IR 05000346/2013007

IR 05000346-13-007; on 07/22/2013 - 08/9/2013; Davis-Besse Nuclear Power Station; Biennial Problem Identification and Resolution (Pi&R) Inspection

ML13266A431
Person / Time
Site:	Davis Besse
Issue date:	09/23/2013
From:	Patricia Pelke NRC/RGN-III/DNMS/MLB
To:	Lieb R FirstEnergy Nuclear Operating Co
References
IR-13-007
Download: ML13266A431 (30)

Text

ber 23, 2013

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000346/2013007

Dear Mr. Lieb:

On August 9, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution biennial inspection at your Davis-Besse Nuclear Power Station.

The enclosed inspection report documents the inspection results, which were discussed on August 9, 2013, with you and other members of your staff.

This inspection was an examination of activities conducted under your license as they relate to problem identification and resolution 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.

Based on the inspection sample, the inspection team concluded that the implementation of the corrective action program and overall performance related to identifying, evaluating, and resolving problems at Davis-Besse Nuclear Power Station effectively supported nuclear safety.

Licensee-identified problems were entered into the corrective action program at a low threshold.

Problems were prioritized and evaluated commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner commensurate with their importance to safety and addressed the identified causes of the problems. Lessons learned from industry operating experience were generally reviewed and applied when appropriate. Audits and self-assessments were effectively used to identify site performance deficiencies, programmatic concerns, and improvement opportunities. Based on the interviews conducted, the inspectors did not identify any impediment to the establishment of a safety conscious work environment at Davis-Besse Nuclear Power Station. Licensee staff is willing to raise concerns related to nuclear safety through at least one of the several means available. Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management 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/

Patricia J. Pelke, Acting Chief Branch 6 Division of Reactor Projects Docket No. 50-346 License No. NPF-3

Enclosure:

Inspection Report 05000346/2013007 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-346 License No: NPF-3 Report No: 05000346/2013007 Licensee: FirstEnergy Nuclear Operating Company (FENOC)

Facility: Davis-Besse Nuclear Power Station Location: Oak Harbor, OH Dates: July 22 through August 9, 2013 Inspectors: J. Rutkowski, Project Engineer, Team Lead M. Holmberg, Senior Reactor Inspector B. Winter, Reactor Engineer T. Briley, Resident Inspector Approved by: Patricia J. Pelke, Acting Chief Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

Inspection Report (IR) 05000346/2013007; 07/22/2013 - 08/9/2013; Davis-Besse Nuclear

Power Station; Biennial Problem Identification and Resolution (PI&R) Inspection.

This inspection was performed by three regional based inspectors and the Davis-Besse Nuclear Power Station resident inspector. No findings of significance or violations of NRC requirements were identified during this inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 4, dated December 2006.

Problem Identification and Resolution Based on the samples selected for review, the team concluded that implementation of the corrective action program (CAP) at Davis-Besse Nuclear Power Station was effective. The licensee had a low stated threshold for identifying problems and entering them in the CAP.

Items entered into the CAP were generally screened and prioritized in a timely manner using established criteria, although the team identified timeliness issues for a small percentage of issues. Issues in the CAP were properly evaluated and corrective actions were generally implemented in a timely manner. The team noted that the licensee reviewed operating experience (OE) for applicability to station activities. Audits and self-assessments were performed at an appropriate level to identify deficiencies. Based on interviews conducted during the inspection, licensee staff expressed freedom to raise nuclear safety concerns and to enter nuclear safety concerns into the CAP.

NRC-Identified

and Self-Revealed Findings None.

Licensee-Identified Violations

None.

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constituted one biennial sample of Problem Identification and Resolution (PI&R) as defined in Inspection Procedure (IP) 71152, Problem Identification and Resolution. Documents reviewed are listed in the Attachment to this report.

.1 Assessment of the Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the licensees Corrective Action Program (CAP) implementing procedures and attended CAP meetings to assess the implementation of the CAP by licensee staff. The inspectors also interviewed licensee staff about their use of the CAP.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC PI&R inspection in March 2011. The selection of issues ensured an adequate review of issues across NRC cornerstones. The inspectors used issues identified through NRC generic communications, department self-assessments, licensee audits, OE reports, and NRC documented findings. The inspectors reviewed Condition Reports (CRs) that were generated and a selection of completed investigations from the licensees various investigation methods, which included root cause, full apparent cause, limited apparent cause, and common cause investigations.

The inspectors selected the instrument air and station air systems to review in detail because the system had numerous operational problems in recent years and was in Maintenance Rule (a)(1) category. The intent of the review was to determine whether the licensee staff were properly monitoring and evaluating the performance of these systems through effective implementation of station monitoring programs. A five-year review of the air systems was performed to assess the licensees efforts in monitoring for system degradation due to aging aspects. The inspectors also performed partial system walkdowns of the main feedwater system, service water system, and emergency diesel generators. A review of the use of the station maintenance rule program to help identify equipment issues was also conducted.

During the reviews, the inspectors determined whether the licensees actions were in compliance with the licensees CAP and 10 CFR Part 50, Appendix B requirements.

Specifically, the inspectors determined whether licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the stations CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also determined whether the licensee staff assigned the appropriate investigational method to ensure the correct determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and eight NRC previously identified findings that included principally non-cited violations.

Documents reviewed are listed in the Attachment to this report.

b. Assessment

(1) Effectiveness of Problem Identification Based on the information reviewed, including initiation rates of CRs and interviews, the inspectors concluded that the licensee has a low threshold for initiating CRs, and from the CRs reviewed, the threshold was appropriate. Some of the non-supervisory licensee staff interviewed believed the CAP was ineffective for items of low safety significance partially due to the large number of low safety significant issues in the CAP. Several of the individuals interviewed stated they refrained from using the CAP for perceived non-safety-significant issues. The same individuals also stated that they would report nuclear safety issues. The inspectors did not identify any safety significant item that was not entered into the CAP. The inspectors assessed the effectiveness of problem identification as adequate.

Observations The inspectors found that issues were being identified and captured in the licensees programs and particularly in the CAP. During a non-outage year, about 4000 to 5000 CRs are initiated with most being of low safety significance. The inspectors found through interviews that licensee staff understood the expectation to write CRs for issues and did write CRs. In several departments, licensee staff regularly passed issues on to their supervisors and the supervisors wrote the CRs. However, several non-supervisory licensee staff from the small groups interviewed said that they believed the CAP system was ineffective for less than significant nuclear safety issues and several of them said that that they would not use the CAP system for minor issues. However, the inspectors noted that all the small groups interviewed stated that they would not hesitate to bring problems and issues to their immediate supervisors. All licensee staff interviewed said they would raise nuclear safety issues. The inspectors did not identify any specific safety significant issues where it was clear that an individual should have written CRs and did not.

Based on a similar concern that had been previously identified to the licensee earlier this calendar year (2013) from a review performed by an external group, the licensee initiated CR 2013-12261, Observation on Condition Reporting Effectiveness.

Corrective actions were identified and scheduled; some of them were ongoing during the inspection in response to the external groups review.

The licensee has an established (but not proceduralized) expectation that CRs are initiated in the CAP within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after discovery of an adverse condition and subsequently initially reviewed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The inspectors reviewed the last nine months of CRs for timeliness of initiation. Of the approximately 4000 CRs that were documented in the CAP, approximately 80 (2 percent) of the CRs were initiated 4 days or more from discovery of the adverse condition and approximately 5 CRs were initiated greater than 30 days after discovery. In the last nine months, the licensee initiated at least 15 CRs to document untimely CR initiation and at least 10 CRs to document untimely supervisory review (24-hour expectation for supervisors to review CRs once initiated). Additionally, the inspectors identified that no CR had been written to document the untimely initiation of CR 2013-11691, which documented failure of an integrated head assembly vent fan, even though the CR was initiated 14 days after discovery of the condition and after actions to address the issue had already been taken.

To address this issue, the licensee initiated CR 2013-12110, Condition Reports not submitted for Notifications associated with BF2129, to document the untimely initiation of CR 2013-11691.

The timely initiation of CRs after an adverse condition is discovered appears inconsistent and was previously documented in various CRs and self-assessments. Although the CAP document (NOP-LP-2001, Corrective Action Program) does not specify time requirements for initiating CRs, licensee staff interviewed during the inspection were aware of the site expectation. To address this issue, the licensee initiated CR 2013-12262, Observation on Condition Report Timeliness.

The inspectors noted that in addition to the CAP, the licensee had other systems that capture items or issues that require action. Specifically, the inspectors briefly reviewed procedure change tracking, mainly in Operations, and the simulator work tracking system. The inspectors did not identify any timeliness issues relative to reporting issues, but had questions on the number of Operations procedures change requests and simulator work issues. The Operations procedure backlog has approximately 900 open change requests.

Findings No findings of significance were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the classification of CRs for resolution and determined that, in general, CRs were assigned appropriate prioritization and evaluation levels. Evaluations in apparent cause and root cause reports reviewed by the inspectors were adequate. In several CR cause evaluations, the inspectors identified some items they considered weaknesses in the evaluation of issues, such as failure to address a contributing cause for Pressurizer Code Safety Valve setpoint test failure and a contributing cause for a failure to properly control equipment configuration and status. The inspectors noted that other internal and external review groups identified issues with the quality of the licensees limited apparent cause evaluations. The inspectors determined that the licensees prioritization and evaluation of issues were sufficient to ensure that established corrective actions would be effective and that there was appropriate consideration of risk in prioritizing issues.

Observations Over the last two years (second half 2011 through August 2013) approximately 12,000 CRs were documented in the CAP. Ninety-five percent or more of the CRs from the second half of 2011 to the end of 2012 are listed either in a closed or archive status.

The majority of those that remain open appear to be related to corrective actions requiring outage related repairs. Approximately 50 percent of the CRs from 2013 (3300 total) are listed in the CAP as closed or archive status. The inspectors determined that these numbers were generally consistent with an effective program.

In CR-2011-88100, Root Cause - Pressurizer Code Safety Valves Setpoint Test Failure, the direct cause was identified as setpoint drift and it was concluded that the exact cause of the setpoint variance (drift) was indeterminate. Additionally, the licensee concluded that the different vendors and test conditions established for the as-left and as-found setpoint tests, were minor in nature, but may have affected the test results.

However, a corrective action (CA) was not assigned to control future test conditions or to maintain a single test vendor to eliminate this potential contributing cause. This example illustrated a weakness in identification of a potential contributing cause for a significant condition adverse to quality. If a contributing cause was not identified, the effectiveness of the CAs taken could be less than fully effective. The inspectors did not identify any CAs that were less than effective as a result of the licensees failure to identify a contributing cause.

In CR-2012-08422, Root Cause- DC (Direct Current) Motor Control Center Busses Not Supplied by Operable DC Sources, the licensee identified that the root cause was less than adequate administrative controls for equipment and system configuration control during maintenance and testing activities. DC battery maintenance work had been field completed, but not through a final post maintenance test, but this status was not properly identified and the system was declared operable. However, no CA was identified to determine if the total population of backlogged work orders of field completed work, waiting for final post maintenance testing, contributed to the cause of this issue. The inspectors noted in self-assessment (SN-SA-2012-0311) the licensee identified a backlog of 57 work orders with a field complete or awaiting testing status. This example illustrated a weakness in identification of a potential contributing cause for a condition adverse to quality. If a contributing cause was not identified, the effectiveness of the CAs taken could be less than fully effective. The licensee initiated CR 2013-12263, Observation on Weakness in Condition Report Evaluation to capture the inspectors observations. The inspectors did not identify any CAs that were less than effective as a result of the licensees failure to identify a contributing cause.

Findings No findings of significance were identified.

(3) Effectiveness of Corrective Actions In general, the corrective actions reviewed addressed the cause of the identified problem, and appeared to have been effective in the majority of samples reviewed, although some weaknesses were observed but did not preclude the inspectors from assessing corrective actions as generally effective.

The licensee used the CAP to identify problems and utilized the Maintenance Rule Program and the System Health Report to develop plans for Station and Instrument Air system improvement. The plans included replacement with new parts and equipment, refurbishment of components, and fine-tuning the operating band of the Station and Instrument Air system. The inspectors concluded that the licensee placed appropriate attention and actions to improve the system performance.

Observations The inspectors did not identify any new recurrent issues of significance, though CRs initiated by the licensee identified several recurrent issues. The inspectors noted that the licensee had activities to address recurring human performance issues that were identified and that were self-revealing. The inspectors also noted that during this assessment period, there was a violation associated with the seismic monitoring system that was essentially the same as a violation in 2007 for which a root cause evaluation was performed. This violation was documented in a quarterly integrated inspection report developed by the resident inspector office. The inspectors did not identify any additional issues regarding this violation beyond those previously documented in the inspection report.

In CR-2012-18831, Root Cause-Decay Heat Pump Cyclone Separator Configuration Control, the licensee concluded that an effectiveness review was not warranted for the CA to preclude the recurrence of the root cause identified as an inadequate design interface review. The conclusion was based on the assumption that the revisions made to the current procedure for control of the design interface reviews would prevent a similar error and in part based upon a CAP data base key word search completed using the terms of DIE and Design Interface. However, a similar design interface review error would not likely be identified in the CAP data base search using these key words unless it had resulted in a substantial issue that required an apparent or root cause investigation. The inspectors determined that this example illustrated a potential weakness in evaluating the effectiveness of a CA.

In CR-2011-88100, Root Cause - Pressurizer Code Safety Valves Setpoint Test Failure, the licensee completed an effectiveness review of the CA that implemented a revised (lowered) setpoint test band to gain additional margin to accommodate for setpoint drift. The scope of the effectiveness review included an evaluation of the subsequent test results for pressurizer Code safety relief valve tests after implementing the revised setpoint test band. These test results included one Code safety relief valve that failed low out of specification (i.e. 3.4 percent below setpoint). The cause of this test failure was setpoint drift but may have occurred, in part, due to the lowered setpoint test band established as the CA for the root cause. However, the licensees effectiveness review did not include an evaluation to determine if the CA for the root cause (e.g.

lowered setpoint band) contributed to this low setpoint lift failure. The inspectors assessed the licensees decision not to investigate the potential negative impacts or unintended consequences of this CA as appearing inconsistent with the recommended actions for conducting effectiveness reviews as discussed in Section 4.7.5.2 of NOPBP-LP-2011 FENOC Cause

Analysis.

This example illustrated a potential weakness in the conduct of a CA effectiveness review. However, the inspectors did not identify an inappropriate corrective action.

The inspectors reviewed the results of CRs used to document some areas of concern identified in the 2012 Safety Conscious Work Environment (SCWE) Surveys.

Specifically the inspectors reviewed CRs written for Regulatory Compliance, Operations, and Maintenance departments. The CRs for Maintenance and Operations had each listed a CA that did not appear to correct any issues but were for additional investigations. Both CRs were closed with no indication of any additional actions to be taken to address the identified issues. Discussions with Maintenance and Operations revealed that the management of those departments did have additional plans to document and address the issues, but that these plans were not written down in any CR documents or any other document provided to the inspectors. While those two CRs were classified as adverse fix (AF), and did not require any detailed analysis under the CAP, the actions listed did not address correcting the identified issues. The inspectors did not identify any non-compliance with licensees procedural requirements associated with the reviewed CRs.

Findings No findings of significance were identified.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed implementing OE program procedures, attended CAP meetings to observe the use of OE information, completed evaluations of OE issues and events, and selected monthly assessments of the OE composite performance indicators. The intent of the review was to: (1)determine whether the licensee was effectively integrating OE experience into the performance of daily activities;

(2) determine whether evaluations of issues were appropriate and conducted by qualified individuals;

(3) determine whether the licensees program was sufficient to prevent future occurrences of previous industry events; and (4)determine whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of OE experience, were identified and implemented effectively and timely.

Assessment Overall, the inspectors determined that the licensee was adequately evaluating industry OE for relevance to the facility. The licensee had entered all applicable items in the CAP in accordance with the licensees procedures. Both internal and external OE was being incorporated into lessons learned for training and pre-job briefs. System Engineers utilized industry OE to resolve equipment operational problems. The inspectors concluded that the licensee was evaluating industry OE when performing root cause and apparent cause evaluations. The inspectors noted that the licensee had identified a small number of OE evaluations where the evaluation time was longer than the procedure NOBP-LP-2100, FENOC Operating Experience Process, requirement of 150 days. However, this did not affect the overall assessment and the inspectors concluded that the licensee used operating experience appropriately.

Observations The inspectors identified a weakness resulting in backlogged 10 CFR Part 21 notifications when the 10 CFR Part 21 Coordinator was transferred to another group.

After the teams discovery, the licensee initiated CR-2013-12246, The Review of 10 CFR Part 21 Notices of D-B Applicability is Backlogged, and initiated actions to distribute the backlogged 10 CFR Part 21 notifications.

b. Findings

No findings of significance were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors assessed the licensee staffs ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions, through efforts from departmental assessments and audits. The inspectors reviewed audit reports and completed assessments.

Assessment The inspectors concluded that self-assessments and audits were typically accurate, thorough, and effective at identifying most issues and enhancement opportunities at an appropriate threshold. The inspectors concluded that personnel knowledgeable in the subject area completed audits and self-assessments. In many cases, self-assessments and audits identified issues that were not previously recognized by the licensee.

Observations The inspectors reviewed some documents that implied or stated the licensee was behind schedule in completing some assessments; however, the inspectors did not identify any issues where the licensees assessments missed issues or were not of sufficient depth.

The inspectors did question the licensees recent assessment of the Self-Assessment process or program. That assessment appeared to be primarily a compliance assessment and did not evaluate the effectiveness of the licensees assessment process. The inspectors were not provided with a document that evaluated the effectiveness of the assessment process over the two-year period of the inspection. The licensee stated that an assessment, to evaluate effectiveness, was planned but had not been done.

The licensee completed a number of self-assessments in the Operations and Maintenance Departments over the past two years. In response to repeat Quality Assurance Department findings of marginal performance in the conduct of operations, the Operation Department had increased the frequency of snapshot type self-assessments with a focus on adverse trend identification. Overall, the assessments and trending for maintenance and operations issues appeared to be thorough and included acceptance criteria to determine when a trend was no longer of concern.

b. Findings

No findings of significance were identified.

.4 Assessment of Safety Conscious Work Environment (SCWE)

a. Inspection Scope

The inspectors assessed the licensees SCWE through the review of the licensees employee concern program (ECP), implementing procedures, discussions with the coordinator of the ECP, interviews with personnel from various departments, and reviews of issue reports. The inspectors also reviewed the results from SCWE surveys conducted in 2011 and 2012.

As part of the overall inspection effort, inspectors discussed department and station programs with a variety of staff members. In addition, the inspectors interviewed approximately 44 individuals, who were placed in twelve groups, each of which was composed of three to five individuals from various departments, to assess their willingness to raise nuclear safety issues. The individuals were non-supervisory personnel and were selected in a manner that provided a distribution across the various departments at the site. In addition to assessing individuals willingness to raise nuclear safety issues, the interviews also addressed changes in the CAP and plant environment over the past 2 years. Other items discussed included:

• knowledge and understanding of the CAP;

• effectiveness and efficiency of the CAP; and

• willingness to use the CAP.

Assessment Interviews indicated that the licensee has an environment where people are free to raise nuclear safety issues without fear of retaliation. Documents provided to the inspectors regarding the SCWE surveys generally supported the conclusions from the interviews.

All interviewees indicated that personnel would raise nuclear safety issues, although several interviewed groups said they might refrain from raising issues of low safety significance. All of the individuals interviewed knew that in addition to the CAP, they could raise issues to their immediate supervisor, the ECP, or the NRC. Several of the individuals interviewed stated they would not use the ECP due to concerns regarding the effectiveness of the program or the anonymity provided by the program; however, these individuals also stated that they had never used the ECP.

The licensee had ongoing actions in place to address the individuals that would not use the CAP or believed that it was not effective for low safety significant items. All of the individuals interviewed stated that they would report nuclear safety issues. The inspectors concluded that the licensees SCWE was acceptable. In addition, the licensee indicated that they were aware of issues with ECP and initiated a CR to address the issues that were identified by the inspectors during interviews with staff.

Based on this information as well as the low number of allegations received by the NRC, the inspectors determined that the ECP process was implemented adequately.

Observations The inspectors reviewed the ECP log and three case files. No issues were identified.

It was also noted that over the last twelve months, there were only two allegations received by the NRC. The inspectors talked with the groups interviewed for SCWE about their use of the ECP. Personnel in several groups stated that they would not use the ECP either because of trust issues or effectiveness of the process. The inspectors noted that many of the interviewed personnel that stated they would not use the program had never used the program. Some other individuals said that it was their personal preference not to use the program. Many said that they had never had the need to use the program. The interview results were consistent with trends shown in SCWE surveys conducted by the licensee. The licensee initiated CR 2013-12258, ECP Program Observation, which as classified requires a limited apparent cause investigation. That CR also documented that the licensee was aware of the issues some station personnel had with the ECP.

All of the twelve groups interviewed identified that one of the organizational issues was staffing. This was identified as an employee concern in previous assessments conducted by the licensee. Individuals stated that they have mentioned this issue to their supervisor, and in many cases, to their management. The inspectors did not identify any CAP issues specifically attributable to the interviewed individuals belief that staffing was inadequate. The licensee was aware of the staffs beliefs related to staffing.

Several groups stated that it is harder now to get work done than it was in the past.

Complexity of requirements and additional requirements has complicated the work process. Several of these groups stated that, while important equipment is being maintained when necessary, because of the more complex processes and lack of resources, some equipment and systems are not being maintained the way staff think it should or consistent with the licensees stated standards of excellence. The inspectors did not identify any CAP issues specifically related to the perceived complexity of work processes.

Several individuals interviewed stated that while the CAP worked for safety significant items, they believed it did not work for less significant items. Some individuals stated that the effectiveness of the program was impacted by the requirement to document all the issues. The inspectors noted that this issue had been previously identified and did not identify any issue that was not captured in the CAP.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On August 9, 2013, the inspectors presented the inspection results to Mr. R. Lieb, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Lieb, Site Vice President

T. Summers, Manager - Site Operations

G. Wolf, Supervisor - Regulatory Compliance

J. Sturdavant, Senior Specialist - Regulatory Compliance

P. McCloskey, Manager - Regulatory Compliance

D. Missig, Superintendent - Maintenance

NRC Personnel

P. Pelke, Acting Chief, Branch 6, Division of Reactor Projects

D. Kimble, Senior Resident Inspector

Attachment

LIST OF ITEMS

Opened

None

Closed

None Attachment