3F1297-37, Responds to NRC Re Violations Noted in Insp Rept 50-302/97-14.Corrective Actions:Maint Procedure MP-402 Series & Preventive Maint MP-178 Series Will Be Revised as Appropriate,By 980331

Responds to NRC Re Violations Noted in Insp Rept 50-302/97-14.Corrective Actions:Maint Procedure MP-402 Series & Preventive Maint MP-178 Series Will Be Revised as Appropriate,By 980331

ML20197J482
Person / Time
Site:	Crystal River
Issue date:	12/29/1997
From:	Holden J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F1297-37, 50-302-97-14, NUDOCS 9801050007
Download: ML20197J482 (11)

Text

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Florida Power P wunna December 29, 1997 3F1297-37 U.S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-0001

Subject:

Reply to Notice of Violations, NRC Inspection Report No. 50-302/97-14, NRC to FPC letter, 3N1297-08, dated December 4,1997

Dear Sir:

In the subject letter, ;:lorida Power Corporation (FPC) received Notice of Violations.

This correspondence provides our response to the violations.

Sincerely, f'//V J. J. Holdon Director Site Nuclea- Operations JJH/dwh-rim -

Attachments ,l xc: Regional Administrator, Region 11 g

_ Senior Resident inspector NRR Project Manager 9801050007 971229 PDR ADOCK 05000302 O pg CRYSTAL RIVER ENCRGY CoMit.EX: is7so w Power une street .cryc'ai never, Fiortda 3442s s70s . ps2> 7*s44se  !

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. U. S. NuclTr RogulCtory Commission 3F1297-37 Page 2 of 12 ATTACHMENT 1 FLORIDA POWER CORPORATION NRC INSPECTION REPORT NO. 50 302/9714 REPLY TO NOTICE OF VIOLATIONS VIOLATION 50-302/97-14-02 10 CFR 50 Appendix B, Criterion XVI, Corrective Actions, requires that conditions adverse to quality such as malfunctions and deficiencies be promptly identified and corrected.

Contrary to the above, conditions advers3 to quality were not promptly corret.ted, in that:

1. Work request Numbers 333797 and 333798, issued in March 1996 to install stem protectors on the actuators for Makeup valves (MUV)-58 and MUV ~T3 were closed without performing the work. As of October 8,1997, the stem protectors had not been installed on these valve actuators.

2. As of October 24, 1997, design engineers failed to take action to correct design drawing errors for Drawings 206-058, Revision 18, and 206-075, Revision 19. As a consequence, incorrect information was used as inputs in several electrical calculations. The licensee's design engineers became aware of the discrepancies on the drawings during development of Revision 3 to emergency diesel generator (EDG)

Calculations E-91-0026 and E-91-0027; however, Precursor Cards or Drawing Change Notices were not initiated to havs the drawinq deficiencies corrected until this issut, was identified during the inspection.

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepu the violation.

REASON FOR THE VIOLATION Example 1 The reason for this violation example was a process weakness. Compliance Procedure CP-113A, " Work Request initiation and Work Package Control," did not contain adequate administrative controls to prevent use of the work request process to identify and document a nonconforming condition. The missing stem protectors represented a nonconforming condition which should have been documented in accordance with the version of CP-111, " Processing of Precursor Cards for Corrective Action Program,"in effect at the time.

A contributing factor was lack of a questioning attitude. An individual assumed that stem protectors were not required on the subject actuators without checking the component design documents (vendor drawings).

i . U. S. Nucirr R:guletory Commission 3F1297-37 Page 3 of 12 Example 2 The reason for this violation example was inadequate adherence to the requirements of Compliance Procedure CP-111. The design angincars were aware of the discrepancies and were recording them by marking up the affected drawings. The engineers in'. ended to document the discrepancies by issuance of a single Precursor Card (PC) wisen the calculations were issued, and did not generate PCs upon discovery, as required by CP-111.

CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND JHE RESULTS ACHIEVED Example i An inspection of Limitorque actuators revealed an additional twenty-three (23) actuators with missing stem protectors. Stem protectors will be fabricated and installed on the affected Limitorque actuators by March 31,1998.

Maintenance Procedure MP-402 series (Limitorque valve operator maintenance) and Preventive Maintenance PM-178-serie3 (Limitorque actuator inspection) procedures will be revised, as appropriate, by March 31,1998, to ensure st9m protectors are reinstalled upon completion of actuator mainte 1ance activities.

Example 2 A PC has been written to document the subject discrepancies and other discrepancies that were identified during the development of Revision 3 to the Emergency Diesel Generator calculations.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS Example 1 The subject violation has been discussed with Maintenance Department supervisory personnel. The need to exhibit a questioning attaude in the decision to cancel or void a work request was re-emphasized.

Revision 21 to CP-112A became effective on July 3,1997. A new step (4.2.1.10) was added to me procedure which stated, " Work Hequests may be used to perform corrective actions but CP-111, Processing of Precursor Cards for Corrective Action Program, must be u,ed to

- identify, document, evaluate, and trend the nonconformance." This statement endorses CP-111 as the process for documenting nonconformances and w'il ensure that nonconformances are evaluated.

Exampl_e,L2 The inappropriate actions noted in this violation example were reviewed with the department involved through staff meetings. A memo has also been issued to design engineering personnelinfomling them of this violation example and reminding them of the requirement to l

, U. S. Nucle:r Reguletory Commission i 3F1297-37 Page 4 of 12 generate PCs immediately upon discovery of a problem. A similar message was presented to site personnel through the Plan of the Day.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance by March 31,1998.

VIOLATION 50 302/97-14-04 10 CFR 50, Appendix B, Criterion XI, Test Control, requires that a test program shall be established to assure that all testing required to demonstrate structures, systems, and components will perform satisfactory in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

The Final Safety Analysis Report (FSAR) Section 6.1.2.1.1, High Pressure injection (HPI) states that "The four HPI valves (MUV 23,24,25, and 26) may be supplied by either of the two channels of the ES electrical buses through operation of selector switches in tce control room."

FSAR Section 6.1.3.1.1, "RCS Cold Leg Small Break LOCA," Table 6-14, "ECCS Single Failure Analysis for RCS Cold Leg Small Break LOCA," and Table 6-19, "ECCS Single Failure Analysis for HPl Injection Line Small Break LOCA", describe required operator action during a SBLOCA coincident with a LOOP and a failure of one of the ES trains to swap the electrical power supply Nr 2 injection valves from the normal to the altemate energized source end opening the valves so that adequate HPI flow can ce provided to mitigate the event.

Enhanced Design Basis Document (EDBD) For The Makeup And Purification System, Revision 8, dated August 8,1997, Section 3.0, Component Parameters, states in part that "MUV-23, MUV-24, MUV-25, iVlUV-26 must each have redundant power supplies."

Contrary 1 the above, as of October 10,1997, the licensee did not establish a test program and procedures to verify that the HPI Valves MUV-23,24,25, and 26 could be powered from both the normal and emergency power sources. Specifically, HPl va!ves were tested per SP-457 and SP-457A. These procedures stroke tint the HK injection valves once from their normal power supply. This testing did not verify that the valves could be powered from the alternate power source and that all control circuitry operates properly.

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.

REACON FOR THE VIOLATION The reason for the violation was personnel error resulting from deficiencies in engineering programs. The programmatic oeficiency was a lack of interface between departments to ensure that implementation of Modification Approval Records (MAR) resulted in new procedures being developed or existing procedures being revised when necessary.

L . ' U. S. Nucle:r Regul t:ry Commission 3F1297-37 Page 5 of 12 As a result of a study on the Small Bieak Loss of Coolant Accident, MAR 79-05-63C, "ECCS Pipe Break Analysis Wiring," was developed to add the capability to supply emergency power to the HPl injection valves upon loss of their normal power. This MAR was installed in 1981 without ensuring procedures were developed to test the new configuration. In 1985, SP-457,

." Refueling Interval ECCS Response to a Safety injection Test Signal," was developed. The objective of this procedure, in part, was to verify that each automatic velve in the flow path

' activates to its correct position on a high pressure or low pressure safety injection test signal, as appropriair This procedure performs a stroke time test on the HPl injection valves using the normal power supply but failed to require testing under the emergency power supply.

CORRECTIVE STEPS THAT HAVE EEEN OR WILL BJ TAKEN AND THE RESULTS ACHIEVED A review has been performed to determlae if other conditions similar to the subject violaHon exist. This review focused on switches (manual and automatic) that are required to deliver

power to equipment during accident conditions. The results of this review show that procedures which test the functions of the safety-related transfer switches are in place.

SP-457 hes been revised to include testing of the transfer se.ches which are used to supply back up power to the HPlinjection valves upon loss of normal power. Each HPi injection v.'Ive will be stroked with normal and emergency power. The revised testing of SP-457 ' vill be corsoleted prior to restart.

SP-457A will be revised by June 30,1998, to include testing of the transfer switches which are used to supply back up power to the HPl inlection valves upon loss of normal power. Each HPl injection valve will be stroked with normal and emergency power. This procedure performs the same functic as SP-457 but is written to be performed during MODE 1 while SP-457 is written to be perfurmed in MODES 5 and 6. SP-457 or SP-457A is required to be performed once every two years.

CORRECTIVE STEPS THAT HAVE DEEN TAXEN TO AVOID FURTHER VIOLATIONS Improvements have been made to the MAR process. Nuclear Engineering Procedure NEP-210, " Modification Approval Record," ensures functional test requirements are clearly specified. A review for functional testing requirements is specifically included in NEP-210.

Potentially affected departments are also pro /ided the opportunity to review the MAR for impact on their procedures.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance by June 30,1993.

VIOLATION 50-302/97-14-05 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstancos.

U. S. Nucle:r R:gul; tory Comm;3sion 3F1297 37 Page 6 of 12 Contrary to the above, activities affecting quality documented in Procedure SP-195, Remote Reactor Vessel Level Instrument Calibration, were not of a type appropriate to the circumstances in that SP 195 directed the technician to readjust the reduced inventory reactor vessel level transmitte s following completion of the calibration section of SP-195, which left the instruments in a condition of no longer being calibrated and not meeting the acceptance criteria in SP-195.

ADMISSION OR DENIAL OF THE ALLEGECs VIOLATION Florida Power Corporation accepts the violation.

REASON FOR THE VIOLATION The reason for the violation was cognitive perconnel error. Rather than performing an engineering evaluation to resolve the difference between an installed instrument level transtnitter indication and tygon tubo indication, incorrect instructions were incorporated into SP 195 to force the indications to match.

A contributing factor was failure to recognize weaknesses in the calculation used as a developmental reference to support the instructions contained in SP-195. Differences in fluid density (demineralized water versus borated water) and temperature between the tygon tube and instrument level transmitter reference leg had not been factored into the calibration calculation. Had the differences been taken into consideration, the indicated differences betwaen the level measuring devices would have been minimized or eliminated.

CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS ACHIEVED A survey has been conducted to determine whether similar conditions exist in other procedures. Enginearing and Maintenance personnel were surveyed. No similar instances were identified where other instrument level uansmitter strings were taken out of calibration to make them agree with some other level indication. FPC concludes that the practice of removing an instnament from a calibrated state is confined to the identified example.

Calculation I 90-1017, " Reactor Vessel Level Instrument Loop Tolerances," will be revised by January 31, 1998, to include compensation for fluid density (with boron) and temperature deviations between the tygon tubing and level transmitter reference jeg fluids for RC-201-LT and RC-202-LT.

2 SP-195 will be revised by February 28,1998, to include the results of calculation I-90-1017 and vendor tolerances. Steps to adjust the zero potentiometer in order to match the tygon tube indication will be removed.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS Nuclear Plant Technical Services (NPTS) Engineering Study Bock Entry (ESBE) 9712.01 has been issued. This ESBE discusses the subject violation and states that removing a calibrated instrument from a calibrated state is not an acceptable method of problem resolution at CR-3.

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. U. S. Nuclear Regulatory Commissi:n 3F1297-37 Page 7 of 12 :

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance oy February 28,1998.

VIOLATION 50 302/9714-06

- 10 CFR 50 Appendix B, Criterion All, Control of Measuring and Test Equipment, as implemented by the licensee's Quality Assurance Program, Final Safety Analysis Report, Revision 23, Section 1.7.1.12.5, Control of Measuring and Test Equipment, requires an investigation to be conducted and documented to determine the validity and acceptaoility of previous usage of measuring and tes; equipment found to ba out of calibration.

Contrary to the above, installed measuring and test equipment Gages MU-22-PI and MU-27 F1, used for in-service Test Program surveillance, were found out of calibration on February 15, 1596, and no investigation of previous usage was conducted or documented.

ADMISSION OR DEN _lAL OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.

REASON FOR THE VIOLATION The reason for the violation was a program weakness. No programmatic requirement exists to notify the appropriate Surveillance Procedure (SP) owner when an installed instrument used in survoillance testing is found to be out of tolersnce.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED _

A review of IST surveillsncs tests identified 62 installed instruments that are used to obtain test data. Of the 62 installed instruments,19 were found to have been out of tolemnce. The IST group valuated surveillance testing which utilized the 19 installed instruments and verified there was nc invalidation of IST test data.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Installed instrumentation is used in test procedures other than IST. Other test ,erocedures will be reviewed by March 31,1998, to identify installed instiumentation used to obtain data. The list will be used to determine notification requirements.

' An engineering expectation for Al-1700, " Conduct of Nuclear Engineering and Projects," will be developed to include guidance to assure that out of tolerance instruments are reviewed.

The expectation will include instructions to notify the appropriate SP owner if the installed instrument is used in sury)illance testing. Th:s action will be comp'eted by February 20,1998.

L. : . U. S. Nuclear Regulatory C::mmission 3F1297 Page 8 of 12 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance by March 31,1998; VIOLATION 50-302/9714-07 h 10 CFR 50, Appendix B, Criterion V, instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by docurnented inttructions, pro,:edures, or cirawings, of a type 8ppropriate to the circumstances and shall be accomplished in accordance with these instructionc.

Foreign Material Exclusion (FME) Control procedure, CP-116A, Section 4.0 provides the instructions for establishing an FME area. Section 4.1.1 directs the principle work group supervisor to refer to Enclosure 1, FME 1.ogic, as needed to determine if an FME area is

- required. - Enclosure 1 noted that if tocls/ materials can fit through the opening, then establish an FME area w;th controls as required per this procedure. Section 3.3.2 provides guidance for instaliing temporary closures for FME areas.

Contrary to the above, activities affecting quality were not accomplished in accordance with the documented instructions in that the principle work group supervisor failed to establisn an FME prea with controls, as required by CP 116A, when covers were removed from the *B" containment building spray pump motor, which provided an opening that would allow tools / materials to fit into the motor enclosure.

ADMIS0lON OR D_E_Nyt N OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation, REASON FOR THE VIOLATIOS The reason for the violation was a process weakness. Compliance Procedure CP-116A,

" Foreign Material Exclusion (FME) Control," did not contain sufficient instructions for establishing ebactive FME controls for electrical and instrument & Control (;&C) components and was written to imply FME controls were optional.

CORRECTIVE STEPS THAT HAVE BEEN "AKEN AND THE RESULTS ACHIEVED A chart labeled "10 Keys To A Successful FME Program was developed. This chart smphasizes the_importance of FME and creates an atmosphere of awareness. This chart was presented to the tour ma;ntenance shops (electrical, mechanical, l&C, and facility services) during moming

• tailgate" sessions. Maintenance shop personnel were encouraged to review in-progress work to determine whether adequate FME controls were in place.

The Maintenance Department developed a self study course on foreign material exclusion.  :

This document was reviewed by the Training Department and converted into an FPC lesson }

plan. This lesson plan includes a requi,ement to establish FME for electrical and l&C components.

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U. S. Nucle:r R:gulatory Commission 3F1297-37 Page 9 of 12 Training on the new FPC lesson plan for FME has been provided to maintenance personnel, including maintenance contractors.

CORRECTIVE STEPS THAT HAVE BEEN 1 AKEN TO AVOID FURTHER VIOLATIONS CP-116A has been revised to include specific instructions for establishing effective FME ccntrols for electrical and I&C components. Findings from FPC Self Assessment CRSA-97-17 (Foreign Material Exclusion) and a comparison to INPO Foreign Material Exclusion Program (MA-320) were considered in the development of this revision to CP-116A. Also, procedural language suggesting requirements were optional has been reviewed and removed, as appropriate.

DATE WHEN FULL COMPLIANCE WILL t3E ACHIEVED FPC has achieved full compliance.

VIOLATION 50-302/97 14-1.1, .

10 CFR 50, Appendix B, Criterion 111 reauires that applicable regulatory requirements and design basis are correctly translated into drawings, procedures and instructions.

Contrary to the above, an of Octeber 24,1997, the design bases were not correctly translated into drawings, procedure 3 and in.structions in that the thermal overload relays for safety related ECCS HPi valves MUV 23 and MUV-24 were set 'o manual reset instead of automatic reset as stated in the FSAR, Section 61.2.4.

ADMISSION OR DEUl@ OF THE ALLEGED VIOLATION Florida Power Corporation accepts the violation.

REASON FOR THE VIOLATION 1 The reason for the violation was personnel error. Overload relays were installed as part of a modification in 1979 that provided two sources of power '- valves MUV-23 and MUV-24. The FSAR statemcnt requiring ECCS electric motor operators to be provided with automatic

, overlorud reset was not considered in the development of the modification package. Also, plant drawings were not revised to reflect addition of the overload relays.

- CORRECTIVE a S,TEPt3 THAT HAVE _BEEN OR WILL BE_TAKEN AND THE RESULTS ACHIEVED

. Overload relays for valves MUV-23, 24, -25, and -26 have been set to the automatic reset position.

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! The actuators for valves MUV-23/24 arid MUV-25/26 are powered from Motor Control Centers (MCCs) MUMC-1 and MUMC 2, r;spectively. The drawings for these MCCs will be revised by

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March 31,1998, to include the overload relays and the settings of the overload relayr A _ __ _ _ - _ _ _ - _ _ _ __ ___ _ . _ _ - - _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ - -

. U. S. Nucle:r Regulatory Commission .

3F1297-37 Page 10 of 12 FPC will review and reset, as necessary, other ECCS motor operated valve overload relays to assure the correct setting is used. This action will be completed under the CR 312-week rolling work schedule process.

By March 31, 1998, FPC will review and reset, as necessary, the overload relays in other MCCs.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVO;D FURTHER VIOLAT!ONE The current process for modifying CR 3 prevents implementation of changes without determining whether the change creates a conflict with the FSAR. This process is describc d in Compliance Procedure CP-213," Preparation of a Safety Assessment and Unreviewed Safety Question Determination (10CFR50.59 Safety Evaluation)," and Nuclear Engineering Procedure NEP-210," Modification Approval Record." NEP-210 requires the performance of a SA/USOD per CP 213. Also, the conceptual design review process for modification approval reccrds at FPC, as described in NEP-202, " Preparation and Processing of Conceptual Designs and Design Wab; downs," requires a preliminary safety assessment to be performed to identify potential changes to the FSAR.

The current process for modifying CR-3 provides instructions for updating drawings. NEP-210 describes the structure of a MAR package and requires installation / Control Room drawings, sketches, and drawings to be as-built, to be licted in the MAR package. Also, NEP-271, "As-Building of Modification Approval Records, Commercial GraJe Work Requests, and PEEREs (Plant Equipment Equivalency Replacement Evaluation),' provides instructions for initiating final drawing revisions and ensuring revisions to other documents have been completed (e.g.,

FSAR, Instruction Manuals, Configuration Management Information System, Design Basis Documents, etc.). These instnictions ensure ' hat drawings impacted by a MAR are updated.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC will achieve full compliance by March 31,1998.

VIOLATION 50-302/97-14-13 6

10 CFR 50, Appendix B, Cr;terion XVI requires, in pr' nat measures shall be established to assure that conditions adverse to quality are promp' ientified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, as of October 24,1997, the configuration of Decay Heat Valves DHV-34 and DHV-35 were being maintained in the closed position during normal operation without an adequate safc'y evaluation to suppoit this configuration. Significant design weaknesses were being addressea by the licensee based on past problems and enforcement in this area; however, this NRC identified specific problem had not been identified by the licensee as part of past corrective actions.

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s U. S. Nuclear Regulat:ry Commission 3F1297-37.

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ADMISSION OR DENIAL OF THE ALLEGED VIOLAT!ON Florida Power Corporation accepts the violation.

REASON FOR THE VIOLATION The reason for the violation was an inadequate corrective action process. That process allowed broadly related iss'.es to be combined without consideration of the resulting complexity, did not enforce timely resolution cf corrective actions and did not provide an appropriate level of priority for resolving safety related design basis issues.

Problem Report (PR) 96-0401 was written to capture and address multiple issues with the documentation and administrative controls for the Appendix R Fire Study. PR 96-0401 included one other PR, six Precursor Cards and sevoial related issues and resulted in a complex PR. Adequate resources were not committed to resolution of this PR.

The investigation concerning the need for a Safety Assessment for DHV-34 and DHV-35 was included in this PR because the current normally closed position was a result of Appendix R analysis. The individuals responding to this PR were addressing Appendix R issues and were not sensitive to other design basis !ssues relat?d to these valves.

CORRECTIVE STEPS THAT HAVE BEEN OR WILL BE TAKEN AND THE RESULTS ACHIEVED A Safety Assessment /Unreviewed Safety Question Determination (SA/USQD) has been completed. An Unreviewed Safety Question (USQ) does exist for DHV-34 and DHV-35 in the normally closed position. An Operability Concems Resolution (OCR) with Justification for Continued Operation (JCO) has been completed and justifies operation with DHV-34 and DHV-35 in the norma!!y closed position.

A License Amendment Request will be submitted to %e NRC by February 27,1998, to propose changes to the CR 3 FSAR. This submittal will resolve the USQ involving the change in position of DHV-34 and DHV-35.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN TO AVOID FURTHER VIOLATIONS As part of the new corrective action process, CP-111 provides guidance for complex problems.

This guidance includes appropriate classification, development of root cause teams and inclusion of additional resources as required to provide necessary expertise. CP-111 specifically addresses the need to meet or extend due dates. The Corrective Action Review Board also provides additional management oversight of complex or significant issues and reviews corrective action plans to ensure those issues are resolved in a timely manner.

DATE WHE_N FULL COMPLIANCE WILL BE ACHIEVFD FPC will achieve full compliance when NRC approval is receivad for the License Amendment noted above.

t U. S. Nucle:r R:gul: tory Commission 3F1297-37 Page 12 of 12 ATTACHMENT 2 The following tablo contains a listing of commitments contained in this response:

-Section f:ommitment- Due_Date ~ ]

Page 3 Stem protectors will be fabricated and installed on the affected March 31,1998 Lim.orque sctuators.

Page 3 Mainterience Procedure MP 402-series (Limitorque valve operato'r' March 31,1998 malmenance) and Preventive Maintenance PM-178-series (Limitorque actuator inspection) procedures will be revised, as appropriate, to ensure stem protectors are reinstalled upon completion of actuator maintenance activities.

Page5 The revised testing of SP-407 will be completed prior to restart. January 15,1998 Page5 SP-457A will be revised to include testing of the transfer switches June 30,1998 which are used to supply back up power to the HPl injection valves upon loss of normal power. Each HPl injection valve will be stroked with normal and emergency power.

Page6 Calculation I-90-1017, "Roactor Vessel Level Instrument Loop J3nuary 31,1998 Tolerances,' will be revised to include compensation for fluid density (with boron) and temperature deviations between the tygon tubing and level transmitter reference leg fluids for RC-201 LT and RC-202-LT.

Page6 SP-195 will be revised to include the results of calculation 1 February 28,1998 1017 and vendor tolerances. Steps to adjust the zero potentiometer in order to match the tygon tube indication will be removed.

Page 7 Other test procedures wul be raviewed to identify installed March 31,1998 instrumentution used to obtain data.

Page 7 An engineering expectation for Al-1700, ' Conduct of Nuclear February 20,1938 Engineering and Projects," will be developed to include guidance to assure that out of tolerance instruments are reviewed. The expectation will include instructions to notify the appropriate SP owr.er if the installed instrument is used in surveillance testing.

Page 9 The drawings fnr these MCCs [MUMC-1 and MUMC-2] will be March 31,1998 revised to include the overload relays and the settings of the overload relays.

Page 10 FPC will review and reset, as necessary, other ECCS motor This action will be operated valve overload relays to assure the correct setting is completed under used, the CR-312-weet rol!ing work schedule process.

Page 10 FPC will review and reset, as necessary, the overload relays in March 31,1998 other MCCs.

Page 11 A License Amendment Request will be issued to the NRC to February 27,1998 propose changes to the CR 3 Final Safety Analysis Report (FSAR). This submittal will resolve the USQ involving the change in position of DHV 34 and DHV-35.

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