Text

10CFR50.75g File: AR00237296 Overflowed CST
	ML101940452
Person / Time
Site:	Brunswick
Issue date:	06/03/2008
From:	; Progress Energy Carolinas
To:	; Office of Information Services
References
	FOIA/PA-2010-0209
	Download: ML101940452 (97)
	v • d • e

Page 1 Printed: 07/08/08 ACTION REQUEST 00237296 Type NCR Orig Date: 06/21/07 16:44 Discovery Date:

Subject : AOP-5 ENTRY DUE TO SPILL AT U2 CST Description WHILE UNIT 1 WAS LOWERING TORUS LEVEL PER lOP-17, THE CONTROL ROOM RECEIVED A REPORT OF A SPILL AT THE UNIT 2 CST.

THE UNIT 1 TORUS LINE UP WAS SECURED AND THE SPILL STOP.

INITIAL REPORTS ARE THAT UNIT 1 TORUS WATER HAS BEEN SPILLED ONTO THE GROUND AND HAS ENTERED THE STORM DRAIN SYSTEM. AOP

-5 WAS ENTERED. E&RC AND LICENSING HAS BEEN NOTIFIED.

CURRENTLY UNABLE TO DETERMINE VOLUME OF LEAK. THE STORM DRAIN SYSTEM ELECTRIC PUMP BREAKERS ARE TURNED OFF TO PREVENT UNCONTROLLED PUMPING AND PLANS ARE BEING DEVELOPED TO PUMP BASIN.

Priority : 1 Report To. : Status: COMPLETE 06/03/08 Due Date : 06/21/08 Event Date Originator : STACYL Originator Group:

Facility : BNP Department : BK5 Organization:

Owed To : Owed To Group : OPSUEVAL Owed To Fac: BNP Department : Discipline AR Status History Updated Date Updated By AR Status AR Due Date 06/21/07 STACYL INPROG 06/21/07 STACYL H/APPR 06/27/07 VANLEW 06/21/08 06/27/07 VANLEW PRE-APRV 06/27/07 VANLEW APPROVED 06/03/08 VANLEW COMPLETE

Page 2 Printed: 07/08/08 ACTION REQUEST 00237296 Request Attribute Value Reqd Date lA POT'L OPER/REPORT N Y 06/21/07 Name : LARRY STACY Request Attribute Value Reqd Date lB EQUIPMENT RELATED N Y 06/21/07 Name : LARRY STACY Request Attribute Value Reqd Date 2 SUPERVISOR REVIEW Y N 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 2A CR VALID? Y Y 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 2B FURTHER INVN REQD Y Y 06/22/07 Name : MARK SCHALL Information to include for No Further Investigation Required Include the following information for Priority 2:

Inappropriate Act statement (include work group involved, if known)

Apparent Cause including code Completed Corrective Actions - CORR, or Additional Corrective Actions if needed - including recommended assignee and recommended due date Include the following information for Priority 3:

Completed Corrective Actions - CORL, or Additional Corrective Actions if needed - including recommended assignee and recommended due date Request Attribute Value Reqd Date 2C RECOMMENDED OWNER OPERATIONS N 06/22/07 Name : MARK SCHALL Initial investigation has shown that it is probable that the associated work order for disassembly of the check valve (WO 1033023, task 11, Clearance request 10836) was added to the CST clearance (CO 138829) without providing a proper isolation. Therefore it appears that the error was in the clearance preparation process.

Request Attribute V* alue Reqd Date 2D OPER/REPORT ISSUE Y Y 06/22/07 Name : MARK SCHALL Request Attribute V* alue Reqd Date 2D1EQUIPMENT RELATED N Y 06/22/07 Name : MARK CHALL

Page 3 Printed: 07/08/08 ACTION REQUEST 00237296 Request Attribute V alue Reqd Date 2E MAINT RULE APPLIC N N 06/22/07 Name : MARK SCHALL Request Attribute V alue Reqd Date 2F SYSTEM 3 070 Y 06/25/07 Name : SYLVIA EDWARDS Changed from N/A to 3070 per Jim Boone, MR Coordinator. sde 6/25/07 Request Attribute Value Reqd Date 3 OPERATIONS REVIEW Y N 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 3A IMMED REPT ISSUE N N 06/22/07 Name : MARK SCHALL See log entry made into the Unit 2 autolog on 6/21/2007 at 15:43. This condition is not immediately reportable.

Request Attribute Value Reqd Date 3B OCR N N 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 3B1 OPER ISSUE N N 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 3B2 REPORT ISSUE Y N 06/22/07 Name : MARK SCHALL Reportability will need to be evaluated due to a condition that existed from the time the check valve was disassembled (approximately 6/1/2007) until the line was properly isolated on the evening of 6/21/2007. The need for this evaluation is based on the following:

During the subject time frame, if an accident occurred on either unit, with fuel damage, and in the course of the accident, the suppression pool needed to be pumped, many gallons of highly contaminated water would have been released through the disassembled check valve to the storm drain basin.

Request Attribute Value Reqd Date 3B3 REW N N 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 3B4 DEG/NCON N 06/22/07 Name : MARK SCHALL Request Attribute Value Reqd Date 3C TRACKING NUMBER N/A N 06/22/07 Name : MARK SCHALL

Page 4 Printed: 07/08/08 ACTION REQUEST 00237296 Request Attribute Value Reqd Date 4 REG AFF REVIEW N Name :

Request Attribute Value Reqd Date 4A OPER/REPORT ISSUE N Y 06/26/07

(

Name : WILLIAM MURRAY Request Attribute Value Reqd Date 4AI OPER ISSUE N Y 06/26/07 Name : WILLIAM MURRAY Request Attribute Value Reqd Date 4A2 REPORT ISSUE N Y 06/26/07 Name : WILLIAM MURRAY This is not immediately reportable under 10 CFR 50.72. However, per Attribute 4B, a follow-up assignment to Engineering has been requested in order to determine whether the identified configuration (i.e., the 2-CO-V162 check valve being disassembled, but the pathway not being isolated) could have resulted in an event or condition that could have prevented fulfillment of the safety function of structures or systems needed to control the release of radiation.

Updated 7/9/07: Based on discussions with Paul Flados, the only scenario of concern for getting highly contaminated water to the torus would be an Alternate Source Term design bases LOCA. A Group 2 isolation occurs on a LLI or high drywell pressure signal, which would isolate the path to radwaste and prevent release of contaminated water under the conditions which are documented in this NCR. This condition could not have prevented fulfillment of containment and, as such, is not reportable. Mark Turkal Request Attribute Value Reqd Date 4A3 REW N Y 06/26/07 Name : WILLIAM MURRAY Request Attribute Value Reqd Date 4A4 DEG/NCON N 06/26/07 Name : WILLIAM MURRAY Request Attribute Value Reqd Date 4B FOLLOWUP ASG REQD N Y 07/09/07 Name : MARK TURKAL Update 7/9/07. It was determined that this is not a reportable condition.

See Attribute 4A2 foradditional discussion on reportability. Mark Turkal A follow-up assignment should be issued to Engineering to evaluate the postulated scenario described in Attribute 3B2 to determine whether the identified configuration (i.e., the 2-CO-V162 check valve being disassembled, but the pathway not being isolated) could have resulted in an event or condition that could have prevented fulfillment of the safety function of structures or systems needed to control the release of radiation. The due date should be July 10, 2007, to allow time for root cause and LER preparation if past operability is a concern. Please

Page 6 Printed: 07/08/08 ACTION REQUEST 00237296 Request Attribute Value Reqd Date 6F LAST COM ITM DUE Name Request Attribute Value Reqd Date 6G EQUIP PRI ISSUE N Name Request Attribute Value Reqd Date 6H RESP MGR N Name Request Attribute Value Reqd Date 61 EQUIP PRI STATUS N Name ACTION REQUEST APPROVAL REVIEW Route List: 001 Route List Initiator: STACYL Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time SCHALM BNP OPSSUPV A SCHALL 06/21/07 16:44 APPROVED 06/22/07 01:21 SCHALM BNP CONTROOM A SCHALL 06/22/07 01:21 APPROVED 06/22/07 01:21 MURRAW BNP REGREV A MURRAY 06/22/07 01:21 APPROVED 06/26/07 08:46 VANLEW BNP UNITEVAL A VAN KLEECK 06/26/07 08:46 APPROVED 06/27/07 06:52 TREND-CAUSE Facility: BNP Trend 1: CCAUSE Trend 2: F Trend 3: F4A Date: 08/07/07 Process: N/A Org: MNT Rank: S Assign:

==

Description:==

POLICY/EXPECTATIONS WERE NOT WELL DEFINED OR UNDER INAPPROPRIATE ACT: CLEARANCE HOLDER/WORK ORDER IMPLEMENTER PERFORMED AN INADEQUATE PRE-JOB BRIEF PRIOR TO STARTING WORK.

CONTRIBUTING CAUSE: FAILURE TO ESTABLISH AND ENFORCE PROPER PRE-JOB BRIEF STANDARDS.

CAUSE CODE: F4A Facility: BNP Trend 1: CCAUSE Trend 2: I Trend 3: I8G Date: 08/07/07 Process: N/A Org: MNT Rank: S Assign:

==

Description:==

FAILURE TO FOLLOW PROCEDURE AS WRITTEN INAPPROPRIATE ACT: FAILURE TO PROPERLY IMPLEMENT THE CLEARANCE REQUEST, AND CLEARANCE DEVELOPMENT PROCESS.

CONTRIBUTING CAUSE: CLEARANCE REQUESTER, CLEARANCE PREPARER, AND CLEARANCE REVIEWER FAILED TO FOLLOW THE APPLICABLE PROCEDURES CAUSE CODE: I8G Facility: BNP. Trend 1: CCAUSE Trend 2: I Trend 3: I8G Date: 08/07/07 Process: N/A Org: OPS Rank: S Assign:

==

Description:==

FAILURE TO FOLLOW PROCEDURE AS WRITTEN INAPPROPRIATE ACT: FAILURE TO PROPERLY IMPLEMENT THE CLEARANCE REQUEST, AND CLEARANCE DEVELOPMENT PROCESS.

CONTRIBUTING CAUSE: CLEARANCE REQUESTER, CLEARANCE PREPARER, AND CLEARANCE REVIEWER FAILED TO FOLLOW THE APPLICABLE PROCEDURES.

CAUSE CODE: I8G

Page : 5 Printed: 07/08/08 ACTION REQUEST 00237296 include Licensing as a secondary owed-to organization for this assignment.

- Bill Murray 6/26/07 Request Attribute Value Reqd Date 4C T. SPEC VIOLATION N Y 06/26/07 Name : WILLIAM MURRAY Request Attribute Value Reqd Date 4D ADD'L REPORT REQD N Y 06/26/07 Name : WILLIAM MURRAY Request Attribute Value Reqd Date 4E PNSC/CSERB REQD N Y 06/26/07 Name : WILLIAM MURRAY Request Attribute Value Reqd Date 5 CLASSIFN/ASSIGNMNT N Name :

Request Attribute Value Reqd Date 5A CR VALID? Y Y 06/27/07 Name : LEWIS VAN KLEECK Request Attribute Value Reqd Date 5B FURTHER INVN REQD Y Y 06/27/07 Name : LEWIS VAN KLEECK Request Attribute Value Reqd Date 6 MISCELLANEOUS N Name :

Request Attribute Value Reqd Date 6A COMMENTS N Name Request Attribute Value Reqd Date 6B COMMENTS N Name Request Attribute Value Reqd Date 6C COMMENTS N Name :

Request Attribute Value Reqd Date 6D COMMENTS N Name :

Request Attribute Value Reqd Date 6E COMMENTS N Name :

Page 7 Printed: 07/08/08 ACTION REQUEST 00237296 Facility: BNP Trend 1: EVENT Trend 2: EC Trend 3: EC65 Date: 06/27/07 Process: OPI Org: OPWC Rank: Assign:

==

Description:==

REQUIREMENTS NOT FOLLOWED Facility: BNP Trend 1: RCAUSE Trend 2: I Trend 3: IIC Date: 08/07/07 Process: N/A Org: MNT Rank: S Assign:

==

Description:==

ASSUMPTIONS NOT VALIDATED INAPPROPRIATE ACT: FAILURE TO PROPERLY IMPLEMENT THE CLEARANCE REQUEST, AND CLEARANCE DEVELOPMENT PROCESS.

ROOT CAUSE: AN OVER RELIANCE, BY INVOLVED INDIVIDUALS, ON OTHER EXISTING CLEARANCE PROCESS BARRIERS TO ENSURE THE PROCESS DEVELOPS A CLEARANCE THAT ENSURES EQUIPMENT AND PERSONNEL SAFETY.

CAUSE CODE: IIC Facility: BNP Trend 1: RCAUSE Trend 2: I Trend 3: IIC Date: 08/07/07 Process: N/A Org: OPS Rank: S Assign:

==

Description:==

ASSUMPTIONS NOT VALIDATED INAPPROPRIATE ACT: FAILURE TO PROPERLY IMPLEMENT THE CLEARANCE REQUEST, AND CLEARANCE DEVELOPMENT PROCESS.

ROOT CAUSE: AN OVER RELIANCE, BY INVOLVED INDIVIDUALS, ON OTHER EXISTING CLEARANCE PROCESS BARRIERS TO ENSURE, THE PROCESS DEVELOPS A CLEARANCE THAT ENSURES EQUIPMENT AND PERSONNEL SAFETY.

CAUSE CODE: IIC Keywords Keyword Keyword Description CFGCNTRL CONFIGURATION CONTROL CLR/OPS CLEARANCE/OPERATIONS HUM PERF HUMAN PERFORMANCE RELATED PROCOMP PROCEDURE COMPLIANCE AR REFERENCE DOCUMENTS DOC SUB DOCUMENT REV MIN TITLE TYP TYP OR BNP AR 00237296 000 AOP-5 ENTRY DUE TO SPILL AT U

Page : 8 Printed: 07/08/08 ACTION REQUEST 00237296 ASS IGNMENT NUMBER 01 SUB Type INVN Due Date :08/07/07 Status COMPLETE Reschedule 3 Pri Resp Group: OPSWCSUPT Assigned To L VAN KLEECK Sec Resp Group:

Subject SACE: INVESTIGATE AOP-5 ENTRY DUE TO SPILL AT U2 CST Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department Z78 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 06/21/07 STACYL INPROG 06/27/07 VANLEW 07/19/07 06/27/07 VANLEW NTFY/PRI 06/27/07 WOODBW ACC/PRI 06/27/07 WOODBW NTFY/ASG 06/28/07 VANLEW ACC/ASG 07/19/07 VANLEW 07/26/07 07/25/07 VANLEW 08/02/07 08/02/07 VANLEW 08/07/07 08/02/07 VANLEW AWAIT/C 08/02/07 VANLEW ACC/ASG 08/02/07 VANLEW AWAIT/C 08/07/07 VANLEW ACC/ASG 08/07/07 VANLEW AWAIT/C 08/07/07 VANLEW COMPLETE Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date EXTERNAL OE RECOMM Y Y 08/02/07 Name : LEWIS VAN KLEECK Assignment Attribute Value Reqd Date INTERNAL OE RECOMM N Y 08/02/07 Name : LEWIS VAN KLEECK Assignment Attribute Value Reqd Date 1 EVALUATOR/ASSIGNEE N Name :

Page : 9 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS EXTENSION N 07/19/07 Name : LEWIS VAN KLEECK Obtained PGM approval for a one week extension, to 7/26/07. More time is required to obtain assignee concurrence and appropriate due dates for various assignments. LVK 7/19/07.

Obtained PGM approval for a one week extension, to 8/2/07. More time is required to obtain assignee concurrence and ensure appropriate Root Cause and CAPRs are assigned. LVK 7/25/07.

Permission has been obtained from the PGM to extend the due date on this assignment to 8/7/07. Due date extension is to allow additional time to modify current investigation and then complete required reviews and processing without going overdue. Agreement has been obtained for final product, and revision is in progress. LVK 8/2/07.

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Assignment Attribute Value Reqd Date 2A COMMENTS RETURNED N 08/07/07 Name : LEWIS VAN KLEECK This INVN was returned to correct minor errors on the INVN chart prior to completion. No conclusions or assignments were changed. The closure route list was revised to include only the OPSUEVAL as approvals from all required individuals was already obtained and no substantial changes were made. LVK 8/7/07.

Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

COMPLETION NOTES CAUSE/ACTION

Page : 10 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: VANLEW Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time VANLEW BNP OPSMGR A VAN KLEECK 08/02/07 13:22 RETURNED 08/02/07 16:24 HOWARS BNP OPSMGR A HOWARD 08/02/07 16:26 APPROVED 08/02/07 16:29 HOBBST BNP PGM A HOBBS 08/02/07 16:29 APPROVED 08/06/07 18:01 VANLEW BNP OPSUEVAL A VAN KLEECK 08/06/07 18:01 RETURNED 08/07/07 11:40 VANLEW BNP OPSUEVAL A VAN KLEECK 08/07/07 11:43 APPROVED 08/07/07 11:44 THEARG BNP OPEXCOORD I THEARLING 08/07/07 11:43 08/13/07 10:21

Page : 11 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 04 SUB Type CAPR Due Date : 10/18/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTMGR Assigned To : R BISSETT Sec Resp Group:

Subject : COMMUNICATE TO PERSONNEL THE IMPORTANCE OF Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : HGL Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 06/21/07 STACYL INPROG 08/07/07 VANLEW 10/18/07 08/07/07 VANLEW NTFY/PRI 09/20/07 BISSER ACC/PRI 09/20/07 BISSER NTFY/ASG 09/20/07 BISSER ACC/ASG 09/20/07 BISSER AWAIT/C 09/20/07 BOYCER COMPLETE COMMUNICATE TO PERSONNEL THE IMPORTANCE OF HAVING THE MINDSET THAT EACH INDIVIDUAL INVOLVED IN ANY PORTION OF THE CLEARANCE PROCESS MUST ACT LIKE THEY ARE THE ONLY BARRIER TO ENSURE PERSONNEL AND EQUIPMENT SAFETY Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name

Page 12 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS ASSIGNMENT SPLIT OUT N 08/29/07 Name : SHEILA WILLIAMS This assignment was originally issued to the Maintenance Manager, Susan Rogers. It was split out to each of the.Maintenance Supts.

-04 Richard Bissett (Maintenance Tech Services)

-27 Tim King (Mechanical Maintenance)

-28 Paul Smith (I&C/E Maintenance)

(SVW 8/29/07)

Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name COMPLETION NOTES COMMUNICATED TO MTS PERSONNEL ON 9/20/07. RAB 9/20/07.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: BISSER Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BISSER BNP MNTPSUPT A BISSETT 09/20/07 09:29 APPROVED 09/20/07 09:29 BOYCER BNP OPSUEVAL A BOYCE 09/20/07 09:29 APPROVED 09/20/07 15:15

Page 13 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 05 SUB Type CORR Due Date 11/13/07 Status COMPLETE Reschedule 1 Pri Resp Group: MNTPSUPT Assigned To R BISSETT Sec Resp Group:

Subject REINFORCE CLEARANCE REQUEST QUALITY STANDARDS Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department HGL Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 06/21/07 STACYL INPROG 08/07/07 VANLEW 10/18/07 08/07/07 VANLEW NTFY/PRI 08/30/07 BISSER ACC/PRI 10/18/07 WILLIS01 11/13/07 11/06/07 BISSER NTFY/ASG 11/06/07 BISSER ACC/ASG 11/06/07 BISSER AWAIT/C 11/06/07 VANLEW ACC/ASG 11/13/07 BISSER AWAIT/C 11/13/07 JOHNSCO5 COMPLETE REINFORCE CLEARANCE REQUEST QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY CLEARANCE REQUEST QUALITY IS AT THE APPROPRIATE LEVEL Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date IA COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name ;

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Page 14 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS ASSIGNMENT SPLIT OUT N 08/29/07 Name : SHEILA WILLIAMS This assignment was originally issued to the Maintenance Manager, Susan Rogers. It was split out to each of the Maintenance Supts.

-05 Richard Bissett (Maintenance Tech Services)

-29 Tim King (Mechanical Maintenance),

-30 Paul Smith (I&C/E Maintenance)

(SVW 8/29/07)

Extend assignment to 11/13/07 per Richard Bissett, acting for Susan Rogers. Additional time needed to complete the assignment. (SVW 10/18/07)

Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CLEARANCE REQUEST QUALITY STANDARDS WERE REINFORCED WITH MTS ON 11/06/07. NTM ITEM (NTM 254326) HAS BEEN GENERATED TO PROJECT MANAGERS AND SUPERVISOR TO CONDUCT OBSERVATIONS FO CLEARANCE PROCESS TO ENSURE QUALITY.

RAB 11/06/07 CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: BISSER Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BISSER BNP MNTPSUPT A BISSETT 11/06/07 16:08 APPROVED 11/06/07 16:08 VANLEW BNP OPSUEVAL A VAN KLEECK 11/06/07 16:08 RETURNED 11/06/07 16:23 BISSER BNP MNTPSUPT A BISSETT 11/13/07 10:18 APPROVED 11/13/07 10:18

Page 15 Printed: 07/08/08 ACTION REQUEST 00237296 JOHNSCO5 BNP OPSUEVAL A JOHNSON 11/13/07 10:18 APPROVED 11/13/07 16:31

Page 16 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUNER 06 SUB Type EREV Due Date : 06/05/08 Status : COMPLETE Reschedule 1 Pri Resp Group: OPSOUTSUPT Assigned To : A PADLECKAS Sec Resp Group:

Subject : COMPLETE AN EFFECTIVENESS REVIEW Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : CU2 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 06/21/07 STACYL INPROG 08/07/07 VANLEW 05/08/08 08/07/07 VANLEW NTFY/PRI 08/07/07 WOODBW ACC/PRI 08/07/07 WOODBW NTFY/ASG 05/02/08 PADLEA ACC/ASG 05/08/08 VANLEW 06/05/08 05/09/08 PADLEA AWAIT/C 06/03/08 VANLEW COMPLETE OF CORRECTIVE ACTION TO PREVENT RECURRENCE Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date IB CHANGE BASIS EXTENSION N 05/08/08 Name : LEWIS VAN KLEECK This assignment's due date was extended 4 weeks to 6/5/08 due to high workload. Assignment has been started and is close to completion but numerous equipment problems require immediate attention and would delay completion of the assignment and the required reviews. Extension approved by S. Howard - Operations Manager. LVK 5/8/08.

Page *: 17 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value \ Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3 ASSGN INIT DATE N Name COMPLETION NOTES ASSIGNMENT CROSS REFERENCES REF REF REF REF NBR STATUS DESCRIPTION TYP N3R SUB TYPE AS 00190202 2800 GNRL COMPLETE VERIFY THAT THE EFFECTIVENESS REVIEW CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List:.001 Route List Initiator: PADLEA Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BAINDO BNP OPSOUTSUPTA BAIN 05/09/08 11:26 APPROVED 05/09/08 22:21 DUBROP BNP OPSMGR A DUBROUILLET 05/09/08 22:21 APPROVED 05/29/08 15:54 WILLIM03 BNP PGM A WILLIAMS 05/29/08 15:54 APPROVED 06/02/08 17:09 VANLEW BNP OPSUEVAL A VAN KLEECK 06/02/08 17:09 APPROVED 06/03/08 06:13

Page 18 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 09 SUB' Type : ENHN Due Date 07/10/07 Status : CANCELED Reschedule : Pri Resp Group: ESSESYS Assigned To : L KUFFEL Sec Resp Group:

Subject : ENGINEERING TO EVALUATE THE POSTULATED SCENARIO Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department : MBH Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 06/21/07 STACYL INPROG 06/27/07 VANLEW 07/10/07 06/27/07 VANLEW NTFY/PRI 07/09/07 VANLEW CANCELED ENGINEERING TO EVALUATE THE POSTULATED SCENARIO DESCRIBED IN ATTRIBUTE 3B2 TO DETERMINE WHETHER THE IDENTIFIED CONFIGURATION (I.E., THE 2-CO-V162 CHECK VALVE BEING DISASSEMBLED, BUT THE PATHWAY NOT BEING ISOLATED) COULD HAVE RESULTED IN AN EVENT OR CONDITION THAT COULD HAVE PREVENTED FULFILLMENT OF THE SAFETY FUNCTION OF STRUCTURES OR SYSTEMS NEEDED TO CONTROL THE RELEASE OF RADIATION.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS CANCEL N 07/09/07 Name : LEWIS VAN KLEECK Based on additional feedback from Mark Turkal, no follow-up assignment is required. This assignment can be canceled. See Attribute 4A2 and 4B.

LVK 7/9/07.

Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES CAUSE/ACTION ASSIGNM[ENT COMPLETION APPROVAL Route List: 001 Route List Initiator:

Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BNP ESSESYS A

Page 19 Printed: 07/08/08 ACTION REQUEST 00237296 BNP LICSUPV A VANLEW BNP OPSUEVAL A VAN KLEECK CANCELED 07/09/07 17:24

Page : 20 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 10 SUB Type CAPR Due Date 10/18/07 Status COMPLETE Reschedule Pri Resp Group: OPSMGR Assigned To S HOWARD Sec Resp Group:

Subject COMMUNICATE TO PERSONNEL THE IMPORTANCE OF Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : Z78 Discipline Est Manhrs :1 Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 10/18/07 08/07/07 VANLEW NTFY/PRI 08/08/07 DUBROP ACC/PRI 08/08/07 DUBROP NTFY/ASG 10/01/07 HOWARS ACC/ASG 10/01/07 HOWARS AWAIT/C 10/08/07 VANLEW COMPLETE COMMUNICATE TO PERSONNEL THE IMPORTANCE OF HAVING THE MINDSET THAT EACH INDIVIDUAL INVOLVED IN ANY PORTION OF THE CLEARANCE PROCESS MUST ACT LIKE THEY ARE THE ONLY BARRIER TO ENSURE PERSONNEL AND EQUIPMENT SAFETY Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Assignment Attribute Value Reqd Date 2A COMMENTS N Name

Page 21 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES SEE IN PROGRESS NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: HOWARS Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time HOWARS BNP OPSMGR A HOWARD 10/01/07 18:24 APPROVED 10/01/07 18:24 VANLEW BNP OPSUEVAL A VAN KLEECK 10/01/07 18:24 APPROVED 10/08/07 06:06

Page 22 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 11 SUB Type CAPR Due Date 10/18/07 Status COMPLETE Reschedule Pri Resp Group: OPSMGR Assigned To J RAINES Sec Resp Group: OPSPROC Subj ect REVISE 01-29, OPERATIONS INTERNAL AUDITS Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : U87 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 10/18/07 08/07/07 VANLEW NTFY/PRI 08/08/07 DUBROP ACC/PRI 08/08/07 DUBROP NTFY/ASG 09/05/07 WILLIM03 ACC/ASG 09/05/07 WILLIM03 NTFY/ASG 09/06/07 ROBERG01 ACC/ASG 09/06/07 VANLEW NTFY/SEC 09/06/07 ROBERG01 ACC/SEC 09/06/07 ROBERG01 NTFY/ASG 09/17/07 RAINEJ ACC/ASG 10/15/07 RAINEJ AWAIT/C 10/17/07 VANLEW COMPLETE REVISE 01-29, OPERATIONS INTERNAL AUDITS, TO ESTABLISH A REQUIREMENT FOR A CLEARANCE PROCESS ASSESSMENT EVERY 2 YEARS WHICH INCLUDES MAINTENANCE AND OPERATIONS Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd. Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Page 23 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS N Name Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name ;

COMPLETION NOTES 001-29 SECTION 6.11, ANNUAL CLEARANCE PROCESS INDEPENDENT INSPECTION, WAS REVISED TO INCLUDE MAINTENANCE AND WORK MANAGEMENT (IF AVAILABLE) TO EVALUATE, THE ADEQUACY OF CLEARANCE/WORK MANAGEMENT PROCESS INTERFACE, OPPORTUNITIES FOR IMPROVEMENTS IN WORK GROUP INTERFACE ACTIVITIES, AND OPPROTUNITIES FOR IMPROVEMENTS IN WORK GROUP COMMUNICATIONS, IN REVISION

53. THIS REVISION ENHANCED THE DIRECTION TO ENSURE WORK MANAGEMENT, AND MAINTENANCE PERSONNEL ARE INCLUDED AS TEAM MAMBERS TO ASSESS THE ABOVE IDENTIFIED AREAS.

THE REVISIONS INCORPORATED MEET THE REQUIREMENTS OF THIS ACTION ITEM PER DISCUSSIONS WITH THE OPERATIONS CAP COORDINATOR.

REVISION 55 OF 0OI-59 HAS BEEN ROUTED TO DOCUMENT SERVICES FOR ISSUE. 10/15/2007. JOHN B RAINES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL

Page : 24 Printed: 07/08/08 ACTION REQUEST 00237296 Route List: 001 Route List Initiator: RAINEJ Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time HOWARS BNP OPSMGR A HOWARD 10/15/07 12:13 APPROVED 10/16/07 12:39 VANLEW BNP OPSUEVAL A VAN KLEECK 10/16/07 12:39 APPROVED 10/17/07 06:08

Page 25 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 12 SUB Type CORR Due Date :10/18/07 Status COMPLETE Reschedule : Pri Resp Group: OPSMGR Assigned To D BAIN Sec Resp Group:

Subject REINFORCE CLEARANCE DEVELOPMENT QUALITY STANDARDS Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : CNI Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn.Due Date 08/07/07 VANLEW INPROG 10/18/07 08/07/07 VANLEW NTFY/PRI 08/08/07 DUBROP ACC/PRI 08/08/07 DUBROP NTFY/ASG 09/10/07 BAINDO ACC/ASG 09/10/07 BAINDO AWAIT/C 09/14/07 VANLEW COMPLETE REINFORCE CLEARANCE DEVELOPMENT QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY QUALITY IS AT THE APPROPRIATE LEVEL.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page 26 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: BAINDO Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time DUBROP BNP OPSMGR A DUBROUILLET 09/10/07 12:55 APPROVED 09/13/07 17:0,6 VANLEW BNP OPSUEVAL A VAN KLEECK 09/13/07 17:06 APPROVED 09/14/07 06:25

Page : 27 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 13 SUB Type : ENHN Due Date : 10/04/07 Status : COMPLETE Reschedule : 1 Pri Resp Group: OPSOUTSUPT Assigned To : A PADLECKAS Sec Resp Group:

Subject : DEVELOP A CLEARANCE REQUEST CHECKLIST Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department : CU2 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 09/06/07 08/07/07 VANLEW NTFY/PRI 08/07/07 WOODBW ACC/PRI 08/07/07 WOODBW NTFY/ASG 09/06/07 VANLEW 10/04/07 09/28/07 PADLEA ACC/ASG 09/28/07 PADLEA AWAIT/C 10/01/07 BOYCER COMPLETE DEVELOP A CLEARANCE REQUEST CHECKLIST TO AID IN REQUEST CONSISTENCY.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS EXTENSION N 09/06/07 Name : LEWIS VAN KLEECK Checklist has been developed and is being distributed for comments.

Upcoming forced outage is preventing timely feedback. Extended due date one month to 10/4./07 to allow additional time for feedback, revision and completion. LVK 9/6/07.

Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES CLEARANCE REQUEST CHECKLIST DEVELOPED AND DISTRIBUTED TO MAINTENENCE PLANNERS FOR REVIEW AND INPUT. THIS IS A LIVING DOCUMENT WHICH WILL BE REVISED AS COMMENTS ARE RECEIVED. NO FURTHER ACTION REQUIRED AS A RESULT OF THIS ASSIGNMENT.

LOCATION K:\SHARED\CLEARANCE INFORMATION\CLEARANCE REQUEST CHECKLIST.DOC CAUSE/ACTION

Page : 28 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGM'ENT COMPLETION APPROVAL Route List: 001 Route List Initiator: PADLEA Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time POTTEM BNP OPSOUTSUPT A POTTER 09/28/07 12:27 APPROVED 10/01/07 10:58 BOYCER BNP OPSUEVAL A BOYCE 10/01/07 10:58 APPROVED 10/01/07 11:33

Page 29 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 14 SUB Type : CORR Due Date : 08/30/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTXSUPV Assigned To : R BISSETT Sec Resp Group:

Subject : CONFIDENTIAL ACTIONS TAKEN WITH CLEARANCE REQUESTER Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : HGL Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 08/30/07 08/07/07 VANLEW NTFY/PRI 08/08/07 GERALK ACC/PRI 08/30/07 BISSER NTFY/ASG 08/30/07 BISSER ACC/ASG 08/30/07 BISSER AWAIT/C 08/30/07 BOYCER COMPLETE CONFIDENTIAL ACTIONS TAKEN WITH THE INVOLVED CLEARANCE REQUESTER Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page : 30 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 - Route List Initiator: BISSER Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BISSER BNP MNTXSUPV A BISSETT 08/30/07 16:57 APPROVED 08/30/07 16:57 BOYCER BNP OPSUEVAL A BOYCE 08/30/07 16:57 APPROVED 08/30/07 17:07

Page 31 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 15 SUB Type : CORR Due Date : 09/13/07 Status : COMPLETE Reschedule : 1 Pri Resp Group: OPSOUTSUPI Assigned To : A PADLECKAS Sec Resp Group:

Subject : CONFIDENTIAL ACTIONS TAKEN WITH THE INVOLVED INDIVIDUALS Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : CU2 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 08/30/07 08/07/07 VANLEW NTFY/PRI 08/07/07 WOODBW ACC/PRI 08/07/07 WOODBW NTFY/ASG 08/30/07 BOYCER 09/13/07 09/13/07 PADLEA ACC/ASG 09/13/07 PADLEA AWAIT/C 09/13/07 BOYCER COMPLETE CONFIDENTIAL ACTIONS TAKEN WITH THE INVOLVED CLEARANCE PREPARER AND CLEARANCE REVIEWER.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS EXTENSION REQUEST N 08/30/07 Name : ROBERT BOYCE Due date extended until 09/13/2007 with Ops Manager permission.

Additional information is required prior to completion of this item that cannot be obtained at this time due to the ongoing INPO visit. RSB 08/30/2007 Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Page 32 Printed:. 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS N Name Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assigrznent Attribute Value Reqd Date 2E COMMENTS N

.Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assiginment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: PADLEA Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time PADLEA BNP OPSOUTSUPTA PADLECKAS 09/13/07 11:37 APPROVED 09/13/07 11:37 BOYCER BNP OPSUEVAL A BOYCE 09/13/07 11:37 APPROVED 09/13/07 11:39

Page 33 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 16 SUB Type : CORR Due Date : 08/30/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTMSUPV Assigned To : K JONES Sec Resp Group:

Subject : CONFIDENTIAL ACTIONS TAKEN WITH THE INVOLVED INDIVIDUAL Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : Z63 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 08/30/07 08/07/07 VANLEW NTFY/PRI 08/08/07 GRADYL ACC/PRI 08/08/07 GRADYL NTFY/ASG 08/20/07 JONESK ACC/ASG 08/20/07 JONESK AWAIT/C 08/20/07 VANLEW COMPLETE CONFIDENTIAL ACTIONS TAKEN WITH THE INVOLVED INDIVIDUAL Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page 34 Printed: 07/08/08 ACTION REQUEST 00237296 Assigrnment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name COMPLETION NOTES CONFIDENTIAL ACTIONS HAVE BEEN TAKEN WITH THE INVOLVED INDIVIDUAL.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: JONESK Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time JONESK BNP MNTMSUPV A JONES 08/20/07 09:17 APPROVED 08/20/07 09:18 VANLEW BNP OPSUEVAL A VAN KLEECK 08/20/07 09:18 APPROVED 08/20/07 17:54

Page 35 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 17 SUB Type CORR Due Date :11/13/07 Status COMPLETE Reschedule : 1 Pri Resp Group: MNTPSUPT Assigned To R BISSETT Sec Resp Group:

Subject REINFORCE CLEARANCE BOUNDARY VERIFICATION QUALITY STANDAR Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : HGL Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 10/18/07 08/07/07 VANLEW NTFY/PRI 08/29/07 BISSER ACC/PRI 08/29/07 WILLIS01 NTFY/PRI 08/30/07 BISSER ACC/PRI 10/18/07 WILLIS01 11/13/07 11/06/07 BISSER NTFY/ASG 11/06/07 BISSER ACC/ASG 11/06/07 BISSER AWAIT/C 11/06/07 VANLEW ACC/ASG 11/13/07 BISSER AWAIT/C 11/13/07 JOHNSCO5 COMPLETE REINFORCE CLEARANCE BOUNDARY VERIFICATION QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY QUALITY IS AT THE APPROPRIATE LEVEL.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

a Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Page : *36 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS ASSIGNMENT SPLIT OUT N 08/29/07 Name : SHEILA WILLIAMS This assignment was originally issued to the Maintenance Manager, Susan Rogers. It was split out to each of the Maintenance Supts.

-17 Richard Bissett (Maintenance Tech Services)

-31 Tim King (Mechanical Maintenance)

-32 Paul Smith (I&C/E Maintenance)

(SVW 8/29/07)

Extend assignment to 11/13/07 per Richard Bissett, acting for Susan Rogers. Additional time needed to complete the assignment. (SVW 10/18/07)

Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL, N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CLEARANCE BOUNDARY VERIFICATION QUALITY STANDARDS WERE REINFORCED WITH MTS ON 11/06/07. NTM ITEM (NTM 254326)

WAS GENERATED FOR PROJECT MANAGERS TO PERFORM OBSERVATIONS OF CLEARANCE PROCESS.

RAB 11/06/07 CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: BISSER Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BISSER BNP MNTPSUPT A BISSETT 11/06/07 16:09 APPROVED 11/06/07 16:09 VANLEW BNP OPSUEVAL A VAN KLEECK 11/06/07 16:09 RETURNED 11/06/07 16:21 BISSER BNP MNTPSUPT A BISSETT 11/13/07 10:15 APPROVED 11/13/07 10:18

Page 37 Printed: 07/08/08 ACTION REQUEST 00237296 JOHNSC05 BNP OPSUEVAL A JOHNSON 11/13/07 10:18 APPROVED 11/13/07 16:32

Page : 38 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 18 SUB Type : ENHN Due Date : 12/20/07 Status : COMPLETE Reschedule : Pri Resp Group: TRGTSUPT Assigned To : L RIEMAN Sec Resp Group:

Subject : CONDUCT TRAINING FOR CLEARANCE REQUESTS, AND Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : GD2 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 12/20/07 08/07/07 VANLEW NTFY/PRI 08/13/07 MCPHEM ACC/PRI 08/13/07 MCPHEM NTFY/ASG 12/17/07 RIEMAL ACC/ASG 12/17/07 RIEMAL AWAIT/C 12/17/07 BOYCER COMPLETE CONDUCT TRAINING FOR CLEARANCE REQUESTS, AND CLEARANCE HOLDER BOUNDARY VERIFICATION TECHNIQUES Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS N Name Please reassign to Eddie Edmunds per Larry Rieman. 09/07/07 Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: RIEMAL Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time RIEMAL BNP TRGTSUPT A RIEMAN 12/17/07 13:19-APPROVED 12/17/07 13:20 BOYCER BNP OPSUEVAL A BOYCE 12/17/07 13:20 APPROVED 12/17/07 14:0 4

Page 39 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMEhNT NUbMBER 19 SUB Type CORR Due Date : 08/30/07 Status COMPLETE Reschedule : Pri Resp Group: MNTMGR Assigned To : R BISSETT Sec Resp Group:

Subj ect REINFORCE CLEAR EXPECTATIONS FOR PRE-JOB BRIEFS Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : HGL Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 08/30/07 08/07/07 VANLEW NTFY/PRI 08/29/07 BISSER ACC/PRI 08/29/07 WILLIS01 NTFY/ASG 08/30/07 BISSER ACC/ASG 08/30/07 BISSER AWAIT/C 08/30/07 BOYCER COMPLETE REINFORCE CLEAR EXPECTATIONS FOR THE PERFORMANCE OF PRE-JOB BRIEFS IN THE MAINTENANCE ORGANIZATION Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page : 40 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name : -

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: BISSER Alert Send' Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time BISSER BNP MNTPSUPT A BISSETT 08/30/07 15:16 APPROVED 08/30/07 15:16 BOYCER BNP OPSUEVAL A BOYCE 08/30/07 15:16 APPROVED 08/30/07 15:32

Page 41 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUNBER20 SUB Type ENHN Due Date : 12/20/07 Status COMPLETE Reschedule Pri Resp Group: MNTBL2 Assigned To : D PROCTOR Sec Resp Group:

Subject : REVISE 2-SP-07-205 TO INCLUDE LESSONS LEARNED Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : BL2 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 12/20/07 08/07/07 VANLEW NTFY/PRI 08/08/07 GERALK ACC/PRI 08/08/07 GERALK NTFY/ASG 11/13/07 PROCTD ACC/ASG 11/13/07 PROCTD AWAIT/C 11/15/07 VANLEW COMPLETE REVISE 2-SP-07-205 TO INCLUDE LESSONS LEARNED FROM THIS EVENT Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: PROCTD Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time GERALK BNP MNTBL2 A GERALD 11/13/07 12:59 APPROVED 11/15/07 14:52 VANLEW BNP OPSUEVAL A VAN KLEECK 11/15/07 14:52 APPROVED 11/15/07 15:56

Page 42 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 21 SUB Type : ENHN Due Date : 01/31/08 Status : COMPLETE Reschedule : 1 Pri Resp Group: MNTMSUPV Assigned To : L GRADY Sec Resp Group:

Subject : CONDUCT CROSS DISCIPLINE TRAINING Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department : HCG Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 12/20/07 08/07/07 VANLEW NTFY/PRI 08/07/07 GRADYL ACC/PRI 08/07/07 GRADYL NTFY/ASG 08/07/07 GRADYL ACC/ASG 11/28/07 VANLEW 01/31/08 01/30/08 GRADYL AWAIT/C 01/31/08 VANLEW COMPLETE CONDUCT CROSS DISCIPLINE TRAINING WITH THE CLEARANCE WRITERS AND W/O PLANNERS Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS N Name :

Please extend due date to 01/31/2008 due to the approaching holiday season. This will maximize attendance of planners and clearance writers.

LG 11/21/07 Due date extended as requested. LVK 11/28/07.

Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES TRAINING AND FEEDBACK SESSIONS HAVE BEEN COMPLETED BETWEEN CLEARANCE WRITERS AND MAINTENANCE PLANNERS.

OVERALL THE CLEARANCE WRITERS ARE RECEIVING ADEQUATE INFORMATION FOR THE DEVELOPMENT OF CLEARANCE ORDERS.

ADDITIONAL INFORMATION THAT CAN BE PROVIDED BY THE PLANNERS IS ALWAYS ENCOURAGED. EMPHASIS WAS PLACED ON ENSURING THAT MULTIPLE BOUNDARY CHANGES THAT WOULD BE NEEDED ARE INCLUDED WITHIN THE REQUEST. IN ADDITION, A TOPIC FOR DISCUSSION WILL BE INCLUDED IN THE UPCOMING MAINTENANCE PLANNERCONTINUING TRAINING AND THE

Page 43 Printed: 07/08/08 ACTION REQUEST 00237296 CLEARANCE WRITERS OR A REPRESENTATIVE WILL RECEIVE AN AN INVITATION TO ATTEND.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: GRADYL Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time GRADYL BNP MNTMSUPV A GRADY 01/30/08 12:15 APPROVED 01/30/08 16:11 VANLEW BNP OPSUEVAL A VAN KLEECK 01/30/08 16:11 APPROVED 01/31/08 06:07

Page : 44 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 22 SUB Type ENHN Due Date : 10/25/07 Status COMPLETE Reschedule Pri Resp Group: TRGOSUPV Assigned To M PEARSON JR. Sec Resp Group:

Subject INCLUDE DISCUSSION OF THIS EVENT Aff Facility: BNP Unit System UCR Schedule Ref Organization: Department : G74 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 10/25/07 08/07/07 VANLEW NTFY/PRI 08/22/07 PEARSM01 ACC/PRI 08/22/07 PEARSM01 NTFY/ASG 08/22/07 PEARSM01 ACC/ASG 09/05/07 PEARSM01 NTFY/ASG 09/06/07 PEARSM01 ACC/ASG 10/24/07 PEARSM01 AWAIT/C 10/24/07 VANLEW COMPLETE INCLUDE DISCUSSION OF THIS EVENT IN CLEARANCE PREPARER AND CLEARANCE HOLDER INITIAL AND PERIODIC TRAINING Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS N Name :

The clearance training program belongs to Technical Training. They should have this assignment; I believe Eddie Edmunds is the SME for that material.

Assignment Attribute Value Reqd Date 2 COMMENTS N Name :

COMPLETION NOTES SEE IN PROGRESS NOTES FOR COMPLETED ACTIONS. TONY PEARSON 102407 CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL

Page 45 Printed: 07/08/08 ACTION REQUEST 00237296 Route List: 001 Route List Initiator: PEARSM01 Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time PEARSM01 BNP TRGOSUPV A PEARSON JR. 10/24/07 13:47 APPROVED 10/24/07 13:48 VANLEW BNP OPSUEVAL A VAN KLEECK 10/24/07 13:48 APPROVED 10/24/07 14:24

Page 46 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 23 SUB Type : ENHN Due Date. : 10/25/07 Status : COMPLETE Reschedule Pri Resp Group: TRGTSUPV Assigned To : E EDMUNDS Sec Resp Group:

Subject : INCLUDE DISCUSSION OF THIS EVENT Aff Facility: BNP Unit System UCR : Schedule Ref :

Organization: Department : GDl Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 10/25/07 08/07/07 VANLEW NTFY/PRI 08/13/07 MCPHEM ACC/PRI 08/13/07 MCPHEM NTFY/ASG 10/16/07 EDMUNE ACC/ASG 10/22/07 EDMUNE AWAIT/C 10/24/07 VANLEW COMPLETE INCLUDE DISCUSSION OF THIS EVENT IN CLEARANCE PREPARER AND CLEARANCE HOLDER INITIAL AND PERIODIC TRAINING Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 CHANGE BASIS N Name :

Please reassign to Eddie Edmunds per Larry Rieman. 09/07/07 Reassigned as requested. LVK 9/7/06.

Eddie Edmunds will accept action for Clearance Holder Training, however Clearance Preparer Training is conducted by Operator Training, contact James Potter to determine who should have that part of the assignment.

You actually need two different assignments. EDE 10/5/07 Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: EDMUNE IAlert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time RIEMAL BNP TRGTSUPV A RIEMAN 10/22/07 15:42 APPROVED 10/24/07 07:05

Page 47 Printed: 07/08/08 ACTION REQUEST 00237296 VANLEW BNP OPSUEVAL A VAN KLEECK 10/24/07 07:05 APPROVED 10/24/07 14:23

Page 48 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NLUMER 24 SUB Type ENHN Due Date : 01/18/08 Status COMPLETE Reschedule : 1 Pri Resp Group: ERCMGR Assigned To M TUSAI Sec Resp Group:

Subject : COMPLETE AN EVALUATION OF THE SPILL IAW 10CFR50.75G Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department : K34 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/07/07 VANLEW INPROG 01/10/08 08/07/07 VANLEW NTFY/PRI 08/28/07 HOLLEN ACC/PRI 08/28/07 HOLLEN NTFY/ASG 01/10/08 HOLLEN 01/18/08 01/11/08 TUSAIM ACC/ASG 01/11/08 TUSAIM AWAIT/C 01/14/08 VANLEW COMPLETE COMPLETE AN EVALUATION OF THE SPILL IAW 10CFR50.75G Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 CHANGE BASIS N Name :

01/10/08: Action was reassigned and due date extended until 01/18/08 to allow new assignee time to complete action, per verbal authorization from ERCMGR.

Assignment Attribute Value Reqd Date 2 COMMENTS N Name COMPLETION NOTES SEE IN-PROGRESS NOTE.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL

Page : 49 Printed: 07/08/08 ACTION REQUEST 00237296 Route List: 001 Route List Initiator: TUSAIM Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time FERGUJ BNP ERCMGR A FERGUSON 01/11/08 09:42 APPROVED 01/14/08 08:13 VANLEW BNP OPSUEVAL A VAN KLEECK 01/14/08 08:13 APPROVED 01/14/08 15:31

Page : 50 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUIMBER 25 SUB Type CORR Due Date : 08/30/07 Status COMPLETE Reschedule Pri Resp Group: MNTESUPT Assigned To : P SMITH Sec Resp Group:

Subject : REINFORCE CLEAR EXPECTATIONS FOR THE PERFORMANCE Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : Z67 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/0.7 WILLIS01 INPROG 08/30/07 08/29/07 WILLIS01 NTFY/PRI 08/29/07 FATKIG ACC/PRI 08/29/07 FATKIG NTFY/ASG 08/30/07 SMITHP ACC/ASG 08/30/07 SMITHP AWAIT/C 08/30/07 BOYCER COMPLETE REINFORCE CLEAR EXPECTATIONS FOR THE PERFORMANCE OF PRE-JOB BRIEFS IN THE MAINTENANCE ORGANIZATION.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date IA COMMITTED N Name Assignment Attribute Value Reqd Date IB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name

Page : 51 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: SMITHP Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time SMITHP BNP MNTESUPT A SMITH 08/30/07 15:21 APPROVED 08/30/07 15:21 BOYCER BNP OPSUEVAL A BOYCE 08/30/07 15:21 APPROVED 08/30/07 15:31

Page : 52 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 26 SUB Type : CORR Due Date 08/30/07 Status COMPLETE Reschedule : Pri Resp Group: MNTMSUPT Assigned To : T KING Sec Resp Group:

Subject : REINFORCE CLEAR EXPECTATIONS FOR THE PERFORMANCE Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : Z77 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 08/30/07 08/29/07 WILLIS01 NTFY/PRI 08/30/07 KINGTI ACC/PRI 08/30/07 KINGTI NTFY/ASG 08/30/07 KINGTI ACC/ASG 08/30/07 KINGTI AWAIT/C 08/30/07 BOYCER COMPLETE REINFORCE CLEAR'EXPECTATIONS FOR THE PERFORMANCE OF PRE-JOB BRIEFS IN THE MAINTENANCE ORGANIZATION Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name

Page : 53 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name COMPLETION NOTES THE MECHANICAL MAINTENANCE SUPERINTENDENT HAS RE

-INFORCED AND COMMUNICATED CLEAR PERFORMANCE EXPECTATIONS IN REGARDS TO PRE-JOB BRIEFINGS TO THE MECHANICAL MAINTENANCE SUPERVISORS. THIS EXPECTATION INCLUDES THAT EACH WORK TASK RECEIVES A PRE-JOB BRIEF PRIOR TO FIELD IMPLEMENTATION. THE COMPLEXITY OF THE TASK WILL DETERMINE THE COMPLEXITY OF THE BRIEFING. TK 8/30/07 CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: KINGTI Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time KINGTI BNP MNTMSUPT A KING 08/30/07 17:15 APPROVED 08/30/07 17:16 BOYCER BNP OPSUEVAL A BOYCE 08/30/07-17:16 APPROVED 08/30/07 17:56

Page 54 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER27 SUB Type : CAPR Due Date : 10/18/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTMSUPT Assigned To : L.GRADY Sec Resp Group:

Subject : COMMUNICATE TO PERSONNEL THE IMPORTANCE OF Aff Facility: BNP Unit System UCR : Schedule Ref Organization: Department : HCG Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 10/18/07 08/29/07 WILLIS01 NTFY/PRI 09/03/07 KINGTI ACC/PRI 09/03/07 KINGTI NTFY/ASG 09/03/07 KINGTI ACC/ASG 10/17/07 GRADYL NTFY/ASG 10/17/07 GRADYL ACC/ASG 10/17/07 GRADYL AWAIT/C 10/18/07 VANLEW COMPLETE COMMUNICATE TO PERSONNEL THE IMPORTANCE OF HAVING THE MINDSET THAT EACH INDIVIDUAL INVOLVED IN ANY PORTION OF THE CLEARANCE PROCESS MUST ACT LIKE THEY ARE THE ONLY BARRIER TO ENSURE PERSONNEL AND EQUIPMENT SAFETY Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

Assignment Attribute Value Reqd Date.

IA COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name :

Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name :

Page : 55 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS N Name Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name :

Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES DISCUSSED THIS NCR WITH MECHANICAL SUPERVISORS AT THE WEEKLY STAFF MEETING. RE-EMPHASIZED THE IMPORTANCE OF ENSURING THAT THEIR DIRECT REPORTS ADHERE TO PROCEDURAL GUIDANCE FOR CLEARANCE ACCEPTANCE. IT IS AN EXPECTATION THAT INDIVIDUALS VERIFY THEY HAVE AN ADEQUATE AND SAFE CLEARANCE PRIOR TO PERFORMING WORK. AT A MINMUM VERIFICATION SHOULD BE PERFORMED VIA DRAWINGS, FIELD WALKDOWNS OR CLEARANCE TAG SHEET. THESE EXPECTATIONS HAVE BEEN COMMUNICATED TO CRAFT PERSONNEL BY THE FIRST LINE SUPERVISORS. AS A FOLLOWUP, A RANDOM POLLOF MECHANICS WAS CONDUCTED TO ENSURE THESE EXPECTATIONS HAD BEEN COMMUNICATED.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: GP ADYL Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time GRADYL BNP MNTMSUPT A GRADY 10/17/07 10:05 APPROVED 10/17/07 10:05 BNP OPSUEVAL A GRADY 10/17/07 10:05 BYPASSED 10/17/07 10:11 SMITHP BNP MNTESUPT A SMITH 10/17/07 10:11 APPROVED 10/17/07 10:58 VANLEW BNP OPSUEVAL A VAN KLEECK 10/17/07 10:58 APPROVED 10/18/07 06:14

Page : 56 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 28 SUB Type : CAPR Due Date : 10/18/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTESUPT Assigned To : P SMITH Sec Resp Group:

Subject : COMMUNICATE TO PERSONNEL THE IMPORTANCE OF Aff Facility: BNP Unit . System UCR : Schedule Ref Organization: Department : Z67 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 10/18/07 08/29/07 WILLIS01 NTFY/PRI 08/29/07 FATKIG ACC/PRI 08/29/07 FATKIG NTFY/ASG 09/28/07 SMITHP ACC/ASG 09/28/07 SMITHP AWAIT/C 10/01/07 BOYCER COMPLETE COMMUNICATE TO PERSONNEL THE IMPORTANCE OF HAVING THE MINDSET THAT EACH INDIVIDUAL INVOLVED IN ANY PORTION OF THE CLEARANCE PROCESS MUST ACT LIKE THEY ARE THE ONLY BARRIER TO ENSURE PERSONNEL AND EQUIPMENT SAFETY.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name

Page 57 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value 'Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name I COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: SMITHP Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time SMITHP BNP MNTESUPT A SMITH 09/28/07 12:23 APPROVED 09/28/07 12:23 BOYCER BNP OPSUEVAL A BOYCE 09/28/07 12:23 APPROVED 10/01/07 07;29

Page 58 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 29 SUB Type CORR Due Date : 10/18/07 Status COMPLETE Reschedule : Pri Resp Group: MNTMSUPT Assigned To : L GRADY Sec Resp Group:

Subject : REINFORCE CLEARANCE REQUEST QUALITY STANDARDS AND ESTABLI Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department :HCG Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 10/18/07 08/29/07 WILLIS01 NTFY/PRI 09/03/07 KINGTI ACC/PRI 09/03/07' KINGTI NTFY/ASG 09/09/07 GRADYL ACC/ASG 10/17/07 GRADYL AWAIT/C 10/18/07 VANLEW COMPLETE REINFORCE CLEARANCE REQUEST QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY CLEARANCE REQUEST QUALITY IS AT THE APPROPRIATE LEVEL.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page : 59 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name :

Assignment Attribute Value Recld Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CLEARANCE REQUEST QUALITY STANDARDS HAVE BEEN REINFORCED WITH CREW HCG AND TARGETED OBSERVATIONS TO VERIFY QUALITY IS AT THE APPROPRIATE LEVEL ARE BEING TRACKED BY NTM'S.

REFERENCE AR 251075 FOR OBSERVATION DETAILS.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route'List Initiator: GRADYL Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time GRADYL BNP MNTMSUPT A GRADY 10/17/07 13:17 APPROVED 10/17/07 13:18 VANLEW BNP OPSUEVAL A VAN KLEECK 10/17/07 13:18 APPROVED 10/18/07 06:15

Page 60 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMlBER 30 SUB Type : CORR Due Date : 10/18/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTESUPT Assigned To : G FATKIN JR. Sec Resp Group:

Subject : REINFORCE CLEAANCE REQUEST QUALITY STANDARDS AND ESTABLI Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department : ZAA Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 10/18/07 08/29/07 WILLIS01 NTFY/PRI 08/29/07 FATKIG ACC/PRI 08/29/07 FATKIG NTFY/ASG 09/28/07 SMITHP ACC/ASG 09/28/07 SMITHP NTFY/ASG 10/01/07 FATKIG ACC/ASG 10/17/07 FATKIG AWAIT/C 10/18/07 VANLEW COMPLETE REINFORCE CLEARANCE REQUEST QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY CLEARANCE REQUEST QUALITY IS AT THE APPROPRIATE LEVEL.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date I UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name

Page 61 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Assignment Attribute Value Reqd Date 2B COMMENTS N Name :

Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name :

Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES REINFORCED WITH ZAA CLEARANCE REQUEST QUALITY STANDARDS AND ESTABLISH NCR 251003 TO PERFORM TARGETED OBSERVATIONS TO VERIFY CLEARANCE REQUEST QUALITY IS AT THE APPROPRIATE LEVEL.

CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: FATKIG Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time FATKIG BNP MNTESUPT A FATKIN JR. 10/17/07 08:29 APPROVED 10/17/07 08:29 VANLEW BNP OPSUEVAL A VAN KLEECK 10/17/07 08:29 APPROVED 10/18/07 06:14

Page 62 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 31 SUB Type : CORR Due Date : 10/18/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTMSUPT Assigned To : T KING Sec Resp Group:

Subject : REINFORCE CLEARANCE BOUNDARY VERIFICATION QUALITY STAND Aff Facility: BNP Unit : System UCR : Schedule Ref Organization: Department : Z77 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 10/18/07 08/29/07 WILLIS01 NTFY/PRI 09/03/07 KINGTI ACC/PRI 09/03/07 KINGTI NTFY/ASG 09/03/07 KINGTI ACC/ASG 10/18/07 KINGTI AWAIT/C 10/18/07 VANLEW COMPLETE REINFORCE CLEARANCE BOUNDARY VERIFICATION QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY QUALITY IS AT THE APPROPRIATE LEVEL.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name :

Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name Assignment Attribute Value Reqd Date 1A COMMITTED N Name Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page : 63 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name :

COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: KINGTI Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time KINGTI BNP MNTMSUPT A KING 10/18/07 13:19 APPROVED 10/18/07 13:20 VANLEW BNP OPSUEVAL A VAN KLEECK 10/18/07 13:20 APPROVED 10/18/07 16:02

Page 64 Printed: 07/08/08 ACTION REQUEST 00237296 ASSIGNMENT NUMBER 32 SUB Type : CORR Due Date : 10/18/07 Status : COMPLETE Reschedule : Pri Resp Group: MNTESUPT Assigned To : P SMITH Sec Resp Group:

Subject : REINFORCE CLEARANCE BOUNDARY VERIFICATION QUALITY STAND Aff Facility: BNP Unit . System UCR : Schedule Ref Organization: Department : Z67 Discipline Est Manhrs : Est Comp Date Assignment Status History Updated Date Updated By Assgn Status Assgn Due Date 08/29/07 WILLIS01 INPROG 10/18/07 08/29/07 WILLIS01 NTFY/PRI 08/29/07 FATKIG ACC/PRI 08/29/07 FATKIG NTFY/ASG 10/17/07 SMITHP ACC/ASG 10/17/07 SMITHP AWAIT/C 10/18/07 VANLEW COMPLETE REINFORCE CLEARANCE BOUNDARY VERIFICATION QUALITY STANDARDS AND ESTABLISH TARGETED OBSERVATIONS TO VERIFY QUALITY IS AT THE APPROPRIATE LEVEL.

Assignment Attribute Value Reqd Date BENEFIT REALIZED N Name Assignment Attribute Value Reqd Date 1 UNIT/SECT EVALUATR N Name :

Assignment Attribute Value Reqd Date 1A COMMITTED N Name :

Assignment Attribute Value Reqd Date lB CHANGE BASIS N Name Assignment Attribute Value Reqd Date 2 MISCELLANEOUS N Name Assignment Attribute Value Reqd Date 2A COMMENTS N Name :

Page 65 Printed: 07/08/08 ACTION REQUEST 00237296 Assignment Attribute Value Reqd Date 2B COMMENTS N Name Assignment Attribute Value Reqd Date 2C COMMENTS N Name :

Assignment Attribute Value Reqd Date 2D COMMENTS N Name Assignment Attribute Value Reqd Date 2E COMMENTS N Name Assignment Attribute Value Reqd Date 3A LTCA APPROVAL N Name Assignment Attribute Value Reqd Date 3B LTCA CONCURRENCE N Name COMPLETION NOTES CAUSE/ACTION ASSIGNMENT COMPLETION APPROVAL Route List: 001 Route List Initiator: SMITHP Alert Send Send Action Action PASSPORT Fac Group/Type Last Name Date Time Taken Date/Time SMITHP BNP MNTESUPT A SMITH 10/17/07 07:58 APPROVED 10/17/07 07:58 VANLEW BNP OPSUEVAL A VAN KLEECK 10/17/07 07:58 APPROVED 10/18/07 06:13

ATTACHMENT 16 Sheet I of 3 Significant Adverse Condition Investigation Report Form CAP-NGGC-0205-16-5 EXECUTIVE

SUMMARY

Action Request Number: 237296 Event Date: June 21, 2007 Sponsoring Manager: Steve Howard - Operations Manager Investigation Team:

Bill Woodbury - OPS, Team.Leader L. E. Van Kleeck - OPS, Priority 1 Investigator Rendell Parker - E&RC Sam Swain - Mechanical Maintenance Kim Gerald - Maintenance Technical Services Joe Ward, Jerry Barnes, Vern Roscoe, Levy Grady - Interim Maintenance Representatives Steve Tabor - SEU, Mentor Summary of Event:

While pumping the Unit 1 Suppression Pool to the Waste Surge Tank, water was inadvertently diverted through a disassembled check valve to the ground adjacent to the Unit 2 CST, due to an inadequate clearance boundary. This resulted in a spill of 2500 to 3000 gallons of contaminated water.

Summary of Root Cause(s):

The Root Cause is an over reliance, by involved individuals, on other existing Clearance process barriers to ensure the process develops a Clearance that ensures equipment and personnel safety.

Summary of Corrective Action(s) to Prevent Recurrence (CAPR):

Communicate to Operations and Maintenance personnel the importance of having the mindset that you, the individual involved in the process, are the only barrier to ensure personnel and equipment safety. Also, revise 001-29 to require a Clearance process assessment every two years to verify the processes of clearance request; clearance development; and clearance boundary verification are being appropriately implemented.

CAP-NGGC-0205 Rev. 5

ATTACHMENT 16 Sheet 2 of 3 Significant Adverse Condition Investigation Report Form CAP-NGGC-0205-16-5 Action Request Number: 237296 Event Time: 1440 Facility: BNP Event Date: 6/21/07 Unit: 0. Investigator: L. E. Van Kleeck

1. Event Description On June 21, 2007, at approximately 1440, Operators on Unit 1 secured pumping the Unit 1 Suppression Pool to the Waste Surge Tank (WSGT) based on reports of a leak at the Unit 2 Condensate Storage Tank (CST). The leak at the Unit 2 CST was coming from a disassembled check valve on the drain line from the Unit 2 CST to the WSGT. The leak occurred because an inadequate clearance boundary was provided for the check valve disassembly work, and allowed water being pumped to the WSGT to also reach this check valve. This resulted in approximately 2500 to 3000 gallons of contaminated water being pumped to the ground in the area of the Unit 2 CST.

2. Problem Description Adequate clearance boundaries are required to be provided to ensure personnel and equipment safety at all times during the performance of maintenance activities. An adequate clearance boundary was not provided for the work associated with disassembly of the check valve on the drain line of the Unit 2 CST. This inadequate boundary resulted in a spill of 2500 to 3000 gallons of contaminated water to the ground. In addition to the spill, an unsafe condition existed in that pumping of the Unit 1, or Unit 2, Suppression Pool to the WSGT coincident with actual valve disassembly/reassembly activities could have resulted in personnel injury. The extent of condition was limited to the clearance associated with the disassembly of the Unit 2 CST drain line check valve.

3. Investigation Summary Barrier Analysis was the primary investigative technique used in the investigation of this event. A Cause and Effect Analysis was used to a lesser extent. Interviews were conducted with the involved individuals, and a Culpability Decision Tree was completed as part of the Human Performance Analysis.

On March 19, 2007, a Work Request (W/R) was initiated on the Unit 2 CST to have the tank drained, cleaned, and the inside surface recoated due to problems with the paint peeling from the tank interior. This W/R became Work Order (W/O) 1033023 and was approved on April 11, 2007. A Project Manager was assigned and a project team was assembled.

NOTE: Refer to Figure 1 of this investigation for a basic system drawing, if needed.

CAP-NGGC-0205 Rev. 5

The draining of the Unit 2 CST was to be completed in two steps. First, clearance order (C/O) 138829 would be hung and the CST would be drained by the normal method by opening the 2-CO-V1 35 and flowing water through the 2-CO-V1 62 check valve and the 2-G16-V449 to the WSGT. This clearance was hung and draining began on May 31, 2007 at approximately 1119. Upon completion of this evolution, about three feet of water would remain in the bottom of the CST. The CST manway would then be opened; a submersible pump would be placed in the CST; the bonnet of the check valve, 2-CO-V1 62, would be removed; a flange and pipe nipple would be installed in place of the bonnet, and the discharge hose of the submersible pump would be routed to the pipe nipple on the 2-CO-V162. This would allow removal of the remaining water in the CST.

W/o task # 11 was initiated to disassemble the 2-CO-V162 bonnet. Clearance request 108360 was initiated to request a clearance for this work. This clearance would actually be a boundary change to clearance 138829, which was in place to allow the first step in the CST draining process. ADM-NGGC-01 04, Work Management Process,Section 9.8.9 states in part:

The Clearancerequest should contain details that will allow the clearance developer to prepare the ClearanceOrder (CO). The following information should be included:

- Clearanceboundary scope (electrical, fluid, air, etc.)

- Specific tagging order (if important to the maintenance activity)

- Components that should NOT be tagged (i.e., components'thatmust be manipulated or removed)

- Components that will need position verification following the maintenance activity (due to work instructions that manipulate the component)

- Boundary extension need, if known

- Special precautionsor instructions for the clearance developer, such as "hang when requested."

Clearance request 108360 actually stated the following:

Condensate storage tank isolated and drainedto the extent possible for recoating tank interior. It is understood that the tank cannot be drainedcompletely and will be drained lAW 2SP-07-205. Reference EC 66436.

The clearance request was inadequate in that it did not request a fluid boundary for the disassembly of the 2-CO-V1 62, as required by ADM-NGGC-01 04.

The clearance preparer developed a boundary change to C/O 138829 which closed the 2-CO-V1 35 to isolate the Unit 2 CST from the water being pumped via submersible pump to the 2-CO-V162. The clearance preparer stated during interviews that he asked the project team on two separate occasions if it was necessary to control the valves downstream of the 2-CO-V1 62 and was told that they would be controlling those valves within the W/O. He did not find it unusual that Maintenance would be controlling valves rather than placing them under clearance. There are other instances where this occurs.

The clearance procedure allows maintenance to control air valves on pneumatically operated valves rather than using a clearance. He believed this Was a similar situation.

CAP-NGGC-0205 Rev. 5

Additionally, he found the following statement in the W/O under Precautions/Prerequisites:

Ensure line is isolated from the Aux Surge Tank and drainedpriorto disassembly.

The clearance preparer understood this to corroborate the information he had already received and was satisfied he had prepared the proper clearance.

OPS-NGGC-1301, Equipment Clearance, Section 4.6.1 includes the following as the Clearance Preparers responsibility:

Prepareand verify clearancesto ensure safe operating conditions exist while equipment is being removed from service, maintained,and returned to service.

Also in section 9.2.1.2.2 it states:

The ClearancePreparershall understand the scope of the maintenance activities and prepare a clearance ensuring that the administrative requirements of this procedure are met.

Clearance preparation was inadequate in that the clearance did not provide for a proper fluid boundary to allow disassembly of 2-CO-V162, which was clearly included in the scope of the W/O, as required by OPS-NGGC-1301.

The Clearance Reviewer was a Senior Reactor Operator (SRO) who reviews and approves clearances developed by the Clearance Preparer, to provide a second check of clearance adequacy. The Clearance reviewer will have the same expectations that the Clearance Preparer has regarding clearance development. In this instance, the Clearance reviewer no longer works for Progress Energy. When contacted, the reviewer stated he relied mostly on the Clearance Request to determine if he had provided an adequate boundary, and believed that tagging 2-CO-V1 35 closed met the requirements of the Clearance Request. The clearance review was inadequate as it also did not provide for a proper fluid boundary to allow disassembly of 2-CO-V1 62, which was clearly included in the scope of the W/O, as required by OPS-NGGC-1301.

The hanging of this boundary change was completed on May 31, 2007 at approximately 1600. Following the hanging of the boundary change, W/O 1033023-11 was given to a Nightshift Duty Crew mechanic to have 2-CO-V162 disassembled. This mechanic stated that he noted the clearance tag on the 2-CO-V135 and believed he had an appropriate clearance for his work. He accepted the clearance, removed the bonnet from the 2-CO-V162, and installed the fabricated drain rig in place of that bonnet.

OPS-NGGC-1301, Equipment Clearance,Sect. 4.10, under Clearance Holder responsibilities, lists one of those responsibilities as:

4. 10. 1 Verify the clearanceboundary is adequate for their assigned work priorto beginning work.

CAP-NGGC-0205 Rev. 5

W/O 1033023-11 contained the following information prior to the Work Instructions Ensure line is isolated from the Aux Surge Tank and drainedpriorto disassembly.

Verify properboundary and sign onto OPS clearancepriorto commencing work.

Although a physical walk down of the clearance is not required, a boundary verification using the clearance information and applicable prints is the expectation. The verification of an adequate clearance boundary by the mechanic was inadequate in that the failure to isolate the Aux Surge Tank (AST) side of 2-CO-V162 was not identified.

Additionally, only an informal Pre-Job Brief was conducted between the mechanic, an HP Tech, and a member of the Atlantic work force. This brief was inadequate in that it did not cover all aspects of even the Simple Task Brief and did not identify the safety concern of verifying a proper clearance boundary prior to work start.

Periodically Operations is required to pump the Suppression Pool to the WSGT or the AST to maintain Suppression Pool level in the normal band. When Operations began pumping the Unit 1 Suppression Pool on June 21, 2007, the inadequate clearance boundary was discovered.

The Adverse Condition for this NCR is that an inadequate clearance boundary existed for the disassembly of 2-CO-V162. As a result, when Operators began pumping the Unit 1 Suppression Pool, a spill occurred. Individual procedure non-compliance errors by the Clearance Requestor, Clearance Preparer, and the Clearance Reviewer resulted in a failure to properly implement the Clearance request, Clearance development, and Clearance implementation processes {inappropriate Act #1). Each individual involved in this sequence failed to follow the applicable procedure {Contributing Cause #1). The Team believed the event was caused by an over reliance, by involved individuals, on other existing Clearance process barriers to ensure the process develops a Clearance that ensures equipment and personnel safety (Root Cause).

The Clearance Holder in this event did not perform an adequate verification of the clearance boundary prior to starting work {Inappropriate Act #2). The Clearance holder's actions did not cause the inadequate boundary to exist, but allowed the inadequate boundary to continue to exist while work was performed. This was also caused by a failure of the individual to follow applicable procedures (Contributing Cause #2). The procedures include OPS-NGGC-1301, Equipment Clearance,and the instructions in the associated W/O.

Lastly, the Clearance Holder/Work Order Implementer did not obtain an adequate Pre-Job Brief prior to starting work (Inappropriate Act #3). The Clearance Holder was a Nightshift Duty Crew Mechanic. Although there was no Supervisor present on the Duty Crew, there is a Lead Mechanic on the crew. Maintenance Team members stated that the Lead Mechanic would be expected to lead briefs for his crew when required. The Clearance Holder/Work Order Implementer believed he was meeting the requirements for a brief when he completed the informal brief. Since the Duty Lead Mechanic was not involved with, or familiar with, the work in progress, it was thought that he would not be able to add additional pertinent information. Since the Holder/Implementer thought he was CAP-NGGC-0205 Rev. 5

meeting expectations with an informal brief, the cause of the error would be unclear expectations or policies related to Pre-Job briefs (Contributing Cause #3).

4. Previous Operating Experience (internal and External)

OE 182213 - Brunswick Unit 1, 3/10/04 During the Brunswick Unit 1 Outage, strainers were being installed in the discharge piping of each Heater Drain Pump (HDP). For the 1B HDP strainer installation there was interference that required the rerouting of a portion of the 1B HDP TBCCW piping.

Pressurized water was encountered when cutting the associated TBCCW pipe.

When the planner created W/O tasks for the three Unit 1 HDP strainer installations they were patterned after the Unit 2 modifications. He cut and pasted partial instructions from the Unit 2 W/Os to create the Unit 1 W/Os, but did not remember the TBCCW line interferences. The W/O did not include instructions to modify the TBCCW piping. The clearance request did not address the isolation of the TBCCW piping.

This incident is applicable based on the inadequate boundary and the role that proper W/O planning, as well as properly requesting a clearance, plays in clearance development.

OE 22676 - Brunswick Unit 1, 4/4/06 During the Brunswick Unit 1 Outage it was identified that a large Feed Water (FW) system Motor Operated Valve (MOV) operator needed to be rebuilt. At the time the FW system was under clearance. The clearance to support this rebuild only established an electrical boundary. During the rebuild, the FW clearance was removed, pressure was applied to the underside of the valve as the system was restored to service, and the valve disc/stem assembly pushed out to the valve body backseat.

Clearance writers and Maintenance personnel had not questioned if there was a system flow or pressure impact and therefore a need for a fluid boundary since this was an MOV operator clearance.

This incident is applicable based on the inadequate boundary and the need for a questioning attitude when developing a clearance.

OE 22828 - St. Lucie Unit 2, 5/4/06.

During the spring 2006 refueling outage, the 2A Turbine Oil Cooler was placed under clearance. When Maintenance removed the end bell cover to repair an oil leak, water began to flow unexpectedly from the cooler. The clearance was found to be inadequate for the work activity. The W/O for repairing the Oil Cooler did not identify the need to isolate, and drain, both sides of the heat exchanger.

This incident is applicable based on the inadequate boundary and the role that proper W/O planning, as well as properly requesting a clearance, plays in clearance development.

CAP-NGGC-0205 Rev. 5

5. Extent of Cause/Condition The extent of condition for this investigation involves the entire clearance preparation culture. Corrective Actions to Prevent Recurrence will be to communicate to Operations and Maintenance personnel the importance of having the mindset that you, the individual involved in the process, are the only barrier to ensure personnel and equipment safety. Also, revise 001-29 to require a Clearance process assessment every two years to verify the processes of clearance request; clearance development; and clearance boundary verification are being appropriately implemented.

A contributing cause for this event, which was common to both organizations involved, was a failure to follow the procedure as written. The extent of Cause would clearly involve a lack of procedure use and adherence behaviors. There is currently a site Adverse Trend in Procedure Use and Adherence documented in NCR 208861. The investigation of this Adverse Trend is complete and six Corrective Actions remain to be implemented. Both Operations and Maintenance have organizational Adverse Trends in Procedure Use and Adherence. The Operations Adverse Trend is tracked by NCR 184970. The Maintenance Adverse Trend is tracked by NCR 194880. Neither organization has open corrective actions remaining in these NCRs.

6. Safety Significance This incident resulted in zero nuclear safety concerns. The actual safety significance involved personnel safety, as an unsafe condition existed such that pumping of the Unit 1, or Unit 2, Suppression Pool to the WSGT coincident with actual valve disassembly/reassembly activities could have resulted in personnel injury. There also existed a potential radiological safety concern based on the activity level of the spilled fluid. The actual radiological safety significance was minimal. No release limits were exceeded and the incident was determined to not be reportable.

7. Summary of Results The Root Cause is an over reliance, by involved individuals, on other existing Clearance process barriers to ensure the process develops a Clearance that ensures equipment and personnel safety.

One Contributing Cause involves the failure of individuals to follow the applicable procedures. Another Contributing Cause involves the failure to establish and enforce proper Pre-Job Brief standards.

CAP-NGGC-0205 Rev. 5

8. Inappropriate Acts / Equipment Malfunctions/Causal FactorslCorrective Action Plan

Complete the below table to identify the required information

Place information in the non-shaded areas only. This is to help align the cause for each Inappropriate Act and to ensure that each Cause is linked to and addressed with a Corrective Action.

Clearly describe each causal factor as to how it applies to the investigated event / condition. (Do not just cut and paste the cause definition from CAP-NGGC-0206). Designate each causal factor as "Root" or "Contributing"

The "Code" column is used to identify the Cause Code (CAP-NGGC-0206 Attachment 2)

" The "ORG" column is used to identify the organization responsible for the Inappropriate act.

" Designate the type of action (CAPR, CORR or ENHN). Reference attachment 15 for guidance as needed.

For completed or interim actions, provide appropriate completion documentation or ensure that the investigation results contain adequate detail to ensure traceability, for example; Work Order "ABC" was completed and approved on mm/dd/yy, Engineering Change Request "XYZ" was completed in the field on mm/dd/yy, or Material Evaluation was completed and approved on mm/dd/yy.

CAP-NGGC-0205 Rev. 5

ATTACHMENT 16 Sheet 3 of 3 Significant Adverse Condition Investigation Report Form CAP-NGGC-0205-16-5 rlnrra~rtiva Artfinn PImn kn inaoequate clearance noundary

secured pumping the i. uompleted ixisted for the disassembly of the 2- Jnit 1 Suppression Pool to

'0-V162 resulting in an unsafe he WSGT.

ondition and a spill.

Roped off area to control 2. CORR 2. E&RC 2. Completed 6/21/07 iccess.

3. Sampled fluid for 3. CORR 3. E&RC 3. Completed 6/21/07 eportability determination.

L.Developed new 4. CORR 4. OPS 4. Completed by

learance for adequate 3122/07 ioundary 9 .9 9.

7ailure to properly implement the IJ GII lU 1. Reinforce Clearance 1. CORR 1. Susan Rogers 1.10/18/07 1earance request, and Clearance over reliance, by ýequest quality standards Ievelopment process. involved and establish targeted individuals, on *bservations to verify other existing Clearance Request quality Clearance process s at the appropriate level barriers to ensure the process 2. Communicate to 2. CAPR 2. Susan Rogers & 2. 10/18/07 develops a Dersonnel the importance ol Steve Howard Clearance that iaving the mindset that ensures equipment --ach individual involved in and personnel any portion of the safety. Clearance process must ad ike they are the only barrier to ensure personnel and 9quipment safety

3. Reinforce Clearance 3. CORR 3. Steve Howard 3. 10/18/07 Jevelopment quality standards and establish

argeted observations to merify quality is at the appropriate level.

CAP-NGGC-0205 Rev. 5

4. Revise 01-29, 4. CAPR 4. Steve Howard 4. 10/18107 Operations Internal Audits, to establish a requirement for a clearance process assessment every 2 years Nhich includes Maintenance and Operations

5. Perform Stand Down Nith Clearance Center Staff 5. CORR 5. OPS 5. Completed by 3/26/07

6. OPS 3. Completed by

3. Issue a Human 6. CORR 3126107.

oerformance News Flash to the Site

7. A. Padleckas F7 9/6/07

7. Develop a Clearance 7. ENHN request checklist to aid in request consistancy Contributing 18G MNT & OPS 1. Confidential actions 1. CORR 1. R. Bisset 1. 8/30/07 Cause: Clearance taken with the involved requester, Clearance Requester Clearance Preparer, and 2. Confidential actions 2. CORR 2. A. Padleckas 2. 8130/07 Clearance taken with the involved Reviewer failed to Clearance Preparer and ollow the Clearance reviewer.

pplicable procedures Clearance Holder/Work Order Contributing 18G VINT 1. Confidential actions 1. CORR 1. K. Jones 1. 8/30/07 mplementer performed an inadequate Cause: Failure to taken with the involved

'erification of proper clearance follow applicable individual

)oundary prior to starting work. procedure

2. Reinforce Clearance 2. CORR 2. S. Rogers 2. 10/18/07 boundary verification quality standards and establish targeted observations to verify quality is at the appropriate level.

CAP-NGGC-0205 I Rev. 5

13. 13.[.

Conduct Training for,

~Clearance requests, and jo ENH N M.McPherso 13 12/20/07

~Clearance Holder Boundary verification techniques JIj I Reinforce clear CORR S. Rogers B/30/07 3xpectations for the

erformance of Pre-Job

riefs in the Maintenance Drganization Revise 2-SP-07-205 to ENHN Bip Proctor 12/20/07 nclude lessons learned rom this event Conduct cross discipline ENHN Levy Grady 12/20107 raining with the Clearance Vriters and W/O planners iclude discussion of this ENHN 1. T. Pearson 1.10/25/07

ývent in clearance preparer ind clearance holder initial 2. L. Rieman .10/25/07 ind periodic training.

'omplete an evaluation of ENHN Jeff Ferguson 1/10/08 he spill lAW 10CFR50.75G Effectiveness Review EREV A. Padleckas 5/8/08

Designate which assignments are Long Term Corrective Action (non-outage related LTCA requires approval by DSO - Manager PE&RAS for corporate).

- Provide justification for corrective actions to prevent recurrence (CAPR) with initial due date that exceeds 90 days and for corrective actions (CORR) with initial due date that exceeds 120 days.

CAP-NGGC-0205 I Rev. 5

8. Basis, If Effectiveness Review is waived: N/A

9. PNSC/CSERB Review Required? YESol NO D 12

135 162 448 447 U-2 CST AST U-1 CST 1067 449 RHR WSGT Figure 1

ATTACHMENT 4 Sheet 1 of 1 EFFECTIVENESS REVIEW (EREV) FORM Form CAP-NGGC-0200-4-16 EREV Evaluator: A. Padleckas EREV Date: 05/07/08 AR Number/Title: NCR 237296 - AOP-5 ENTRY DUE TO SPILL AT U2 CST Event Summary: While pumping the Unit 1 Suppression Pool to the Waste Surge Tank, water was inadvertently diverted through a disassembled check valve to the ground adjacent to the Unit 2 CST, due to an inadequate clearance boundary. This resulted in a spill of 2500 to 3000 gallons of contaminated water.

1. Is the current set of Corrective Actions to Prevent Recurrence the same as in the original *Yes ri No approved Corrective Action Plan? [Indicate changes, additions, deletions, and reason (e.g.,

training needs analysis required adding training to LOCT, etc.)],

Comments/

References:

CAPRs associatedwith this clearanceerrorprimarily were focused on reinforcementof standards,communication of importanceor roles and responsibilitieswithin the clearanceprocess and increasedassessment of the clearance process by multi-disciplinedteams.

2. Have the Corrective Action(s) To Prevent Recurrence been completed and has there been sufficient time for the result of implementation to be assessed? [Indicate how long the m Yes Ei No CAPR have been in place and degree to which they have been challenged.

Comments/

References:

Standardreinforcement and communication CAPRs have been in place for several months (since 10/18/07). The processedhas been especially challenged throughoutB 116F3 and B 117R 1. 001-29 revision has been completed to schedule multi-discipline assessments, however none of the assessments have been completed to date.

3. Are appropriate barriers in place to prevent recurrence of the Event?

[Consider the effectiveness of the barrier resulting from each individual CAPR as well as the

" Yes E[ No collective effectiveness of the barriers. For CAPRs that resulted in procedure revisions, is the CAPR information properly annotated per the applicable procedure writer's guide?]

Commentsl

References:

001-29, Operations InternalAudits, Revision 55 incorporateda Bi-annualassessment of the ClearanceProcess that includes maintenance and operations personnel. The assessmentprocess should aid in identificationand resolution of future clearanceissues.

4. Based on a review of Corrective Action data, has a Repeat Event been prevented?

[If review identifies recurrence of this condition or a condition sufficiently similar to indicate the problem still exists indicate NCR# and source (e.g., NAS, PES, INPO, NRC, Self- " Yes E[ No Assessment, etc.)]

Comments/

References:

Based on a review of NCRs generatedsince CorrectiveActions were implemented it appearsthat actions taken were successful in mitigatingreliance on other work groups to ensure an adequate clearance boundaryexists. Several examples can be provided where an implementing organization within the clearanceprocess has challengedboundary adequacy. During BI 17R1 one clearance error(NCR 271607occurredin which a drain pipe was cut outside of the establishedclearance boundary. In this case the maintenance individuals involved were sharedresourcesand were not recipientsof corrective actions associatedwith this event. Corrective actions associatedwith NCR 271607 will address deltas between NGGC fleet clearanceprocess implementation.

5. Based on interviews with personnel, has a .Repeat Event been prevented?

[If not provide specifics, including references to the Repeat Event documentation. List type n Yes ci No of personnel interviewed (supervisors, craft, etc.)]

Comments/

References:

Based on interviews with clearance preparersand maintenance supervision it appearsthat actions taken were successful in mitigating reliance orf other work groups to ensure an adequateclearanceboundary exists. Some candid discussion was exchanged during maintenancesupervisor continuing trainingrelative to this event and effectiveness of corrective actions.

6. Overall, are the Corrective Actions to Prevent Recurrence considered effective such that no further actions are required to prevent recurrence?

Comments/

References:

No further actions are requiredas a result of this specific event.

Corrective actions taken have shown a clear affect on individuals' attitudestoward reliance on others within the clearanceprocess in providing an adequate clearanceboundary.

Other challenges still exist with implementation of the clearanceprocess.As previously discussedin one instance during B 117R I sufficient barrierswere broken such that a drain pipe outside of the establishedclearanceboundary was cut into by a sharedresource group. NCR 271607 will drive corrective actions relative to that specific event.

Also, NCR 257188 has recently been investigatedidentifying an adverse trend for Operationsin the implementation of the clearanceprocess. Furtherimprovements to the implementation of the clearanceprocess will be driven via this NCR.

Information was communicated on 10/01/07 via email below and re-emphasized (continuing) in continuing training introduction 07-05.

To All Operations Personnel.

From Steve Howard Clearance process barriers to protect equipment and ensure personnel safety. Attached is a summary of the inadequate clearance boundry which enabled contaminated water to be spilled in the area of the Unit 2 CST. The Corrective Action to Prevent Reoccurance could have been to place another barrier in the clearance process. However, the existing process provides adequate barriers when the process/procedure is followed and it was determined another barrier was not the answer.

With safety as our first priority, we can not afford to make errors and we must maintain a questioning attitude. Each one of these barriers MUST be independent of each other and not relying on the other barrier to maintain the person or equipment safe. As clearance requesters, preparers, reviewers and holders; we MUST have the mind set that each individual barrier is the only barrier from damaging equipment, injuring personnel or even killing someone.

Thanks, Steve

SUMMARY

On June 21, 2007, at approximately 1440, Operators on Unit 1 secured pumping the Unit 1 Suppression Pool to the Waste Surge Tank (WSGT). A leak at the Unit 2 CST was coming from a disassembled check valve on the drain line from the Unit 2 CST to the WSGT. The leak occurred because an inadequate clearance boundary was provided for the check valve disassembly work, and allowed water being pumped to the WSGT to reach this disassembled check valve. This resulted in approximately 2500 to 3000 gallons of contaminated water being pumped to the ground in the area of the Unit 2 CST.

In addition to the spill, an unsafe condition existed in that pumping of the Unit 1, or Unit 2, Suppression Pool to the WSGT coincident with actual valve disassembly/reassembly activities could have resulted in personnel injury.

Adequate clearance boundaries are required to be provided to ensure personnel and equipment safety at all times during the performance of maintenance activities.

DISCRIPTION Refer to Figure 1 for a basic system drawing.

Work Order (W/O) 1033023 (April 11, 2007) was to drain, clean, and recoat the inside surface of the Unit 2 CST due to problems with the paint peeling from the tank interior.

A Project Manager was assigned and a project team was assembled.

The draining of the Unit 2 CST was to be completed in two steps. First, clearance order (C/O) 138829 would be hung and the CST would be drained by the normal method by opening the 2-CO-V135 and flowing water through the 2-CO-V162 check valve and the 2-Gi6-V449 to the WSGT. This clearance was hung and draining began on May 31, 2007. Upon completion of this evolution, about three feet of water would remain in the bottom of the CST. The CST man way would then be opened; a submersible pump would be placed in the CST; the bonnet of the check valve, 2-CO-V162, would be removed; a flange and pipe nipple would be installed in place of the bonnet, and the discharge hose of the submersible pump would be routed to the pipe nipple on the 2-CO-V162. This would allow removal of the remaining water in the CST.

W/O task # 11 was initiated to disassemble the 2-CO-V 162 bonnet. Clearance request 108360 was initiated to request a clearance for this work. This clearance would actually be a boundary change to clearance 138829, which was in place to allow the first step in the CST draining process.

The first barrier which broke down was that the clearance request was inadequate in that it did not request a fluid boundary for the disassembly of the 2-CO-V162, as required by ADM-NGGC-0104.

The clearance preparer developed a boundary change to C/O 138829 which closed the 2-CO-V135 to isolate the Unit 2 CST from the water being pumped via submersible pump to the 2-CO-V162.

The second barrier which broke down was that the clearance preparation was inadequate in that the clearance did not provide for a proper fluid boundary to allow disassembly of 2-CO-V162, which was included in the scope of the W/O.

The Clearance Reviewer (SRO) who reviews and approves clearances developed by the Clearance Preparer, to provide a second check of clearance adequacy. The Clearance reviewer (a SRO) will have the same expectations that the Clearance Preparer has regarding clearance development. The reviewer relied mostly on the Clearance Request to determine if he had provided an adequate boundary, and believed that tagging 2-CO-V 135 closed met the requirements of the Clearance Request.

The third barrier which broke down was that the clearance review was inadequate as it also did not provide for a proper fluid boundary to allow disassembly of 2-CO-V162, which was clearly included in the scope of the W/O, as required by OPS-NGGC-1301 Although a physical walk down of the clearance is not required, a boundary verification using the clearance information and applicable prints is the expectation.

The forth barrier which broke down was that the clearance holder verification of the clearance boundary was inadequate in that the failure to isolate the Aux Surge Tank (AST) side of 2-CO-V162 was not identified.

CONCLUSION As stated above, four separate and independent barriers broke down and failed to prevent 2500 to 3000 gallons of contaminated water being pumped to the Unit 2 CST ground area and potentially injuring personnel (including death). All four barriers are examples of not following procedure. When ask why four separate tasks (which was four different individuals) including two different departments did not follow procedure, the root cause was determined to be the involved individuals over relied on the other existing Clearance process barriers to protect equipment and ensure personnel safety. With safety as our first priority, we can not afford to make errors. That is why we must maintain the independence of these barriers especially the clearance preparation and review and maintain a questioning attitude.

We as operators CAN NOT allow/tolerate these behaviors. Each one of these barriers MUST be independent of each other and not relying on the other barrier to maintain the person or equipment safe. As clearance requesters, preparers, reviewers and holders; we MUST have the mind set that the each barrier is the only barrier from damaging equipment, injuring personnel or even killing someone.

21earance standards have been reinforced. A monthly review of clearance standards has

)een communicated and scheduled.

Clearance Request Checklist WO Task: CR #: Planner:

This checklist is intended as a guide to ensure that sufficient and specific information is provided for developing an accurate clearance. This is not a QA document and has no record retention requirements.

REQUIRED ELECTRICAL ISOLATIONS:

Electrical components should normally be de-energized by:

Opening a breaker

Operating a switch

Pulling a fuse In those cases where this is not feasible, it is permissible to lift leads or slide links. If leads have to be lifted or links slid, it is preferred that the leads are lifted/links slid locally at the component and documented using NGGC/Site configuration control methods. Leads/links shall be Independently Verified on those systems required by site procedures.

4 KV 480 VAC 120 VAC 125 VDC Logic Annunciator Specifics:

" Grounding Devices required o Motor heaters deenergized o Fuses pulled o Leads Lifted

" Breaker Compartment entry required o Alternate power supplies addressed REQUIRED MECHANICAL ISOLATIONS:

A clearance is not required to work on pneumatic components if a local pneumatic isolation is available and the pneumatic component is not a boundary isolation valve. NGGC/Site configuration control methods shall be used to ensure the components are restored to correct position.

Isolated Vented Drained Fluid Pneumatics Cooling Water Specifics

" Gagging equipment o Torquing Valves into seats o Blind flanges El Freeze seals

" Single Isolation o Specific Plant Configurations / Conditions SPECIAL RESTORATION REQUIREMENT:

" Rotational Bumps o Off Pending Testing o Components manipulated within the boundary o Required restoration sequencing o Pre-planned boundary changes o Maintenance present when placing in service Reference Drawings Procedures:

Other Comments:

(Rpv n 6/28/67)

Discussed with Thomas his involvement with the #2 CST. His clearance request was incomplete in that he did not request a fluid boundary for the work to be completed (check valve disassembly). He was counseled to request either an electrical, fluid, or hydraulic boundary for the specific work scope in the future.

The above verbiage has been entered in the subject employee's evaluation. This coaching and documentation was deemed appropriate based on the employee's previous performance (no planning or other performance related issues in recent history) and the nature of his error as pertains to the cause of the event. Item is closed based on this action. RAB 8/30/07.

Confidential actions complete. This assignment can be considered closed.

DPI1301N, the initial generic lesson plan for Clearance Training, has been revised to

equire a review of this event as OE for the Clearance Holder BNP population. Also,

-learance requests and clearance holder boundary verification techniques were included n the biennial clearance holder required training package which completed 12/12/07.

Expectations for pre-job briefs were reinforced with the MTS organization on 8/29/07.

1. All work, no matter how simple or routine, requires a pre-job brief per Al-1 22.

_. Continuing jobs (from shift to shift and day to day) must be re-briefed each shift or day

3. All pre-job briefs must include a discussion of critical task(s) (e.g., actions, which ifnot

.3xecuted properly, will result in irrecoverable errors/events).

,. All briefs must include a discussion of core management standards and expectations

egarding the use of core HU tools

3. Back shift or weekend work where a supervisor may not be present still require a pre-job brief.

rhese briefs can be given by a lead person.

3. All briefs must include a discussion on the expectation to conduct a two-minute or job site drill

k PRR (PRR-254452) has been generated to capture lessons learned from the spill that

)ccurred during the Unit 2 CST Project. The procedure not yet written for Unit 1 CST xill encompass these lessons learned in the unit one special procedure for the CST

-ecoating. There will be a statement addressing clearances boundaries and events

)ertaining to the unit 2 CST Spill. DBP 11/13/07

DPI1301N, the initial generic lesson plan for Clearance Training, has been revised, (Rev.

11) to require a review of this event as OE for the Clearance Holder BNP population.

Fhis event will also be covered in the next retraining session for all BNP clearance iolders as indicated in assignment 23. This event was reviewed by the Operations Vianager during the LOCT Cycle 07-5 kickoff and was also included for review in the DPS CT Newsletter, Cycle 07-5. Action completed. 102407. T. Pearson

D'PI1301N, the initial generic lesson plan for Clearance Training, has been revised, (Rev.

11) to require a review of this event as OE for the Clearance Holder BNP population.

Fhis event will also be covered in the next retraining session for all BNP clearance iolders.

Evaluation of Spill IAW 10CFR50.75(g) 3ased on a review of 10CFR50.75(g), the documentation associated with this spill should

)e vaulted as a decommissioning record.

3uggest Operations initiate a separate NTM assignment to have Operations DMA

ransmit/vault this NCR (#237296) as a decommissioning record.

Pre-job briefs were re-enforced with supervisors as required.

The following was communicated to the shop as requested by this action item.

A few months ago during the CST cleaning evolution, while pumping the Unit 1 Suppression Pool to the Waste Surge Tank, water was inadvertently diverted through a disassembled check valve to the ground adjacent to the Unit 2 CST, due to an inadequate clearance boundary. This resulted in a spill of 2500 to 3000 gallons of contaminated water.

Although a physical walk down of the clearance is not required, a boundary verification using the clearance information and applicable prints is the expectation. The verification of an adequate clearance boundary by the mechanic was inadequate in that the failure to isolate the Aux Surge Tank (AST) side of 2-CO-V162 was not identified.

The Clearance Holder in this event did not perform an adequate verification of the clearance boundary prior to starting work. The Clearance holder's actions did not cause the inadequate boundary to exist, but allowed the inadequate boundary to continue to exist while work was performed. This was also caused by a failure of the individual to follow applicable procedures. The procedures include OPS-NGGC-1301, Equipment Clearance,and the instructions in the associated W/O.

On the surface this may appear to be a minor event. We may rationalize that this was just a spill that was easily cleaned up. However, if conditions had been different (high pressure or high voltage) we could be talking about a significant injury or even death of you or your co-worker.

Although other barriers failed, the final barrier of verifying an adequate clearance boundary prior to starting work is your responsibility. It is my expectation and it should be yours that you will verify that you have an adequate clearance boundary prior to starting work.

Thanks Paul Smith

Z1earance boundary verification quality standards have been reinforced and

-argeted observations to verify quality is at appropriate level are being

.racked by NTM's. Reference AR 251075 for observation details.

-S1earance boundary verification quality standards have been reinforced and targeted

)bservations to verify quality is at appropriate level are being tracked by NTM' s.

keference AR 251003 for observation details

ML101940452

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ML101940452

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