IR 05000206/1998019
| ML20198B529 | |
| Person / Time | |
|---|---|
| Site: | Point Beach, San Onofre  |
| Issue date: | 12/04/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198B527 | List: |
| References | |
| 50-266-98-19, 50-301-98-19, NUDOCS 9812210005 | |
| Download: ML20198B529 (26) | |
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U.S; NUCLEAR REGULATORY COMMISSION
! REGIONlli
i Docket Nos: 50-266;50-301 l License Nos: DPR-24; DPR-27 Report No: 50-266/98019(DRP); 50-301/98019(DRP)
l Licensee: Wisconsin Electric Power Company Facility: Point Beach Nuclear Plant, Units 1 & 2 Location: 6610 Nuclear Road Two Rivers, WI 54241 Dates: October 6 through Novensber 20,1998
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inspectors: F. Brown, Senior Resident inspector P. Louden, Resident inspector P. Simpson, Resident inspector Approved by: B. Burgess, Chief Reactor Projects Branch 7 l-I k
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e 9812210005 981204
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gDR ADOCK 05000266 PDR
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k EXECUTIVE SUMMARY Point Beach Nuclear Plant, Units 1 & 2 Inspection Report 50-266/98019(DRP); 50-301/98019(DRP) !
i This inspection included aspects of licensee operations, engineering, maintenance, and plant !
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support. The report covers a 6-week inspection period by the resident inspector Operations
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The inspectors concluded that safety systems in the Unit 2 containment were in good l condition. The briefing conducted prior to a containment entry exhibited weaknesses I including: a lack of clearly defined leadership roles, the radiation protection organization was not adequately prepared for the entry, no contingency plans were discussed, and l no actions in the event of an emergency or evacuation alarm were discussed. However,
the actual containment inspection was performed in a deliberate and thorough manne (Section O2.2)
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The licensee issued new procedure use guidance for operations department personne I The inspectors had several questions regarding the appropriateness of the lice.nsee's implementation of the new procedure that will be reviewed as an Unresolved ite (Section O3.1)
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The licensee's training plans were determined to be robust in terms of preparing control room operators for the transition to an 18-month operating cycle. In addition, the incorporation of applicable industry feedback and operating experience into the licensed operator requalification training development plans was considered a positive programmatic aspect. (Section 05.1)
Maintenance -
. Multiple and/or repetitive failures of nonsafety-related equipment caused planned and unplanned reactor power changes. Specific problematic equipment included instrument air compressors, a steam generator feed pump, and the Unit 2 auxiliary transforme These failures created unnecessary challenges to control room operators, often resulted in significant impacts on the work scheduling process, and required maintenance personnel to re-allocate resources to address emergent work items. (Section M2.1)
. Vendor and industry recommendations for preventive maintenance had not been implemented or identified for all safety-related equipment or nonsafety-related
, equipment with high failure rates. (Section M2.2) l
. Appropriately, the licensee used industry data in lieu of poor quality plant-specific data in an evaluation of equipment failure histories performed in support of the transition to an 18-month operating cycle. (Section M3.1)
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The inspectors reviewed the past deficiencies in the licensee's American Society of Mechanical Engineers Code,Section XI pressure test program and the status of t corrective actions. The review indicated that the licensee had identified numerous
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them. Pending review by the inspectors of the corrective actions, this will remain open as an apparent violation. (Section E1.2)
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The licensee effectively implemented the recent Technical Specification change from a 12-month to an 18-month fuel cycle. The effects of the changes on the operational performance of the containment spray system and the new and spent fuel storage areas were appropriately considered by the licensee. (Section E2.1)
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The licensee effectively used the quality assurance surveillance process to evaluate the progress and readiness of the 18-month fuel cycle project. The surveillance identified weaknesses in the project requiring resolution to ensure timely and effective
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implementation of the extended 18-month fuel cycle. (Section E7.1)
Plant Support
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There were no significant plant support findings during this inspection period.
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Report Details Summary of Plant Status Both Units operated at 100 percent power until October 23,1998, when Unit 2 was taken offline i to address emergent concerns with the 345/13.8 kilovolt main transformer. Unit 2 was returned i to 98 percent power following the removal of the main transformer from service. On l October 30,1998, the Unit 2 reactor started an end-of-iife power coast down towards a December 5,1998, scheduled refueling outage. On November 14,1998, Unit 1 experienced a failure of the "A" steam generator feed pump forcing a rapid reduction from 100 percent to 45 percent power. The inspection period ended with Unit 1 at 50 percent power while the "A" steam generator feed pump was repaired.
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I. ODerations 01 Conduct of Operations 01.1 General Comments (Inspection Procedure (IP) 71707)
The inspectors conducted frequent reviews of ongoing plant operations, including Unit 1 and Unit 2 control room shift turnovers and other routine control room activities. No me or problems were identifie .2 L 1 "A" Steam Generator Feed Pumo Failure (IP 93702)
O November 14,1998, Unit 1 control room operators received a high temperature alarm on the outboard bearing of the "A" steam generator feed pump. Operators investigated the cause of the alarm and observed that the outboard pump bearing was glowing red and extremely hot to the touch. In response, control room operators began a rapid load reduction from 100 percent power. Two minutes later, the outboard pump bearing catastrophically failed and an oil mist and a small fire issued from the bearing housing. Auxiliary operators extinguished the fire within one minute. The control room operators tripped the "A" steam generator feed pump and stabilized reactor power at 45 percent. The inspectors responded to the event and verified Unit 1 was stable and no immediate safety issues existed. The licensee formed a multi-disciplined team to investigate the incident. The invest!gation included a review of the plant equipment response, the operators' response, and plant management's response to the even The root cause team's efforts, as well as the repairs to the "A" steam generator feed pump, were ongoing at the end of the inspection perio O2 Operational Status of Facilities and Equipment O2.1 General Comments (IP 71707)
During frequent plant tours, the inspectors observed generally acceptable l housekeeping. The inspectors noted that some plant equipment, such as instrument
, transmitters and valve stems, were being used as coat hooks and that the Unit 1 and
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l Unit 2 "A" and "B" safety injection (SI) pumps were not being kept clean of oil from leaks l
or boric acid buildup. The inspectors discussed these observations with plant i management who agreed that station cleanliness expectations had not been met.
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Following the discussion, short-term improvements were note .2 Unit 2 at Power Containment inspection Inspection Scope (IP 71707)
l On October 29,1998, the inspectors accompanied licensee personnel into the Unit 2 containment to perform a routine walkdown of containment safety system ;
1 Observations and Findinas The inspectors attended the pre-job briefing for the containment entry. The beginning of the briefing was delayed due to the tardiness of several key members of the entry group. The briefing was further delayed because of the limited availability of
" ready-to-use" neutrons dosimeters. The decision was made to continue witn the briefing and the dosimeter issue was eventually resolve Although a senior reactor operator discussed operational aspects of the entry and a radiation protection (RP) supervisor discussed radiological conditions and ensured that the teams of personnel entering containment were matched with dedicated RP technicians, the overall conduct of the briefing was somewhat disorganized and no group or organization was clearly in charge of the activity. In addition, the inspectors noted that the briefing did not include a discussion on contingencies, response to containment alarms, or alternate emergency egress points from the containment in the event of an emergenc The actual containment inspection was performed in a methodical and thorough manner. Operations personnel efficiently performed routine and non-routine inspection activities in the containment with appropriate considerations for dose rates in high radiation areas. The inspectors noted that safety systems within the Unit 2 containment were in good condition and no significant active leaks were identifie Conclusions The inspectors concluded that safety systems in the Unit 2 containment were in good condition. The briefing conducted prior to a containment entry exhibited weaknesses including: a lack of clearly defined leadership roles, the radiation protection organization was not adequately prepared for the entry, no contingency plans were discussed, and no actions in the event of an emergency or evacuation alarm were discussed. However, the actual containment inspection was performed in a deliberate and thorough manne . . . .--
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l 03 Operations Procedures and Documentation 03.1 Review of Operations Department Procedure Adherence Standards Inspection Scope (IP 71707)
l The inspectors continued an ongoing review of the licensee's standards and guidelines on procedure use and adherence, Observations and Findinas
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The need for additional inspector attention in this area was documented in Inspection
- Follow-up item (IFI) 50-266/97020-02; 50-301/97020-02 issued in October 1997. The
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intent was to evaluate the licensee's ongoing procedure upgrade program relative to the following:
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upper tier administrative procedures for procedure adherence and procedural controls are consistent with the current licensing basis and NRC guidance;
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the methods for establishing procedural controls, which are commensurate with licensee staff training and supervisory oversight, such that activities affecting safety are performed in a controlled manner with predictable results; and
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the process of assuring that work plans are not used to circumvent procedure change requirements.
l The licensee's procedural use and adherence performance has been discussed in several reports since this IFl was opened. For instance,
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Violation (VIO) 50-266/97026-01(DRP); 50-301/97026-01(DRP) documented that
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operators had been granted inappropriate blanket authorization to deviate from l abnormal and emergency operating procedures. Section O3.1 of Inspection Report (IR) 50-266/98006(DRP); 50-301/98006(DRP) documented the slow development of a proposed procedure upgrade program; however, a trend of improved procedural content and adherence was also documented at that time. Section O3.1 of IR 50-266/98017(DRP); 50-301/98017(DRP) documented an occurrence where
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operators manipulated nonsafety-related plant equipment in a manner outside of its i
intended design functio Licensee Procedure Adherence Guidance During this inspection period, the inspectors completed a review of Operations l
. Manual (OM) Procedure 1.4, Use of Operations Group Procedures and Work Plans,"
l Revision 0, issued August 7,1998. The purpose of OM 1.4 was, in part, to allow the l partial performance of operating procedures and the non-performance of steps in operating procedures by the use of "N/A" (not applicable) annotations, when equipment or plant conditions were different than had been assumed when the operating procedure
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was prepared, reviewed, and approved. The use of partial procedures or N/A for steps was not considered to be a procedure change. Procedure OM 1.4 specified that the use of N/A and partial procedure performance were not authorized if their use would result in undesirable conditions or changes to the intent of the operating procedures. Examples of the undesirable conditions which were to be avoided included: (1) failure to establish proper conditions for performing a test; (2) operation or manipulation of equipment in a manner inconsistent with the equipment's design or function; and (3) creation of a previously unevaluated equipment or personnel safety concer Procedure OM 1.4 also contained guidance on when a procedure was required for performance of work. Attachment A of OM 1.4 indicated that procedures were not required for " skill-of-the-craft" activities as " defined via Systematic Approach to Training." This guidance applied to safety . elated and nonsafety-related activitie Inspector Observations The inspectors discussed the content of OM 1.4 with station management. The plant manager and his staff indicated that the controls of OM 1.4 were based on industry guidance and were similar to, or more conservative than, comparable controls at other nuclear plants. The plant staff provided numerous examples of the intended use of N/A and partial procedure performance. Each example was reasonable and none represented potential safety concerns. The plant staff acknowledged that operations department supervisors had been determining " skill-of-the-craft" based upon perceived task complexity and on-the-job trainin Notwithstanding plant staff's stated conservative intentions and the reasonableness of the intended use of the OM 1.4 guidance on N/As, partial procedure adherence, and the use of " skill-of-the-craft," the inspectors questioned whether the implementation of these concepts was consistent with the intent of American National Standards Institute (ANSI)
Standard N18.7, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."
The inspectors will treat the procedure adherence issue as an Unresolved Item ((URI) 50-266/98019-01(DRP); 50-301/98049-01(DRP)) pending additional review by the Nuclear Regulatory Commission. Specifically, this review will consider the requirements for the reviewer of a procedure change, what level of changes involve changes of intent, what training level defines " skill of the craft," and the use of N/A for procedural steps.
c. Conclusions The licensee issued new procedure use guidance for operations department personne The inspectors had several questions regarding the appropriateness of the licensee's implementation of the new procedure that will be reviewed as an Unresolved Ite . . - . .- . -- -- - - -- _ - - . . _ .
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l 05 Operator Training and Qualifications 0 Month Operatino Cvele Operator Trainina l
~ inspection Scope (IP 71707)
i The licensee intended to load an 18-month core into Unit 2 during its twenty-third l refueling outage scheduled to begin December 5,1998. Previously, Unit 2 operated
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using cores designed for 12-month operating cycles. The inspectors interviewed the
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licensed operator requalification training supervisor and the control room simulator support staff to determine how the training department had addressed the operating cycle length chang Observations and Findinas l
The licensee planned a control room simulator outage for December 1998, to install the new Unit 2 core model since significant differences were expected between the current 12-month core model and the 18-month core model. The exact changes would not be known until late November 1998, when the reload fuel vendor supplied the control room simulator core model and design report. Licensee staff stated that licensed operator requalification training Cycls 99-01, scheduled to start in January 1999 and end prior to Unit 2 startup from Refueling Outage 23, would provide all of the operating crews with
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both simulator and classroom training on the Unit 218-month core. The classroom training would cover reactor theory, operating procedure changes, core characteristic changes, and appropriate industry experience. The control room simulator training would consist of startup and pertinent transient scenarios using the Unit 218-month core mode Conclusions The licensee's training plans were determined to be robust in terms of preparing control room operators for the transition to an 18-month operating cycle. In addition, the incorporation of applicable industry feedback and operating experience into the licensed operator requalification training development plans was considered a positive programmatic aspec '
07 Quality Assurance (QA)in Operations I
07.1 Indeoendent Audit of QA Proaram (IPs 71707 & 40500)
The Off-Site Review Committee (OSRC) conducted a biennial audit of the QA l organization as documented in Audit Report A-SP-98-01, dated September 24,1998.
l Technical Specification 15.6.5.2.8, " Audits," required the OSRC to perform this audi The audit, in part, examined the effectiveness of the QA organization's audit program l
and its ability to effect change in the performance of plant activities encompassed by l 10 CFR Part 50, Appendix B. The OSRC auditors concluded that the QA organization, l through the audit process, could effect change and have a positive effect on the identification and correction of deficiencies. However, the OSRC auditors observed that
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the deficiencies identified in QA audits, in some instances, were not aggressively pursued by the QA organization to determine the potential effects on plant equipment or operations. The licensee initiated Quality Condition Report (QCR) 98-0287 to address .
this observation. In addition, the inspectors noted that findings from previous OSRC i audits were adequately corrected and no significant repeat problems were identifie The inspectors reviewed Audit Report A-SP-98-01 and concluded that its findings were consistent with previous inspection findings and plant performance. The licensee had several ongoing initiatives to improve the performance of the QA organization. The OSRC audit appeared to be very thorough and detailed. See Section M3.1 of this report for inspector observations on OA performance of an audi .2 Institute of Nuclear Power Operations Plant Assessment The inspectors reviewed the 1998 plant evaluation. The evaluation did not identify any significant issues that were not already documented by the NR Miscellaneous Operations issues 0 (Closed) IFl 50-266/96019-02(DRP): 50-301/96019-02(DRP): Followup on licensee commitment to formalize a program to periodically assess control room conduct. This l item was initiated to followup on a licensee commitment made in response to Confirmatory Action Letter No. Rill-96-012. A formal operations department assessment program was developed and administered through Procedure OM 6.1,
" Performance Assessment Program." This program included requirements for each operations crew and off-shift licensed operators to perform a minimum number of crew and peer assessments per quarter. As of September 2,1998,202 self-assessments had been performed by the crews in areas such as alarm response, communications, command and control, and danger (equipment) tagging. Operations department managers reviewed the results of the assessments monthly to identify any negatively trending performance areas. The inspectors concluded that the licensee was effectively implementing the commitment for a self-assessment progra .2 (Closed) Licensee Evert Reoort (LER) 50-266/97010-00 & -01: Service Water and Component Cooling Water T/S Action Requirements Not Met. This event was discussed in IR 50-266/97003(DRP); 50-301/97003(DRP) Section 08.1. No new issues were revealed by the LE .3 (Closed) LER 50-266/97029: 50-301/97029: SI Accumulators isolated During Plant Startup; Procedure in Violation Of T/S. On April 23,1997, the licensee discovered that an operating procedure allowed the isolation of the Sl accumulators during plant startup when primary system pressure exceeded 1000 pounds per square inch gauge, a condition prohibited by T/S 15.3.3.A.1.h. The licensee in the LER committed to correct the applicable procedure and determine if a T/S clarification was necessary. The inspectors verified Operating Procedure - 1 A, " Cold Shutdown To Approach To Criticality," Revision 58, corrected the reported problem and required the accumulators be operable prior to exceeding 1000 pounds per square inch gauge. The licensee determined that the wording of T/S 15.3.3.A.1 was ambiguous, but decided it did not
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warrant changing until the planned conversion to improved standard T/S. The inspectors determined that the licensee's corrective actions were adequate and that there was no violation of NRC requirement II. Maintenance M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Multiole Failures of Some Plant Eauioment Inspection Scope flP 62707)
The inspectors reviewed several plant material condition issue Observations and Findinos The failures of some secondary side plant equipment led to unplanned changes in the ,
unit's power level. The plant experienced the following degradation or failures of l nonsafety-related equipment during this perio I I
Unit 2 Auxiliary Transformer: The transformer had to be removed from service because ;
of_the internal build-up of explosive gasses. The gasses were generated by arcing i between the transformer core and a conductive strap which had apparently been bent l during maintenance activities in the previous outage, Station Air and Instrument Air Comoressors: Nonsafety-related air compressors were rendered inoperable by repetitive failures of unloading valves and by multiple failures of system pressure boundary piping. Initiallicensee investigation of the unloading valve
' failure identified potential engineering and maintenance practice problem Unit 1 SGFP: The Unit 1 "A" SGFP failed while operating shortly after the replacement of an incorrect impeller, which had been installed during the previous refueling outag Conclusions Multiple and, in one case, repetitive failures of balance-of-plant equipment caused planned ana unplanned power changes. These failures created unnecessary challenges to control room operators, often resulted in significant impacts on the work scheduling process, and required maintenance personnel to re-allocate resources to address emergent work item *
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M3 Maintenance Procedures and Documentation M3.1 Eauioment Histories and the 18-Month Ooeratina Cvele Project Insoection Scope (IP 62707)
The inspectors reviewed the licensee's documentation supporting the change to an 18-month operating cycl Observations and Findinas The licensee's 18-month fuel cycle project plan stated that non-T/S equipment histories would be reviewed to ensure that the extended operating cycle would not introduce a safety hazard. A report titled " Review of Operation's Maintenance and Surveillance Testing Callup's for the Transition to a Nominal Eighteen Month Refueling Cycle," dated June 1,1998, was referenced as completing this project plan item. This report stated that extending preventive maintenance frequencies in support of an 18-month operating cycle would not introduce a safety hazard " based on the review of the surveillance testing history."
The licensee's QA organization completed an assessment of the 18-month operating cycle project (see Section E7.1). The QA assessment reached the following conclusion concerning the June 1,1998, report: "the reviews that were completed were thorough and provided adequate justification on which the basis to extend the cycle of testing was established."
The inspectors also reviewed the documentation upon which the conclusions in the June 1,1998, report were based. After extensive discussion with cognizant licensee personnel and a review of project records, the inspectors concluded that there was no evidence that plant specific data more recent than that used for the 1990 Plant Specific Assessment had been used when preparing the June 1,1998, report. When questioned about this apparent discrepancy, licensee staff stated that the plant's historical records of nonsafety-related equipment failures were not of high quality. These personnel stated that ine June 1,1998, report assessment of equipment failure histories was most likely based on industry experience (used in compiling the CMPs) rather than recent site specific data. The use of industry data in lieu of poor quality plant-specific data to perform the evaluation was considered appropriate by the inspector The inspectors were concerned that the June 1,1998, report used wording that did not account for the data actually used to compile the test histories. The inspectors were also concerned that the QA assessment of this report failed to identify this apparent discrepancy. This observation was discussed with the quality assurance manager, who stated that QA assessments were intended to look not only at the conclusions of audited reports, but also the basis for those conclusions. In addition, he stated that this issue would be reviewed with QA personne . - . .. -. .
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l Conclusions Appropriately, the licensee used industry data in lieu of poor quality plant-specific data in
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an evaluation of equipment failure histories performed in support of the transition to an 18-month operating cycle.
l M8 Miscellaneous Maintenance issues l
l M8.1 (Closed) LER 50-266/97003: 50-301/97003: Spare Containment Penetrations Not Leak i Tested in Accordance With T/S. On January 9,1997, the licensee identified that two l spare containment penetrations (per unit) were not being tested in accordance with ,
i T/S 15.4.4, " Containment Tests." Test procedures were revised to include these penetrations and the penetrations were subsequently tested with satisfactory result Given that the integrity of these penetrations was tested annually during the containment integrated leak test, the safety significance of this problem was minor. As such, the failure to test the two spare penetrations as required by T/S 15.4.4 is considered a violation of minor significance and not subject to formal enforcement actio M8.2 (Closed) LER 50-266/97038: 50-301/97038: Standby Emergency Power inoperable in Excess of T/S Allowed Outage Time. On September 3,1997, Emergency Diesel Generator G-03 failed to start during performance of a surveillance test. Subsequent licensee investigation determined that G-03 had been inoperable because of a failure in the engine governor since August 18,1997, the date of its last operation. The licensee l repaired the engine governor and successfully retested G-03 restoring it to an operable status. The inspectors reviewed Root Cause Evaluation 97-094, committed to be performed in the LER, and found it to be acceptab!e with recommended corrective actions being addressed by Condition Report (CR) 97-2665.
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I E1 Conduct of Engineering E Emeraency Core Coolina System (ECCS) Leakaae (IP 37551)
During a routine walkdown of the Unit 1 SI system, the inspectors noted the Unit 1 "A" SI pump manual discharge isolation valve (1SI-888A) had been identified by the licensee as having a packing leak. Valve 1SI-888A is part of the outside containment
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ECCS recirculation flow path. The inspectors reviewed Final Safety Analysis Report l (FSAR) Section 14.3.5, " Radiological Consequences Of Loss Of Coolant Accident,"
l which documented the assumptions of 400 and 800 cubic centimeter per minute I leakage from ECCS equipment in post-accident dose calculations for the control room
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and offsite, respectively. In addition, the inspectors reviewed FSAR Section 6.2.4,
" Required Procedures and Tests," which described the licensee's testing and monitoring program for assuring that ECCS leakage assumptions of the radiological analyses remained vali l l
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The inspectors questioned the licensee's Leakage Reduction and Preventive Maintenance (LRPM) pregram engineer on how leakage identified outside of a planned inservice test was captured by the LRPM program. The engineer stated that no feedback method existed other than the periodic system engineer walkdowns or LPM engineer reviews performed after surveillance tests. The inspectors questioned whether the ECCS components identified outside of the normal LRPM feedback methods as leaking, such as the 1SI-888A, could be unaccounted for in the licensee's LRPM cumulative ECCS leakage log and thereby resulting in leakage exceeding the leakage assumed in dose calculations. The inspectors discussed this issue with the LRPM engineer and plan + management who agreed it was a valid concern and would be
. addressed in the LRPM program revision that was currently in progres Ei.2 American Societ" of Mechanical Enaineers (ASME)Section XI Pressure Test Proaram (PTP) Issues i Inspection Scope OP 37551)
The inspectors reviewed the implementation of the licensee's ASME Section XI PTP and associated corrective action documents.
, Observations and Findinos i The inspectors noted during a routine review of CRs that CR 98-3574, initiated on 1 October 5,1998, implied that the Unit 1 PTP did not comply with the requirements of ASME Section XI. The licensee evaluated the issues identified in CR 98-3574 and identified no immediate safety concerns. The inspectors also evaluated CR 98-3574 and concluded that no immediate safety concerns existed, but noted that the quality of the licensee's PTP test result documentation was poo The inspectors compiled the following document time line of PTP-related deficiencies ,
and corrective actions. The time line indicated that the licensee i ;d failed to estabh0h a I fully compliant PTP even after repeated indications that the PTP was deficien '
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- On December 7,1992, CR 92-823 documented numerous discrepancies following a contractor review in July 1992 of the Unit 1 PTP for the second l inspection interval. The discrepancies indicated that the PTP was inadequate with respect to ASME Section T requirements. Corrective actions consisted of dispositioning the inconsistencies in the second interval test documentation and the development of a formal PTP document with assigned responsibilities for implementation of the third interva On August 7,1996, the licensee documented the results of a seif assessment (S-A-96-06) of several ASME Section XI engineering programs, including the
, PTP. The assessment made the following conclusions:
- The scope, purpose, and basis cf the PTP was not adequately addresse ,
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A general misunderstanding existed among the licensee's staff of the specific requirements of ASME Section XI testin On September 16,1996, CR 96-0840 documented that eight required pressure tests were not in the PTP and six other tests which had been scheduled but not performed. In response, the licensee narrowly focused corrective action by revising the third interval PTP document on February 13,1998, to include the eight pressure test July 31,1997, was the end of the second 40-month period of Unit 1 third interva At that time, the waste gas system reached the end of the 40-month period in which it should have been tested. This system was identified ten months earlier in CR 96-0840 as having exceeded its regularly scheduled test date. The waste gas system was not tested until January 3,199 On September 12,1997, CR 97-2850 was written to document inadequate coordination of PTP testing. Corrective action completed in November 1997, included establishment of a test director position responsible for coordinating performance of pressure tests. As of October 23,1998, the corrective action to perform a complete review of the PTP, including the existing test precedures, to ensure all ASME Section XI pressure test requirements were identified and implemented had not been starte On October 24,1997, CR 97-3517 documented that the Authorized Nuclear Insurer inspector reviewed the PTP and found it unsatisfactory. The licensee closed out this CR without any further action to the previously identified corrective actions for CR 97-2850 and Root Cause Evaluation (RCE)97-012 On October 31,1997, CR 97-3593 was written to document that a relief request was being used to exclude certain piping from the PTP; however, the request had not been submitted to or approved by the NRC for use by the license l Identified corrective actions included performing RCE 97-0123 and submitting a relief request to the NR On November 4,1997, CR 97-3729 identified that 16 40-month pressure tests required by ASME Section XI, were not identified as required by the PT Engineering personnel performed an operability determination that concluded the affected systems were operable but degraded based upe ~ :her periodic surveillance tests conducted on those systems. The the derval PTP document was revised on February 13,1998, to reflect these addroonal system pressure ,
test On January 2,1998, CR 98-0014 was written documenting that five 40-month pressure tests listed in CR 97-3730 were not conducted as required within the ,
required frequency and by the last completion date. Completed corrective actions included submittal of an LER and performance of RCE 98-00 On February 2,1998, the licensee submitted LER 50-266/98001; 50-301/98001 reporting the condition identified in CR 98-0014 as missed surveil!ances. The
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cause of the missed surveillances was an inadequate procedure. This issue was inadvertently dispositioned twice as NCV 50-266/97026-04(DRP);
50-301/97026-04(DRP) and NCV 50-266/98014-05(DRP);
50-301/98014-05(DRP) of T/S 15.4.2.B.1. The duplicate ;
NCV 50-266/98014-05(DRP); 50-301/98014-05(DRP) is retracte ,
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From March 16 to April 16,1998, QA personnei conducted an audit (A-P-98-02)
of the ASME Section XIin-service inspection and repair / replacement program l The audit team determined that, overall, the ASME Section XI programs were !
marginally effective and required additional management attention. This was conclusion was based on the following:
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inadequate management support for ASME examinations and tests,
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fragmented involvement of numerous site groups combined with a lack of
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lack of resources to ensure programs, procedures, and databases were
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inadequate training and understanding of ASME requirements, l
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lack of overall procedural guidance required to implement program '
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insufficient program monitoring, feedback, and performance evaluation.
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The auditors categorized the ASME Section XI program findings as a QA l program significant issue to ensure the proper level of management attention i was focused to correct the deficiencies. On April 3,1998, RCE 97-0123 was completed and evaluated why engineering
- programs related to ASME Section XI testing failed to adequately perform. The RCE concluded that " .. inadequate management attention to these programs and '
program owners. The resultir.g rapid succession of personnelled to unrecoverable knowledge losses and a lack of program improvement over tim There has never been a commitment by management to establish a strong program or organization based on a good knowledge and industry experience base." Recommended corrective actions related to the PT P such as to provide training and develop strong written program documents were tracked by QCR 97-0148, but had not yet been started as of October 23,199 On April 23,1998, the evaluation of the missed pressure tests reported in CR 98-0014 and LER 266/98-001 were documented in RCE 98-001. The licensee identified that the same problems identified in the 1996 self-assessment still existed, that is, the PTP was weak in detail, scope, and verification. The program design had not improved despite indications the PTP was weak. The RCE concluded there was a lack of engineering management commitment to the PTP and inadequate program monitoring and management. Recommended corrective actions included developing a clear mission statement and goals for the PTP, developing a PTP performance monitoring system, establishing lines of authority and communication for PTP implementation, and developing a project plan to guide the PTP get well effort. The inspectors reviewed the status of the
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RCE 98-001 corrective actions and determined that as of October 23,1998, no work had started other than to either reassign the responsibility for the corrective I actions or to extend the due dat I
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l On April 29,1998, the licensee submitted LER 50-266/98012; 50-301/98012 l reporting the condition identified in CR 97-3593 as missed T/S surveillance The cause of the missed surveillances was attributed to inadequate PTP
,
monitoring and management that resulted in using relief request provisions prior l to approval by the NRC. As part of the corrective action for this LER, the licensee committed to implement the recommendations contained in (
RCE 98-001. This LER was closed and dispositioned in Section E8.5 of l
IR 50-266/98009(CRP); 50-301/98009(DRP) as an '
NCV (50-266/98009-05(DRP); 50-301/98009-05(DRP)).
The inspectors reviewed the results of a recent pressure test (Work Order l Number 9813677) completed on October 16,1998, and the associated inservice Test Procedure (IT)-1030, "40-Month Pressure Test Of The Spent Fuel Cooling System," l Revision 1. The test results documented that the test coordinator had identified the i spent fuel storage pool (SFSP) was equipped with a leakage collection system j previously unexamined as part of the ASME XI PTP. The licensee documented this '
self-identified finding in CR 98-374 Technical Specification 15.4.2.B.1 requires, in part, that inservice inspection of l ASME Coce Class 1, Class 2, and Class 3 components be performed in accordance I with Section XI of the ASME Boiler and Pressure Vessel Code and appycable Addend l
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ASME Code,1986 Edition, no Addenda (the Code version implemented by the licensee),
Section XI, Table IWD-2500-1, Category D-C, requires a VT-2 visualinspection of the pressure retaining boundary of the SFSP each inspection period. ASME Code, 1986 Edition, no Addenda,Section XI, paragraph IWA-5243, " Components With Leakage Collection Systems," requires, in part, that where leakages from components !
are normally expected and collected, the visual examination VT-2 shall be conducted by verifying that the leakage collection system is operative, Contrary to these requirements, the inspectors determined that prior to October 16,1998, the licensee failed to perform an adequate VT-2 visual examination of the pressure retaining boundary of the SFSP common for both Units 1 and 2 during each Code inspection period. Specifically, the VT-2 visual examination performed failed to verify the absence of leakage from the SFSP liner, an ASME Code Ciass 3 pressure retaining boundary, as monitored and collected by the SFSP poo! leakage collection system. Further, the VT-2 visual examination failed to verify that the sptem was operative. At the end of the inspection report period, the licensee's proposed corrective actions were still being formulated. The inspectors will review and document the licensee's evaluation and proposed corrective actions in a subsequent report. This issue, the failure to adequately complete the Code VT-2 visual examination of the Units 1 and 2 SFSP, may represent a violation of T/S 15.4.2.B.1 and will remain open as an example of an apparent violation for a reasonable time to allow the licensee to develop its corrective actions (eel 50-266/98019-02a(DRP); 50-301/98019-02a(DRP)).
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On October 30,1998, QA personnel reviewed the same pressure test and IT-1030 l results that the inspectors reviewed and documented their findings in Work Monitoring Report 98-0234. Several CRs and QCRs were wftten as a results of these finding The inspectors observed the conditions in CRs 98-3744 and 98-3769 were both identified as being discovered several days or weeks prior to the CRs being initiate The inspectors discussed this observation with plant managemen On November 13,1998, the licensee identified that three Unit 1 pressure tests had not been performed within the required ASME Section XI frequency. The following systems <
were affected (only the portions of piping outside containment): main steam, component cooling water, and chemical and volume control. Since the licensee could not complete the missed tests within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed by T/S 15.4.0, the licensee requested enforcement discretion, to avoid shutting Unit 1 down, in letter NPL 98-0964, dated November 13,1998. Region ll1 management reviewed the request and, because of the low safety significance of the missed tests and the low risk, exercised enforcement discretion. The required pressure tests were comple;ed satisfactorily on November 14,199 ASME Code,1986 Edition no Addenda,Section XI, Parag.uph IWA-2430, " Inspection Intervals," requires, in part, that system pressure tests be completed during each of the l inspection intervals for the service lifetime of the power unit. Contrary to the above, the i licensee identified, as of November 13,1998, certain Ifnit 1 systems had not been inspected within the frequency specified by the ASME Section XI Code. Specifically, the licensee failed to complete the Code system pressure tests during the second ;
inspection period which ended on July 31,1997, for portions of the piping outside containment for the main steam, component cooling water and chemical and volume control Unit i systems. At the end of the inspection report period, the licensee's proposed corrective actions were still being formulated. The inspectors will review and i document the licensee's evaluation and proposed corrective actions in a subsequent report. This issue, the failure to perform the required tests, may represent a violation of T/S 15.4.2.B.1 which requires the systems be bspected as specified by the ASME Section XI Code and will remain open as an exLmple of an apparent violation for a reasonable time to allow the licensee to develop its corrective actions ;
(eel 50-266/98019-02b(DRP)).
The inspectors, after having reviewed previously identified and documented PTP deficiencies and the status of the resultant licensee corrective actions, concluded that l I
the licensee hao not effectively corrected programmatic deficiencies regarding the ASME Section XI pressure testing requirements. The licensee repeatedly identified a variety of PTP deficiencies, sometimes repetitively, over the course of several years without fully resolving them. This concerned the inspectors since a failure to properly l implement the ASME Section XI requirements could result in an increased risk for !
pressure boundary leakage or failure at power, which would challenge plant operators l and/or plant engineered safety features. As of the end of the inspection period, the
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licensee informed the inspectors that a draft PTP program plan had been prepare .. . ._. .
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, Conclusions l
The inspectors reviewed the past deficiencies in the licensee's American Society of Mechanical Engineers Code Section XI pressure test program and the status of corrective actions.- The review indicated that the licensee had identified numerous
!
deficiencies in the pressure test program but had not effectively addressed many of
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them. Pending review by the inspectors of the corrective actions, this will remain open as an apparent violatio E2 Engineering Support of Facilities and Equipment E2.1 ' Licensee's Preoaredness For 18-Month Fuel Cycles Inspection Scope (IP 37551)
The inspectors reviewed the licensing changes necessary for the extended fuel cycles and verified that the approved current licensing basis reflected the changes. The following documents were referenced during this review:
. T/S amendment request Numbers 179 and 183 issued on September 4,1997, a T/S amendment request Numbers 180 and 184 issued on September 23,1997,
. T/S amendment request Number 190 issued on July 21,1998,
. Environmental impact assessment for the fuel enrichment effects for the spent fuel pool dated August 7,1997, and a Point Beach Cycle 24 Fuel Loading Plan dated October 1,199 Observations and Findinas ,
Operatina Parameter Chances The inspectors verified that docketed changes were currently reflected in the T/Ss. The T/S changes involved operating parameter changes relative to the boron concentrations for the refueling water storage tank and Si accumulator volumes. The refueling water storage tank boron concentration requirements for critical and supercritical reactor conditions were changed from 24,100 gallons of 2000 parts per million (ppm) to 26,600 gallons of 2700 ppm. The Si accumulator boron concentration requirements were changed from 2000 ppm to 2600 ppm. The inspectors verified that these changes were implemented in accordance with T/S amendment number 180 and 184 issued on September 23,199 Extended Fuel Cvele Effects on Containment Sorav System Performance l
- The inspectors reviewed the effects that the extended fuel cycle would have on the operational performance of the containment spray system. The higher enriched fuel (
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would require higher boron concentrations for boron injection flow paths. This higher ;
acidic concentration would result in a slightly lower pH for the water accumulated in the l containment sump following a loss of coolant accident. One of the functions of the containment spray system is to provide for pH control for the containment sump wate This is accomplished by injecting sodium hydroxide via an eductor arrangement into the l containment spray normal flow path. The current analyzed containment sump pH ranged between 7.5 and 9.0. The licensee had calculated (Calculation Number 97-0021) that the increased boron concentration had a slight effect on the i resulting pH while maintaining current sodium hydroxide injection parameters. The re-calculated pH band was estab'ished as 7.0 to 10.0. The licensee planned to include this analysis in a 10 CFR 50.59 safety evaluation which was scheduled to be completed near the end of November 1998. These pH parameters would then be revised in the applicable sections of the FSAR. The inspectors determined that tne licensee had appropriately addressed the effects that the higher enriched fuel would have on the operational performance of the containment spray syste l Effects of Increased Fuel Enrichment on SFSP Nuclear fuel changes necessary to support the change to 18-month cycles involved the I use of fuel enriched to higher percentages of uranium-235 (U-235). The previous licensing basis limited U-235 weight percentages to 4.0 and 4.75 for standard and optimized fuel assemblies, respectively. The approved fuel specification changes allowed for the use of standard and optimized fuel assemblies with U-235 enrichments up to 5.0 weight percent. The specification further required that fuel assemblies containing U-235 enrichments greater than 4.6 weight percent would incorporate integral fuel burnable absorber The licensee and NRC evaluated the effects that the higher enriched fuel assemblies would have on storage requirements within the new and spent fuel areas. The licensee d NRC concluded that sufficient margin was incorporated in the designs for each dorage area to eliminate any potential criticality concern The inspectors reviewed the changes made to the T/Ss and discussed the fuel loading and storage plans with reactor engineering personnel. Allinformation on the new fuel core Icading patterns had been received from the fuel vendor. The licensee was modifying plant procedures to reflect the fuel vendor's recommendations and limitations contained in the T/S changes issued on September 4,199 c. Conclusions The licensee effectively implemented the recent Technical Specification change from a 12-month to an 18-month fuel cycle. The effects of the changes on the operational performance of the containment spray system and the new and spent fuel storage areas were appropriately considered by the license . .c _ _
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E3 Engineering Procedures and Documentation E Month Operatino Cvele Source Term (IP 37551)
The inspectors, in assessing the licensee's readiness for converting to 18-month fuel cycles for Unit 2, reviewed the following calculations:
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Calculation Number 98-0050, " Comparison of NUREG-0578 and 18-Month Cycle Source Terms," Revision 0, and
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Calculation Number 98-0058, " Post-LOCA [ Loss of Coolant Accident] Reactor Coolant Sampling System Doses Rates," Revision The licensee concluded the extension of the operating cycle from that previously analyzed to 18-months would not appreciably change the source term or '
post-loss-of-coolant accident sample system dose rates. The inspectors concluded both calculations to be thorough and properly performed.
E E7 Quality Assurance in Engineering Activities E Quality Assurance Surveillance of the 18-Month Fuel Cycle Project Inspection Scope (IP 40500)
The inspectors reviewed the report for a QA surveillance of the 18-month fuel cycle project. The report number for the surveillance conducted on August 3 through 7,1998, was S-P-98-1 Observations and Findinos The surveillance was conducted to evaluate the progress and thoroughness of the station's efforts in preparing for the upcoming 18-month fuel cycle. The aspects of the project reviewed included readiness of T/S changes, FSAR changes, procedure changes, plant chemistry changes, needed modifications, training, and NRC commitment The surveillance concluded that the implementation of the project was marginally effective and three QCRs were generated as a result of the findings. The three QCRs (98-0266,98-0267 98-0268) concerned failures and weaknesses of the project to effectively involve and consider probabilistic safety assessment impacts, evaluate effects on the station environmental impact statement, and effectively manage the overall projec The inspectors determined that the surveillance was effective in identifying implementation concerns for the 18-month fuel cycle extension project. The project manager had implemented corrective action to address the identified QA concems following the surveillanc . - _ - . . - _ .. _ - -. . _ - -.
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, Conclusions
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The licensee effectively used the quality assurance surveillance process to evaluate the progress and readiness of the 18-month fuel cycle project. The surveillance identified weaknesses in the project requiring resolution to ensure timely and effective
, implementation of the extended 18-month fuel cycle.
E8 Miscellaneous Engineering issues E (Closed) IFl 50-266/96018-12(DRP): 50-301/98018-12(DRP): Lack of control room emergency ventilation system description within the FSAR. This item was left open pending an FSAR revision submittal to the NRC. The licensee submitted the full FSAR update to the NRC in June 1998. That FSAR revision contained a discussion of
the control room emergency ventilation system in Section 9.8.
- E (Closed) IFl 50-266/96018-14(DRP)
- 50-301/96018-14(DRP): Adequacy of 10-year structural inspection frequency relative to 10 CFR 50.65 " Maintenance Rule" guidanc This item was opened to review the adequacy of the licensee's structuralinspection i frequency against Maintenance Rule guidance. Subsequently, a Maintenance Rule
- inspection (Inspection Report 50-266/97025(DRS); 50-301/97025(DRS)) was conducted in December 1997 which, in part, reviewed the licensee's " Facilities Monitoring Program." As a result of this inspection, an IFl (50-266/97025-06(DRS);
50-301/97025-06(DRS)) was initiated that specifically identified deficiencies in the l Facilities Monitoring Program relative to guidance contained in Regulatory Guide 1.16 i Therefore, the earlier IFI, 50-266/96018-14(DRP); 50-301/96018-14(DRP), is close l
E8.3 (Closed) IFl 50-266/96015-04(DRP): 50-301/96015-04(DRP): Review of load calculation I for 2803/2B04 Unit 2 480V [ volt) safeguards buses. This item was initiated to review the final load calculations for the Unit 2 480-volt safeguards buses (2803/2804). The final calculation was completed in October 1998. The inspectors reviewed the load calculations and had no further questions regarding this matte E8.4 (Closed) LER 50-266/97004: 50-301/97004: Potential Common Mode Failure in Vital l Direct Current Electrical System. On January 13,1997, the licensee identified the potential for a particular common mode failure to occur in the vital direct current electrical system that could affect opposite trains of Unit 2 safeguards equipmen i Further review by the licensee identified a similar common mode failure potential for ;
Unit 1. The inspectors reviewed the documentation associated with this issue and !
considered the docketed information to be accurate and comprehensive. The corrective actions, which included the replacement of the breakers subject to the common mode failure, were considered to be appropriate. This licensee-identified, non-repetitive failure to maintain the respective Unit 1 and Unit 2 safeguards equipment free from common mode failures is being treated as an NCV (NCV 50-266/98019-03(DRP);
50-301/98019-03(DRP)) of 10 CFR Part 50, Appendix B, Criterion Ill, " Design Control,"
in accordance with Section Vll.B.1 of the NRC Enforcement Polic _ . _ _
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E8.5 (Closed) URI 50-266/96008-04(DNMS): 50-301/960008-04(DNMS): Adequacy of the ,
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dry cask reflood system, especially the heat exchanger. In response to CR 96 0509 which documented this item, the licensee resolved the issue by modification of the system (Modification Number 92-120*E). This included replacing the heat exchanger l
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with a heat exchanger (and associated valves and piping) designed for a higher temperature and pressure. Additionally, the licensee assured that all other remaining system components met system pressure and temperature requirements. The inspectors original concerns are considered reselve IV. Plant Support R1 Radiological Protection and Chemistry (RP&C) Controls R General Comments (IP 71750)
During this inspection period, the inspectors conducted frequent tours of the radiologically controlled area. No significant problems were observed with radiological postings or controls; however, the inspectors identified several minor discrepancies regarding contamination control. These discrepancies were discussed with RP supervision who promptly corrected them S8 Miscellaneous Security and Safeguards issues S (Closed) LER 50-266/97S01: 50-301/97S01: Uncompensated Protected Area Alarm Zone. This event was discussed and dispositioned in Section S4.1 of .
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IR 50-266/97007(DRS); 50-301/97007(DRS). No new issues were revealed by the LE V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on November 20,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Ne proprietary information was identifie . .. .. _ . _ . .- . __ .. _ .. _ . . . _ _ _ _ . _ _ . ~ . _ . _ . . . _ _ ._ _,
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. PARTIAL LIST OF PERSONS CONTACTED
. Licensee .
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Wisconsin Electric Power Comoany
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M. E. Reddemann, Site Vice President
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R. G. Mende, Plant Manager J. R. Anderson, Operations Manager
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D. P. McCloskey, Maintenance Manager
- J. G. Schweitzer, Site Engineering Manager R. P. Farrell, Health Physics Manager l- V. M. Kaminskas, Regulatory Services and Licensing Manager
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INSPECTION PROCEDURES USED
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IP 37551: . Onsite Engineering
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IP 40500: Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems
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IP 61726: Surveillance Observations-
'IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92901: ' Followup - Operations IP 92902: Followup - Maintenance:
. IP 92903: Followup - Engineering IP 92904: Followup - Plant Support
. lP 93702: Prompt On-Site Response to Events at Operating Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-266/98019-01(DRP) URI Licensee Procedure Adherence Guidance 50-301/98019-01(DRP)
50-266/98019-02a(DRP) ' eel Failure to Adequately Complete the Code VT-2-50-301/98019-02a(DRP) Visual Examination of the Units 1 and 2 SFSP 50-266/98019-02b(DRP) eel ' Failure to Complete System Pressure Tests
' 50-266/98019-03(DRP) -NCV Potential Common Mode Failure in Vital DC 50-301/98019-03(DRP) System Closed 50-266/96019-02(DRP) IFl Followup on licensee commitment to formalize a 50-301/96019-02(DRP) program to periodically assess control room conduct-50-266/97010-00 & -01 LE Service Water and Component Cooling Water T/S '
50-301/97010-00 & -01 Action Requirements Not Met 50-266/97029 .LER SI Accumulators isolated During Plant Startup; 50-301/97029 Procedure in Violation of T/S
.50-266/97003 LER Spare Containment Penetrations Not Leak Tested '
50-301/97003 In Accordance With T/S g 50-266/97038 LE Standby Emergency Power inoperable in Excess 50-301/97038 Of T/S Allowed Outage Time L
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! 50-266/98018-12(DRP) . ~ IFl Lack of control room emergency ventilation system L 50-301/98018-12(DRP) description within the FSAR l-
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50-266/98018-12(DRP) IFl Lack of control room emergency ventilation system 50-301/98018-12(DRP) description within the FSAR 50-266/96018-14(DRP) IFl Adequacy of 10-year structural inspection 50-301/96018-14(DRP) frequency relative to 10 CFR 50.65 " Maintenance Rule" guidance 50-266/96015-04(DRP) IFl Review of load calculation for 2803/2B04 Unit 2 50-301/96015-04(DRP) 480V safeguards buses l 50-266/97004 LER Potential Common Mode Failure in Vital Direct 50-301/97004 Current Electrical System 50-266/90008-04(DNMS) URI Adequacy of the dry cask reflood system, 50-301/96008-04(DNMS) especially the heat exchanger 50-266/97801 LER Uncompensated Protected Area Alarm Zone 50-301/97S01 50-266/98019-03(DRP) NCV Potential Common Mode Failure in Vital DC 50-301/98019-03(DRP) . System Discussed i
50-266/97020-02(DRP) IFl Assess procedural controls 50 301/97020-02(DRP)
50-266/97026-01(DRP) VIO Inappropriate procedure adherence guidance 50-301/97026-01(DRP)
Retracted 50-266/98014-05(DRP) NCV Missed Surveillances Required by the Section XI 50-301/98014-05(DRP) Pressure Test Program Constituted an Operation Prohibited by T/S
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l LIST OF ACRONYMS USED IN POINT BEACH REPORTS l
I AFW'
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. ANSI American National Standards Institute l
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= ASME American Society of Mechanical Engineers ; i
' CFR - Code of Federal Regulations '
I CMP- . Component Maintenance Program C . Condition Report =
- ~ DNMS Division of Nuclear Materials Safety i DR Division of Reactor Projects
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U L DRS - Division of Reactor Safety l _ DS Duty Shift Superintendent ECC Emergency Core Cooling System eel L Apparent Violation ESF- . Engineered Safety Feature EP' Emergency Planning
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. FSAR Final Safety Analysis Report IFl . Inspection Follow-up Item IP inspection Procedure IPE Individual Plant Evaluation
! IR Inspection Report'
I Inservice Test Procedure LCO - ~ Limiting Condition for Operation
! LER Licensee Event Report t- LRPM Leakage Reduction and Preventive Maintenance N/A_ Not Applicable
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NCV- Non-Cited Violation NRC Nuclear Regulatory Commission
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Of . . Operating Instruction OM Operations Manual OP Operating Procedure OSRC~ - Off-Site Review Committee ppm - Parts Per Million ,
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PTP' __ Pressure Test Program QA' -. Quality Assurance QC . Quality Condition Report ~
RCE ' Root Cause Evaluation RCS Reactor Coolant System
' RP '- Radiation Protection
.SER :
Safety Evaluation Report ;
SFSP Spent Fuel Storage Pool
= SI' Safety injection j
- SW Service Water .
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T/S Technical Specification :
L . TS Technical Specification Test L URI Unresolved item L VIO . Violation u . V' Volt -
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gin wi- g- ,y y a .- - -- w m-se mi