IR 05000282/2003007
| ML032890501 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/16/2003 |
| From: | Louden P NRC/RGN-III/DRP/RPB5 |
| To: | Solymossy J Nuclear Management Co |
| References | |
| IR-03-007 | |
| Download: ML032890501 (25) | |
Text
October 16, 2003
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000282/2003007(DRP); 05000306/2003007(DRP)
Dear Mr. Solymossy:
On September 18, 2003, the U.S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Prairie Island Nuclear Generating Plant. The enclosed report documents the inspection findings, which were discussed on September 18, 2003, with you and other 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 with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
The team concluded that, in general, problems were properly identified, evaluated and corrected. There was one Green finding identified during this inspection associated with ineffective corrective actions taken to address critical drain path blockages. This finding was determined to be a violation of NRC requirements. However, because of its very low safety significance and because it has been entered into your corrective action program, the NRC is treating this finding as a Non-Cited Violation in accordance with Section VI.A.1 of the NRCs Enforcement Policy.
If you contest the subject or severity of a Non-Cited Violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission -
Region III, 801 Warrenville Road, Lisle, IL 60532-4351; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Prairie Island Nuclear Generating Plant. In accordance with 10 CFR 2.790 of the NRC's Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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 by Jamnes Cameron Acting for/
Patrick Louden, Chief Branch 5 Division of Reactor Projects Docket Nos. 50-282; 50-306 License Nos. DPR-42; DPR-60
Enclosure:
Inspection Report 05000282/2003007(DRP); 05000306/2003007(DRP)
w/Attachment: Supplemental Information
REGION III==
Docket Nos:
50-282; 50-306 License Nos:
05000282/2003007(DRP); 05000306/2003007(DRP)
Licensee:
Nuclear Management Company, LLC Facility:
Prairie Island Nuclear Generating Plant Location:
1717 Wakonade Drive East Welch, MN 55089 Dates:
August 25 through September 18, 2003 Inspectors:
R. Skokowski, Senior Resident Inspector - Byron, Team Leader D. Jones, Reactor Inspector D. Karjala, Resident Inspector - Prairie Island Approved by:
Patrick Louden, Chief Branch 5 Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000282/2003007(DRP), 05000306/2003007(DRP); 08/25/2003 - 09/18/2003; Prairie
Island Nuclear Generating Plant, Units 1 & 2; Identification and Resolution of Problems.
The inspection was conducted by a senior resident inspector, a resident inspector, and a region based inspector. One Green finding which also was associated with a Non-Cited Violation was identified. 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 licensee adequately identified, evaluated, and resolved problems within the requirements of the corrective action program (CAP). In general, the threshold for entering issues into the CAP was appropriate. The licensees effectiveness at problem identification was demonstrated through the relatively few externally identified deficiencies throughout the review period. The team did note however, that although the stations coding and trending guidance manual was detailed, the coding of CAP data was inconsistent among station departments, raising a question to the usefulness of the trend data.
The inspectors determined that a large percentage of the apparent cause evaluations (ACEs) reviewed during the inspection did not contain some of the information specified in the Action Request (AR) guidance procedure. For example, some apparent causes were not well founded and extent of condition assessments were sometimes narrow in scope. Although the licensee was aware of some of these programmatic shortcomings, continued emphasis to improve in this area appeared warranted.
Corrective actions were generally effective and timely; however, the inspectors noted a few examples of corrective actions not being closed in accordance with the licensees process. Licensee audits and assessments were found to be effective and highlighted issues similar to those observed by the team. On the basis of interviews conducted and observations completed during the inspection, workers at the site felt free to input safety findings into the licensees CAP.
A.
Inspector-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
- Green.
The inspectors identified a finding of very low safety significance for inadequate corrective actions to preclude repetition. Specifically, licensee actions taken in October and November 2002 to address inadvertent blocking of critical drainage paths associated with safety-related cooling water (CL) pumps were ineffective. This was evident when the inspectors identified, during the inspection, plastic caution signs on the floor of the 121 CL pump room with no measures to secure them from blocking critical drainage paths. Once identified, the licensee removed the material to ensure that the critical drain path could not be blocked. This finding also affected the cross-cutting area of Problem Identification and Resolution because the corrective actions for a significant condition adverse to quality were inadequate to preclude repetition.
This issue was more than minor because the design control and human performance attributes of initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations were affected. The materials identified in the 121 CL pump room changed the physical conditions assumed in the internal flooding analysis. The finding was of very low safety significance because the finding did not contribute to the likelihood of a primary or secondary system loss of coolant accident, did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available, and did not increase the likelihood of a fire or internal/external flood. The issue was a Non-Cited Violation of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Action, for failing to take actions to preclude repetition of a significant condition adverse to quality. (Section 3)
Licensee-Identified Violations
No findings of significance were identified.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Identification and Resolution of Problems
.1 Effectiveness of Problem Identification
a. Inspection Scope
The inspectors reviewed items selected across the seven cornerstones of safety to determine if the licensee was effectively identifying, characterizing and dispositioning plant problems via the corrective action program (CAP). Specifically, the inspectors reviewed selected plant procedures and program manuals, interviewed selected plant personnel, and attended various station meetings to understand the stations process for implementing the CAP and related activities.
The inspectors selected several action requests (ARs) generated since the last Problem Identification and Resolution (PI&R) Inspection. The inspectors also selected areas that exhibited potential trends and assessed whether the licensee had appropriately identified and captured these trends within the CAP.
To assess trending, maintenance rule implementation, and to identify items that the licensee failed to enter into the CAP, the inspectors reviewed the past performance of three risk significant systems which had a high importance to safety ranking. The systems selected were the auxiliary feedwater, emergency alternating current (which included emergency diesel generators and distribution), and feedwater and condensate.
As part of this assessment, the inspectors interviewed system engineers, reviewed associate action requests and work orders, and completed partial system walkdowns.
The inspectors also evaluated the licensees operator work around (OWA) process.
The evaluation included a review of the governing procedure and the licensees list of identified OWAs. In order to assess the licensees performance with respect to identifying OWAs, the inspectors evaluated issues described in various licensee CAP documents to determine whether issues that met the threshold to be considered an OWA were appropriately dispositioned.
b.
Issues The team determined that the licensee was effective in identifying and properly characterizing problems. During this inspection, one issue was identified by the inspectors, that involved inappropriate material being left in the safeguards cooling water pump rooms such that this material could have potentially blocked the rooms critical drain paths. Even though the licensee had taken actions to prevent recurrence, these actions were ineffective, as evidenced by the recent identification of the uncontrolled material. Moreover, this was the fourth time since October 28, 2002, that the inspectors had identified this issue. Further discussion regarding this issue is provided in Section 3, Effectiveness of Corrective Actions.
In addition, the team identified two situations in which the licensee identified issues, but failed to recognize the need to take formal corrective actions. Specifically:
- During the licensees Performance Assessment organizations review of a Root Cause Evaluation (RCE) associated with recurring configuration control events, it was determined that the RCE was unacceptable; however, no actions were taken as a result of this review to improve the RCE.
- A Corrective Actions Review Boards quality review of past Apparent Cause Evaluations (ACEs) determined that approximately 50 percent of the ACEs were unacceptable; however, no CAP item was initiated to determine the cause and correct the condition until after the inspectors raised the issue with the licensee.
Further assessment of RCE and ACE quality is provided in Section 2b of this report.
The team determined that the licensees trending of issues was adequate. Station personnel identified individual specific deficiencies and entered those deficiencies into the CAP database, which allows the information to be used for tracking and trending purposes. Two methods of trending were used; table-top reviews and coding.
Table-top reviews of CAP items and Work Orders were used by most departments and was effective in identifying some emerging trends. The licensees Performance Assessment staff performed table-top reviews to identify site-wide trends and was effective in identifying some emerging trends. Although the stations coding and trending manual provided detailed guidance, the inspectors found instances where the coding of CAP data was inconsistent. Some departments were not entering trend codes, and some incorrect trend codes were entered. The inspectors noted that the licensee was aware of this issue and a CAP AR was initiated to review the issue.
The team determined that the licensees audits and self-assessments of the corrective action program were of appropriate depth and scope. Also, the associated findings and recommendations were appropriately captured. The licensees audits and self-assessments were consistent with the teams inspection results.
No findings of significance were identified.
.2 Prioritization and Evaluation of Issues
a. Inspection Scope
The team reviewed previous inspection reports and corrective action documents generated since July 2001. In particular, the team reviewed selected RCEs, ACEs, operability determinations, and common cause analyses to verify that identified issues were appropriately prioritized and evaluated when entered into the CAP. The team focused on the technical adequacy of the cause determinations, extent of condition reviews, including evaluations of potential common causes or generic concerns, and the appropriateness of the corrective actions. In addition, the team focused on the operability and reportability determinations.
The team selected several items to ensure proper implementation of the Maintenance Rule. This included verifying that the functional failures and unavailability time were properly counted and tracked.
The team attended management meetings to observe the assignment of CAP AR categories for current issues, including the initial operability and reportability evaluations. The team also evaluated the licensees process for reviewing industry operating experience.
A listing of the specific documents reviewed is attached to the report.
b.
Issues The team determined that, in general, identified issues were appropriately categorized and prioritized. The team noted that RCEs quality improved significantly after the completion of a self-assessment, which was part of the corrective actions to a Non-Cited Violation (NCV) in 2001. The inspectors determined that a large percentage of ACEs reviewed did not contain some of the information specified in CAP procedures.
An ACE was the licensees second level tool for cause determination, one step below an RCE. The licensees process allowed the use of ACEs to determine the basic causes of significance level A, B, and C issues. Many ACEs that the team reviewed contained neither a formal nor systematic approach in the cause determination. In many cases, instead of determining why the condition occurred and asking the why question twice, as described in the licensees ACE desktop instructions, what was provided was the most obvious cause.
The team reviewed approximately 50 ACEs and noted the following:
- a large percentage did not contain a logical approach to identify the cause;
- the causes were sometimes superficial or not clearly determined; and,
- extent of condition reviews were sometimes narrowly focused An example of some of these observations was illustrated in CAP Item 23907, initiated on June 19, 2002. This AR was written to address incorrect O-ring material used for environmentally qualified motor-operated valves (MOVs) in containment. Apparent cause evaluation 8445 was written to evaluate the issue. The inspectors reviewed ACE 8445 and noted that no systematic method was used to determine the cause; the apparent cause of attention to detail and following through with questioning attitude, did not determine why the condition occurred; the corrective actions of removing two sets of O-rings from storage, and counseling warehouse personnel to be more watchful of the future shipments from the O-ring vendor did not directly address the identified cause; and the extent of condition review only looked at the specific issues of O-rings and gaskets, and not at other situations where the cause could be applicable.
Approximately 2 months later, on August 27, 2002, CAP Item 24884 was written to address wrong O-rings issued for installation in another MOV. This CAP item referred to the ACE described above, and noted that the associated corrective actions were ineffective as evidenced by the incorrect O-rings again being issued from the warehouse. Therefore, a second ACE, number 8551, was written to address ACE 8445 not effectively identify the extent of condition.
The team reviewed ACE 8551 and noted that no systematic method was used to determine the cause; and the apparent cause only stated what had happened with respect to previously completed O-ring inventory reviews and did not determine the cause. In addition, the team noted that the extent of condition review was not completed in accordance with the licensees guidance. The review only addressed the technical issue and did not examine other areas where the cause may apply.
Further, the ACE discussed concerns that the individuals who completed ACE 8445 were unclear of the expectations regarding extent of condition reviews, and that the individuals were subsequently trained on the expectations for extent of condition reviews. The team noted that the licensee did not address in the ACE the possibility that other organizations and individuals were also unclear on the expectations for extent of condition reviews. This led the team to question the extent of site personnels understanding of the CAP extent of condition guidance.
The issues associated with the O-rings were reviewed and determined not to be a violation of regulatory requirements. For the initial concern, the licensee was able to justify the operability of the MOVs with the incorrect O-rings installed. For the second concern, although the incorrect O-rings were issued from the warehouse, the questioning attitude of the technician prevented the installation of the O-rings.
Regarding the licensees threshold for using ACEs in their corrective action program, the team noted that prior to 2003, the licensee was using ACEs to address many significance level C issues. This resulted in a higher than expected number of ACEs.
Subsequently, the licensee made some adjustments to their threshold for writing ACEs such that ACEs are no longer used to routinely address significance level C issues.
The team had the following additional observations related to ACEs:
- Guidance on ACEs provided in the licensees desktop instruction was thorough, but it did not appear to be routinely used and many individuals were unaware that the guidance existed.
- Training on ACEs was not provided across the site, and the training provided to the engineering department was limited and did not address managements expectations for quality.
The team reviewed a few ACEs of good quality. Most of those ACEs were written later in the assessment period; however, improvement was not consistent across all departments. Additionally, the team noted that issues involving ACE quality had been identified many times in the past by the licensee, through self-assessments, Nuclear Oversight audits, and CAP items, but the issues continue to be a challenge to the organization. The Corrective Actions Review Boards review of past ACEs quality found about a 50 percent unacceptable rate; however, no CAP AR was initiated to determine that cause and correct the condition. After the team discussed the issue with the licensee, a CAP AR was generated.
No findings of significance were identified.
.3 Effectiveness of Corrective Actions
a. Inspection Scope
The team reviewed selected ARs and associated corrective actions to evaluate the effectiveness of corrective actions. The team reviewed ARs, operability determinations, ACEs, and RCEs to verify that corrective actions, commensurate with the safety significance of the issues, were identified and implemented in a timely manner, including corrective actions to address common cause or generic concerns.
The team also verified the implementation of a sample of corrective actions. In addition, the team reviewed a sample of corrective action effectiveness reviews completed by the licensee. The samples were selected based on their importance in reducing operational risks and recurring problems. The team reviewed information recorded since July 2001.
A listing of the specific documents reviewed is attached to the report.
b.
Issues and Findings General Observations For most issues reviewed by the team, the corrective actions were effective in addressing the identified problems. In addition, in cases where significant conditions adverse to quality existed, effective actions were taken to prevent recurrence, with one exception noted. Specifically, the licensee failed to prevent recurrence of a previously identified concern associated with the control of materials that could potentially block the cooling water (CL) pump room critical drains. This finding is described in detail in Section 3c below.
The team noted a few examples where CAP items were not closed in accordance with the licensees process. For example:
- The licensees process does not allow for the closure of significance level B items to other processes, such as the work request process. The team identified that Corrective Action (CA) 3260 (significance level B), associated with the discovered test rod installed on RH8-1 - 11/12 residual heat removal (RHR)pump suction relief, was improperly closed to an open work request.
- The licensee improperly closed a corrective action to prevent recurrence for CA 3791, associated with the recurring problems with power supply failures, to a non-CAP AR.
In addition to these, the licensee had identified similar examples of improperly closed CAs. Based on the teams review, these issues were minor in nature, and did not constitute a violation of NRC requirements.
The team reviewed corrective actions created to address NCVs. This review indicated that the licensees proposed actions were completed in a timely manner and the actions were appropriate as evidenced by the lack of repeat problems. One exception was noted, in that the corrective actions to prevent recurrence associated with the control of material that could potentially block the cooling water pump rooms critical drain paths as discussed below.
Failure to Maintain Critical Drain Paths Free of Blockage
Introduction:
A Green finding and associated NCV was identified for inadequate corrective action to preclude repeated failures to control material that could potentially block critical drainage paths, as specified in site procedures.
Description:
On September 4, 2003, the team identified plastic caution signs on the floor of the 121CL pump room with no measures to secure them from blocking critical drainage paths (floor drains and drain channels beneath doors). Administrative Work Instruction (AWI) 5AWI 8.9.0, Section 6.2.2, stated materials that could plug drainage paths be prevented from doing so by tethering or anchoring the material when required equipment within the area is operable.
This issue was the subject of an NCV in NRC Integrated Inspection Report 2002-09.
During that inspection, the team identified that on three occasions the existence of loose materials in the safety-related CL pump rooms that were specifically prohibited due to their potential adverse effect on required critical drainage paths: 1) on October 28, 2002, the team identified two oil absorbent pads in the 22 diesel-driven cooling water (DDCL) pump room; 2) on November 6, 2002, the team identified a temporary power cable routed through a critical drainage path in the 12 DDCL pump room; and 3) on November 13, 2002, the team identified a significant quantity of foreign material in the 121 motor-driven CL pump room while the pump was aligned as a safety-related pump.
In each case listed above, the licensee did not remove, properly control, or prevent the introduction of materials that could block critical drainage paths associated with operable safety-related CL pumps. The materials identified by the team on October 28 and on November 13 were not tethered or anchored, and in both cases the associated safety-related CL pumps were considered operable.
Corrective actions were implemented for the October and November 2002 occurrences.
However, the previous corrective actions were inadequate to prevent recurrence as evidenced by the condition identified by the team on September 4, 2003. The team determined that the failure to establish effective corrective actions was a performance deficiency warranting a significance evaluation. The team determined that this finding was more than minor because it was associated with two of the cornerstone attributes listed in IMC 0612, Appendix B, Section C and affected the initiating events cornerstone objective. Specifically, the design control and human performance attributes of the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations was affected by the materials that were introduced into the safety-related CL pump rooms because the introduced materials changed the physical conditions assumed in the internal flooding analysis. Therefore, for the time that these conditions existed, the licensee could not demonstrate that the safety-related CL pumps would have remained available during an internal flood. The loss of a safety-related cooling water pump or pumps during an internal flood could upset plant stability. This finding also affected the cross-cutting area of Problem Identification and Resolution because the corrective actions for a significant condition adverse to quality were inadequate to preclude repetition.
Analysis:
The team evaluated the finding in accordance with IMC 0609, Significance Determination Process, because the finding was associated with an increase in the likelihood of an initiating event. Using the Phase 1 screening, the team determined that the finding did not contribute to the likelihood of a primary or secondary system loss of coolant accident, did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available, and did not increase the likelihood of a fire or internal/external flood. The team determined the finding to be of very low safety significance (Green).
Enforcement:
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, states, in part, that in the case of significant conditions adverse to quality, the measure shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition. Contrary to the above, on September 4, 2003, the corrective actions taken by the licensee in October and November 2002 for past failures to ensure that materials could not block critical drainage paths associated with operable safety-related CL pumps failed to preclude repetition as evidenced by the September 4, 2003, identification by the team of plastic caution signs on the floor of the 121 CL pump room with no measures to secure them from blocking critical drainage paths. Upon identifying the condition, the licensee removed the material to ensure the critical drain path could not be blocked. Because this violation was of very low safety significance, and the licensee entered the conditions identified by the team into their corrective action program with CAP Item 32208, this violation is being treated as an NCV in accordance with VI.A.1 of the NRCs Enforcement Policy (NCV 05000282/2003007-01; 05000306/2003007-01).
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
The team interviewed plant staff to assess the establishment of a safety conscious work environment.
During the conduct of interviews, document reviews and observations of activities, the team looked for evidence that suggested plant employees may be reluctant to raise safety concerns. Most of the individuals interviewed were asked questions similar to those listed in Appendix 1 to NRC Inspection Procedure 71152, Suggested Questions for Use in Discussions with Licensee Individuals Concerning PI&R Issues. The team also reviewed the stations procedures related to the Employee Concerns Program, and discussed the implementation of this program with the stations program coordinator.
b.
Issues During the interviews, the team noted no indications of unwillingness to raise safety issues. However, during some of the interviews, workers suggested that upon resolution of an issue, feedback should be provided to the CAP AR initiator to ensure the issue was addressed.
4OA6 Meeting(s)
.1 Exit Meeting
The team presented the inspection results to Mr. J. Solymossy and other members of licensee management in an exit meeting on September 18, 2003. Licensee management acknowledged the findings presented and indicated that no proprietary information was provided to the team.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- J. Solymossy, Site Vice President
- M. Werner, Plant Manager
- T. Allen, Production Planning Manager
- W. Bodin, Operations Support Manager
- S. Cook, Nuclear Oversight Manager
- G. Eckholt, Regulatory Affairs Manager
- D. Fricke, Performance Assessment Engineer
C, Goranowski, Employees Concerns Program Manager
- P. Huffman, System Engineering Manager
- A. Johnson, Radiation Protection Manager
- J. Kivi, Licensing Engineer
- M. Klee, Performance Assessment Engineer
- M. Ladd, General Superintendent Plant Maintenance
- S. Northard, Engineering Director
- A. Qualantone, Security Manager
- T. Silverberg, Performance Assessment Manager
Nuclear Regulatory Commission
- J. Adams, Senior Resident Inspector, Prairie Island
- P. Hiland, Acting Deputy Division Director, Division of Reactor Projects
- P. Louden, Chief Reactor Projects Branch 5
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000282/2003007-01 NCV Inadequate Corrective Actions to Prevent Recurrence for
- 05000306/2003007-01 the Control of Material That Could Potentially Block Critical Drain Paths
Discussed
None
LIST OF INFORMATION REQUESTED 1.
A copy of administrative procedure(s) for the corrective action process, trending program, quality assurance audit program, self-assessment program, corrective action effectiveness review program, and industry experience review program.
2.
A copy of Quality Assurance audits and/or self-assessments of the corrective action program completed since July 2001.
3.
A copy of the Quality Assurance manual.
4.
A copy of the Employee Concerns Program/Ombudsman administrative procedure.
5.
A list of Quality Assurance audits completed since July 2001 with brief description of areas where findings were identified.
6.
A list of self-assessments completed since July 2001.
7.
A list of root cause evaluations completed since July 2001.
8.
A list of test failures (In-Service Testing or Technical Specification surveillances) since July 2001, with a brief description of component/system which failed.
9.
A list of all open condition reports sorted by significance level. Include a description of the issue and the significance category.
10.
A list of condition reports closed since July 2001 including a description, significance category, date initiated, date closed, and whether there is an associated operability evaluation.
11.
A list of condition reports initiated since July 2001 that involve inadequate or ineffective corrective actions. Include a brief description, status, and significance category of the issue.
2.
A list of condition reports initiated since July 2001 that identify trends of conditions adverse to quality. Include a brief description, status, and significance category for each item.
13.
A copy of any performance indicator reports used to track the corrective action program effectiveness.
14.
A list of condition reports issued during the past three refueling outages sorted by system and component, including a brief description, status, and significant category for each item.
15.
A list of the top 10 risk significance systems and components.
16.
Copies of the latest outage critiques for each unit.
17.
Copy of the site organization chart.
18.
List of times and locations of meetings, particularly those associated with the corrective action process.
19.
List of rework items and repeat equipment failures since July 2001.
20.
Copies of any condition reports generated as a result of any self-assessments conducted of the corrective action program in preparation for this inspection.