IR 05000443/1997009

Insp Rept 50-443/97-09 on 971215-18 & 980120-21.Violations Noted.Major Areas Inspected:Maint

ML20203E417
Person / Time
Site:	Seabrook
Issue date:	02/20/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203E395	List: IR 05000443/1997009 ML20203E390 ML20203E409
References
50-443-97-09, 50-443-97-9, NUDOCS 9802270045
Download: ML20203E417 (19)

Text

. - _ _ _. -. -. _ _ _. _. _..

.. _ _ _._ _. _. _ _ __.. _ _.._. _ ___.-_.. _ _ _ _.. _ _.. _._.. _ _ __

i -

.

A d

'

U. S. NUCLEAR REGULATORY COMMISSION

REGION 1

,

Docket No:

50-443

License No:

NPF-86 Report No:

50-443/97 09 c

!

Licensee:

North Atlantic Energy Service Corporation

>

Facility:

Seabrook, New Hampshire 03874

-

.

Location:

Post Office Box 300 Seabrook, New Hampshire 03874

,

,

-

!

Dates:

December 15,1997 - December 18,1997 and

!-

January 20,1998 - January 21,1998

Inspector:

Keith A. Young, Reactor Engineer, DRS, EEB

!

Approved by:

William H. Ruiand, Chief Electrical Engineering Branch Division'of Reactor Safety

'

-

i A

9802270045 980220

PDR ADOCK 05000443 G

PDR

,

.

_

_

_

. _...

_. _ _

_

.

_-__-_- _

.

.

..

..

.

.

.

EXECUTIVE SUMMARY Seabrook Generating Station, Unit 1 NRC Inspection Report 50-443/97 09 The report covers a six day inspection conducted by a regional engineering inspector.

Maintenance j

Based on the inspector's review of documents re, lated to Seabrook Station's M&TE calibration program "ocluding procedures, root cause analysis, and engineering evaluation)

and on his interviews of the M&TE staff, the inspector concluded that:

The MixTE calibration program at Seabrook Station is acceptable with the exception

of the noted violations. (Section M3.1)

The instrumentation and control (l&C) technician's use of procedures and equipment

to perform calibrations of M&TE is acceptable. Also, the M&TE morning meetings are useful for discussing current and future M&TE issues. These meetings allow for

- the open exchange of ideas in the M&TE laboratory. (Section M4.1)

ii

,

e

.

Reoort Details 11. Maintenance M3 Maintenance Procedures and Documentation M3.1 Measurina and Test Eauioment (M&TE) Procedure and Document Review a.

Insoection Scoce (35750)

The purpose of this inspection was to evaluate and determine the adequacy of the M&TE calibration program at Seabrook Station. The inspector reviewed the administrative procedure that provides control of calibrating M&TE, reviewed set point methodology, and reviewed severalissues related to the adequacy of the M&TE calibration program. The inspector also reviewed the M&TE Change Management Plan including root cause analysis and reviewed = elected station operating procedures, b.

Observations and Findinos The inspector found that the M&TE calibration program at Seabrook Station was acceptable with the exception of the violations outlined in section M3.2 and the unresolved issue associated with section M3.5. The inspector reviewed several M&TE calibration issues as discussed in sections M3.3, M3.4, M3.6, M3.7, M3.8, M3.9, and M4.1 to substantiate that an acceptable M&TE program was in place at Seabrook Station, c.

Conclusions The inspector concluded that the M&TE calibration program at Seabrook Station was acceptable with the exception of the noted violations and an unresolved issue.

M3.2 Procedure MA 2.3 Review a.

Insoection Scope (35750)

The inspector reviewed procedure MA 2.3, " Control and Calibration of Measuring and Test Equipment," Revision 15, to determine implementation of accuracy ratios between the procedure and the UFSAR. The inspector also reviewed procedure -

MA 2.3 to determine its adequacy.

b Observations and Findinas The inspector found differences between how the UFSAR and the implementing procedures applied M&TE accuracy ratios. The UFSAR, section 17.2.12.3 required a 4:1 accuracy ratio to be maintained from the primary standard to the end use equipment and procedure MA 2.3 required a 4:1 accuracy ratio to be maintained from the primary standard to the field standard. The inspector confirmed that-procedure MA 2.3 had not been updated to control M&TE accuracies from primary to end use equipment as stated in the UFSAR. Furthermore, the inspector noted

.

_

_ _ _ _ _ _ _ _ _ _ _

__ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.-

-..

.

2 that procedure MA 2.3 had been previously changed without the licensee performing a 10 CFR 50.59 evaluation. The inspector determined that the licensee changed procedures as described in the UFSAR and failed to perform a written safety evaluation to determine that the change did not involve an unreviewed safety question. Specifically, the licensee changed procedure MA 2.3 and failed to perform a written safety evaluation to determine that no unreviewed safety question existed. This was a violation against 10 CFR 50.59(b)(1). (VIO 50-443/97 09 01)

The inspector also found that procedure MA 2.3 was inadequate in that it did not require a formal evaluation of the impact of revised M&TE on the end use equipment or engineering verification. The inspector found that the licensee's control of M&TE allowed revisions to M&TE without formal review and is not consistent with the requirements of 10 CFR 50, Appendix B, Criterion Xil, " Control of Measurement and Test Equipment" and with UFSAR Section 17.2.12.3,

" Calibration," which states, "Less accurate standards may be acceptable when the use of such standards and the basis of calibration acceptance is authorized and documented." (VIO 50-443/97 09-02)

c.

Conclusions The inspector concluded that procedure MA 2.3 and the UFSAR differed in how they apply M&TE accuracy ratios and that procedure MA 2.3 was inadequate in that it allowed M&TE to be accepted without engineering or end use evaluations.

M3.3 Instrument Setogint Document Review a.

Insoection Scooe (35750)

The inspector reviewed document number 39140, " Instrument Setpoint,"

Revision 1, to verify if M&TE accuracy assumptions from the M&TE to eno use equipment was bounding for setpoint calculations, b.

Observations and Findinas The inspector verified that the M&TE accuracy assumptions from the M&TE to end use equipment was bounding for setpoint calculations. The inspector found that section 5.5.1, " Measuring and Test Equipment Accuracy" maintained the 4:1 accuracy ratio from the primary standard to end use equipment and provided a basis for bounding setpoint calculations. The inspector noted variables in the setpoint calculation equation allowed for M&TE accuracy assumptions and bounds setpoint calculations. The inspectar dete mined that this was acceptable.

c.

.Qpoclusions The inspector concluded that M&TE accuracy assumptions from the M&TE to end use equipment was bounded within setpoint calculations.

-.

..

.

-.

..

--

- ____

-

_ -. _ - -

_ - -.. --

. -

. -.

.-

--

--

,

,

,

M3.4 Calibration of Eouloment by Non Aooroved Subtler Vendors

,

a.

insoection Scoce (35750)

The inspector reviewed the licensee's actions of calibrating some equipment by non-approved subtier vendors to determine if this was a wide spread problem at Seabrook Station.

b.

Observations and Findinag The inspector found that there was no wide spread problem of equipment being calibrated by non-approved subtler vendors at Seabrook Station. The inspector reviewed adverse condition report (ACR) 961281, and found that the instance in which this occurred was isolated to one vendor. ACR 961281 identified accelerometers being shipped to Hayes instruments for calibration and Hayes Instruments forwarding the devices to their original manufacturer for calibration.

The licensee identified s 7 pieces of equipment that was calibrated by a non-approved subtier vendor, in all cases, the calibration was performed by the original

equipment manufacturer to the equipments specifications. Additionally, the inspector found that the purchase order provides control of what vendor is authorized to calibrate equipment and the receipt inspection program provided checks and balances to determine if a non approved vendor was used. The

Inspector found no further instances of equipment being calibrated by a non-approved vendor, c.

Conclusions The inspector concluded that there was no generic problem with non-approved equipment calibration at Seabrook Station and acceptable equipment calibration controls were in place.

M3.5 Calibration of Instrumentation to a Lessor Accuracy a.

insoection Scoce (35750)

The inspector reviewed the licensee's actions of calibrating instrumentation to a lesser accuracy than specified by procedures without being identified as restricted or needing evaluation a broad problem at Seabrook Station.

b.

Observations and Fir.dinas The inspector found that the licensee has not completed their overall review of the impact of revised M&TE accuracies. The inspector found through discussions with licensee personnel, that an effort to perform an assessment on allinstruments to determine safety significance was instituted. This issue remains unresolved pending licensee completion of their review and subsequent review by the NRC.

(URI 50-443/97-09-03)

'

.

.

c.

Conclusions -

The inspector concluded that the licensee had not completed their review of revised M&TE accuracles.

M3.6 Eauioment Not Calibrated at Standard Conditions a.

insoection Scone (35750)

The inspector reviewed the licensee's actions of not calibrating equipment at standard conditions to determine if M&TE temperature effects are bounded by engineering calculation M&TE assumptions including sttpoint methodology assumptions.

b.

Qbservations and Findinas The inspector found the licensee had performed an evaluation of equipment not being calibrated at standard conditions. The inspector found the licensee's evaluation of this issue to be consistent with ISA S67.04,"Setpoints for Nuclear Safety-Related Instruments," concerning the Root Sum of the Squares (RSS)

treatment of M&TE uncertainties included M&TE temperature effects. The inspector also found that the licensee's evaluation of this issue adequately addressed the broad imp!ications of calibrating M&TE at non-standard conditions. Additionally, the inspector reviewed calculation CAL-R 1, " Reactor Protection System (RPS)-

Engineered Safety Features (ESF)/ Actuation," and verified that M&TE temperature effects are bounded by engineering calculation M&TE assumptions including set point methodology assumptions.

c.

Conclusion The inspector concluded that the licensee's evaluation of equipment not being calibrated at standard conditions to be acceptable 4nd that M&TE temperature effects were bounded by engineering calculation M&TE assumptions including set point methodology assumptions.

M3.7 Enaineerina Evaluation Review a,

insoection Scope (35750)

The inspector reviewed engineering evaluation SS EV-0021, Revision 1, to determine if the licensee had updated this document to eliminate the reference to a draft standard.

b.

Observations and Findinas The inspector found that the licensee had updated engineering evaluation SS-EV-0021, Revision 1 to eliminate the reference to a draft standard (ISA-dS67.06, Response Time Testing of Nuclear Safety-Related instrument Channels in Nuclear

,

-

-

.

..

.

.

.

___

__ __ _ _ _ _ _ _. _ _ _ _ _. _ - _ _ - - _ _ _

_ _ __ - _ -

.

5 Power P.its). The inspector found that the licensee had changed this reference to ISA S67.06-1984, the appropriate document to reference. The inspector agreed

!

with this change, c.

Conclusions The inspector concluded that ISA S67.06-1984 was the appropriate document to reference in the licensee's engineering evaluation.

M3.8 Chance Manaaement Plan and Root Cause Analvsis Review a.

Insoection Scooe (3'125_Q)

The inspector reviewed the Change Management Plan and the Root Cause Analysis to evaluate the adequacy of the licensee's actions to restructure the M&TE calibration program at Seabrook Station, b.

Observation and Findinas The inspector found that the licensee's plans to restructure the M&TE calibration program was presented through implementation of the Change Management Plan.

The inspector reviewed the Change Management Plan, approved December 13, 1997, which outlines restructuring of ths M&TE process to meet the needs of Seabrook Station. The restructuring effort was the result of several corrective actions outlined in the M&TE Calibration Facility Evaluation and Root Cause Analysis, conducted from May-13,1997, through July 15,1997, and Seabrook Station Measuring and Test Equipment Organizational and Programmatic Root Cause Analysis Phase ll Results, approved September 23,1997. The inspector determined that these correctivs actions were scheduled to be implemented into the M&TE calibration program and are expected to address deficiencies in the M&TE calibration program as outlined in the root cause analysis. The inspector noted that the schedule in the Change Management Plan is expected to implement these corrective actions by December 1998. These corrective actions included technical basis documentation and validation, M&TE ucer program restructuring, M&TE administrative program restructuring, sool control user programs and response to ACR-recommenJed corrective actions.

c.

Conclusions-The inspector concluded that the actions taken by the licensee to restructure the M&TE program at Seabrook Station were acceptable.

.

_

__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

_ _ _ _. - _ _ - _ _

_ _. _

.

t

\\

'

M3.9 Review of Selected StatimOceratina Procedures a.

inspection Scoos (35750)

The inspector reviewed several randomly selected station operating procedures for calibrating M&TE to determine the adequacy of these procedures.

b.

Observations and Findinas

,

The inspector found that the randomly selected station operating procedures were adequate for performing calibrations of M&TE. The inspector reviewed the following station operating procedures for calibrating M&TE.

ID0601.002, *M&TE Calibration for Fluke Model 8600A Digital Multimeter,"

-

Revision 5; ID0601.245,"M&TE Calibration for Fluke Model 8840A", Revision 0;

ID0601.106,"M&TE Calibration for Torque Wrenches," Revision 5;

ID0601.018,"M&TE Calibration for Fluke 80T 150Temperatu'e Probe,"

F.evision 5; ll>060 s.110, *M&TE Calibration for Omega 450 Series Digital e

Thermometers," Revision 4; MTDI 11 1, "M&TE Calibration for Outside Micrometers," Revision 1;

MTDI 1020, "M&TE Calibration for AMP Crimping Tools," Revision 0; and

1D0601.104,"M&TE Calibration for Fluke 2168A Digital Thermometer with

Probe," Revision 2.

The inspector found thal the procedures had adequate procedural steps to perform acceptable calibrations of the identifkd M&TE. This included proper calibration standard preconditioning (equipment warm up), equipment to be calibrated g

preconditioning, and environments.1 determinations for calibation. The inspector also found that the procedures contained appropriate documentation including maintenance record, test equipment specification sheet, calibration form, data form, tool control system usage record, and checkout sheet. All reviewed procedures appropriately maintained a 4:1 or better accuracy ratio between the M&TE and the end use :quipment, c.

Conclusions The inspector concluaed that the reviewed statinn operating procedures were adequate to perform calibrations of M&TE at Seedrook Station.

.-

-

.

.. _ - - _. -.,

- _ -..

-

.. --.

.

.. -.

..- -

,

- - -

._

_.

-_

.

- - -

-

- _ _ _ _

. _ _ - -

.

.

M4 Maintenance Staff Knowledge and Performance M4.1 Witness Calibration of M&TE and Observation of Mornina Meetina a.

Insoection Scopo (36750)

The inspector witnessed the calibration of a selected piece of M&TE equipment to evaluate staff knowledge of the calibration process. The inspector also observed a M&TE morning meeting to determine if relevant M&TE issues were discussed and if the M&TE staff had a questioning attitude toward each other and the M&TE supervisor, b.

Obseryations and FindiDat The inspector found that the M&TE staff had sufficient knowledge of the calibration process. The inspector randomly selected a Fluke 8810A Digital Multimeter (ID# FLS 756) to witness the M&TE calibration process. The calibration was performed by an instrument and control (l&C) technician who used the appropriate procedure (ID0601.071, Revision 3) for the equipment being calibrated to begin the calibration process. The inspector reviewed the procedure and found that the appropriate documentation and procedural steps were in place to perform an acceptable calibration of the selected M&TE. The l&C technician properly warmed-up the calibration standards and equipment to be calibrated, determined and recorded proper environmental conditions, determined if the 4:1 accuracy ratio was being maintained between the primary standard and end use equipment, and selected the appropriate data forms to record the parameters of the equipment being calibrated. The inspector noted that all primary standards used for this calibration had valid calibration stickers. The inspector found that the l&C technician was knowledgeable about the procedure and the equipment used to calibrate the M&TE.

The inspector also noted that proper procedural steps were in place to disposition primary standards that do not meet the 4:1 criteria. Discussions with other l&C technicians reveled that the licensees approach tu M&TE calibration process was uniform. The inspector concluded that the approach to the calibration for this particular piece of M&TE was acceptable.

The inspector found that the M&TE morning meetings wcre useful for information exchange of relevant M&TE issues and that the M&TE staff had a questioning attitude toward each other and the M&TE supervisor. On December 17,1997 the inspector observed a M&TE morning meeting which is said to occur every Monday, Wednesday, and Friday. When necessary, ad hoc meetings were called by the l

M&TE supervisor. The meeting was attended by seven M&TE personnel (the M&TE

supervisor, four technicians, and two administrative assistants). The inspector noted that the meeting provided pertinent information to the M&TE staff concerning current and future issues. Issues covered in this meeting concerned plant status, training, current ACR status, equipment needs, and personnelissues. Tha inspector noted that M&TE I&C technicians and administrative assistants freely voiced opinions. They also showed a questioning attitude toward each other and the

!

_. _ _ _

_ _.. _ _ _ _ _ _. _ _ - _ _ _. _ _ _ _ _ _ _

_. _ _ _ _ _ _ _. _ _. _ _. -

-

t

8 M&TE supervisor. The M&TE supervisor responded to the staff appropriately. The inspector determined that these meetings are useful for the M&TE staff and are

'

effective at keeping communications open between the staff and management.

c.

Conclusions The inspector concluded that the M&TE l&C technician's use of procedures and equipment to perform calibrations of M&TE was acceptable. The inspector also

~

concluded that the M&TE morning meetings were useful for discussing current and future M&TE issues and these meetings allowed for open exchange of ideas in the M&TE laboratory.

V. Mananoment Meetinas X1 Exit Meeting Summary i

The inspector prraented the inspection result:: to members of licensee management at an

exit meeting on s;inuary 21,1998. The licensee acknowledged the findings presented.

~1 The inspector asked the licensee whether any material reviewed during the inspection

'

should be considered as propnetary information. No proprietary information was identified.

.

The I!censee provided briefing information on the M&TE calibration program at Seabrook I

Station to the inspector af ter the entrance meeting was completed. This information is provided as an enclosure 2 to this inspection report.

!

- -

-

.-

.

.

_ _ _,

. _ _ _ _ -

_.

.

.

PARTIAL LIST OF PERSONS CONTACTED Seabrook W. Alcusky, Instrumentation & Control Engineer R. Bergeron, Electrical Engineering Manager A. Chesno, Maintenance Technical Manager R. Coonay, Assistant Station Director B. Drawbridge, Director of Services W. Hinton, Metrology Laboratory Supervisor M. Makowicz, Corrective Action Manager G. Mcdonald, Nuclear Quality Manager M. Ossing, Senior Project Engineer J. Peschel, Regulatory Compliance Manager J. Peterson, Maintenance Manager HILQ R. Lorson, Senior Resident inspector J. Brand, Resident Intern W. Ruland, Chief, Electrical Engineering Branch INSPECTION PROCEDURES USED IP 35750:

QA Program for M&TE IP 92903:

Follow-up Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened VIO 50-443/97 09 01 Failure to Perform a 10 CFR 50.59 Evaluation When Procedure MA2.3 was Changed VIO 50-443/97-09 02 M&TE was not Properly Controlled

,

URI 50-443/97-09-03 Assessment of Instruments to Determine Safety Significance

,

.

.

.,

.

INCIDSimi' 2 M&TE CilANGE MANAGEMENT PLAN The M& 7E Change Management Plan implements thefollowingfour (s task teams:

Technleal llasts Documentation and Validation Revision of Specification Sheets to document the attributes for each piece of e

equipment, providing appropriate references to engineering evaluation.

Resolution of restriction and accuracy issues to ensure deviations from vendor

recommendations have been evaluated. Potentialimpact on safety related systems, structures, and components has been addressed in an oflicial engineering evaluation, Consolidation of basis information for equipment performance, calibration and e

use of MATE, changes to accuracy and calibration cycle, and industry i

accepted methodology.

'

M&TE User Program Revision of user program to strenthen and fonnalize lateral integration between

.

the calibration facility, user groups, and engineering, as well as reduce the level

of burden sensed by those involved. Issues invoMng failure reports, restricted use, vendor M&TE, and the equivalent equipment decision process will be addressed.

M&TE Administrative Program Revision of administrative program to fomalize the integration between

.

calibration facility, user groups, and engineering and to define programmatic and regulatory requirements. Validation against the UFSAR and associated ANSI specifications, M&TE Prograrn and Engineering interface issues, engineering controls, and M&TE program requirements will be evaluated and defined.

Tool Control Program Revision of program to include overall direction and purpose, address

.

accountability and personal ownership of tools, identify facility and software improvements, and improve outage contractor tool issue and control.

.

• l

.

.

METROLOGY FACILITY OPERATION DAY TO DAY OPERATION:

• All Af & TEismes are documentedandresolvedwithin the Corrective Action Program Continued relqforcement of a questioning attitude

Estc.butshment of a department goalfor continued improvement

Use of tri-weekly meetingfor rettforcement andfeedback

Implementation ofcontinued team building training

CORRECTIVE ACTION PROCESS:

Issuance of the change managementplan(ChfP)

Station Director andMaintenance Afanager support of Chip

Provision of adequate resources s

- Afonitoring ofeffectheness TRAINING AND BENCIIMARKING:

Task Analysis to ensure adequate quahfications

Training needs to improve general and metrology skills have been identified

Trainingprograms to be developedin wpport ofAfaintenance Technical I998

strategicplan Use of bestpracticesfrom benchmarking

BENEFITS:

Afultiple department involvement in solution development

User training willprovide understanding ofprogram changes

Afultiple department impacts ofAf&TEprogram will be idennped

.

-

.

.

e METROLOGY LAB COMMUNICATIONS

-

Metrology program success requires active communications with both internal and external stakeholders, as delineated below.

MA 2.3 Control And Calibration Of Measuring And Test

.

Equipment Delineates the programmatic requirementsfor implementation of the Ai& TEProgram (Status) A complete revision is required as addressed in the change management plan.

Metrology Lab Calibration Procedures

.

Provides direction andguidancefor the performance ofA fet Lab activities (Status) This effort is compleic and controlled by the Met. Lab.

M & TE Equipment Specification Sheets

.

Delineates to the end user and Engineering the specific calibration data (Status) Revision and verification is in progress and is expected to be complete by June.

M & TE Equivalency

.

Provides the end user with equimlent test equipment to that specified (Status) Presently an informal system exits which will be proceduralized as part of the change management plan.

Restricted Use Tags

.

Delineates to the end user all restrictions associated with a particular piece ofAi& TE (Status) All Engineering evaluations are presently in final review with a

'

scheduled completion of 1/15/98.

-

- _ _ _ _ _

_ - _ _ _ _

-

--

,,

,

'

i..

M & TE Failure Reports

.

.

Provides end user with M & 7Efalhares requiring emluation and documenting that enluation j

(Status) The present process in place is supplemented by the informal

support cf the M & TE Lab Supervisor. Revision of this process is being

]

addressed in the change management plan.

i a

,

4

$

i d

,

t

%

,----m,-

--

-,-,.,-y,,,.-

,

,,,,.,-.,.....-.,m

---

-

7-y.

.-.,,,.,. ~,.,.-._,

---

- -,, -.

4-,

-

>w,,

-..y,-

,

-- -

-

-

-

_ -

.

_ _

_. _ -

_ _

_ -.

_ _ - _

-

- - _ -

.

UFSAR REQUIREMENTS

-

UFSAR Section 17.2.12.3 Requirements:

-

.

Primary Standards shall have an accuracy offour times the required accuracy of the end use equipment being calibrated Less accurate standards are acceptable u hen use the use ofsuch

'

standards, and the basis of cahbration acceptance is authori:ed and documented NAQA Section 12.2.4.3 Requirements:

.

Primary standards shall have an accuracy of at leastfour times the required accuracy of the end use equipment being cahbrated Less accurate cahbration standards may be acceptable when the use of such standards, and the basis of calibration acceptance, are authorized

.

anddocumented

,

Metrology Laboratory (MA 2.3):

.

Ensures that the UFSAR andNAQA requirementsfor a 4 : I ratio are met (primary standard toficid standard).

lI'here the 4:1 criterion is not met, the cahbration tolerance apphed to thefield standard is reduced (guard banding) to provide an equivalent cahbration.

Engineering Evaluation SS - EV - 97 - 0021:

.

Assess the safety sigmficance of the reportedM & TE cahbration discrepancies.

Select a representative safety sigmficant sample population to provide reasonable assurance.

Instrument loop selection criteria:

Parameter diversity e.g. flow, level, temperature andpressure Instrument loops u hich support the " Accident Analyses" instrument loops which contain minimum margin

.

._-

_. -..

-

,

, _. -,. _ -.....

, _ _ -.. _ _.

,

, _ -..

l'crification of the 4:1 ratio between the primary standard and thefield

.

standard, or equimient (guard handing)

Conclusions:

The evaluation demonstrated that the Identified hi & TE discrepancies do not have safety significance, that a 10 CFR 50.59 safety evaluation is not required as the evaluation did not identify the necessity to make changes to thefacility orprocedures as describedin the UFSAR, perform tests or experiments not descrlhed in the UFSAR, change the Operating License or require the implementation of a setpoint change or recalibration. None of the previously identifled hI & TE discrepancies affect the margin ofsafety.

.

.

l

'

l

.

.

-

-

.p p

i s

u ot q

on E

L em e

s s

s u n

e r o

U t

i c-s t

n a

d i

I t

n P

n E

e d

m le u

i c

f F

o o

d os d

ie n

t i a c a

R a1 m

r n

d u0 o

a e c1 it r c a

r iA c

s g

e fi a

D ts i

u D

jer d

i k

r u

a q

c d

E e

o n

T r

l a

t s

B S

&

no d

M it n

e a

l o

F d

i i

e t

D a

-

r f

b o

2 i

o s

t e

l i

a ai b

c a

C R a*

L n

r I d u:

t o

e c4 e

i r

t M

c i c uA e

q S

eR

2 AM

.

d

.d r

d t

r a

t S

e d

S P

n y

a yr t

r a

S admn b

o i

a r c L

P eS r

.

<