IR 05000263/2022013
| ML22325A226 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 11/21/2022 |
| From: | Laura Kozak NRC/RGN-III/DORS/RPB3 |
| To: | Domingos C Northern States Power Company, Minnesota |
| References | |
| IR 2022013 | |
| Download: ML22325A226 (1) | |
Text
November 21, 2022
SUBJECT:
MONTICELLO NUCLEAR GENERATING PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000263/2022013
Dear Mr. Domingos:
On October 17, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Monticello Nuclear Generating Plant and discussed the results of this inspection with Mr. S. Hafen, and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Kozak, Laura on 11/21/22 Laura L. Kozak, Acting Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Docket No. 05000263 License No. DPR-22
Enclosure:
As stated
Inspection Report
Docket Number: 05000263 License Number: DPR-22 Report Number: 05000263/2022013 Enterprise Identifier: I-2022-013-0008 Licensee: Northern States Power Company, Minnesota Facility: Monticello Nuclear Generating Plant Location: Monticello, MN Inspection Dates: September 26, 2022 to October 14, 2022 Inspectors: L. Haeg, Project Manager R. Ng, Senior Project Engineer C. Norton, Senior Resident Inspector J. Robbins, Operations Engineer Approved By: Laura L. Kozak, Acting Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Monticello Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees problem identification and resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
Problem Identification and Resolution Effectiveness: The inspectors assessed the effectiveness of the licensees problem identification and resolution program in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a 5-year review of the reactor water cleanup system.
Operating Experience: The inspectors assessed the effectiveness of the licensees processes for use of operating experience.
Self-Assessments and Audits: The inspectors assessed the effectiveness of the licensees identification and correction of problems identified through audits and self-assessments.
Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Based on the samples reviewed, the team concluded that the licensee's implementation of the Corrective Action Program was generally effective and supported nuclear safety.
Effectiveness of Problem Identification:
Based on the samples reviewed, the team determined that the licensee continued to identify issues at a low threshold and appropriately entered these issues into the Corrective Action Program. The team also determined that the licensee usually entered problems into the Corrective Action Program completely and accurately.
The team noted that issues were being identified by all levels of organization and with varying degrees of safety significance. The licensee also utilized a number of Corrective Action Program support processes to identify problems, including the self-assessment and audit process and the Operating Experience Program. Some deficiencies were identified by external organizations that had not been previously identified by licensee staff and were subsequently entered into the Corrective Action Program for resolution. For example, the licensee performed departmental self-assessments and Nuclear Oversight audits to identify issues in station processes. The identified deficiencies and improvement opportunities were entered into the Corrective Action Program for resolution. Similarly, the licensee screened issues from both NRC and industry operating experience and entered them into the Corrective Action Program when they were applicable to the station.
As low level, as well as safety significant issues were entered into the CAP, the team determined that the licensee was generally effective at identifying trends and taking appropriate corrective actions to prevent more significant problems from developing. In addition, the licensee used the Corrective Action Program to document instances in which previous corrective actions were ineffective or were inappropriately closed.
The team performed a 5-year review of the reactor water cleanup system. Specifically, the team focused on any recurring or age-related issues of the system. As part of this review, the team interviewed the system engineer, reviewed plant health reports, and selected corrective action and condition evaluation documents. In addition, the team performed a partial system walkdown to assess the material condition of the system piping, selected components and surrounding areas. The team concluded that deficiencies and concerns were identified and entered into the Corrective Action Program at a low threshold and the corrective actions were adequate and timely, commensurate with their safety significance.
Effectiveness of Prioritization and Evaluation of Issues:
Based on the samples reviewed, the team determined that licensee performance was generally effective at prioritizing and evaluating issues commensurate with the safety significance of the identified problem. In general, once a degraded or non-conforming issue was identified, the CAP process was effective in directing equipment operability/functionality review. The licensee pre-screened issues at the site level and then formally dispositioned the issues at the Fleet CAP Screening meeting. During the meetings the team observed, licensee staff were generally thorough and intrusive in reviewing and screening issues. The team also observed healthy dialogue and good interactions among the members of the screening groups. The members came prepared and challenged each other on disposition of the identified conditions. Actions were prioritized based on the safety significance of the issues.
Effectiveness of Corrective Actions:
Based on the samples reviewed, the team determined that the licensee was generally effective in implementing corrective actions. In general, corrective actions for deficiencies that were safety significant were implemented in a timely manner. Problems requiring the performance of a root cause evaluation or other causal evaluation methodologies were resolved in accordance with Corrective Action Program requirements. The team sampled assignments associated with violations that were identified by the NRC previously, and with licensee event reports (LERs). The team determined that the corrective actions sampled were generally effective and timely.
The team noted a few examples of minor process issues with the Corrective Action Program.
For example, following the 2021 refueling outage, a corrective work order tied to a corrective action to enact repairs on an isolation valve was allowed to be cancelled, and a Procedure Change Request (PCR) tied to a corrective action was allowed to be inappropriately postponed beyond the next refueling outage in 2023. Due to other programmatic barriers, this valve would not have been allowed to be tested at an extended frequency against the requirements of Title 10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors Program. Also in 2021, following a B severity level event where workers were not signed on to a clearance order, the corrective action to evaluate the process was closed to no action. Because additional actions were taken that were not directly linked to the apparent cause, the condition adverse to quality was corrected.
Lastly, a PCR tied to a corrective action to improve guidance within the fleet valve packing procedure was found to have a lower priority incorrectly assigned. Although this lower priority didnt impact how the PCR would have been handled in the CAP, the inspectors observed that it could have resulted in the corrective action not being taken in a timely manner. These minor process issues are documented here to emphasize the overall importance of effective and timely corrective action. The licensee entered these issues into the Corrective Action Program for evaluation.
Assessment 71152B Based on the samples reviewed, the team determined that licensee's performance in the use of operating experience was generally effective. The licensee screened industry and NRC operating experience information for applicability to station. Based on these initial screenings, the licensee-initiated actions in the Corrective Action Program to fully evaluate the impact, if any, to the station. When applicable, actions were developed and implemented under the Corrective Action Program to prevent similar issues from occurring. Operating experience lessons learned were communicated and incorporated into plant operations. The team observed the information being used in daily activities, such as pre-job briefs, as well as Corrective Action Program issues reviews and investigations. As stated in the Corrective Action Program assessment section, the licensee screened issues as a fleet and as such the use of operating experience was inherent to Corrective Action Program implementation.
Assessment 71152B Based on the samples reviewed, the team determined that the licensee's performance of self-assessments and audits was generally effective. The licensee performed department self-assessments and quality assurance audits throughout the organization on a periodic basis. These self-assessments and audits were generally effective at identifying issues and enhancement opportunities at an appropriate threshold. The self-assessments and audits reviewed by the team identified issues that were not previously known, including issues within the Corrective Action Program itself. Nuclear Oversight (NOS) had identified deficiencies with the licensee's processes and those issues were addressed by the station using the Corrective Action Program.
Assessment 71152B The team assessed the safety-conscious work environment (SCWE) at Monticello Nuclear Generating Plant. The teams conducted individual interviews and facilitated supervisor and worker focus groups. The team also reviewed CAP documents, Nuclear Safety Culture Monitoring Panel reports, the results of Pulse Surveys, and the 2022 Safety Culture Assessment. The team did not identify any SCWE issues. The team concluded that an environment exists at Monticello where personnel were free to raise nuclear safety concerns without fear of retaliation. No issues of concern were identified.
Minor Violation 71152B Minor Violation: During this inspection, the team reviewed the licensee's scaffold program due to a number of issues related to the proximity of scaffolding to safety-related systems, structures, and components.
Licensee fleet procedure FP-MA-FSC-01, Scaffolding, Revision 0, establishes that scaffold placed on top of the torus may be supported from the torus shell as long as a 2-inch clearance is maintained between the scaffold and any permanent structure. The weight of the scaffold and its payload was also required to be less than 750 pounds. Scaffolding attached to, resting on, or supporting safety-related systems or ISFSI important to safety systems required an engineering evaluation and approval from the plant's Operations department.
Further, FP-MA-FSC-01 required that documentation of the scaffold evaluation and approval be retained on form QF1817 in accordance with FP-G-RM-01, Quality Assurance Records Control. During a walkdown of the scaffoldings in the reactor building, the team identified that scaffold 89 was constructed on top of the torus and did not maintain a 2-inch clearance from the reactor building wall. The team questioned the licensee regarding the acceptability of the scaffolding considering those procedural requirements. The licensee was unable to produce form QF1817 for scaffold 89 that detailed the engineering evaluation and approval of the build. On October 4, 2022, the licensee reevaluated and reperformed the scaffold approval for scaffold 89. After determining that the scaffold was acceptable, the licensee documented such on QF1817, under Approval Number 602000009397.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that the performance deficiency was minor as it was similar to Appendix E, "Examples of Minor Issues," example 4.a, where a subsequent evaluation determined that there was no safety concern. Specifically, the licensee reperformed the engineering evaluation and determined that the scaffold configuration was acceptable. The licensee entered this issue into the CAP as 501000066951.
Enforcement:
Title 10 CFR Part 50, Appendix B, Criterion XVII, Quality Assurance Records, requires in part that sufficient records shall be maintained to furnish evidence of activities affecting quality and the records shall be identifiable and retrievable.
Contrary to the above, the licensee did not maintain and could not retrieve records to furnish evidence of activities affecting quality. Specifically, the licensee did not maintain and could not retrieve the engineering evaluation that determined the configuration of scaffolding that was attached to a safety-related structure and resting on the torus, a safety-related component, was acceptable.
This failure to comply with 10 CFR 50, Appendix B, Criterion XVII constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 14, 2022, the inspectors presented the biennial problem identification and resolution inspection results to Mr. S. Hafen and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71152B Corrective Action 500000313882 Condition Evaluation: Internal Contamination 985 RWPR 10/12/2022
Documents 500001474449 XR-27-1 Had Excessive Leakage During Leak Rate Testing 04/14/2015
500001481220 Temperature Rating of Sprinkler Nozzle Appears Incorrect 05/30/2015
500001486523 MOV SSA: Offsite Power Transient Degraded Voltage 07/17/2015
Analysis
500001496761 Potential Non-Conservative Tech Spec for EDG Voltage 10/14/2015
500001517339 EDG Room and Cabinet Temperature Calculation Issues 03/30/2016
500001527265 Elevated Temperature in SBGT Room 07/05/2016
500001547508 CV-1995 Did Not Open on a Shutdown of 12 RHR Pump 01/14/2017
501000001720 External OE: Fermi NCV for TOL Sizing 08/16/2017
501000005677 URI for Blast Analysis14-068 11/20/2017
501000009081 AA NRC Insp Obsv - Vital Area Access 03/02/2018
501000010409 Lower Insoluble Cu Deposition on Fuel 04/20/2018
501000010436 Legacy FW Temperature Input Issue 04/06/2018
501000015104 Snubber C-22 Shows Accelerated Wear 08/02/2018
501000019500 NOS: Fire Doors Not Validated to Tech Eval 03/03/2021
501000020085 'C' Outboard MSIV Failed to Stroke 11/16/2018
501000020811 Loss of Comp. Assessment in CAS / SAS 12/06/2018
501000020960 Potential Adverse Trend on Sec UPS 12/11/2018
501000024706 Door-43, HPCI to Tank Room, Seal Loose 03/27/2019
501000025875 MO-2076 RCIC Otbd Over App J Admin Limit 04/19/2019
501000026810 RWCU Flow FT-12-4-75A 0 Flow Off Calibration 05/03/2019
501000027548 Shutdown Safety Lessons Learned From ACE 05/17/2019
501000027682 Drywell CAM Reading Trending Upward 05/21/2019
501000027946 ECCS Leakage Program Boundary - HPCI/RCIC 05/30/2019
501000028365 AS-78, AS-79 Found Open 06/11/2019
501000031053 ESW-1-2 IST Test Not Performed in 1R29 08/21/2019
501000032661 Updates to Access Review List (ARL) 10/03/2019
501000036077 SAP Functional Locations, Security Equipments 12/26/2019
501000036402 Receipt Issues with Refurbed MSIV Actuators 01/09/2020
501000037221 2020 FP Insp: Fire Flow Test Concerns 01/30/2020
Inspection Type Designation Description or Title Revision or
Procedure Date
501000040114 Operating Permit Use Issue Identified 04/29/2020
501000040145 Suspected RC-50-2 Seat Leakage 04/30/2020
501000040279 Documentation Error in Calc 14-037 05/05/2020
501000040878 Void was Found at Location CSP-B10 05/21/2020
501000042946 ANS Siren Actuation Test Issue 08/06/2020
501000043536 Dr-25 Not Design HELB Water Ht. 08/26/2020
501000044138 TSC Vulnerability 09/15/2020
501000044842 Anonymous CAP: Security LTA PI&R 09/29/2020
501000045576 Downgrade of NLO Must Perform Tasks 10/16/2020
501000045723 Improvement Opportunity for HELB 10/22/2020
501000045769 Apparent Cause Evaluation: CV-1052 demand signal went to 0
100%
501000048045 Apparent Cause Evaluation: LHRA T.S. Compliance/Dose 0
Rate Alarms
501000048823 Comanche Peak OE - Grid Frequency 02/18/2021
501000048909 EPRI Part 21 Info Transfer - DLL 3.1 02/23/2021
501000048959 EPRI Part 21 Limitorque Fatigue Life 02/23/2021
501000049788 Lack of Contingency for CAP 501000047989 03/23/2021
501000050558 Apparent Cause Evaluation: Late Identified Scheduled Risk 04/16/2021
501000051042 RWCU/RBCCW Drain Improvement 04/25/2021
501000051048 MO-2397 Exceeded Appendix J Administrative Limit 04/25/2021
501000051150 MO-2397 Failed Leak Rate Test (0137-12) 04/27/2021
501000051151 MO-2398 Failed Leak Rate Test (0137-12) 04/26/2021
501000051496 MO-2397 Exceeded Appendix J Administrative Limit 05/04/2021
501000051763 EDG Relay Failed to Pick Up 05/09/2021
501000051829 MO-2-3/43A Pressure Lock Damage 05/12/2021
501000053565 Inattentive Officer 06/28/2021
501000053835 Apparent Cause Evaluation: Loss of Security Power During 07/07/2021
298-02
501000054313 NOS: Clarity on Termination Timeliness 07/23/2021
501000054841 Unexpected Security Response 08/07/2021
501000056255 GEH Safety Communication 21-07 R0 Issued 09/21/2021
501000056520 TSO Notification Voltage Violation 09/28/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
501000056540 RMAs Not Entered for Yellow Risk 09/29/2021
501000057782 P-160B PMT Didn't Have 3108 Step 10/27/2021
501000058188 12 SBLC Pump Flow High Out of Band 11/10/2021
501000058336 Mid-Cycle Gap to Excellence PI.1-14 11/16/2021
501000058604 Unauthorized USB Media Used on CDA 11/23/2021
501000059356 Issues found on 4KV Sec Disc EAASHG-1's 03/15/2022
501000059738 DWFDS ROC Increase 01/13/2022
501000059965 Inattentive Security Officer 01/22/2022
501000059988 Apparent Cause Evaluation: XR-7-2 Body to Bonnet Leak 1
Identified
501000061303 PART 21 Lists Prairie Island impacted 06/17/2022
501000061419 ECR Cancelled Due to Lack of Funding 03/18/2022
501000062426 NRC Obs. Security Defensive Positions 04/20/2022
501000062468 EDG FO Pumps Found Running, 12 EDG Inoperable 04/21/2022
501000062473 CAPR Re-evaluation 04/22/2022
501000062808 Steam Leak on MS-23-2 05/05/2022
501000063050 Door 209 Ingress Reader 05/12/2022
501000063075 MS-24-2 Packing Leak 05/13/2022
501000063092 Steam Leaks Mean High Post-LOCA Dose 05/13/2022
501000064506 Evaluate Comp Measures for Harmonics PM 07/07/2022
501000064672 RWCU Trip 07/12/2022
600000834812 Effectiveness Review of CAP Training 11/29/2021
600000899222 NRC PART 21 2020-33-00 07/16/2021
600000966000 NRC PART 21 2021-27-00 02/01/2022
600001027260 NRC PART 21 2022-05-00 07/15/2022
610000001120 INPO Rapid OE: Weakness in Rad Shipping 12/01/2021
610000001195 OEER: NRC RG 1.200, Rev 3 02/25/2021
610000001343 OEER: NRC RG 1.205 Rev. 2 07/16/2021
610000001394 Operating Experience Evaluation (OEER) NRC RG 1.175 R1 09/01/2021
610000001433 OEER: NRC RG 1.21 Revision 3 09/15/2021
Corrective Action 501000066808 2022 PIR ACE Closure Quality 09/29/2022
Documents 501000066840 22 PIR No Open WO for MO-2397 09/29/2022
Resulting from 501000066842 22 PIR Inadequate Action Closure 09/30/2022
Inspection Type Designation Description or Title Revision or
Procedure Date
Inspection 501000066875 22 PIR - EWI-08.06.02 Figure 1 10/03/2022
501000066884 22 PIR - Incorrect Priority Placed on CA 10/03/2022
501000066939 Gaps Identified in Scaffold Proc Use 10/05/2022
501000066944 Questions on Torus Scaffold Ladder 10/05/2022
501000066951 Loss of Documentation 10/04/2022
501000067024 22 PIR Wrong Basis for Mgmt. Exception 10/07/2022
501000067049 22 PI&R Inaccuracies Identified in SSA 10/10/2022
501000067096 22 PIR ACMP Closure Action Documentation 10/11/2022
501000067108 22 PIR Procedures Not Updated Timely 10/11/2022
501000067109 22 PIR CAPs Closure Quality 10/11/2022
501000067156 22 PIR Improper Due Date Extension 10/12/2022
501000067611 22 PIR Closure Quality Pot Trend 10/20/2022
Miscellaneous Adverse Condition Monitoring Plan - Drywell CAM Reading 05/31/2019
Trending Upward
A-OPS-MNGP- 2021 Nuclear Oversight Audit of Monticello Nuclear 02/26/2021
21-1 Generating Plant Operations/Chemistry
Nuclear Oversight MNGP NOS FLEX Special Audit 2018 02/08/2018
Audit Report A-
FLEX-MNGP-
2018-1
Nuclear Oversight Maintenance 05/02/2022
Audit Report A-
MAINT-MNGP-
22-1
Utilities Service Xcel Energy Nuclear Safety Culture Assessment 2022 06/23/2022
Alliance Nuclear
Safety Culture
Assessment
Procedures 0275-03 Fire Door Inspections 47
297-02 PAL UPS / Security UPS Battery 28
Operability Check - Quarterly
297-02 PAL UPS / Security UPS Battery 29
Operability Check - Quarterly
298-02 Security System Emergency Generator 31
Inspection Type Designation Description or Title Revision or
Procedure Date
Operability Check & Alarm
B.09.03-05 - H.5 System Contingency Voltage Notification 46
EWI-08.06.01 MNGP Primary Containment Leakage Rate Testing Program 24
EWI-08.06.02 LLRT Extended Eligibility Determination 11
FG-G-PCR-01 Procedure Change Request (PCR) Initiation, Screening, and 26
Processing
FG-PA-EVAL-01 Evaluation Methods 6
FP-MA-FSC-01 Scaffolding 0
FP-MA-VPI-01 Valve Packing Installation and Adjustment 1
FP-OP-OL-01 Operability 22
FP-PA-ARP-01 CAP Process 62
FP-PA-ARP-03 Management of Change (MOC) Process 18
FP-PA-OE-01 Operating Experience Program 32
FP-PA-SOER-01 Significant Operating Experience Report (SOER) Processing 12
FP-S-AA-01 Access Authorization Program 36
FP-S-FSIP-07 Access Controls 21
FP-STND-SCP- Station Common Priority Scheme 9
Self-Assessments 602000016617 Review of Open CAP Activities with Management Exception 03/31/2022
LTA Flag
2000016617 2021 CAP CA Quality Closure Snapshot 12/31/2021
606000001164 2020 CAP CA Closure Snapshot 12/31/2020
606000001196 Implementation of Flexible Power Operations (FPO) 02/10/2021-
Following Receipt of a MISO Award 02/14/2021
606000001365 Access Authorization Snapshot 10/29/2021
606000001381 Security Review of Part 37 Program Snapshot 12/01/2021
606000001406 2021 NRC EP Exercise and Inspection 06/2021-
07/2021
606000001553 FSA: Problem Identification & Resolution at MNGP 03/25/2022
A-CYBER-FLT- 2021 Nuclear Oversight Audit of Fleet Cyber Security and 08/19/2021
21-1 Security
A-SEC-FLT-2020- 2020 Nuclear Oversight Audit of Fleet Security and Cyber 08/20/2020
Security
Inspection Type Designation Description or Title Revision or
Procedure Date
Work Orders 700052249 QIM_501000024706_Door-43, HPCI to Tank Room, Seal 03/29/2019
Loose
700055395 Reactor Steam Supply Valves Leak Rate Testing 05/10/2021
700066828 Perform 8905 Prior To CSP Venting DIV 2 02/23/2021
700082979 UPS-PAL-1 2YR PM 09/15/2021
700083080 UPS-PAL-2 2YR PM 04/16/2021
13