IR 05000387/2006006
| ML060860203 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/15/2006 |
| From: | James Trapp Reactor Projects Region 1 Branch 4 |
| To: | Mckinney B Susquehanna |
| Trapp J RGN-I/DRP/PB4/610-337-5186 | |
| References | |
| IR-06-006 | |
| Download: ML060860203 (23) | |
Text
rch 15, 2006
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NOS. 05000387/2006006, 05000388/2006006
Dear Mr. McKinney:
On February 10, 2006, the US Nuclear Regulatory Commission (NRC) completed a team inspection at the Susquehanna Steam Electric Station, the enclosed inspection report documents the inspection findings, which were discussed on February 10, 2006, with you and members of your staff during an exit meeting.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
On the basis of the sample selected for review, the team concluded that in general, problems were properly identified, evaluated, and corrected. There was one green finding identified during this inspection associated with problem identification. The finding was the failure to identify that a scaffold had been inappropriately constructed contacting a safety-related instrument sensing line. The finding was determined to be a violation of NRC requirements.
However, because of the very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as Non-Cited Violation, in accordance with Section VI.A.1 of the NRCs Enforcement Policy. If you deny this Non-Cited Violation, you should provide a response with the basis for your denial, within 30 days of the date of this inspection report, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC, 20555-0001, with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC, 20555-0001; and the NRC Resident Inspector at the Susquehanna facility.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document
B. Room or from the Publically Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
James M. Trapp, Chief Projects Branch 4 Division of Reactor Projects Docket Nos. 50-387, 50-388 License Nos. NPF-14, NPF-22 Enclosure: Inspection Report Nos. 05000387/2006006, 05000388/2006006 w/Attachment: Supplemental Information
SUMMARY OF FINDINGS
IR 05000387/2006-006 and 05000388/2006-006; 01/23/2006 - 02/10/2006; Susquehanna
Steam Electric Station, Units 1 and 2; Biennial Baseline Inspection of the Identification and Resolution of Problems. One violation was identified in the area of identification of deficiencies.
This inspection was conducted by three regional inspectors and one resident inspector. One finding of very low safety significance (Green) was identified during this inspection and was classified as a Non-Cited Violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,
Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems The team concluded that the implementation of the corrective action program (CAP) at Susquehanna was generally good. The team determined that Susquehanna was effective at identifying problems and entering them in the CAP. However, while the identification of equipment deficiencies was acceptable, the team identified one finding and several minor issues where there appeared to be an attitude of acceptance of deficiencies and abnormal conditions. Once entered into the system, the items were screened and prioritized in a timely manner using established criteria. Items entered into the CAP were properly evaluated commensurate with their safety significance. The causal evaluations reasonably identified the causes of the problems and developed appropriate corrective actions. The team noted a trend over the last two years of a lack of rigor with regard to operability evaluations. Corrective actions were typically implemented in a timely manner and appropriately addressed the root causes. However, the team identified one example where the corrective actions to prevent repetition for a NRC identified NCV were implemented in an ineffective manner constituting a minor violation. Licensee audits and self-assessments were generally adequate. The team also noted that the licensees efforts to reduce human performance error rates were continuing.
On the basis of interviews conducted during the inspection, the team concluded that workers at the site felt free to input safety concerns into the CAP.
ii
NRC Identified and Self-Revealing Findings
Cornerstone: Mitigating Systems
C Green: The inspectors identified a NCV of 10 CFR 50, Appendix B, Criterion XVI,
Corrective Action, for failure to identify, for greater than a year, that a scaffold was constructed contacting a safety-related instrument sensing line which provided an input to the automatic depressurization system (ADS). The affected system was declared inoperable until the scaffold was removed. The licensee took prompt corrective action to remove the subject scaffold and entered the issue into the corrective action program.
The licensee conducted an extensive plant walk-down that identified other scaffolds which were not properly constructed. The licensee subsequently determined that ADS was operable but degraded.
This finding was greater than minor because it is associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of the ADS system that responds to initiating events to prevent undesirable consequences. The inspectors noted the issue was also greater than minor, based on a review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues and Cross-Cutting Aspects, Example 4.a - the issue is not minor if later evaluation determined that safety-related equipment was adversely affected. The finding was determined to be of very low safety significance (Green) because the performance deficiency did not represent a design deficiency and did not result in the loss of a safety function. The finding had a cross-cutting aspect related to the area of Problem Identification and Resolution; specifically, station personnel did not identify that the incorrect construction of the scaffolding was a condition adverse to quality. (Section 4OA2.1.b.(1))
Licensee-Identified Violations
None.
iii
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution (PI&R) (Biennial - IP 71152B)
.1 Effectiveness of Problem Identification
a. Inspection Scope
The inspection team reviewed the procedures describing the corrective action program (CAP) at the Susquehanna Steam Electric Station (SSES). SSES staff identified problems by initiating Action Requests (ARs). For conditions adverse to quality, human performance problems, equipment nonconformances, industrial or radiological safety concerns, and other significant issues, the ARs are classified as Condition Reports (CRs). The CRs are screened for operability, categorized by priority and significance (L1 through L3), and assigned for evaluation and resolution.
The team reviewed CRs selected across the seven cornerstones of safety in the NRCs Reactor Oversight Program (ROP) to determine if problems were being properly identified, characterized, and entered into the CAP for evaluation and resolution. The team selected items from the maintenance, operations, engineering, emergency planning, security, radiological control, training, and oversight programs to ensure that SSES was appropriately considering problems identified in each functional area. The team used this information to select a risk-informed sample of CRs that had been issued since the last NRC PI&R inspection, which was conducted in February 2004.
The team also selected items from other processes at Susquehanna and from the AR system which had not been classified as CRs, to verify that they appropriately considered these items for entry into the corrective action program. Specifically, the team reviewed a sample of work orders, engineering requests, operator log entries, control room deficiency and work-around lists, operability determinations, engineering system health reports, completed surveillance tests, current temporary configuration change packages, and training requests. The documents were reviewed to ensure that underlying problems associated with each issue were appropriately considered for resolution via the corrective action process. In addition, the team interviewed plant staff and management to determine their understanding of and involvement with the CAP.
The CRs and other documents reviewed, and a list of key personnel contacted, are listed in the Attachment to this report.
The team reviewed a sample of Quality Assurance audits, including the most recent audit of the CAP, the CAP trend reports, and the departmental self-assessments. This review was performed to determine if problems identified through these evaluations were entered into the AR system, and whether the corrective actions were properly completed to resolve the deficiencies. The effectiveness of the audits and self-assessments was evaluated by comparing audit and self-assessment results against self-revealing and NRC-identified findings, and current observations during the inspection.
The team considered risk insights from the NRCs and SSESs risk analyses to focus the sample selection and plant tours on risk-significant components. The team determined that the five highest risk-significant systems were the 125 volt direct-current (DC) system including the station black-out diesel, the emergency diesel generators, the residual heat removal system, the emergency service water system, and the reactor core isolation cooling system. For the selected risk-significant systems, the team reviewed the applicable system health reports, a sample of work requests and engineering documents, plant log entries, and results from surveillance tests and maintenance tasks.
b.
Assessment and Findings In general, the team determined that the identification of equipment deficiencies to be acceptable at SSES. However, the team identified several minor issues where there appeared to be an attitude of acceptance of deficiencies and abnormal conditions. For example, the inspectors identified scaffolds built without the necessary clearance to adjacent safety-related equipment, breakers not fully racked-in on safety-related direct current load centers, material stored next to or touching safety-related equipment, and ground water intrusion around safety-related pipe penetrations. With the exception discussed below regarding scaffolding, all of the issues that were failures to comply with NRC requirements, constituted violations of minor significance that are not subject to enforcement action in accordance with the NRCs Enforcement Policy.
The housekeeping and cleanliness in some areas of the plant required improvement, in that it had the potential to directly affect equipment or mask worsening conditions.
Examples included the failure to clean up oil leaks, failure to return ladders to the designated areas after use, failure to remove transient combustibles, and failure to clean water stains on the walls. At the end of the first week of inspection, SSES management instituted an aggressive review of all plant areas, and identified numerous other problems with scaffolding and general housekeeping. During the second week of on-site inspection, the inspection team identified additional discrepancies in areas that SSES had already walked-down.
The team also reviewed a sampling of Quality Assurance audits and departmental self-assessments and considered them to be adequate.
- (1) Failure to Identify That Scaffolding Was Adversely Affecting Safety-Related Equipment
Introduction:
The inspectors identified a NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action. The licensee did not recognize that a scaffold was constructed in contact with a safety-related instrument sensing line which provided an input to the automatic depressurization system (ADS); this resulted in the system being declared inoperable until the scaffold was removed.
Description:
On January 25, 2006, the inspectors identified a scaffold constructed between the Unit 2 D residual heat removal (RHR) pump and RHR heat exchanger.
The attached scaffold inspection tag indicated that the scaffold was built in January 2005 and was last inspected on March 19, 2005. The inspector noted that the scaffold mid-rail was resting on top of the instrument tubing for two RHR pump discharge pressure switches (PS-E11-2N020D and PS-E11-2N016D). The pressure switches provide inputs to the ADS permissive logic, indicating that the RHR pump is running and has sufficient discharge pressure.
Station procedure MT-AD-504, Scaffold Erection, Review and Inspection, referred to drawing C-1804, Physical Clearance Criteria, which required a minimum clearance of 7/8-inch between scaffold components and instrument tubing. Step 6.1.8 of MT-AD-504 required an engineering evaluation/resolution if scaffolding could not be erected within the seismic requirements of the procedure. The step also stated that if an engineering resolution could not be obtained, the affected component needed to be declared inoperable or taken out-of-service. No evaluation existed for the observed deviation.
The inspectors discussed this with the scaffold System Engineer, who took the issue to the Control Room for an operability determination. The Shift Manager determined that the affected portion of ADS was inoperable and entered Technical Specification Limiting Condition for Operation 3.3.5.1.5.f, for the low pressure injection permissive for ADS initiation. The issue was immediately entered into the CAP as CR 745248. An extent-of-condition conducted by SSES included a site-wide inspection of scaffolding, that revealed many additional scaffolds which were not built in accordance with the procedure with respect to clearance and attachment requirements. Examples included a threaded rod for supporting a drywell nitrogen make-up line that was bent out around scaffolding and scaffolding that was impairing a pre-action sprinkler system which required a continuous fire watch. SSESs investigation also revealed that the associated work package for the Unit 2 RHR scaffolding incorrectly indicated that the scaffold was removed on March 19, 2005.
Analysis:
The inspectors determined that the performance deficiency was the failure of SSES personnel to identify a condition adverse to quality that existed for over a year.
Specifically, a scaffold was constructed with less than the minimum required clearance from safety-related equipment. Subsequent evaluation by SSES determined that the scaffolding could have disabled the signal input from the D RHR pump to that channel of ADS, but the other low pressure inputs (the B RHR pump and the core spray pumps) would have permitted that channel of ADS to function. The inspectors determined the issue was greater than minor, based on a review of NRC Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues and Cross-Cutting Aspects, Example 4.a - the issue is not minor if later evaluation determined that safety-related equipment was adversely affected.
The finding is associated with the equipment performance attribute of the Mitigating Systems Cornerstone; in that it contributed to the decreased capability of the safety-related ADS system to respond to an initiating event to prevent undesirable consequences. The inspectors performed a Phase 1 screening using IMC 0609, Appendix A, Determining the Significance of Reactor Inspection Findings for At-Power Situations. The finding was determined to be of very low safety significance (Green)because the performance deficiency did not represent a design deficiency; did not result in the loss of a safety function; did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event (e.g. seismic snubbers) and did not involve the total loss of any safety function identified by the licensee through a probabilistic risk or similar analysis.
The finding had a cross-cutting aspect related to the area of Problem Identification and Resolution; specifically, station personnel did not identify that the incorrect construction of the scaffolding was a condition adverse to quality.
Enforcement:
Appendix B, Criterion XVI, Corrective Action, of 10 CFR 50, requires that conditions adverse to quality be promptly identified and corrected. Contrary to this, SSES personnel failed to identify that scaffolding around the Unit 2 D RHR pump and heat exchanger was not constructed in accordance with the controlling procedure (MT-AD-504) and was resting on safety-related tubing which provided an input to the permissive logic for the ADS system. This condition had existed for approximately twelve months. After the issue was identified by the NRC, an SSES engineering evaluation determined that the affected train of ADS was degraded but operable due to the scaffolding. Because this violation is of very low safety significance (Green) and was entered into the licensees corrective action program (CR 745248), this violation is being treated as an NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy:
NCV 05000388/2006006-01, Failure to Identify Scaffolding that Affected the Safety-Related RHR Discharge Pressure Instrument Tubing Input to ADS.
.2 Prioritization and Evaluation of Issues
a. Inspection Scope
The inspection team reviewed the CRs listed in the attachment to the inspection report to assess whether SSES adequately evaluated and prioritized the identified problems.
The team selected the CRs to cover the seven cornerstones of safety identified in the NRCs ROP. The team also considered risk insights from the SSES Probabilistic Risk Analysis to focus the CR sample. The review was expanded to five years for SSESs evaluation of problems associated with their energy control process and equipment tagging, including incorporation of industry operating experience information for applicability to their facility.
The CRs reviewed encompassed the full range of SSES evaluations, including root cause analysis, apparent cause evaluation, and a basic evaluation. The review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of the resolutions. For significant conditions adverse to quality, the team reviewed SSESs corrective actions to preclude recurrence. The team observed several of the CR screening committee meetings, in which SSES personnel reviewed incoming CRs for prioritization, and evaluated preliminary corrective action assignments, analyses, and plans. The team also reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems. The team assessed the backlog of corrective actions, including the backlog in the maintenance and engineering departments, to determine, individually and collectively, if there was an increased risk due to delays in implementation. The team further reviewed equipment performance results and assessments documented in completed surveillance procedures, operator log entries, and trend data to determine whether the equipment performance evaluations were technically adequate to identify degrading or non-conforming equipment.
b. Assessment No findings of significance were identified.
The team determined that SSES screened the CRs appropriately and properly classified them for significance. There were no items in the engineering and maintenance backlogs that were risk significant, individually or collectively. The team considered the effort of the CR Screening Committee added value to the CAP process, the discussions about specific topics was detailed and there were no classifications or operability determinations that the NRC disagreed with. The team noted that significant conditions adverse to quality were normally classified as Priority L1" and received a formal root cause analysis and an extent-of-condition review. Less significant conditions, Priority L2" and L3," typically received an apparent cause evaluation or a basic causal review, respectively. The majority (>99%) of the CRs written were for less significant issues.
The quality of the causal analyses reviewed was generally adequate, although the team noted that the documentation for several of those reviewed was limited and did not support the final conclusion. For example: the Apparent Cause Evaluation (ACE) for the failure of the 2X270 transformer in July 2004 (CR 596092) did not clearly capture the fact that the maintenance procedure was not followed with respect to performing an evaluation of the Doble test data. This was the subject of NRC Finding 2004004-03. In addition, the ACE did not capture the basis for the decision to not re-perform the Doble test prior to returning the transformer to service.
The team noted that there was a trend over the last two years of a lack of rigor with regard to operability determinations. Of the nine operability determinations chosen for detailed review, four had inadequate bases and documentation (although the conclusion was correct), two had the wrong conclusion (called the equipment operable when it was inoperable), two did not properly address the appropriate condition, and one had the correct conclusion but did not make the equipment inoperable. The equipment issues have been reviewed and documented, as appropriate, in previous NRC inspection reports. The team noted that the two most recent operability determinations had the correct conclusion with respect to operability, but the documentation was limited and did not always support the conclusion. Discussions with the SSES staff provided the additional information to support the conclusion, and the operability determinations were revised to become stand-alone documents.
The inspectors performed an expanded evaluation of problems related to the energy control process (the terminology used by SSES for the control and tagging of equipment out-of-service). The team reviewed a large sample over the past five years of condition reports, self-assessments, inspection findings, and internal and external operating experience. The review indicated that the number of CRs increased in 2003 after SSES noted that CRs were not being effectively utilized to document energy control issues.
Over the last three years, the number of events has remained steady at approximately forty per year. SSES has incorporated industry and site operating experience into station procedures for the energy control process in an effort to reduce the number of events. This has resulted in improved procedures, in that, the procedures have redundant verification for equipment tagging; however, these improvements have not significantly reduced the number of events. Many of the events are related to human performance with respect to the implementation of the process, and not to weaknesses in the energy control process.
In 2004, SSES began training on the use of human performance tools to reduce the number of human performance errors. Although there was a decrease in the error rate in 2004, there was no appreciable reduction in 2005. In late 2005, SSES concluded that additional effort was required to understand the root cause of the active human performance errors (why human performance tools were not effective or used) and therefore continue to reduce the error rate. While SSES is more consistently using human performance tools at the station, areas for improvement in the analysis of active human performance errors remain.
.3 Effectiveness of Corrective Actions
a. Inspection Scope
The team reviewed the corrective actions associated with selected CRs to determine whether the actions addressed the identified causes of the problems. The team reviewed CRs for repetitive problems to determine whether previous corrective actions were effective. The team also reviewed SSESs timeliness in implementing corrective actions and their effectiveness in precluding recurrence for significant conditions adverse to quality. The team reviewed the CRs associated with selected non-cited violations and findings to determine whether SSES properly evaluated and resolved these issues.
b. Assessment and Findings No findings of significance were identified.
The team concluded that corrective actions were generally appropriate, effective, and completed in a timely manner. The team noted the incorporation of industry operating experience information in the determination of the corrective actions, as appropriate.
For significant conditions adverse to quality, corrective actions were identified to prevent recurrence.
The team noted one example where the corrective actions to prevent recurrence for a NRC-identified NCV were implemented in an ineffective manner. In May 2005 a ventilation damper for the D ESW pump failed closed due to a failure of the pneumatic operator for the damper. Maintenance secured the damper by wiring it in the open position, using a preventive maintenance work order as the controlling document. Both operations and maintenance personnel failed to recognize that the wiring of the damper constituted a temporary modification. In June 2005, the resident inspectors questioned the seismic qualification of the damper and SSES determined that the damper did not meet the required seismic qualification. This issue was entered into the licensees CAP (CR 681948) and was documented as a NCV in NRC Inspection Report 05000387 &
388/2005003-002.
A Root Cause Analysis (RCA) team was formed to determine the cause of this finding and to develop corrective actions to prevent recurrence. These corrective actions to prevent recurrence included training most station personnel on the definition and purpose of temporary modifications and each department was to evaluate their respective CAP responsibilities and implement appropriate changes to ensure that the process for controlling temporary modifications was properly implemented. The findings and recommendations of the RCA team were reviewed and approved by plant management.
The inspectors identified that the CAP database indicated that all the corrective actions were closed; however, appropriate actions were not implemented to address the issues of temporary modification training and process reviews. Specifically, only the engineering and operations department conducted temporary modification training.
The assignments for maintenance, chemistry, work management, and quality assurance departments were closed without training being performed based on a determination by departmental management that training was not required. In addition, the departmental review of the processes for controlling temporary modifications resulted in all departments concluding that the existing procedures were adequate.
While the ineffective implementation of corrective actions did not result in a recurrence of the original issue, an opportunity was missed to address and correct a programmatic weakness in the control of temporary modifications which was the underlying cause of the original issue. This issue is considered to be a violation of minor significance. As such, this issue is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During the interviews with station personnel, the team assessed the safety conscious work environment (SCWE) at the SSES. Specifically, the team interviewed station personnel to assess whether they were hesitant to raise safety concerns to their management and/or the NRC, due to a fear of retaliation. The team also reviewed SSESs Employee Concerns Program (ECP) to determine if employees were aware of the program and had used it to raise concerns. The team reviewed a sample of the ECP files to ensure that issues were entered into the corrective action program.
b. Assessment and Findings No findings of significance were identified.
The team determined that the plant staff were aware of the importance of having a strong SCWE and expressed a willingness to raise safety issues. No one interviewed had experienced retaliation for safety issues raised, or knew of anyone who had failed to raise issues. All persons interviewed had an adequate knowledge of the CAP and ECP.
Based on these limited interviews, the team concluded that there was no evidence of an unacceptable SCWE.
4OA6 Meetings, including Exit
On February 10, 2006, the team presented the inspection results to Mr. Britt McKinney, Susquehanna Senior Vice President, and other members of the Susquehanna staff, who acknowledged the findings. The inspectors confirmed that no proprietary information reviewed during inspection was retained.
ATTACHMENT: Supplemental Information In addition to the documentation that the inspectors reviewed (listed in the attachment),copies of information requests given to the licensee are in ADAMS, under accession number ML060690367.
ATTACHMENT -
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- P. Brady - Supervising Engineer, Allentown
D. Brophy - Regulatory Affairs Engineer
L. Brosious - Discipline Planning Supervisor
S. Clements - Human Performance Leader
- D. Coffin - Supervisor, Emergency Planning
- S. Cook - Manager, Quality Assurance
V. DAngelo - Assistant Maintenance Manager
- D. DAngelo - Manager, Station Engineering
A. Fitch - Assistant Operations Manager
- J. Grisewood - Manager, Corrective Action & Assessment
R. Hoffert - Employee Concerns Program Representative
- A. Iorfida -Project Manager, Maintenance
J. Jeanguenat - Senior Engineer
- K. Kennedy - Assistant Site Manager, McCarls Inc. (Contractor)
R. Kessler - Senior Health Physicist
A. Kissinger - Operations Engineer
- H. Koehler - Senior Engineer, System Engineering
- D. Kostelnik - Senior Engineer, Allentown Engineering
B. McKinney - Senior Vice President & Chief Nuclear Officer
D. Mitchell - Senior Engineer
J. Moyer - Maintenance Production Foreman
- R. Pagodin - General Manager, Nuclear Engineering
- R. Paley - Manager, Work Management
M. Rochester - Employee Concerns Program Representative
D. Roland - Non-Outage Scheduling Manager
- M. Roper - Foreman, Effluents Management Services
- R. Saccone - Vice President, Nuclear Operations
- H. Snavely - Foreman, Mechanical Maintenance, Scaffolding
- R. Vazquies - Senior Engineer, Allentown Engineering
- T. Walters - Senior Engineer, System Engineering
S. Wary - Human Performance Leader
E. Wolf - Radiological Operations Supervisor
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000388/2006006-01 Failure to Identify Scaffolding that Affected the Safety-Related RHR Discharge Pressure Instrument Tubing Input to ADS (Section 4OA2.1.b.(1))