IR 05000263/1998009

Insp Rept 50-263/98-09 on 980511-0612.No Violations Noted. Major Areas Inspected:Review of 10CFR50.59 Safety Evaluation & Screening Activities

ML20236V621
Person / Time
Site:	Monticello
Issue date:	07/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236V614	List: IR 05000263/1998009 ML20236V612
References
50-263-98-09, 50-263-98-9, NUDOCS 9808040087
Download: ML20236V621 (29)

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U.S. NUCLEAR REGULATORY COMM;SS!ON REGIONlli Docket No: 50-263 License No: DPR-22 Report No: 50-263/98009(DRS)

Facility: Monticello Nuclear Generating Station Licensee: Northern States Power Company Location 2807 West Highway 75 Monticello, MN 55362 Inspection Performed: May 11 - June 12,1998 Inspectors: H. A. Walker, Team Leader M. J. Miller, Reactor Engineer J. H. Nelsler, Reactor Engineer G. M. O'Dwyer, Reactor Engineer D. L. Schrum, Reactor Engineer D. J. Wrona, Resident inspector Approved by: J. M. Jacobson, Chief, Lead Engineers Branch Division of Reactor Safety

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PDR ADOCK 05000263 G PDR

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EXECUTIVE SUMMARY Monticello Nuclear Generating Station NRC Inspection Report 50-263/98009

' This inspection was a Corrective Action inspection combined with an Engineering and Technical Support inspection which included a review of 10 CFR 50.59 Safety Evaluation and Screening activities, it was an announced team inspection of approximately three weeks duratio .

In most cases, design changes and modifications were well controlled and implemented, in a few cases, as with the control room ventilation system modification, the design changes created additional unanticipated problems. No significant concerns were t

identified during the inspection even though some deficiencies and weaknesses were I

noted. Design and configuration controls were maintained and were adequate (Section E1.1).

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Overall safety evaluations and screenings were thorough, with one exception noted in addition, the procedure for temporary modifications allowed bypass of 10 CFR 50.59

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requirements for an " urgent or emergency condition" without defining or qualifying these terms, within the context of 10 CFR 50.54(x). This item is unresolved pending demonstration of adequate controls to preclude the potential for inappropriate bypass of 10 CFR 50.59 requirements (Section E1.2).

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Identification and documentation of both intemal and extemal problems were good.

l Employee Observation Reports were reviewed and converted to condition reports as l

appropriate. In most cases, actions to correct identified problems was adequat However, in some cases, the time required to complete actions to correct identified problems was excessive. Ninety nine actions to correct condition report related <

problems had not been completed and had been open for more than two year Although no delays in specific priority safety related items were noted, the timeliness of the actions to address the problems was considered a weakness. The closing of condition reports prior to completion of required actions obscured the length of time some issues had been open (Section E2.1).

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Quality trending was poor. Transmittal of data for trending had recently been discontinued and quarterly trending and problem reports were no longer being prepared and distributed. Use of both manual and computerized trending was considered weak.

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There was no objective evidence that repetitive foreign material exclusion issues, noted by the inspectors, were detected and addressed by the trending program (Section E2.2).

. Engineering support to maintenance was acceptable; however, weaknesses existed in support to preventive maintenance, in a number of cases, engineering had identified the need for additional PM tasks or the need to revise existing tasks to preclude failures and the required actions had not been completed and had been open for years (Section I E2.3).

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The operating experience program provided adequate assessment of operating j experience originating from both inside and outside the licensee's organization. In most 1 cases, the information received was reviewed, evaluated and the necessary actions appropriately determined. In some cases, however, completion of the required actions {

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was untimely and some actions had not been completed after several years (Section l E2.4). j l

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Engineering personnel were well qualified, experienced and cognizant of work activities l

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and issues (Section ES). .

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Report Details 111. Engineering The review of engineering included both design and support engineering activities. The design review included design changes, temporary design changes as well as 50.59 safety evaluations and screenings. Engineering support included systems engineering, problem resolution and corrective action activities as well as normal involvement with operations, maintenance and other plant organization E1 Conduct of Engineering E Design Changes and Modifications i Insoection Scoos l

The methods used to control design changes and modifications at the Monticello plant were reviewed to verify adequacy, control, and compliance with regulatory requirements. The review included basic design change procedures and 21 selected l modification packages. The modification packages selected included both open and closed modifications with emphasis on installed modifications. The selected l modifications were discussed with cognizant system and design engineers and the j inspectors walked down assessable portions of selected modification installation Observations and Findings

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l The design changes and modifications reviewed were adequately designed, reviewed, installed and tested with one exception. Both design and systems engineers were knowledgeable of assigned systems and modifications. Modifications reviewed were simple and no recent complex modifications were available. With the exception of the ,

control room ventilation system modification, no significant concems were identified even though some minor items were noted. Design configurations and configuration controls were maintained and were adequat t

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Modification 96O0015: This modification required the installation of permanent blanking plates in the intake ducts for both normal control room ventilation systems (V-EAC-14 A and B) to block off the outside air supply to the system The modification was required because the air inlet dampers in-leakage could increase operator radiation dos:: levels beyond the allowable limits set in 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 19 for newly identified scenarios of reactor accidents and for power re-rate accident condition Fo!!owing the above modification, when either of the normal control room ventilation systems were in use, the control room was at a slightly negative pressure, compared to adjacent areas. The negative pressure could allow contaminated air to be drawn into the control room during an accident.

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The modification conflicted with Sections 6.7.1 and 6.7.2 of the Updated Safety Ar:alysis Report (USAR) and Section 3.17 of the plant Technical Specifications

! (TS) bases since these documents stated that the Main Control Room was

, normally pressurized compared to adjacent areas. The control room emergency l filteration trains (EFTS) were not affecte Upon review, licensee personnel determined that this condition was bounded by previous dose calculations. Changes to the USAR and TS bases had been requeste The installation of this modification created unanticipated problems, which resulted in the buildup of odors and carbon dioxide (CO2) in the control room due to limited fresh air from outside. Personnel monitored CO2 to ensure that the concentration stayed below 1000 par;s per million. Operators ran the EFTS j as needed, to obtain fresh air. This practice contributed to frequent replacement '

of carbon filters in the EFT As a result of the problems caused by this modification, a manual damper was planned to be installed in one of the normal ventilation systems. This new design change was scheduled for installation in 1999. The change would reduce in-leakage to acceptable limits and return the ventilation system to previous flow paths. The modified system was to be the primary system used during normal operations with the other system used as backu Conclusions in most cases, modifications were well controlled and implemented; however, in a few cases, as with the control room ventilation system modification described above, the l

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design changes created additional unanticipated problems. No significant concerns were identified even though some deficiencies and weaknesses were noted. Design configurations and controls were maintained and were adequat E Safety Evaluations, and Screeninos )

a. Insoection Scoce The inspectors reviewed the methods used for 50.59 safety screenings and evaluation Emphasis in the review of this procesr, was on design changes and modifications. The review included the controlling procedures as well as a review of the safety evaluation /

screenings performed for the modifications and bypass items reviewed during the inspectio b. Observations and Findinos Tb >ectors reviewed Administrative Work Instructions (AWis) 4 awl-05.06.02, "10 CF s.59 Applicability Screenings," Revision 1, and 4 awl-05.06.03,"10 CFR 50.59 Evaluations," Revision 0. These procedures described effective methods for controlling

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e and performing 50.59 safety screenings and evaluations; however, the inspectors noted some weaknesses in supporting procedures involving 10 CFR 50.59 regulatory requirement .

Byoass Control Procedurg During the review of bypass control procedure 4 AWi-04.04.03, " Bypass Control," Revision 9, the inspectors noted that Section 4.3.1.D of the procedure stated "...a System Engineer review is required to determine the need for a 10 CFR 50.59 evaluation. Note that for an Urgent or Emergency condition, the bypass may be used and the review performed later."

While 10 CFR 50.54(x) allows immediate action in an emergency condition, the procedure does not define the terms " urgent or emergency condition."

Immediate action and bypass of the requirements of 10 CFR 50.59 are acceptable only within the context of the conditions described in 10 CFR 50.54(x). The procedure, as written, does not provide adequate controls to assure that the requirements of 10 CFR 50.59 are met. During the review of existing bypass items, the inspectors did not identify any examples where a bypass had been implemented without a prior 50.59 safety evaluation or screening. This item is unresolved since the procedure, as written, could allow noncompliance with 10 CFR 50.59 requirements (50-263/98009-01(DRS)).

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Modification 960015: The details of this modification are discussed in Section E1.1 of this report. The safety evaluation for the change did not address all issues. During normal operations, the negative pressure could cause in-leakage from areas around the control room and unmonitored radioactivity could be drawn into the room. Control room dose calculations did not consider radioactivity entering the Control Room without an automatic actuation of the emergency filteration train (EFT). Licensee personnel did not address the negative pressure of the control room in the safety evaluation and therefore, did not perform a thorough review for unreviewed safety questions (USQs). In a subsequent review licens.ee personnel were able to demonstrate that the condition was bounded by previous dose calculations and additional actions were not require c. Conclusions Overall, safety evaluations were thorough, with one exception noted. An unresolved item was written on one of the implementing procedures, which did not provide adequate controls to meet 10 CFR 50.59 regulatory requirements for temporary modifications.

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E1.3 Temocrarv Modifications (Bvoass) Insoection Scooe The inspectors reviewed the methods used to control temporary modifications. A number of temporary modifications were selected and reviewed to verify adequate engineering involvement and contro Observations and Findinas The inspectors reviewed temporary modification procedure, AWi-04.04.03," Bypass Control," Revision 9. The procedure provided adequate controls for temporary modifications except in the area of 10 CFR 50.59 safety evaluations and screen;ng This procedural deficiency is discussed in Section E1.2 of this repor The procedure stated that temporary modifications (bypasses) were generally expected to be installed for three months or less. In addition, the goal was to limit each bypass to less than two years with the permanent resolution to be completed within this tim Thirty temporary modifications were open when the list of temporary modifications was received for the inspection. Two items had been open since 1994. One item was open since 1995. Seven items were open since 1996. All 30 items had been open more than 3 months. The number of temporary modifications was substantially reduced during the inspection. The lack of timely actions to remove these temporary modifications promptly was considered a program weaknes Conclusions Control of temporary modifications was acceptable and the number of installed temporary modifications was not excessive. A procedural deficiency, which allowed temporary modifications to be installed without a prior 50.59 safety evaluation or screening, was a program weakness. No evaluation or screening problems were found with the temporary modifications reviewe E2 Engineering Sucoort of Facilities and Eauioment The inspectors reviewed the methods used to provide engineering support to plant organizations, which included plant management, operations and maintenance. Much of the engineering support involved assistance in the documentation, evaluation and resolution of problem E Corrective Action Insoection Scoce The inspectors reviewed the corrective action process which included implementing j procedures, records and reports. Timeliness and priority of actions completed or scheduled were considered as well as trending of problems and tracking of corrective

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actions to correct or minimize the problems. Selected samples of condition reports l (CRs) and other documents, used to document problems, were reviewed as well as I internal reports and tracking systems. Actions taken to correct problems were reviewed to verify effectivenes b. Observations and Findinas When problems were identified, CRs were usually written to document the problem h

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Besides CRs, employee observation reports (EORs), external operating event reports (XORs) were also used. Data from these sources was entered into the tracking system l for follow up and status. Separate entries were made for actions associsted with CR Each identified action was given a separate number to facilitate tracking. The CRs did not have a set of sequential numbers and an observer could not readily determine the number of CRs written in a period of time by using the CR numbe EORs were reported on small cards available to anyone on site and computer access was not required for initiation. rhe EORs appeared to have a lower initiation threshold

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than CRs. Once written, ar, EOR was given a separate number and placed ir, the licensee's tracking system or the F.OR was converted to a CR. The EOR data was also incorporated into quarterly reviews by each departmen The XOR covered all extemal sources of potential issues. This included operating events at other nuclear sites; 10 CFR Part 21 notifications; vendor information; and NRC bulletins, generic letters, and ins. The inspectors further noted that the licensee appropriately included significant events which occurred at the corporation's own fossil unit Effectiveness of Corrective Actions CRs were normally used by licensee personnel to document identified problems. During the inspection,33 CRs were reviewed. The review included the actions taken to resolve the problems or issues. After desired actions were determined for resolution, the CRs were closed and the actions were placed in the plant action item tracking system for follow-up and status. The closing of CRs to the action items was not a good practice because the tracking system had less control and the date of problem discovery was not i always eviden Evaluation of problems and the determination of required actions for resoittion by licensee personnel was excellent. For safety related items, actions were thorough and l were completed promptly. For non-safety related items and items where immediate

, action was not required by regulatory requirements, actions were determined and were placed in the action item tracking system. Completion of these items was sometimes slow and untimely. This issue is discussed in a Section that follows entitled, " Delayed Corrective Actions."

l . Off gas storage building feeder faults - On November 25,1997, the l underground direct buried 480 volt feeder cables, which supplied power to the

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off-gas building failed. Power was lost to both recombiner and both off-gas '

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storage trains. Without the recombiners, the condenser vacuum was lost and the reactor was manually scrammed. Following the scram, the licensee installed temporary cables above ground to support continued operations. A modification to construct an underground duct bank for the feeders was in progress and was scheduled for completion by the Fall of 199 A previous failure of one of the feeders in 1994, had resulted in an engineering decision to include meggering of the cables in the PM program with the cables to be meggered every other refueling outage. Even though the PM task was not developed and implemented, both cables were meggered after the 1994 failur Cable problems were found and the cables were repaired. The licensee also initiated a meggering program for other direct buried plant cables to detect cable fault %fthough the PM task was not established as planned, meggering of direct buried cables was initiated and continues. The present modification to construct an undergicund duct bank, following the fault on both feeders, was a good resolution to the off gas storage building feeder problem Delaved Corrective Actions During the review of the CR process, the inspectors noted that CRs were usually closed when desired actions were determined, assigned, and entered into the action item tracking system. On May 21,1998, the inspectors were provided a report which listed 99 open CR related action items, that had been assigned for longer than two years without action being completed. The delay in performing actions to correct plant hardware and other plant problems was of concern. Examples of delayed corrective actions noted are cs follows:

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Containment Isolation Butterfiv Valves: The oldest action item related to a 1984 IN regarding butterfly valves. The corrective actions required changes to a PM procedure. Only changes to the procedure was required and no parts or special plant conditions were required to accomplish the task. Action to revise the PM procedure and establish PM on the valves had not been completed at the time of the inspectio In 1998, a containment isolation butterfly valve failed to seat properly during a local leak rate test and the leak rate grossly exceeded the acceptance criteri The recommended PM procedure change may have prevented the failure of the butterfly valve.

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Emeroency Diesel Generator Room Backwater Valves: Following the review of IN 83-44, Supplement 1, dated August 30,1990, licensee personnel recommended that a PM procedure be written to periodically inspect the emergency diesel generator room backwater valves. In the assessment, the site

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classified the issue as being significant such that the event could have an adverse affect on plant safety. At the time of the inspection, the PM procedure had not been writte .

Station Blackout Diesel Generator Cooling System Annunciator: This action item, No. 93000361, was written on October 22,1993, to provide action to correct a problem documented on CR 93000271. The station blackout diesel generator, DG No.13, cooling water low level alarm annunciator was inoperabl The annunciator had apparently been inoperable since the DG was installed since required power was not provided to the level detector. Operating procedures required that the diesel coolant water level be verified each shift by the operators during shiftily rounds. Although the significance of the failure to take action was low, the failure to take action for almost five years without completion is a concer Conclusions Based on the inspection results the inspectors concluded that identification and documentation of possible problems, both intemal and external to the plant, were goo EORs were appropriately reviewed and converted to CRs if appropriate. Actions identified to correct identified problems were very good. In some cases, the time required to complete planned actions was excessive. An increase in management attention appeared to be needed in this area. Although the inspectors did not identify delays in priority safety related items, the timeliness of the actions was poor. The inspectors considered the closing of CRs prior to completion of required actions a weakness and a poor practice that obscured the length of time an issue had been ope E2.2 Trending Insoection Scone The inspectors reviewed the methods used to determine repetitive failures and detect negative quality trends. This review included a review of procedures, records and actions taken when negative trends were noted, Observations and Findings Most of the trending was performed utilizing CRs. CRs contained three fields that were useful for trending purposes. The fields consisted of a process code, up to three causal codes, and a three line word searchable title. While the process code and the causal code lists were well defined and extensive, the titles did not use any specific key words

! and was not spell checked. Searching titles without key words and a spelling check I

reduced the effectiveness but still provided a workable syste Most departments did some quarterly trending using manual techniques. Until recently, each department was supplied with a listing of all CRs and EORs that were written during the quarter, which applied to the specific department. The department then

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reviewed the specific data and provided a summary report. After the departments had completed the reviews, a representative from each department attended a quarterly meeting to discuss the findings and determine if there were common themes. An overall report was then created and provided to the plant manager. Due to recent changes in job assignments, the coordinator position for this task was empty and the quarterly meetings had not occurred for 1998. The licensee scheduled a replacement for the position and planned to resume the report proces I i

During the review of CRs, the inspectors noted that several documents identified the intrusion of foreign materialinto plant systems. The inspectors then reviewed the tracking of foreign material exclusion (FME) issues. CRs 97001832,98001052, and 98001055 contained FME issues but did not have FME related process or causal code The titler did not contain words that would have been searchable to identify the CR as related to an FME issue. It appeared that the FME related process and causal codes were typically used in relation to events caused by FME and did not capture lower level issues such as identified poor FME practice The inspectors also noted three FME issues identified in Outage Observation Trend Summary reports for March 1998. The observations dispositioned locally did not appear to result in CRs. All of the FME issues noted by the inspectors were of low consequence. However, the lack of incorporating the issues into the trending data base in a manner that would allow trending of FME issues, prevented the licensee from identifying weak FME practices and taking corrective actions before a more significant issue occurred. During discussions on FME issues, licensee personnel stated that they were aware of FME problems and that some of the r scent CRs involving FME were written because of this awarenes I Conclusions

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Based on the inspection results, the inspectors concluded that quality trending was poor. Transmittal of data for trending had recently been discontinued and the preparation and distribution of quarterly trending and problem reports no longer existe Use of both manual and computerized trending was considered weak. There was no objective evidence that FME issues were detected and addressed because of the trending program or trending effur E2.3 Enaineerina Succort to Maintenance Insoection Scoce

The inspectors reviewed and evaluated involvement of engineering in the development and implementation of predictive and preventive maintenance. The methods used by engineering to support maintenance were reviewed with an emphasis .

on PM. The review included a review of relevant procedures and records as well as l discussions with cognizant personne l

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Procedure 4 AWi-01.04.02, " Plant Maintenance Organization," Revision 3, adequately controlled the PM program by stating that the Superintendent of Maintenance Engineering shall be responsible for: (1) providing engineering support for the PM program; (2) PM procedure preparation; and (3) monitoring the PM program for effectiveness. Maintenance engineers stated that they usually prepared PM procedures that involved more than one system and that usually the system engineer prepared the PM procedures that were specific to the system. DCPs required that PM procedures be written if neede During the inspection the inspectors noted several long outstanding actions where PM tasks or procedures were to be written or revised and implemented. Examples of these items are as follows:

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Action in response to NRC IN 84-04, was to develop and implement two new PM tasks for batterfly valves. The need for these Phis was identified on November 19,1985. At the time of the inspection. June 4,1998, the two preventive maintenance tasks had not been issue .

Action in response to NRC IN 83-44, Supplement 1, dated August 30,1990, was to develop and implement PM procedure to periodically inspect the emergency diesel generator room backwater valves. The issue was classified as being significant such that the event could have an adverse affect on plant safety. At the . lie of the inspection, June 4,1998, the PM procedure had not been writte Conclusions Based on the inspection results, the inspectors concluded that engineering support to ;

maintenance was acceptable. In a number of cases, however, the need for additional l PM tasks or modification of existing tasks was identified but the required actions were i not completed and had been open for year E2.4 Ooerating Exoerience Reoort (OER) Program Insoection Scoce The inspectors reviewed and evaluated the methods used by engineering to address outtide or industry information and problem notifications such as generic letters, ins, l Institute of Nuclear Power Operations (INPO) notifications, service information letters, etc. The implementing procedure and selected records were reviewed and discussed with cognizant plant personne Observations and Findings l l

The inspectors reviewed procedure 4 awl-10.01.03," Condition Report Process,"

Revision 7, and .noted that the procedure described a good program for reviewing both 12 l

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inside and outside problem notification documents. These documents included vendor information and notifications, INPO significant operating event reports, significant event -

reports, and notifications generated by the NR I During the review of records, the inspectors noted that most of the OER reviews (

resulted in technically sound corrective actions, which were properly implemente Personnel appeared to be appropriately trained in this area and information was properly disseminated and appropriately emphasized by plant management and staf In most cases, actions taken were adequate and were completed promptly. Procedures were noted to have been revised to incorporate lessons learned from OERs and some modification packages referenced OER ;

in a few cases, the inspectors noted that the OER program did not appear to function l

properly. Documents were received, evaluated and required actions determined promptly; however, the actions were put into the action tracking system and were not 3 completed for several years. Examples of these items follow:

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NRC IN 84-04," Failure of Elastomer Seated Butterfly Valves Used Only During Cold Shutdown," dated January 18,1984, described failures of butterfly containment isolation valves to properly seat. From the IN review, the Operations Committee required development and implementation of new PMs to address this problem. The assessment was dated November 19,1985 ,

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The problem was documented on CR 84000007 and tracked as action item 84000396. At the time of the inspection, June 4,1998, the two PM tasks had not '

been issued. The scheduled completion date, as listed on June 4,1998, was December 30,1998. (See F- 9n E2.1 of this Report.)

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NRC Information Notice 89- Jed December 6,1989, documented problems 1 with inadequate 10 CFR 50... waluations or screenings for temporary modifications. (See Section E1.2 of this Report.) The inspectors noted that Section 4.3.1 of procedure awl-04.04.03, " Bypass Control," contained a problem statement similar to the program problem iden2fied in IN 89-91. This IN had apparently not been addresse c. Conclusions Based on the inspection results, the inspectors concluded that the OER program was ,

acceptable to assess operating experience originating from both inside and outside the l licensee's organization. In most cases, the information received was reviewed, evaluated and the necessary actions appropriately determined. Completion of the  !

required actions, however, was sometimes untimely and some actions had not been l completed after several years.

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E5 Engineering Staff Training and Qualification Insoection Scone No formal evaluation of training and qualification of licensee personnel was performed during this inspection. After interface, discussions and communications with personnel the :nspectors were asked to comment on the apparent qualification of personnel. Most of the personnelinvolved were system or project engineer Observations and Findings The system and design engineering personnel, interfacing with the inspectors, were degreed engineers working in the appropriate engineering discipline. Personnel were generally Lperienced engineers and had more than ten years experience with the licensee orga,ilzation. All appeared to be knowledgeable of the modifications, problems or other issues being discusse Conclusiqu2 Based on the inspection results the inspectors concluded that personnel associated with the inspection were qualified, experienced and cognizant of the issues discusse E8 Miscellaneous Engineering issues This section describes the review of items identified in previous NRC inspection E (Closed) Unresolved Item (50-263/96005-03k Operation of the core spray pump motors with reduced or no water cooling to the pump motor lubricating oil. Due to problems in maintaining the required service water flow to the core spray motor lubricating oil ,

coolers, licensee personnel conducted tests and analysis to determine the effect of a reduced or a loss of service water flow to the motor oil cooler The inspectors reviewed the test results and the analysis conducted on the issue. The matter was also discussed thoroughly with cognizant licensee personnel. During these discussions the inspectors were told that flow to the existing core spray oil coolers would continue. A written commitment that the flow be verified every three months and the coolers would be back flushed if the flow was below the existing minimum was also reviewed. Changes to this written commitment were to be provided to the NRC in writing.

l E8.2 (Closed) Violation (50-263/96006-01 Ah Inadequate operations procedure. Operations Manual Procedure B.4.3.2-05.G, " Combustion Gas Control System (CGCS), Post-LOCA CGCS Startup and Operation," Revision 4, did not provide adequate instructions for operator initiation of the CGCS system following a loss of coolant accident. If the procedure was followed, as written, it would have prevented the inlet and outlet isolation valves from opening on deman _

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i The procedure was revised as required. The inspectors reviewed Revision 5 of the procedure and noted that the operators were now instructed to place the control j switches for the inlet and outlet isolation valves in the open position and verify that the trip light was not illuminated before releasing the control switch to the open positio l l

l E8.3 (Closed) Violation 50-263/96006-01B.): inadequate surveillance test procedure Surveillance test procedure 0255-21-111-1(2)A(B),"CGCS Tests," Revision 15, and l

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0417-1(2)A(B), "CGCS Recombiner Tests," Revision 3, were inadequate and did not require the simulation of a primary containment Group 11 isolation signal during testing to ,

demonstrate that the isolation signal would be automatically bypassed upon system demand as required. The inspectors reviewed revisions to procedures 0255-21-111-l 1(2)A(B) and 0417-1(2)A(B) and verified that the procedures provided for the testing of j the CGCS logic. Licensee personnel satisfactorily tested the CGCS bypass of the l primary containment Group ll ! solation signal during the 1996 refueling outag l l

E8.4 (Closed) Insoection Followuo item (50-263/96006-05): Discrepancy in the Updated Safety Analysis Report ( USAR). The USAR stated that " provisions are made for automatic fast transfer of the auxiliary load from the primary station transformer to the reserve transformer or auxiliary reserve transformer." Monticello design did not include an automatic fast transfer to the auxiliary reserve transformer. The transfer to the auxiliary reserve transformer had a time delay of five seconds for loss of voltage and nine seconds on degraded voltage prior to initiation of a load transfe The inspectors verified that licensee personnel had submitted changes to Chapters and 8.4 of the USAR to correct these discrepancies and adequate safety evaluations were performe F6.5 (Closed) Insoection Followuo item (50-263/96009-01): The Plant TS did not address electric power requirements while shutdown. Technical Specification Interpretations, developed to address power sources during shutdown conditions, lack TS explicitly for addressing electrical power source requirements for conditions other than the run mode (operating at power). The inspectors were concerned that electrical power requirements for other than power operation had not been incorporated into the T The team determined that Standard Technical Specifications were in development for BWR/4 plants. The licensee was planning to adopt the Standard Technical Specifications at Monticello, which should clarify this issu j E8.6 (Closed) Violation (50-263/96009-02): Uncontrolled design calculations. This violation addressed changes to a calculation which were not entered into the document control system and a record of the " revised" calculation was not identifiable or retrievable within the quality assurance records system. The inspector verified that the changes to the calculation were formalized in accordance with appropriate procedures. The licensee's calculation control process was not adhered to or there was a lack of attention to detail.

, The inspector verified that engineering and technical staff personnel attended special training on the importance of rigor and attention to detail in performing, reviewing, I

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j approving, and documenting calculations. The licensee's corrective actions and evaluation of the causes of the event were appropriate. The inspectors had no further concems in this area.

t E8.7 [CJnsed) Violation (50-263/96009-01): Inadequate design verifications. This violation concerned inadequate verification activities related to an evaluation of net positive suction head to the emergency core cooling system. Specifically, the calculation reached an incorrect conclusion as to the amount of available net positive suction head because the vapor pressure value used in the calculation for water at 191 *F was

incorrect. The calculation had been independently redone by an outside engineering consultant. The inspector verified that the appropriate vapor pressures were incorporated in the calculation The licensee's calculation control process was not adhered to or there was a lack of I attention to detail. The inspector verified that engineering and technical staff personnel l attended special training on the importance of rigor and attention to detailin performing, reviewing, approving, and documenting calculations. The licensee's corrective actions and evaluation of the causes of the event were appropriate. The inspectors had no further concerns in this are i E8.8 (Closed) Violation (50-263/96009-05)

Engineering design unverified and non-conservative. This violation involved non-conservative and non-verified assumptions contained in a calculation. The inspector verified that the calculation assumptions were adequately corrected and documente The licensee's calculation control process was not adnered to or there was a lack of attention to detail. The inspector verified that engineering and technical staff personnel attended special training on the importance of rigor and attention to detain in performing, reviewing, approving, and documenting calculations. The licensee's corrective actions

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and evaluation of the causes of the event were appropriate. The inspectors had no i further cornern E8.9 (Closed) Unresolved item (50-263/96009-07): Possible inadequate load study for the changeout of two residual heat removal (RHR) pump motors. The size of two of the motors, Nos.15 and 16, were increased to 700 hp while the other two motors, Nos.13 and 14, remained at 600 hp. The inspector questioned whether consideration of the

different current loadings for both size motors had been included in the load study l voltage drop calculation The inspectors reviewed calculation CA-97-090, "AC Voltege Study," which was performed using the DAPPER Version 4.5 computer program and condition Report

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96002796. Based on these documents, there was no significant difference in the current drawn by the different size motors and voltage drops were similar depending l upon which bus provided power to the motors.

I E8.10 (Closed) Violation 50-263/96009-09: Failure to verify that plant changes due to a canceled modification did not involve an Unreviewed Safety Question. During closeout

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l of DCP 85M042, "RHR System Pressure Upgrade Modification," Revision 1, the safety evaluation failed to provide the bases for the determination that the physical plant changes that were not retumed to their original values following the modification's i cancellation did not involve an unreviewed safety questio l Licensee engineering failed to recognize that the work completed under modification 85M042 prior to its cancellation constituted a change to the facility as described in the ,

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The inspectors verified by review of revised procedures and training commitments that the licensee's corrective actions were adequat E8.11 (Closed) Violation (50-263/96009-10): Inadequate 10 CFR 50.59 Safety Evaluation or Screening. Safety Review item (SRI)96-016 proposed 16 USAR changes with a single  !

safety evaluation. These changes involved pipe breaks at containment penetrations and appeared to be mostly editorial. Actually the changes redefined containment isolation boundaries. The evaluation dealt with moving the containment boundary based on not having to consider a high energy line break and relaxed containment leakage test criteria. Neither addressed why the licensing basis for the containment isolation system was not affected. Although the SRI provided a reason section for each identified change, not all reason sections adequately explained the basis or provided justification for the chang The inspectors reviewed the licensee's response, dated March 26,1997, and determined the actions described to be reasonable and complete. Addendum 4 to SRI 96-016 was reviewed to verify that the corrective actions described in the response had been implemented. Awls 4 AWi-05.06.03," 10 CFR 50.59 Evaluations," had been developed, implemented and training presented to appropriate plant staff. Procedures 4 AWi-05.06.01, " Safety Review Item," 4 AWi-06.01.05, " Alteration Process,"

4 awl-05.01.10. " Project Description," had been revised to include the requirements of 4 awl-05.06.03 *10 CFR 50.59 Evaluations." The inspectors had no further concerns in this are I E8.12 (Ocen) Vio;ation (50-263/96009-12): Incorrect acceptance limits included in the surveillance test procedure. An error was made in determining the effective heat exchanger transfer area which erroneously indicated an improvement in the heat exchanger transfer rate of approximately five percent. Acceptance limits in the surveillance test procedure were based on this inaccurate informatio The inspectors reviewed VIO 96009-12 and NSP's reply to the Notice of Violation. In the reply to the Notice of Violation, NSP committed to the following:

The Condition Report Process AW1 will be reviewed and additional guidance provided as necessary to help ensure corrective actions are identified and tracked related to updating of plant documents.

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Plant AWis goveming procedure content and format will be reviewed and revised I as necessary to require that bases for design document requirements and acceptance limits is provided within each procedure or by reference to an

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acceptable bases documen *

All TS, Section 3/4 procedures will be examined over the next three year period to ensure that a basis for design document requirements and acceptance limits within the procedure, or by ruference to an acceptable bases document. The

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procedure will be reviewed and revised as necessary by March 31,2000. Other procedures will be checked, as resources allow, to ensure that a basis for design document requirements and acceptance limits is properly documente j l

The inspectors noted that the commitments made by the licensee appeared to be adequate. The inspectors verified that 4 AWi-02.02.02,4 awl-02.03.03, and 4 AWi-10.01.03 were changed as per commitments. However, this item will remain

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open since the commitment to examine the TS Section 3/4 procedures is not far enough {

along in the process to determine if corrective actions are adequat I E8.13 (Closed) Violation (50-263/96009-13): Inadequate verification of a design control computer program. This violation pertained to an inadequate verification of a change to a computer program used to calculate heat exchanger capability. The original verification confirmed that the changed computer program arrived at the same numerical result as the human verifier. The verification did not question the fundamental changes being made to the program regarding the equations and instrument ranges. The inspector reviewed the revised verification and found it appropriat The licensee's calculation control process was not adhered to or there was a lack of attention to detail. The inspector verified that engineering and technical staff personnel attended special training on the importance of rigor and attention to detailin performing, reviewing, approving, and documenting calculations. The licensee's corrective actions and evaluation of the causes of the event were appropriate. The inspectors had no further concerns in this are E8.14 (Closed) Violation (50-263/96009-14): Failure to perform required surveillance testing prior to returning a RHR heat exchanger to service. The inspectors reviewed the issue and the licensee response dated March 24,1997. The actions described in the response appeared to be reasonable and complete and no similar or related problems were note E8.15 (Closed) IFl 50-263/96011-02: Inadequate cable tray labeling. The Monticello USAR states that markers are applied to cable trays at intervals not exceeding 20 feet on straight runs, at all points where trays change direction and at points adjacent to all tray junctions. Various trays in the plant did not meet these requirements.

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During this inspection, the team verified that the licensee has taken appropriate steps to assure cable trays are properly marked. Procedure MWi-8-M-4.03, " Electrical Cable,

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Wire, and Raceway identification," has been revised to require that cable trays be

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i marked as described in the USAR. The licensee currently is inspecting and replacing i tray markers in conjunction with their cable replacement activit V. Management Meetings V1 Exit Meetina Summarv The inspectors presented the inspection results to members of licensee management in an exit meeting on June 9,1998. The licensee acknowledged the information presented but indicated that more information was available to address NRC concems on corrective action issue l Additional information was provided and reviewed by the inspectors and the results were provided to licensee staff by telephone discussion on June 12,1998. This concluded the i inspectio :

The inspectors noted that several documents had been provided during the inspection that were identified as proprietary. Licensee personnel were asked to identify any additional information discussed during the inspection which might be !dentified as proprietary. No additional proprietary information was identified, i

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I PARTIAL LIST OF PERSONS CONTACTED Licensee l i

D. Ca> stens, Core Spray Systems Engineer S. Engelke, Superintendent, Electrical and Instrument Engineering j J. Grubb, General Superintendent - Nuclear Generation Services I M. Hammer, Plant Manager B. Linde, Senior Production Engineer S. Ludders, Senior Operations Specialist L. Nolan, General Superintendent of Safety Assessment J E. Reilly, General Superintendent of Maintenance C. Schibonski, General Superintendent of Engineering -

P. Tobin, Senior Production Engineer M C. Carpenter, Project Director T. Kim, Project Manager D. Roth, Acting Resident inspector A. Stone, Senior Resident inspector i

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INSPECTION PROCEDURES USED IP 37001: 10 CFR 50.59 Safety Evaluation Program IP 37550: Engineering IP 37700: Design Changes and Modifications IP 40500: Effectiveness of Licensee Controls in identifying, Resolving and preventing Problems IP 92701: Followup IP 92702: Followup on Corrective Actions for Violations and Deviations ITEMS OPENED, CLOSED, AND DISCUSSED OPENED 50-263/98009-01 URI Inadequate Bypass procedur CLOSED 50-263/96005-03 URI Operation of the core spray pumps with reduced or no water cooling to the pump motor lubricating oi / 96006-01 A VIO Inadequate operations procedur / 96006-01B VIO Inadequate surveillance test procedure /96006-05 IFl Discrepancy in the Updated Safety Analysis Repor /96009-01 IFl The Plant Technical Specifications did not address electric power requirements while shutdow /96009-02 VIO Uncontrolled design calculation /96009-03 VIO Inadequate design verification /96009-05 VIO Engineering design unverified and non-conservativ /96009-07 URI Possible inadequate load study for residual heat removal (RHR)

pump motor /96009-09 VIO Failure to verify that plant changes due to a canceled modification did not involve an Unreviewed Safety Questio /96009-10 VIO Inadequate 10 CFR 50.59 Safety Evaluation or Screenin /96009-13 VIO Inadequate verification of a design control computer progra /96009-14 VIO Failure to perform required surveillance requirement /96011-02 IFl Inadequate cable tray labelin )

DISCUSSED I 50-263/96009-12 VIO Inadequate test contro I

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l LICENSEE DOCUMENTS AND RECORDS REVIEWED DURING THE INSPECTION l

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The following is a list of licensee documents reviewed during the inspection, including

! documents prepared by others for the licensee. Inclusion on this list does not imply that NRC l inspectors reviewed the documents in their entirety, but, rather that selected sections or portions of the documents were evaluated as part of the overallinspection effort. NRC acceptance of the documents or any portion thereof is not implie Procedures l

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4 AWi-01.04.02," Plant Maintenance Organization," Revision 3 4 AWi-02.02.02," Work Procedure Reviews and Approval," Revision 7 4 awl-02.03.03," Work Procedure Preparation," Revision 9 4 awl-04.04.03," Bypass Control", Revision 9 4 awl-05.01.10," Project Description

4 awl-05.06.01, " Safety Review Item" l 4 awl-05.06.01.05, " Alteration Process" 4 awl-05.06.02,"10 CFR 50.59 Applicability Screenings," Revision 1 4 awl-05.06.03,"10 CFR 50.59 Evaluations," Revision 0 4 AW1-10.01.03," Condition Report Process," Revision 7 MP-97Q110-01, * Design Change Procedure Attachment to WO9800061," Revision 0 i MP-970110-02," Design Change Procedure Attachment to WO9800062," Revision 0 l MP-97Q255-01, " Design Change Procedure Attachment to WO 9800059," Revision 0 MP-97Q255-02, " Design Change Procedure Attachment to WO 9800060," Revision 0 Operations Manual Procedure B.4.3.2-05.G, " Combustion -Gas Control System (CGCS),

Post-LOCA CGCS Startup and Operation," Revision 4 Operations Manual Procedure B.8.13-05.04, " Control Room Heating and Ventilation and Emergency Filtration Train - Abnormal Procedures," Revision 4 SGP-06.02," Nuclear Network Screening Guide," Revision 2 SGP-06.03," External Operating Events," Revision 1 Surveillance Test Procedure 0255-05-IIA-1, "RHR Service Water Pressure Test, Loop A,"

Revision 4 Surveillance Test 0255-05-11 A+2, "RHR Service Water Pressure Test, Loop B," Revision 2 Surveillance Test 0255-05-11 A-2, "RHR Service Water Pressure Test, Loop B," Revision 2

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Surveillance Test 0255-21-111-1(2)A(B), "CGCS Test;,' Revision 15 l

Surveillance Test 0417-1(2)A(B), "CGCS Recombiner Tests," Revision 3 Surveillance Test Procedure 1136, "RHR Heat Exchanger Efficiency Test", Revisions 18 and 19 1 Modification Packages l DCP 85M042, "RHR System Pressure Upgrade Modification" l 920030 Minor Structural Modifications l 92O215 Closure of Intake Gates on Omit Switches 960015 Control Room Dose Reduction - Install Permanent Blanking Plates for the Control Room Intake Duct" 960 035 Resolution of SQUG Outliers

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i i 960040 Install Artificial Cooling for 4kV Switchgear Rooms, Revision 1 96Q150 RHRSW Air Vent Valve Modification, Revisions 0 and 1 960165 Single rod scram timing panelimprovements 97Q020 Modifications to Support Power Rerate, Part B, Revision 0 970035 Drywell Atmosphere Cooling 4-Fan Pressure Differentia'l Control Removal 970050 Containment Penetration X16B Bellows Replacement, Revision 0

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97Q065 RWCU line break isolation logic

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970090 LPCI Loop Select Timer Replacement

, 97Q110 "MO-2373/2374 Replacement," Part 0, Addendum 0, Revision 0 l 97Q130 Install Control Circuit Surge Suppression on MO-2080 l 97Q140 Rand Instrument Transformer Tap Changes 97Q215 Cross Tie to Floor Drain Collection Tank 97Q225 Upgrade EDG Fuel Oil Filters .

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97Q255 RHR Heat Exchanger Temperature Monitoring Upgrade, Part 0, Addendum 0, Revision 0 l E-98QO10 GL96-06 Containment Isolation Valve Modification to X-8 Steam Drain Line, X-17 Vessel Head Spray, and X-12 RHR Shutdown Cooling j 980020 RHRSW Motor Cooling Coil Flow Improvements j

li Temporary Modifications (Jumper Bypass)

l 94-199 Temporary flow instrumentation installed in parallel with FW flow transmitters to support performance testing 96-107 Temporary isolation Valve on GEZIP tank

'98-035 WO 97 05G39 to connect test equipment to trend feed flow vs flow demand

for rerate testing '

l 97-023 Different Spring in Actuator for VD-9111 B/P l I Plant Drawings Drawing NH-119259, "Zine Injection Passivation System (GEZIP) P & ID," Revision A Condition Reports (CRs)

93000254 Two 2" vent pipes in the EFT bldg first floor room 807 electric equipment

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Division 2 room were supported by baling wire from conduits l 96001014 Jet pump stacking tool tip dropped in reactor vessel i 96001197 CRD collet housing cracking 96001305 Foreign material in feedwater heater 96001353 12 EDG crankcase pressure alarm during ECCS test start 96001513 Valve OF-25 found in a position contrary to that identified in the prestart valve checklist 96001610 Failure to implement a temporary change to the CRD change ou. precedure 96002313 Chem wipe found in spare CSP pump motor bearing oil reservoir 96002513 Micrometer RM-10 Found Out of Calibration 96002585 AC load study - non-conservative loading assumption reactor recirc inotor loads

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96002873 Work was performed beyond 0o scope of work order 96002985 During routine annual calibration at Instrumentation Service Inc. Keithley Model 261 picoampere source found out of calibration 97000141 RHR Heat Exchanger Efficiency Test - Issues 97000182 During annual calibration gauge found out of "as found" tolerance and each point i 97000378 Electric shop megger test set voltmeter function found out of spec during routine calibration 97000392 Reportable Condition Associated with Generic Letter 96-06 Pressure Relieving Devices not Installed on Some Penetration 97000701 Torque wrench TW-073 found damaged from apparent over-range. No log entries to indicate prior use 97000770 Surface Area of the RHR/RHRSW Heat Exchanger Incorrect 97000993 NRC Commitment M97018A, Tech Spec section 3/4 procedures to be

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examined and revised as necessary for requirements / limits 97000994 NRC Commitment M97019A, Plant AWis on proc content & format review l and revise to require bases for requirements / limits 97001867 Two rags were found in the spare core spray pump motor lower oil reservoir 97001967 Procedural conflict between procedure 2188 and B.1.3 results in near miss over-pressurization of HCU 42-31 97002174 Electric shop found Columbia Electric Co. TONG Tester out of specification ,

during annual calibration j 97002189 XS-9081, Hewlett Packard model 51008 Scaler exceeded due date for l calibration l

97002542 Potential to inadvertently precondition HPCI and RCIC steam line isolation valves in tests 0056,0058,0060, and 0062 l 97002920 During vendor calibration of Keithley Model 261 picoampere source one ,

range found out of as found tolerance 98000885 Over tightening of swegelok plugs on RWCU flow transmitter calibration taps 98000925 When checking for synchronous conditions across ACB-52-309, LC 103/104 i crosstie, sync. scope showed 180*F out-of-phase l 98001036 Requirements and documentation of FME controls for activities performed

! on the refueling floor when reactor head is removed need to be clarified 98001052 A tray was hnoked over the hand rail on the refueling bridge and the hooks were not captured by tapo orlanyards ]

98001055 Two of twenty personnel observed on refueling floor did not have lanyards l on their eyeglasses 98001387 it has been brought to my attention that in some cases feedback to blue l cards originator (s) are not completed l 98001832 Bolt dropped into generator hydrogen cooler line VI. Corrective Action Records (for actions more than two years old)

84000396 Revise PM and prepare new PMs for butterfly valves 85000504 Set up process computer to monitor RPV heatup and cooldown j 87000372 Pursue possible TS changes to eliminate use of test plugs 87000505 Create computer alarm to monitor >145 'F between Rx head temps

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89000700 Complete review of CA 94-008 89000702 Prepare surveillance to test leak rate of CRD pump discharge check valve 89000703 Plant operations committee to endorse general method of analysis 89000841 Revise HPCI test and RCIC test to provide corrective action range criteria for evaluating turbine acceleration transient data 89000856 Establish a formalized 480 volt motor maintenance program 90000342 Write PM to periodically inspect backwater valves in EDG room drainage system 90000397 Develop a venting and/or monitoring methodology for explosive gases if long-term storage of spent resin in closed containers becomes necessary 91000090 Replace thermal overload relay and molded case circuit breaker i 91000348 Evaluate present procurement practices for bolting materials against the recommendations contained in NUREG 1339 91000373 Revise EDG operations manual to include a discussion of maintaining EDG jacket water temperature to the engine a 160 - 165 F 91000397 Install thermocouple capable of reading temperatures up to 450 *F on top and bottom of FW lines 91000421 Obtain temperature profiles of SRVs for use in bench testing procedure 91000568 Revise procedure (for stuck open SRV) requiring operations to initiate torus cooling to mix water ,

91000602 Complete maintenance program for the EDG to either include all I manufacturers recommendations or justify why they are not done 91000606 Develop receipt inspection checklist for EDG governors 92000126 Complete alteration 90M025 in panel C24A and C24B j 92000153 As built mod data bases. All mods performed before the formal controls were in place should be reviewed 92000156 Perform an engineering evaluation of the cables identified in NSP Calc M94-052 92000157 Replace cables identified as a result of investigation performed in corrective l action N9208509 92000159 Spare terminal blocks will be received from GE and replace all of this design 92000427 Revise USAR table to correct the applicable appendix J type test information 92000613 Following the 1993 outage inspection, prepare a routine inspection i

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procedure for the backdraft dampers of the SBGT system 93000306 Provide detailed procedure guidance similar to recirc discharge valves I

93000332 Modify MO-2029 and MO-2030 93000354 Walk down all non-safety related piping systems within the EFT building 93000360 Perform modifications to retum limit switches back to their original configuration 93000361 Perform modification to change the design so that 13 DG low water level j l alarm functions properly 93000382 Process a setpoint change request to change calibrator and readout as found tolerances to less restrictive values 93000652 Evaluate feasibility of installing excess flow check valves on generator hydrogen supply lines and drain lines 93000700 Lower the setpoint for PS 13-78 (RCIC inner rupture disc failure alarm) from 10 psig to 5 psig

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93000726 Revise MOV PM program to include appropriate motor brake activities 93000798 Establish necessary key shutdown cooling parameters and have them incorporated on the new SPDS screens for use during shutdown conditions 93000836 Complete at least a system level review of the CHAMPS equipment database to identify those systems that have potential for SCTMT boundary concerns 93000872 Update turbine maintenance manual to replace turbine protection system solenoids ever third outage 94000400 Determine feasibility of modifying the bellows leakage detection system so that tiny leaks with no detrimental affect on SRV operability will not cause an ,

alarm 94000440 Develop and/or revise dept. training plans to address the training requirements 94000479 Identify and megger those additional underground feeders which have the greatest potential to impact plant operations

94000620 Determine root cause of abnormal operation of CV 1729 94000661 Revise proc. # 0056 to provide better guidance for manually actuating relays 94000770 Revise EDG 4 cycle maintenance FMs to include identification and

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calibration due date change 1 94000872 Vendor investigating the drywell bad bolt torque criteria, as well as possible I

! downsizing of the drywell heu gasket I l

94000899 Evaluate potential effects an SCTMT for operation of and failures in the following systems and lnitiate the appropriate CARS 94001350 Prepare a consolidated " loss of heating" procedure, including secondary containment l 95000251 Rebuilt spares parts control 4 awl-06.03.01, will be reviewod and revised to l include maintenance, storage, and traceability requirements for 4 kv l

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breakers 95000281 Develop plan to prevent accumulation of, or mitigate effects of foreign l materialin the ESW pumps l 95000296 Modification on control circuit should be performed to remove positioner i from BV-8203-4 and BV-8203-5

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95000306 Obtain sufficient replacement spacer rings and o-rings / gaskets for the four j existing SBGT test trays 95000307 Revise test 0149 to explicitly describe the test cartridge and spacer ring configuration 95000308 Provide instructions in procurement documents for the charcoal test trays or j prepare a procedure for reloading the trays 95000378 Replacement bearings for all 4 kv breakers have been ordered and will be installed during outage breaker maintenance 95000419 Provide operations with periodic update of status regarding current software problems / changes 95000579 Perform a safety review item to justify the abandonr;. ant of the panel conduit seals on SV's 1728,1729,1994,1995,1996,1997 95000622 Write alteration to allow installation 95000623 Provide training to electricians

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95001129 Add operator guidance for reloading the condensate service water keep fill system to essential power prior to starting RHR or CS for loss of offsite power 95001170 Revise ops manual A.3-004 " Fire Fighting Procedures and Strategies" to include instructions on how and when to apply water safely to an electrical fire 96000013 Establish long term plan for inspection of safety related cables based on results from actions 9600013 and 9600014 96000101 Create calibration procedure (s) for instruments which provide significant input into RPT and SPIs 96000140 Consider adding an alarm to the retention ponds similar to the lift station

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96000178 Revise 8197 to allow use of more conservative test results when desired 96000306 Revise piping specification NPD-M-38 to reflect current classification of offgas system 96000350 Revise ISIisometric drawings 96000497 Monitor validated feedwater temperature for indication or instrument failure

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96000498 Improve accuracy of main steam flow computer point calculation by including a correction for steam pressure 96000499 Create alarms to wam of failed instruments for all computer points used in i

the calculation of reactor power 96000500 Save all computer points used in the calculation of reactor power 96000746 Review design changes since 1991 for cable separation 96000776 Develop method to assure that separation requirements for cable

installations are being met l 96001023 Investigate and repair the source of water leakage l 96001293 Test snubber in location RV-25-H1 A during the 1998,1999, and 2001 refueling outages to determine appropr' ate service life 96001299 Review site QA boundary for augmented quality requirements, 96001456 Add inspection criteria to Test 1297-1 to inspect physical condition of door, 1 looking for cracks, loose hinges, etc i

96001468 Place available information on fuel oil base tank level switches into plant l

controlled manual system 96001409 Repair / replace V-EF-18B flow control damper Vll. Work Orders (WOs)

WO 9600475, " Repair / replace GZP Skid components" WO 9602974, " Replace actuator for VD-9111B" l WO 9704009, Support DC 970110,4900-1PM, Votes Test for MO-2373 l WO 9800059," Installation of Thermowell on RHR A Heat Exchanger" l WO 9800060, * installation of Thermowell on RHR B Heat Exchanger" WO 9800061," Replacement of MO-2373" WO 9800062," Replacement of MO-2374" WO 9801020, " Perform Pre-operational Test of MO-2373 & MO-2374" WO 9801085 " Perform Operational Test of MO-2373 & MO-2374" 27 j l

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i Vil Miscellaneous Documents and Records Calculation CA-97-090,"AC Voltage Study" QA Report FG-97-006," Power Rerate License Amendment Request & Associated Topical reports' Accuracy" I

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LIST OF ACRONYMS USED AWI Administrative Work Instruction CFR Code of Federal Regulations CGCS Combustion Gas Control System CO2 Carbon Dioxide CR Condition Report DCP Design Change Package DRS Division of Reactor Safety EFT

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Emergency Filtration Train

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EOR Employee Observation Reports GDC General Design Criteria

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IFl Inspection Followup Item IN information Notice LOCA Loss of Coolant Accident MCC Motor Control Center OER Operating Experience Report PM Preventive Maintenance RHR Residual Heat Removal SRI Safety Review item TS Technical Specifications URI Unresolved item USAR Updated Safety Analysis Report USQ unreviewed safety question ,

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VIO Violation I XOR Extemal Operating Event I

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