IR 05000373/1997014

Insp Repts 50-373/97-14 & 50-373/97-14 on 970625-28 & 0813-16.No Violations Noted.Major Areas Inspected: Operations.Deficiencies Were Observed in Areas of Emergency Plan Classification & Reporting & Command & Control

ML20198L381
Person / Time
Site:	LaSalle
Issue date:	10/17/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198L372	List: IR 05000373/1997014 ML20198L369
References
50-373-97-14, 50-374-97-14, NUDOCS 9710270014
Download: ML20198L381 (13)

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,. U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos: 50-373;50-374 License Nos: NPF-11; NPF-18

. Report Nos: 50-373/97014(DRS); 50-374/97014(DRS)

Licensee: Commonwealth Edison Company (Comed)

Facility: LaSalle County Nuclear Generating Station, Units 1 & 2 Location: 2601 North 21st Road Marseilles. IL 61341 Dates: . June 25-28 and August 13-16,1997 Inspectors: D, S. Muller, Examiner, inspector in Training J. A. Lennartz, Examiner / Inspector

Approved by: Melvyn Leach, Chief Operator Licensing Branch

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Division of Reactor Safety

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9710270014 971017 PDR ADOCK 05000373 0 Pm

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EXECUTIVE SUMMARY LaSailo County Nuclear Generatirg Station, Units 1 & 2 NRC Inspection Reports 50 373/97014; 50-374/97014 This inspection included o leview of the construction, conduct, and results of the LaSallo High Intensity Training (HIT) program. In addition, operator poiformanco in the control roam simulator was elso observed. Overall, the HIT progiam was an offectivo training piogra ElcmontSElllctLConltibulcilo the HIT orogram's effectivenesajacludei

+ The training sct.3dulo was demanding (Section 05.1)

• Trainir.g noods woro well selected (Soction 05.1)

• Training timo in the simulator was productively used (Section 05.2)

• The simulator exercisos woro challenging (Soction 05.2)

• Foodback to the operators on their performance in the simulator was offectivo (Section 05.2)

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Classroom instruction was offectivo (Section 05 3)

• The remediation prograrn was appropriato and logically constructed (Sottion 05.4)

+ Hi0h staMards for measuring oporator performance in the simulator were utilized (Soction US.4)

• Senior management was involved in the training (Soction 05.6)

• The crows and instructors displayed a positivo attitude toward the training (Section 05.0)

RchicaciculdenMod with the HIV crogram includai

. The written exams were of marginal quality (Section 05.5)

. Learning objectives woro not bein0 reviewod during simulator training (Section 05.2)

• Critical tasks woro not consistently used during simulator training (Section 05.2)

Operator performnco in the s'mulator was acceptable (Section 04.1). Doficienclos woro observed in th hwing areas:

. Lack of p :odural usaga and imptopor procedural adherenco e improper and untimely amorgency plan classifications and reporting

• Inoffectivo command and control e Not utilizing formal communications

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Reoc71 Details LQatfAtlona 04 Operator Knowledge and Performance'

0 OpcIntor Performatico During3lmulator Exercises of ibe High Intensity Training (HIT)

P.LO9 tam Inspasilonacops.MUEEG1D21)

The inspectors observed the performance of four crews in the LaSalle Unit i Simulator; two crews were observed from June 25-June 28 (HIT week one) and two different crews were observed on August 13,14 and 16 (HIT week two). On Jurie 25 27 and August 1314, training sessions were observed; on June 28 and August 16, the inspectors observed evaluated exercise Qhsafyallong.and FindlDQS Each crew consisted of a Shift Manager (SM), Sinit Technical Advisor (GTA), Unit Supervisor (US), and two Nuclear Station Operators (NSOs). All of the observed deficiencies were jointly observed by both the licensee and the inspectors. A majority of the following deficiencies were self-identified by the crew members. These deficiencies were discussed during the exercises by on line coaches or were u', cussed at the post exercise critiques. In some cases, depending on the severity of the deficiency, deficiencies observed during the evahated exercises required some form of remediation and/or re-examination. Areas of most concern were:

. Lock of procedural usage and improper procedural adherence

• Improper and unti,nely emergency plan classifications and reporting

. Ineffective command and control

. Not utilizing formal communications Procedural adherence and usage were generally acceptable throughout the observed exercises. On a few occasions Abnormal Operating Procedures (AOPs) were not promptly entered. Also, on a few occasions annunciator response procedures were not promptly used. On one occasion, when shifting a turbine driven reactor feedpump to manual control, no procedure was referenced. One crew was slow to bliow-up with the AOPs when a loss of Turbine Building Closed Cooling Water (TBCCW) occurre Another crew did not reference the high conductivity AOP when feedwater conductivity was high. A final example was that one US skipped steps while in the Ememency Opersting Procedure (EOP) flowcharts. With reactor water level tr.pidly decreasing, the

' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized inspection report outline, Individual reports are not expected to address all outline topic ,

Ls realized that ho nooded to perform an omorgoney depressurization and skipped some portions of the EOP flowcharts. One specific stop that was skipped was for the US to diroct an NSO to inhibit the automatic depressurization uystem, in this caso, thoto was no safety significance to this order not being mado. Also, this US directed an omorgency deptossurl/ation prior to his review of the omorgency deprossurization flowchart. In this caso the US did not review the proroquisites for the depressurization prior to giving out tho ordor. Onco again, thoto was no safety significance to not reviewing the proroquisitos, as the proroquisitos in this particular case woro satisfie Another concern was in the area of omorgoney plar, classifications and notification Ono indicator of problems was the significant number of SMs that have boon identiflod by the licensoo as having deficiencies in this area throughout the course of the HIT program. The inspectors observed that ono SM fallod to classify and make the required notilications In a timely fashion. On another occasion ono SM was not clear in his tolophono reporting of an ovent due to changing his classification throo timos as the event escalate Command and control during the observed oxorcisos was adoquato. On a few instancos the US/SM did not active!y onsure procedural uso, and the operators performod somo actions without using procedutos. On a few occasions, the US did not assign responsibility for a particular proceduro or a particular paramotor to monitor. Ono examplo of this occurred whero a crew was in two AOPs simultaneously and opolators woro not assigned to a specific proceduro. In another caso, during an anticipated transient without scram an operator was not assigned to monitor supp'ossion pool temperature which would have cued the US to inject boron. In the sccond examplo, boron was injected at 112 degroo F supprossion pool temporature, alinou0h the EOP required Injoction at 110 degroo F. During some exorcises improvemont was noodod in the arons of planning and prioritization. Ono examplo of this occurred outing an oxercise which included a TDCCW lock. Due to poor planning the methods to isolato the leak and the heat loads that would be offected by isolating the TBCCW leak woro not thorou0hly investl0ated. The reactor was scrammed in anticipation of isolating the TBCCW leak, but following the scram the leak was not isolated for several minutos due to the crew taking post scram actions and due to some confusion amongst the crew about what valvos noodod to la closed to Isolato the leak. Also, securing the affected heat loads was dolayed whilo discussions occurred. Good planning would havo identified how the loak was to be isolated, heat loads that would be affected, and offects on the plant prior to the anticipatory scra Communications during the observed exercisos woro adoquato. The throo-leg communication techniquo (ordor, repeat back, acknowledgment of repeat back) was used a majority of the time, however occasional misuso of throo log communications was observed, Orders woro Donorally conciso, but on a few occasions they were excessively wordy and impreciso. Control room brlofs woro Donorally good, but again on a few occasions they woro unor0anized and confusing. Plant announcements woro clear and conciso, but occasionally they woro not mado; on one occasion a reactor scram was not announcod, oi, a + or occasion a major fluid system loak was in progress but personnel woro not told to evacuato, etc. Ono aspect of communications

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whero improvement was observed over the course of the inspection was the ability of the crows to maintain a calm and controlled atmosphoto during the exorcisos, DcluS1005 Crow performanco observed as part of the HIT program was adequato. A noticeable improvement was observed in the crews' ability to maintain a calm and controlled atmosphoro during exorcises. Doficienclos woro observed in the areas of procedural adherenco and uso, omorgency plan classifications and &,tifications, command and control, and communication Operator Tralnli a and Qualification 05.1 Dackground Objectlyos Dad.Conskucilon of the HIT Program Inspection _Scopo_L41500)

The inspectors interviewod training staff personnel to dolormino the background, objectivos, and construction of the HIT program. The inspectors also conducted interviews with crew members to obtain the trainee point of view, in addition, training schedulos woro rov'rved, ObseIyaticas.and. Endings Lato in 1990, LaSa!!o County Station conducted an Indopondent Self Am sment MA)

which included a review of oporating crew performance and training offectiveness. H,0 ISA reviewed operator performance problems that havo occurred at the station over the last soveral years and reviewod operator performanco problems that have boon observed during simulator oxorcises as part of the operators' continuing roqualification training. The ISA raised questions about operator compotoney and training offectivonoss. As a result of the ISA and as a part of LaSailo's restart plan, additional training for operators was determined to be necessary. This additional training was labeled High Intensity Training (HIT), and was developed jointly by the licensee's training and operations staffs, in addition, the operators themselves had an input regarding the contont of the HIT program. The overall goal for the HIT program was to produce a significant improvement in operator performanc In March 1997 the first operating crow began training under the HIT program. During a sir,1ulator exerciso conducted on this first crew, poor crow performanco was observe As a result of the poor performance observed,lic1nsoo management decided to assess the performanco of all the crews, utilizing two scenario exercises per cre The HIT presgram consisted of throo phases: initial assessment (as discussed abovo),

wook one training, and week two training. Wook one training concentrated on AOPs, management expectations, and standardization of crew responso. Wook one training was appropriately selected for several reasons, including: (1) most operator training in the past has focused on EOPs; (2) most of the events that have occurred during the

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, day to day operations of the plant have required use of the AOPs and not the EOPs;(3)

the format of the AOPs has recently changed, there are many now revisions to the  !

AOPs; and (4) the events trained on and a failure to understand managornent expectations are the kind of issues that the licensoo has had difficulty with in the pas .

Wook one training consisted of approximately 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of training in the simulator and I 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> of classroom instruction. Each training day was roughly divided into a fivo-hour session in the simulator and five hours of classroom instruction. At the conclusion of the training wook, each crow was ovaluated using a two hour written exam and two gradod exorcisos in the simulator, This resulted in roughly a 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> training woo Wook two tralning also consisted of roughly a 60 hour6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> training wook, similar to week one, however, wook two training concentrated on Emorgency Operating Proceduros (EOPs), Conclusions The overall objective of improving operator performance was appropriato. Tho 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> por wook of tralhing was a domanding schedulo. Training on AOPs and managemont expectations during HIT week one was an appropriato response to the ISA results and ,

past oporator performance issues at LaSailo. EOP training was still considered important, as this training was incorporated into the HIT program's wook two training, including an input by operations department personnel (both the management staff and the operators)into the selection of training topics and the program's construction enhanced the offectivonoss of the HIT progra .2 ConductsLSittlulator Training h1spection.Scoon.L41500)

The inspectors observed the conduct of simulator exorcisos during a portion of HIT wook one (June 25 28,1997) and HIT wook two (August 1310,1997). In addition, the oxerciso Duldos for the observed training were also reviewed. The inspectors also conducted interviews with crew members and instructors. The offectiveness of the training was ovaluated, in part, using NUREG 1220," Training Review Critoria and Procoduros," Re Ohservation1A11d Findings Each day's simulator training consisted of walkthrough exorcises, a panel walkdown awareness exorciso, and real timo exercises. The walkthrough exercisos consisted of insorting the malfunction (s), placing the simulator in froozo, allowing the crow to observo plant responso and to discuss what operator actions should be taken, taking the simulatet out of froozo, and then having the operators take the discussed actions and observing plant response. The walkthrougn exorcisos wor 9 an offective training tool; they fostored extensivo discussion within the crew while the simulator was in frooze, which would be missed during a real-timo exerciso. The panel walkdown awareness exercise consisted of insorting various subtle malfunctions (readings outside their

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, normal bands but not alarming, valves partially opened, etc.), and giving the crew 15 minutes to locate the off normal trends. At the end of the 15 trinutes, the instructor would walk down the panels with the crew and reveal the discopancies. The panel i walkdown exercises were an effective tool for increasing the cmws' pd.o! awarenes The real time exercises used in HIT week one training focused on AOPs and generally consisted of a series of related malfunctions (with technical specification implications and/or 10 CFR 50.72 notifications) and would eventually require the crew to insert a manual scram. These exercises were challenging for several reasons including: (1) the crews were using procedures that were often overlooked during EOP type training, (2)

the crews were making different decisions (especially concerning Technical Specifications and operability of equlpment) than those made during EOP type training, and (3) of%ite notifications and emergency plan classifications were not as straightforward as that encountered when in the EOPs. The EOP real time exercises used during HIT week two woro very similar to NRC initiallicensing exams. These exercises typically consisted of a normal evolution, one to two instrument or component malfunctions, followed by a major transient rmmplicated by other instrument or component malfunctions. The EOP exerciss,s challenged the crews by entering multiple EOP flowcharts and also by entering some very challenging contingency actions, including containment floodin Feedback to the crews on their performance in the simulator utilized on-line coaching and videotaped exercises. One coach was provided for controlioom cupervision (SM, US, STA) and one coach was provided for the NSOs. The on-line coaches provided immediate feedback to the operators on their performance and offered suggastions to the operators throughout the exercises, immediate feedback helped the operators realize their mistakes and take corrective actions while the exercises were still in progress, which resulted in an increase in training value over hearing about mistakes only in a post exercise critique. The coaches also provided feedback to the operators during the post exercise critiques. During the real-time exercises, the coaching was typically reduced, to allow the crews to " practice" for the evaluated exercises. During the evaluated exercises no coaching was used. The coaches themselves were highly respected operators who were normally on shift, but they were removed from shift to assist with the HIT program. Also, the same two coaches were used during all the simulator training for all the crews. This ensured: (1) direct operations department input to the training, (2) enhanced credibility of the coaches, and (3) a greater degree of standardization of training. Another technique that the licensee used to provide feedback to the crews was the use of videotaped real time exercises. Each day one of the crew's real time simulator exercises would be videotaped and reviewed with an instructor on the following day. This practice was an effective means of providing feedback to the crew members on their performance, while the exercise was still somewhat fresh in their mind When the inspectors first observed simulator training, it was noted that objectives were not being reviewed by the instructors, identifying and reviewing learning objectives during training is one element of an effective systems approach to training. This was brought to the attention of the training staff and rapidly corrected. For the remainder of the observed simulator training, learning objectives were consistently reviewe . ._- . . .

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, During the conduct of the critiques for the training exercises, the inspectors noted that no discussion of critical task completion occurred. Although each exercise uitique -

would identify generic areas for crew improvement (listening skills, communications, calm and controlled response to alarms, etc.), specific objectives / critical task completion and whether the crew effectively achieved these were not discussed (i.e., perform  ;

actions per the flooding procedure and isolate a specific leak within five minutes of discovery, perform actions per a specific procedure and secure a particular pump within five minutes of the initiating event, etc.). Critical tasks also were not identified in the instructor guides. The practice of not using critical tasks during the training week reduced the overall effectiveness of these exercises, especially the effectiveness of the post exercise critiques. It should be noted that critical tasks were used for the evaluated exercises. The evaluated exercises therefore had additional performance standards that were not evident during the training week exercises, Conclualona Overall, the quality of the simulator training was good. Walkthrough exercises, panel awareness exercises, and real time exercises were effective training tools. The AOP simulator exercises used in the week one HIT program were challenging, due primarily to the difference in decisions made when compared to EOP exercises. The EOP simulator exercises used in the week two HIT program were challenging, due in part to the fact that these exercises entered multiple EOP flowcharts and contingencies. The use of on line coaching and videotaped real time exercises provided effective feedback to the crews; these methods enhanced the simulator training. The fact that the instructors were not reviewing leaming objectives represented a deficiency in the simulator training methodology. In addition, the lack of critical tasks in the training exercises reduced their effectivenes .3 CQDduct of Classroom Activities

- ID!ipection Scoce (41500)

The Inspectors observed the conduct of classroom instruction during a portion of HIT week one, in addition, the student guides and tralr.ing schedules were reviewed. The inspectors also conducted interviews with crew members and instructors. The effectiveness of the training was evaluated, in part, using NUREG 1220," Training Review Criteria and Procedures," Re ObseIyallons and Findinas Classroom topics consisted primarily of discussions about AOPs during HIT week one and EOPs during HIT week two, and thus complimented the simulator training. The crew members ac'Ively participated in the training, asking many questions and participating in discussions. The instructors reviewed the objectives at the beginning and end of training topics, answered the crew member's questions, and questioned the crew members to determine their understanding and to ensure their participation. To accompany the lectures, the crew members followed along with a well prepared text of

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, the materials presented. Charts, diagrams, and other visual alds used by the instructors .

were clear and easy to rea Conclusions The overall quality of the observed classroom training was very good. The instructors maintained active participation of the crew members. Both the crews and the instructors displayed a positive attitudo about the trainin .4 Remodjation Rates. Remed!ation Methods. and PerformaDCQ_Simd?Ld3 Insacction Scone f41500)

The inspectors discussed with training staff personnel the methods of remediation employed in response to operatu performanco deficiencies observed during the HIT program. The inspectors also reviewed documents made available by the licensee indicating the number of operators that had required some form of remediation and/or re examination as a result of the HIT program. Performance standards woro determined by the observation of the exercise critiques and through interviews conducted with crew members and tralning staff personnel, QhscIyations and Findings As a result of significant performanco deficiencies observed for the first crew that started the HIT program (March 1997), all of the operating crews woro examined during the initial assessment phase. The results of this initial assessment (out of a total of 60 licensed operatorc) were:

. 14 operators were assessed as fully satisfactory

. 43 operators were assessed as requiring some form of remediation and re-exomination prior to resuming licensed dulles

. 3 oportetor licenses were terminated Out of the 43 operators who required remediation, roughly two-thirds of these operators were remediated, re-examined and retumed to licensed duties within a week (short term remediation); the other one third would have to successfully complete the entire HIT program before being returned to licensed duties (long term remediation).

Simulator exam results for HIT week one (out of a total of 57 licensed operators) were:

. 47 operators were assessed as fully satisfactory

. 8 operators woro assessed as requiring some form of remediation and re-examination prior to returning to licensed duties

. 2 operator licenses were terminated Out of the eight operators who required remediation, five were remediated, re-examined and returned to licensed dutles within a week. Three of the above eight operators were

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remediated and re examined, but not returned to licensed duties as these operators had  :

been selected for long term remediation as a result of the initial assessment phas Five of the above 6ight operators were on one crew; this crew performed poorly and the ,

entire crew was selected for remediation. Also of note is that four Shift Managers (SMs) _;

failed the simulator exam due to difficulties encountered with classifying and reporting emergency plan event Simulator exam results for HIT week two (out of a total of 55 licensed operators) were: 1

• - 42 operators were assessed as fully satisfactory )

+ 13 operators were assessed as requiring some form of remediation and re-examination prior to returning to licensed duties Out of the 13 operators that required remediation, eight were remediated, re examined end retumed to licensed duties within a week. Five of the above 13 operators had no change in status. These five were selected for long term remediation during the initial ,

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- assessment phase and will require additional training, self study, and re examination before returning to licensed dutie The first implementation of the remediation program occurred following the initial assessment phase. For highly significant performance deficiencies, operators were y placed into long term remediation. Long term remediation consisted of satisfactory '

completion of the entire HIT program before being allowed to return to licensed dutie For performance deficiencies not as significant, operators received some form of short term remediation and possible re-examination. Short term remediation was individually >

tailored for each operator, depending on his or her observed deficiencies, in some .

cases a discussion of the chserved deficiencies with an instructor, while viewing a videotape of the operator's performance was all that was required prior to resuming

- licensed duties. In other cases, additional practice in the simulator and a re-examination for an entire crew was required prior to resuming licensed duties. Short term remediation generally took it ss than a week to complet The licensee's performance stindards for operators in the simulator were most readily determined during the evalostad simulator exercise critiques. Procedural compliance, correct diagnosis of plard conditions, proper annunciator response, and accurate control board operations were seen as the minimum acceptable standards for crew performance. Evaluations focused not only on whether tasks were successfully completed but on how effectively they were completed. Remediation for crew members occurred not only when certain tasks were not completed successfully, but also if these tasks were not completed effectively; i.e., if communications were not precise during the evolution or if the US did not clearly assign responsibilities for actions (even if these actions were correctly carried out). During all the critiques and evaluations observed during this inspection, the licensee always noted some deficiencies regarding crew communications. Also of note is that many of the observed deficiencies during the simulator training exercises were identified by the crew members.

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. CDDGlullQnt The use of a multi tiered (long term, short term, re-examinations) flexible remediation program to address different levels of observed operator deficiencies was a logical and appropriate method of remediation. High standards for measuring crew performance during simulator exercises were utilized. The fact that the standards for operator performance were significantly raised was apparent from the low rate of satisfactory results (14 out of 60 licensed operators were fully satisfactory) obtained during the initial assessment period. It is also apparent from the critiques and remediation that the licensee is making a focused effort to improve communications. The fact that a large number of the performance deficiencies were self identified by the crews indicated that the operators understood the new performance standard .5 Written Exams a lasacetion Scong_(ZiQQ1)

The inspectors conducted an in office review of two written exams that were used as part of the Saturday evaluation. The exams reviewed were:

. HIT 1-4.TST Version: 5

. HIT 2-3.TST Version: 5 Obsetyations and FindiDQs Several questions did not appear to have the ability to discriminate between competent and non competent operators. Approximately three to four questions on each exam were not operationally based or were memory level questions. Examples of this type of question included identifying the correct definition for core inlet subcooling or differentiating between delayed neutron fraction and effactive delayed neutron fractio Approximately four to five questions on each exam were direct look up questions, requiring little or no analysis by the operators. Examples of this type of question included identifying a set of chemistry parameters that satisfied Technical Specifications or identifying the correct action for a particular fire panel alarm. Approximately one to two q, istions on each exam were constructed poorly. Examples of this type of problem inaded the use of "all of the above" as an answer choice for a multiple choice question or having unnecessary information in the question stem (one question had some information about the High Pressure Core Spray system that was irrelevant to the question being asked). Conclusions The written exams reviewed were of marginal quality. The written exams reviewed were not an effective tool for measuring an increase in operator performance. The combination of memory level /not operationally based questions, direct look up questions, and poorly constructed questions, accounting for roughly eight to eleven questions on a 40-question exam, limited the effectiveness of the written exam I1

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l 05.0 Miscellaneous _Ohnemations .

Additional elements which contributed to the effectiveness of the HIT program included Senior Management !nvolvement with the training and the positive attitude of the crews ,

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and instructors. Senior Management was involved in the program, as demonstrated by; (1) a training manager was present during all the observed simulator training, assessing i t

the quality of the training and providing feedback to the instructors, (2) the LaSalle Site Vice President observed a portion of the simulator training, and (3) an Operations  !

Manager was used as an evaluator for the evaluated simulator exercises, it was also noted that the crews, coaches, and Instructors displayed a positive attitude about the  ;

i training. The crews appeared highly receptive to the training, and believed that the training was necessary. It also appeared that the instructors and coaches saw that the training they were conducting was important to improving LaSall ;

l L_ManagementMeetines X1 Exit Meeting Summary  ;

The inspectors presented the inspection results to rnembers of licensee management at the conclusion of the inspection on September 4,1997. The licensee acknowledged the findings presente The inspectors asked the I;censee whether any materials examined during the inspection  ;

should be considered proprietary. No proprietary information was identifie !

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PARTIAL LIST OF PERSONS CONTACTED Licensen (

P. Barnes, Regulatory Assurance Supervisor

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F. Dacimo, Plant General Manager O. Kaegl, Operations Training Superintendent D. Sanchez, Training Manager S. Smith, Plant Manager

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NRC D. Calhoun, Acting Senior Resident inspector

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INSPECTION PROCEDURES USED IP 41500: Training and Qualification Effectiveness IP 71001: Licensed Operator Regefification Program Evaluation NUREG 1021: Operator Licensing Examinetion Standards for Power Reactors, Interim Rev 8 ITEMS OPENED, CLOSED, AND DISCUSSED Opened NONE Closed NONt!

Discussed NONE

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