properly documented and adequate corrective actions were identi fied. The OR corrective action due date was extended twice and was not yet complet Interviews indicated that the corrective actions were to be completed prior to the first winter's freez Enclosure _ _ _ _ _________
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e Five Corrective Action Reports (CARS) (2170, 2193, 2217, 2218 and 2235) were reviewed and found to be complete, comprehensive, and adequately ensured that corrective actions for NRC violations were tracked and resolved, e Corrective Action Report 2139 was issued in response to V10 50-364/95 08 04. Loss of Personnel cnd Material Control in the Unit 2 Spent Fuel Pool (SFP) Controlled Radiation Area Boundary (CRAB). The corrective actions were focused on the SFP CRAB and did not address other potential areas of concern. Subsequently, in IR 50-348. 364/96-13. the NRC discussed the considerable number of minor instances of foreign materials entering the Unit 2 SFP and reactor cavity, during Unit 2 Refueling Outage 11. The licensee addressed the foreign material exclusion events via the OR process and the number of occurrences of foreign material issues was significantly reduced during the following Unit 1 Refueling Outage 1 Conclusion The Corrective Action Report process adequately tracked NRC violation Event cause analysis determin8tions, safety assessments, and effectiveness of corrective actions were generally satisfactor Licensee response and corrective actions for NRC v.olations were generally complete and comprehensive, although some minor administrative errors were identifie II. Maintgnantg M8 Miscellaneous Maintenance Issues (IP 40500)
M (Closed Licensee Event Reoort (LER) 50-364/96-004-00: Manual Reactor Trip Due to Rod Control System Malfunction. This event was discussed in detail in Innection Re) ort (IR) 50-348, 364/96-1 No new issues were revealed by t7e LER. T11s item is close M8.2 (Closed) LER 50-348/96-003-00: Actuation of Engineering Safety Feature Equipment Due To An Apparent Relay Contact Failure. This LER was a minor issue and was close M8.3 (Closed) Violation (VIO) 50-348. 364/97-130-03014: Failure to Identify the Degraded Penetration Room Boundar The inspector verified the corrective actions described in the licensee's response letter, dated May 28, 1997, were completed. No similar problems were identifie This item is closed Enclosure
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V. Manaaement Meetinas and Other Areas X1 Review of UFSAR Commitments A recent discovery of a licensee o>erating its facility in a manner contrary to the UFSAR description lighlighted the need for a special, focused review that compares plant practices, procedures and/or
.paramete's to the UFSAR descriptions. While performing the inspections discussed in this re> ort, the inspectors reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspectors verified that the UFSAR word'ng was consistent with the observed plant practices, procedures ano/or parameter X2 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management on Auaust 29, 1997. The licensee acknowledged-the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary, No proprietary information was identifie . PARTIAL LIST OF PERSONS CONTACTED Licensee R. Badham. Safety. Audit and Engineering Review (SAER) Supervisor C. Buck. Manager in Training R. Coleman. Maintenance Manager P. Crane. Nuclear Operations Training Supervisor-S. Fulmer. Technical Manager S, Gates. Maintenance Team Leader D. Grissette. Operations Manager C. Hillman. Site Security Manager H. Jones. Staff Analyst R. Lulling. Planning and Scheduling Supervisor R. Martin. Superintendent Operations Support C. Nesbit. Assistant General Manager - Support-L. Stinson Assistant General Manager - Plant Operations J. Thomas. Engineering Support Manager R. Vanderb W. Warren.y Strategic Emergency AnalystPreparedness Coordinator G. Waymire. Administration Manager P. Webb. Hhnical Training Supervisor-B. Yance, M Manager Enclosure
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INSPECTION PROCEDURES USED IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems ITEMS CLOSED AND DISCUSSED Closed lygg Ites Number Status Descr13 tion and Reference
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LER 50-364/96-004-00 Closed Manual Reactor Trip Due to Rod Control System Malfunction (Section M8.1)
LER 50-348/96-003-00 Closed Actuation of Engineering Safety Feature Equipment Due To An Apparent Relay Contact Failure (Section M8,2)
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V10 50 348,364/97-130 03014 Closed Failure to Identify the Degraded Penetration Room Boundary (Section M8.3)
Discuss.ed Iygg Item Number Status Description and Reference LER 50-348/97-010-00 Open Motor Operated Valve Local - Remote Control Circuit Wiring Discrepancies (Section 07.14) _
LER 50-348, 364/97-09-00 Open lack of Missile Protection For Service Water Flow Switches (Section 07.14)
Enclosure
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