Text

Advises of Planned Insp Effort for Next 6 Months at Byron. Encl Info Provided to Minimize Resource Impact on Staff & to Allow for Scheduling Conflicts & Personnel Availability to Be Resolved in Advance of Inspector Arrival Onsite
	ML20197K007
Person / Time
Site:	Byron
Issue date:	12/02/1998
From:	Jordan M; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O; COMMONWEALTH EDISON CO.
References
	NUDOCS 9812160058
	Download: ML20197K007 (35)
	v • d • e

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t e UNITED STATES

ja natug%,- NUCLEAR REGULATORY COMMISSION

[ o, REGION til y y 801 WARRENV!LLE ROAD e LISLE. ILLINOIS 60532-4351

\,u,,*/ December 2, 1998 l

Mr. Oliver D. Kingsley President, Nuclear Generation Group i Commonwealth Edison Company I l- . ATTN: Regulatory Services !

Executive Towers West lll

' 1400 Opus Place, Suite 500 Downers Grove, IL 60515

SUBJECT:

MID-YEAR INSPECTION RESOURCE PLANNING MEETING - BYRON Dear Mr. Kingsley; On November 4,1998, the NRC staff held an inspection resource planning meeting (IRPM).

The IRPM provided a coordinated mechanism for Region 111 to adjust inspection schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in April 1999.

Enclosure 1 to this letter advises you of our planned inspection effort for the next 6 months at Byron.

This attached information is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. The rationale or basis for each inspection outside the core inspection program is provided so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed due to their ongoing and continuous nature.

Enclosure 2 contains a historical listing of plant issues, referred to as the Plant issues Matrix (PIM), that was considered during the IRPM. The PIM includes only items from inspecuon reports or other docketed correspondence between the NRC and Commonwealth Edison Company.

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C. Pederson, Rlll w/encls

B. Clayton, Rlli w/encls l

SRI Byron w/ enc!s DRP w/encls - l TSS w/encls DRS (2) w/encls Rlli PRR is M /

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We willinform you of any changes to the inspection plan. If you have any questions, please contact me at 630-829-9637.

Sincerely, Michael J. Jordan Michael J. Jordan, Chief Reactor Projects Branch 3 l

Docket Nos.: 50-454;50-455 License Nos.: NPF-37; NPF-66

Enclosures:

1. Inspection Plan

2. Plant issues Matrix 1

cc w/encls: D. Helwig, Senior Vice President 1 H. Stanley, PWR Vice President C. Crane, BWR Vice President R. Krich, Regulatory Services Manager D. Greene, Licensing Director DCD - Licensing K. Graesser, Site Vice President W. Levis, Station Manager B. Adams, Regulatory Assurance Manager R. Hubbard, MHB Technical Associates M. Aguilar, Assistant Attorney General State Liaison Officer State Liaison Officer, Wisconsin Chairman, Illinois Commerce Commission DOCUMENT NAME: :G:\Byro\insppin7.byr To receive a copy of this document, indicate in the bos *C* = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N* = No copy OFFICE Rlli E. Rlil j NAME Tongue:dpff Jorda,n 77lhh DATE idN98 I4N98 OFFICIAL RECORD COPY

i 1

f BYRON l lNSPECTION / ACTIVITY PLAN

' \

iP Inspection Procedure Core - Minimum NRC Inspection Program (mandatory all plants)

Regional Initiative - Discretionary Inspections 4

NUMBER OF TYPE OF INSPECTION NRC INSPECTION /

/ TITLE / PROGRAM INSPECTORS / PLANNED ACTIVITY-ACTIVITY AREA INDIVIDUALS DATES COMMENTS IP71001 Licensed Operator 2 November 30- Core Requal December 4, 1998 1

IP62705 Breaker 1 January 11 - 15, Regional i Maintenance 1999 Initiative @ l IP71707 Operational 2 January 25 - 29, Regional Assessment 1999 Initiative @

IP73753 Inservice inspection 1 Outage Core

(April 1999)

,L . .

IP83729 Radiation 1 April 19 -23, Regional

. Protection / Outage 1999 Initiative @

Activities Notes

@ Followup on previously identified issues.

@ Followup on previously identified configuration management concerns.

j

PLANT ISSUES MATRIX "'

Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* ; SALP Area =

Operations

Beginning Date = *10/1/97* ; Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION i O!18/1998 NCV IR 98017 Licensee Operations 1A 3A The inspectors concluded that a poor questioning attitude by a non-licensed operator and a lack of positive administrative controls combined to allow the main control room office ventilation system to be started while Technical Specifications required the system to be shut down to isolate the main control room ventilation (VC) system. A non-cited violation was issued.

2 9/18/1998 IR 98017 NRC Operations 1A 3B 18 The inspectors concluded that the main condenser tube leak and the failure of the bank overlap unit created some minor challenges and distractions for the main control room operators during the recovery from the Unit 1 loss of offsite power. These problems have occurred previously, however, the licensee properly documented them and has plans for correcting the bank overlap unit at the next available opportunity. No violations were identified.

3 8/24/1998 Weakness IR 98017 NRC Operations 3B 3C The inspectors concluded that the Unit 1 loose parts monitoring system was unnecessarily rendered inoperable by a system engineer's manipulation of the sensor alignment without authorization from the operations department. The inspectcrs also concluded that the licensee's response to it.is event was thorough and that the planned corrective actions appeared to be comprehensive. In addition, since January 1998, '

the licensee had identified numerous configuration control events. While the licensee identified each of these issues and implemented acceptable corrective actions for each event, the inspectors concluded that the licensee's actions had not yet been effective at arresting the adverse trend of configuration contro' events.

Page 1 of 11

PLANT ISSUES MATRIX ur23/e Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column *SALP* , SALP Area a

Operations * , Beginning Data = *10/1/97* . Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 4 8/24/1998 VIO/SL-IV IR 98017, LER NRC Operations 3C 1A The inspectors identified an operability concem with the VC system while 454/98016 main control room doors were propped open as documented in NRC Inspection Report 50-454/98014(DRP); 50-455/98014(DRP). The licensee's subsequent investigation identified that during two periods of time, the VC system was not capable of maintaining the required positive pressure and therefore, the licensee was in a condition prohibited by Technical Specification. The procedural guidance contained in Byron Administrative Procedure 1100-3, " Fire Protection Systems, Fire Rated Assemblies, Ventilation Seals, Flood Seals, and Water Tight Doors impairments," Revision 11, allowed licensee personnel to incorrectly reach the conclusion that the safety-related VC envelope could be altered by simultaneously impairing three main control room doors without affecting the operability of the system. A no response violation was cited.

5 8/4/1998 Positive IR 98017 NRC Operations 1B 2A The inspectors concluded that operator performance during the Unit 1 loss of offsite power event was exce!!ent. The inspeders observed strong command and control oversight by the unit supervisor, with the operators focused on one task at any given time. Although material condition issues resulted in distractions to the operators, the shift appropriately prioritized their actions throughout the event. Adequate numbers of operators existed to perform operations as required, yet an excessive number of personnel did not exist in the main control room.

Operators routinely used three-way communications and procedures as applicable.

6 6/23/1998 Negative IR 98014 Self- Operatione 3B On June 23,1998, an unexpected, minor reactor coolant system (RCS)

Revealed temperature transient (approximately 1 degree Fahrenheit) occurred on Unit 2 due to operators misinterpreting Byron Operating Procedure (BOP)

CV-6, " Operation of the Reactor Make-up System in the Borate Mode."

The operators identified the unexpected response while monitoring plant parameters after pe forming a boration evolution. Appropriate operator response quick!y restored the RCS temperature to normal. The inspectors concluded that the temperature transient was caused by an isolated knowledge weakness in accounting for the residual boric acid remaining in the make-up line combined with a misinterpretation of BOP CV-6. No violations were identified.

Page 2 of 11

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'1/23/98 PLANT ISSUES MATRIX Byron .

_ 1earch Sorted by Date (Descending) and SMM Codes (Ascending): Search Cobmn = "SALP" ; SALP Area = " Operations * , Begir$ning Date = 10/1/97* . Ending Data = *10/1/98*

_- . . ~ _

TYPE SOURCE ID BY SALP SMM CODES J4 OATE_ DESCRIPTION 7 6/15h 998 URi IR 98014 NRC Operations 3B During the period from June 15 - 18,1998, three doors which formed a portion of the contrcl room ventilation envelope were propped open on two occasions for approximately 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months each. Based on the failure to maintain a positive pressure in the main control room, the inspectors were concerned with the operability of the main control room ventilation system. The inspectors also believed that if the main control room ventilation envelope was operable, a safety evaluation should have been performed prior to propping open a main control room double-door vestibule. Furthermore, the inspectors concluded that corrective actions to a similar previous event were not adequate to prevent the recurrence.

An unresolved item was issued.

8 5/17/1998 Positive IR 98011 NRC Operations 1A 3C The inspectors concluded that overall operator performance during the ;

Unit 2 startup was good. The inspectors observed senior management ,

and Quality and Safety Assessment oversight of the startup. Operating shift management provided an effective high impact activity briefing and closely supervised reactivity manipulations. However, the shutdown bank control rods did not withdraw on demand due to the control room operators failing to bypass the high flux rod stop for an inoperable power !'

range channel contrary to procedural requirements. This failure constitutes a violation of minor significance and is not subject to formal enforcement action. In addition, the inspectors noted one example of a icck of a questionirig attitude regarding unexpected loss of rod speed indication.

9 5/17/1998 VIO/SL-IV IR 98011 NRC Operations 1A SC The inspectors concluded that the licensee identified and initiated corrective action for a self-identified adverse trend in out-of-service ,

(OOS) errors. The licensee's interim corrective actions initially appeared effective, focusing on human performance during placement and removal of OOS cards and computer program errors. However, during the Unit 2 refueling outage, several OOS errors occurred, each involving the failure of multiple barriers. These errors indicated that the licensee's actions were not completely effective. The most notable OOS errors included mechanics performing work prior to the associated OOS being hung and inadequate OOS boundaries due to poor communication between departments. A violation was cited.

Page 3 of 11 i

PLANT ISSUES MATRIX "'2 '*6 '

Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP' , SALP Area = ' Operations" , Beginning Data = *10/1/97* ; Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 10 5/4/1998 VIO/SL-IV IR 98011 Self- Operations 3A The inspectors concluded that the spent fuel pool level was inadvertently Revealed lowered due to the licensee failing to follow Byron Operating Procedure RH-9," Pump Down of the Refueling Cavity to the RWST [ Refueling Water Storage Tank]." The inspectors concluded that contributors to this event were poor communications, poor coordination of plant evolutions, 1 and poor administrative control of the sluice gate by the operations department. A violation was cited.

11 4/16/1998 Negative IR 98011 Self- Operations 3A During the refueling cavity floodup for the Unit 2 refueling outage, a valid Revealed high radiation engineered safety feature actuation signal occurred due to abnormally high radioactivity levels in the reactor coolant system water.

The inspectors concluded that the causes cf the event included inadequate cleanup of the reactor coolant system following a planned crud burst. Poor communication between operators and chemistry department personnel and a lack of administrative controls resulted in the ,

licensee flooding the refueling cavity before the crud burst cleanup was complete.

12 4/15/1998 NCV IR 98011 Licensee Operations 3A Quality and Safety Assessment personnel and the inspectors independently concluded that the operating shift management and system engineer failed to recognize that an operator error of securing the wrong battery charger invalidated the result of Byron Operating Surveillance 7.5.e.1-2, " Essential Service Water Makeup Pump OB Monthly Operability Surveillance," Revision 19. The inspectors concluded that the actions taken for this issue by Quality and Safety Assessment personnel, including urging the licensee to perform the surveillance test again, were indicative of a strong quality assurance organization. A non-cited violation was issued.

13 4/11/1998 Positive IR 98011 NRC Operations 1A 3B The inspectors concluded that the shutdown of the Unit 2 reactor was conducted in a safe and controlled manner. Specifically, management oversight of the shutdown was evident; reactivity management of the evolution was effective; and the heightened level of awareness briefing was generally thorough. The inspectors also concluded that control room operators adhered to the Nuclear Operations Division Operations Department Standards during the shutdown, with the exception that ;

operators often omitted the response acknowledgment from directed communications. i Page 4 of 11

PLANT ISSUES MATRIX "/23/98 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Cotumn = *sALP* , SALP Area =

Operations" Beginning Date = *10/1/97* Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 14 4/11/1998 NCV IR 98011, LER NRC Operations 3A 3C The inspectors concluded that the licensee failed to perform a local leak 454/98008 rate test on the Unit 1 containment emergency hatch in accordance with Technical Specification (TS) Surveillance Requiremer't 4.6.1.3.b due to ineffective inter-departmental communication and failing to follow station procedures. In addition, the inspectors concluded that the licensee's root '

cause investigation into the event was thorough and the corrective actions delineated in the licensee event report appeared appropriate. A non-cited l violation was issued.

15 4/7/1998 Positive IR 98011 NRC Operations 1A 3C The inspectors observed thorough evaluation of shutdown risk for planned activities during the Unit 2 refueling outage, effective heightened level of awareness briefings for infrequently performed evolutions, strong reactiv;ty management, and effective oversight of infrequently performed evolutions by operations management and Quality and Safety Assessment personncL 16 4/6/1998 Strength IR98009 NRC Operations 2A 1B 3A The inspectors concluded that the replacement steam generators operated as designed and the plant responded to the planned transients as expected with no significant anomalies noted. In addition, during the replacement steam generator testing, the inspectors observed effective supervisory oversight of the evolutions and good coordination between operators, system engineers, and maintenance personnel. The inspectors also noted that the control room operators generally adhered to the Nuclear Operations Division Operations Department Standards (4/6/98).

17 4/6/1998 Weakness IR98009 NRC Operations 3B The inspectors concluded that the licensee's process for maintaining senior reactor operator licenses active was weak, in that, an Operations Policy Memo allowed credit for proficiency to be taken for shift supervisor t and administrative shift supervisor positions contrary to the requirements i c' 10 CFR Part 55 and the licensee's operating surveillance test.

However, no violations of regulatory requirements were identified because all senior reactor operators that conducted licensed duties during the quarter met the requirements of 10 CFR Part 55 and the licensee's operating surveillance procedure. The inspectors also concluded that several log entries for shift personnel did not meet the licensee management's expectations (4/6/98).

Page 5 of 11

PLANT ISSUES MATRIX "' 3'S8 Byron .

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" , SALP Area = " Operations * . Beginning Date = *10/1/97 . Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 18 3/11/1998 VIO/SL-IV IR98009 NRC Operations 3C 5A The inspectors concluded that Byron Operating Procedure VC-2,

" Shutdown of Control Room HVAC System," Revision 2, was not appropriate to the circumstances due to an inadequate technical review during the procedure revision completed on January 7,1998. In addition, the inspectors concluded that cn at least eight occasions, the control room operators performed this procedure and did not identify the procedural deficiencies and initiate corrective action, which was not in accordance with licensee managements's expectations and standards for procedural adherence as described in Nuclear Operations Division Operations Department Standards, Section Vill. " Procedural Adherence."

A violation was cited (3/11/98).

19 3/7/1998 Positive IR98009 NRC Operations 1A 3A The inspectors concluded that overall operator performance during restart ,

on March 7,1998, of the Unit 1 reactor was good. The criteria for startup termination, based on boron concentration and dilution volume, were clearly stated and fully understood. This alleviated the confusion that was l present during the aborted startup the previous night. The inspectors also concluded that procedure usage, crew communication, and crew briefings were effective (3/7/98).

20 3/7/1998 LER LER 50- Self- Operations 2A Manual Reactor Trip due to indeterminate Rod Sequencing Problem.

454/98005, IR Revealed The root cause was indeterminate however, the cause of the improper l 98009 rod bank sequencing was most probably a failure of the bank overlap thumbwheel switch.

21 3/6/1998 Positive IR 98009 NRC Operations 1A 3A The inspectors conc luded that overall operator performance during the aborted Unit 1 reactor startup on March 6,1998, was good, including the ,

development of trip contingency actions, the use of procedures and three- t way communications. The inspectors also noted that conservative operating decisions were made, most notably the decision to shutdown the reactor after failing to achieve criticality at the estimated boron concentration. The inspectors noted one example where the Qualified Nuclear Engineer created confusion while attempting to explain the boron concentration limits to the operating crew (3/6/98).

Page 6 of 11

PLANT ISSUES MATRIX 11/23/98 Byron .

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = " Operations * . Beginning Data = *10/1/97* : Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 22 3/6/1998 Negative IR98009 NRC Operations 1A 3A Observed portions of low power physics testing were conducted in a safe manner. Each reactivity manipulation was closely monitored by the Unit Supervisor. However, communications between the Qualified Nuclear Engineer and the Unit 1 Nuclear Station Operator did not meet the station management's expectations for three-way communications. At times unnecessary personnel congregated in the area of the center desk and participated in discussions not related to the operation of the plant.

Although these discussions resulted in the background noise level being ,

elevated, no adverse consequences were noted (3/6/98).

23 3/6/1998 VIO/SL-IV IR98009 NRC Operations 2A 28 The inspectors concluded that the entry of Unit 1 into Mode 4 (Hot Shutdown) from Mode 5 (Cold Shutdown) with the seal table room floor drain plugged was a violation of Technical Specifications and should have been prevented by corrective actions from previously identified issues with the floor drain system. The inspectors concluded that significant contributions to not recognizing the inoperable seal table floor drain were poor maintenance work request content and documentation, poor problem description on the problem identification form, and poor followup by the system engineer's when notified by mechanics that the floor drains remained plugged. A violation was cited (3/6/98).

24 3/5/1998 LER LER 50-454/98008 Self- Operations 1B Manual Reactor Trip on 3/5/98 due to a Loss of Communication During Revealed Rod Drop Testing Caused by Procedure Deficiency. The manual trip was .

initiated during the testing as an expected response for a loss of communication between control room operators inplant field test personnel.

25 2/2/1998 Negative 98005 NRC Operations 1B 3C The inspectors concluded that the nuclear station operators (NSOs) were working large amounts of hours just under the overtime guidelines for extended periods of time. The inspectors did not identify any significant deviation from the overtime guidelines. However, the inspectors concluded that generally, the 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months shifts worked by the NSOs caused large amounts of overtime hours and the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months shifts caused long periods of work without a day off. Additionally, the 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months shifts caused excessive shift rotations. The inspectors concluded that the large amounts of hours worked by some NSOs and the extra shift rotations caused by the 16 haur shifts were poor human factor practices.

(2/2/98)

Page 7 of 11

PLANT ISSUES MATRIX "' '88 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" , SALP Area = " Operations" Beginning Date = *10/1/97* : Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 26 1/21/1998 VIO/SL-IV 98005 Licensee Operations 1A The inspectors concluded that an out-of-service error on the chemical and volume control system occurred due to poor communication between the involved operators, assigning multiple tasks to be performed concurrently, and a perceived pressure to accomplish work rapidly.

Although licensee identified, a violation was cited because this was a repetitiveissue. (1/21/98) 27 1/12/1998 97024 NRC Operations 1A Routine control room operations were conducted safely and conservatively. Good annunciator alarm response was observed and the operators were knowledgeable of the status of all the annunciator alarms. Operators were aware of activities that could affect the safe operation of each unit. Good communication between the unit operators and good supervisory oversight by the unit supervisors were also noted (1/12/98). Teamwork / Skill Level 28 1/12/1998 97024 NRC Operations 1A The Plan of the Day (POD) meeting was an effective communication tool ,

and helped identify key performance measures at the site (1/12/98).

Self-Critical 29 1/12/1998 97024 NRC Operations 1C The shutdown risk program and its implementation were excellent. A detailed licensee review of the outage schedule was conducted. The licensee determined the risk level for each key safety function based on plant configuration and equipment availability and used safety system functional assessment trees (SSFATs). A core damage frequency (CDF) was included in the risk profile. The shutdown risk review board (SRRB) approved all changes to the shutdown risk models. Shutdown risk was communicated to all station personnel. Contingency plans provided additional guidance for operators and existed for most higher risk conditions (1/12/98). Teamwork / Skill Level 30 1/12/1998 97024 NRC Operations 2A The housekeeping for Unit 2 was very good. Unit 2 structures, systems, '

and components were easily accessible to operators. General area housekeeping was good given the amount of outage activities that were in progress during the inspection period. Equipment was staged ,

appropriately and carts properly secured. The control of outage related material was good except for two failures to control transient combustible material (1/12/98). Other/NA Page 8 of 11

M/23/98 PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP* , SALP Area = Vperations* Beginning Date = *10/1/97* , Erdng Date = *10n/98*

DATE TYPE SOURCE ID BY SALP l

SMM CODES DESCRIPTION 31 12/1/1997 97022 NRC Operations 1A Routine control room observations were very good. Control room personnel conducted themselves professionally, unit supervisors and nuclear station operators completed their duties without distraction, control room personnel were knowiedgeable of plant conditions, and operators practiced proper three-way communications while performing ,

plant evolutions. The addition of a work execution center outside the control room significantly reduced the number of personnel requiring entry to the control room. Those personnel entering the control room behaved professionally, observed the proper control room protocol, and entered for the conduct of technical or administrative business with the unit supervisors or nuclear station operators. (12/1/97) Teamwork / Skill Level 32 11/7/1997 97022 NRC Operations 1B The Unit 1 shutdown on November 7,1997, was well executed. Excellent '

command and control, very good three-way communications, and good briefs and oversight by management were observed. (11/7/97)

Teamwork / Skill Level 33 10/21/1997 97022 NRC Operations 3B The Unit 2 startup on October 21,1997, demonstrated excellent opera. -

performance. Consistent three-way communications between operatorr, and formal comrnand and control by the unit supervisor and shift manager were observed. The operators minimized the number of personnel in the control room, thus reducing distractions. The qualified nuclear engineer reported directly to the unit supervisor and made good ;

recommendations and observations. The operators responded to each :

annunciator alarm, reviewed the procedure and took appropriate action.

The approach to criticality was slow and controlled. Teamwork / Skill Level 34 10/16/1997 IR 97020 NRC Operations 1B The plans to shutdown Unit 2 due to the degraded extraction steam bellows were conducted in a thorough and conse vative manner. !

Because of the preexisting plans in place for the maintenance outage, transition from the unexpected Unit 2 reactor trip into the maintenance outage was smooth. Excellent teamwork was displayed by a!!

departments involved in the maintenance outage. Decisions conceming scheduling the outages and the impact of each unit's status on the other unit were safe and conservative (10/16/97). Teamwork / Skill Level Page 9 of 11

PLANT ISSUES MATRIX 11/23/98 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; SALP Area =

Operations * , Begirnng Date = *104/97* . Erxhng Date = *104/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 35 10/16/1997 97020 NRC Operations 1B The operating crew response to the Unit 2 trip on October 10,1997, resulting from the failed rod drive power supplies, was excellent. This was demonstrated by good command and control, control of personnel allowed in the control room, team work between the operating crew members, response to annunciators and reference to procedures and proceduralcompliance. (10/10/97) Teamwork / Skill Level 36 10/16/1997 97020 NRC Operations 1B During the Unit 1 technical specification (TS) shutdown on October 9, 1997, the crew focus was safe and conservative. Operator distractions did not exist. The operators were attentive to the control boards and clear formal communications were observed by the inspectors. Operator performance during the shutdown was excellent. Consistent excellent performance was also observed during the start-up after repairs to the check valve were completed on October 15,1997 (10/15/97).

Teamwork / Skill Level 37 10/16/1997 97020 NRC Operations 3A The licensee did not incorporate issued TS amendments within the stated implementation time for each amendment. This resulted in not having current copies of TS available for personnel involved in licensed activities, i.e., control room operators. Without the current revisions available, the possibility of not adhering to TS existed. A violation was issued (10/16/97). Personnel Performance Deficiency 38 10/16/1997 97020 NRC Operations 3C The format of the operations crew shift change brief was changed to conduct a tumover at each watch station, then a crew b:lef was conducted outside the control room followed by watch relief. At first, the crews appeared rushed to retum to the control room to relieve the watch and a concem existed that the time a!! owed for the brief may not always be sufficient for a thorough turnover. However, an excellent brief was observed in preparation for the Unit 1 cooldown on October 10,1997.

Routine briefs appeared time constrained; however, when required, the operators took the necessary time for a thorough brief (10/10/97).

Teamwork / Skill Level 39 10/16/1997 97020 NRC Operations SC The licensee had a controlled well managed process to track and trend overdue corrective actions (10/16/97). Involved Management Page 10 of 11

PLANT ISSUES MATRIX ii/23rd Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area =

Maintenance * ; Beginning Date = *10/1/97* , Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1 9/18/1998 Positive IR 98017 NRC Maintenance 2A 2B The inspectors concluded that observed surveillance tests were performed well. Specifically, the sunreillarice tests satisfied the surveillance requirements of Technical Specification and each of the tested components met their respective acceptance criteria.

2 9/18/1998 Negative IR 98017 NRC Maintenance 3A 28 The inspectors concluded that due to poor work planning and lack of knowledge of Technical Specification on one occasion personnel failed to recognize the entry conditions for a Technical Specification Limiting Condition for Operation (LCO) for the 1 A residual heat removal pump.

The actions required by the LCO were not exceeded. Furthermore, the inspectors concluded that insufficient planning for on-line maintenance activities resulted in additional unavailability of the containment spray system. No violations were identified.

3 9/18/1998 Positive IR 98017 NRC Maintenance 3A 3B The inspectors concluded that observed maintenance activities were conducted well. Specifically, oversight of maintenance activities was evident; maintenance activities were completed in accordance with station procedures; and maintenance personnel were knowledgeable of the associated activities.

4 7/13/1998 Positive IR 98014 NRC Maintenance 2B The inspectors concluded that each of the observed surveillance tests were performed well. Specifically, the surveillance tests satisfied the requirements of Technical Specifications and each of the tested components met their respective acceptance criteria and remained operable. The inspectors noted very good material condition of the equipment in the plant. The minor exceptions being the OA control room ventilation make-up fan that tripped on low flow due to a discharger damper control circuit problem and the safety injection pump that had high discharge header pressure due to leakage past the reactor coolant system.

5 7/13/1998 Negative IR 98014 NRC Maintenance 28 The inspectors concluded that the licensee did not control as a temporary alteration the installation of a portable pumping system in the nonsafety-related chemical feed system for the essential service water system. No violation of regulatory requirements occurred.

6 7/13/1998 Positive IR 98014 NRC Maintenance 2B The inspectors concluded that the observed maintenance activities were conducted well; specifically, procedures were followed; personnel were knowledgeable of work activities; and supervisors, system engineers, and quality control personnel were attentive to monitoring work in progress.

Page 1 of 7

PLANT ISSUES MATRIX n/2and Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = " Maintenance" , Beginning Date = *10/1S7" ; Ending Date = *10/188*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 7 -7/9/1998 Positive IR 98015 NRC Maintenance 28 Regarding the maintenance rule, the establishment of performance criteria and goal setting was considered acceptable. The reliability and unavailability performance criteria established were adequately linked to the values assumed in the probabilistic safety assessment, which resolved the concem identified in the baseline inspection. In addition, the revised performance criteria for the fuel handling and emergency lighting systems were acceptable.

8 7/9/1998 Positive IR 98015 NRC Maintenance 28 Regarding the maintenance rule, the required periodic assessment, issued in March 1998, contained several good overall evaluations of the effects of the maintenance rule on the maintenance program. The assessment met the requirements of the maintenance rule, although it was not issued in a timely manner. The implementation of the Outage Rick Assessment and Management Program demonstrated the licensee's commitment to making improvements in the control of outage risk.

9 7/9/1998 Positive IR 98015 NRC Maintenance 2B Regarding the Maintenance Rule, the low-safety-significance risk ranking for four ventilation systems, questioned during the baseline inspection, were considered appropriate based on additional analysis and calculations that demonstrated that operability of associated high significant equipment would not be affected.

10 7/9/1998 Positive IR 98015 NRC Maintenance 28 SC Regarding the maintenance rule, the recent corporate assessment of Byron's maintenance rule program was good and demonstrated Comed's intent to continuously improve maintenance rule programs based on lessons leamed.

11 6/14/1998 Negative IR 98017 NRC Maintenance 3A 2B The inspectors concluded that the 1 A component cooling water safety loop was made inoperable during performance of surveillance testing without the licensee entering the appropriate Technical Specification action requirement, however, no violation of Technical Specification LCO requirements occurred due f.* the short duration of the test.

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PLANT ISSUES MATRIX '88 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* , SALP Area = " Maintenance * : Beginning Date = *10/1/97* , Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 12 4/20/1998 VIO/SL-IV LER 50- NRC Maintenance 3B Inadequate Administrative Controls Lead to Operation Outside the 455/98005, IR Ventilation Design Basis. The inspectors concluded that the facility was 98011 in a condition outside of the ventilation design basis due to multiple examples of failing to follow station procedures. Consequently,if a loss-of-coolant accident occurred while the non-accessible ventilation system was outside the design basis, the offsite dose would have been increased '

by approximately 15 millirem and the control room habitability dose would have been increased by approximately 4.4 millirem. The cause of the events was attributed to inadequate administrative controls over ventilation barrier impairments and a failure to provide workers with adequate pre job briefings. Two violations were cited.

13 4/6/1993 Nega*ive IR98009 NRC Maintenance 2B The inspectors noted that generally, work requests were adequately controlled and scheduled; however, an example of unauthorized work in progress was identified by the inspectors. Approximately 50 work requests were on hold with valid authorizing signatures which indicated !

weaknesses in the authorization process. The inspectors concluded that the control of WRs on hold was undocumented, inconsistent, and ;

problems were not identified by the licensee. A violation was cited l (4/6/98).

14 4/6/1998 Negative IR98009 NRC Maintenance 2B The inspectors concluded that each of the observed maintenance activities satisfied the regulatory requirements. The inspectors also noted that based on the failure to conduct an appropriate blue check and the l additional seat flatness tests required to ensure a correct seating surface, [

the licensee did not initially have the necessary expertise to satisfactorily repair Safety injection Check Valve 1S18956B (4/6/98).

15 3/6/1998 LER LER 50-454/98007 Licensee Maintenance 1A 3C Valve Returned to Service after Maintenance without Adequate Testing due to Personnel Errors. Process Samp!ing valve 1PS9354A was found with a packing leak. A priority action request was written and approved using the "Off Hours Screening Process" and a Work Package was developed, approved and worked to tighten the packing. No provisions were called out for pre and post maintenance testing as required for a contianment isolation valve. The root cause was a personnel error when l an Operations supervisor approved the request and overlooked the i need for testing.

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n/23sa8 PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = " Maintenance * , Beginning Date = *10/1/97* , Ending Data = *10/1/98*

DATE TYPE SOURCE l lD BY SALP SMM CODES DESCRIPTION 16 2/28/1998 VIO/SL-IV LER 50- Licensee Maintenance 2A 1B Reactor Coolant System Leak Detection System Inoperable Due to 454/98004, IR inadequate Communication. During document reviews while in Mode 3 98009 and following refueling outage B1R08, it was determinge that a plugged drain in the Reactor Containment incore Instrumentation Seal Table Room had not been properly evaluated. The root cause was inadequate written and oral communications. It is believed to have been inoperable for at least 2 fuel cycles. A violation was issued in IR 98009.

17 2/23/1998 Positive 98005 NRC Maintenance 28 Observed maintenance and surveillance activities were well conducted.

Procedures were used and personnel were knowledgeable. Surveillance tests were properly authorized and coordinated. Good coramunications were observed between operators. (2/23/98) 18 1/21/1998 VIO/SL-IV 93005 NRC Maintenance 28 The inspectors concluded that the licensee's recovery plan after ideratifying a main condenser tube brush in the containment spray system was appropriate. However, the brush represented another example of continuing poor foreign material exclusion controls by the station.

Numerous examples of foreign material in pint systems were identified by the licensee and quality and safety assessment group during the refueling outage. The inspectors concluded that NSWP-A-03, " Foreign Material Exclusion," Revision 0, was inadequate to prevent the intrusion of foreign material into safety-related systems. A violation was issued.

(1/21/98) 19 1/12/1998 97024 NRC Maintenance 1C Based on procedure usage, supervisory oversight, and adequate protection of Unit 2 systems, the observed Unit 1 steam generator removal and replacement activities were conducted appropriately (1/12/98). Teamwork / Skill Level 20 1/12/1998 97024 NRC Maintenance 3B Observed maintenance and surveillance activities were conducted well.

Maintenance procedures were used and personnel were knowledgeable

of the associated activities. Survenlance testing was performed well with proper authorizations, good procedure adherence, and effective comnunications and coordination (1/12/98). Teamwork / Skill Level Page 4 of 7

2 PLANT ISSUES MATRIX "' '*8 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Colurnn = *SALP* ; SALP Area =

Maintenance * , Beginning Data = *10/1/97* , Erd.rg Date

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 21 1/8/1998 VIO/SL-IV 98005 NRC Maintenance 3A The inspectors concluded that maintenance personnel did not follow station procedures; specifically, an engineering request was not prepared to get engineering approval prior to installing a gasket in a the 1B and 2B essential service water pumps. Additionally, the mechanics work procedure did not discuss the use of a gasket. The inspectors concluded that appropriate design control measures had not been taken prior to adding the gasket. A violation was issued. (1/8/98) 22 12/1/1997 97022 NRC Maintenance 3B Observed maintenance and surveillance activities were well conducted.

Procedures were used, personnel involved were knowledgeable, most foreign material exclusion (FME) controls were good, and issues were identified by maintenance personnel. Additionally, based on proper authorization, procedure adherence, good communication and coordination, and verification that the survei!!ance acceptance criteria was met, the observed surveillance testing was well performed. (12/1/97)

Teamwork / Skill Level 23 11/21/1997 97022 NRC Maintenance 2A On November 21,1997, during a system walkdown, the inspectors noted boron deposits on the seal injection lines fittings and connections that had been previously repaired in September 1997. The deposits had been identified by the licensee and an action request had been written. The inspectors considered previous maintenance was not effective to prevent system leakage. (11/21/97) Self-Critical 24 11/17/1997 97022 NRC Maintenance 28 Foreign material control around the Unit 1 containment floor drain sump was poor and not in accordance with the station procedure goveming foreign material control. The sump was designated as an FME area and holes in the floor drain sump cover were not protected with FME covers.

A violation for failure to follow the FME procedure was issued.

(11/17/97) Personnel Performance Deficiency 25 11/5/1997 97022 NRC Maintenance SC After dropping a section of runway to be used during the steam generator replacement, the licensee responded appropriately, quarantined the area and promptly performed a formal investigation. (11/5/97)

Teamwork / Skill Level Page 5 of 7 i

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PLANT ISSUES MATRIX M/23/98 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; SALD Area =

Maintenance" ; Beginning Date = *10/1/97* Erdng Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP lSMM CODES DESCRIPTION 26 10/16/1997 97020 NRC Maintenance 3B The receipt of new fuel was property conducted in a safe and expeditious manner. Plant personnel were krowledgeable of their responsibilities as evidenced by referral to and use of the applicable procedures, their responsibilities, and the use of fuel movement equipment. Inspection of the new fuel was thorough (10/16/97). Teamwork / Skill Level 27 10/16/1997 97020 Licensee Maintenance 3C The licensee identified several problems associated with the 2B CV charging pump maintenance that prevented work completion within the expected 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months and delayed the pump's retum to service. The delay caused operators to begin a TS required shutdown; however, the pump was retumed to service, tested and declared operable prior to a significant power reduction. The inspector and the licensee determined many of the problems should have been prevented, including: confusion about whether the pump had been drained or not, lack of a fill and vent procedure, and communication problems between operators, mechanics, and system engineering personnel (9/8/97). Inadequate Procedure / Instruction 28 10/16/1997 97020 NRC Maintenance 3C Observed maintenance activities and surveillance testing were conducted according to approved procedures, in accordance with TS, and had appropriate oversight by supervision, system engineer, and quality control ,

personnel. One observed weakness in procedure adequacy was that expected alarms were not generally included in operations department surveillance test procedures (10/16/97). Teamwork / Skill Level 29 10/16/1997 97020 NRC Maintenance SA The inspectors identified a poor work practice where personnel signed for ,

performing steps in a work instruction after all work was done, in lieu of signing for each step after each step was accomplished (10/7/97)

Personnel Performance Deficiency Page 6 of 7

PLANT ISSUES MATRIX '/2at9s Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascerdng): Search Column = *SALP" ; SALP Area =

Engineering * , Beginning Date = *104/97* . Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1 9/18/1998 Negative IR 98017 NRC Engineering 48 The inspectors concluded that the licensee was aware of the industy concern regarding the orientation of Anderson Greenwood check valves.

However, the licensee had not initiated action to identify those valves that were not oriented as specified by the vendor technical manual or correct those valves that were misoriented.

2 7/13/1998 VIO/SL-IV 1R 98014, IR NRC Engineering 4A SC The inspectors concluded that neither the spent fuel pool cooling system 98011 suction piping nor the skimmer discharge piping contained a design feature to prevent inadvertent draining below 423 feet 2 inches, as required by Technical Speciiication 5.6.2. The spent fuel pool cooling suction connections were located at approximately 417 feet 9 inches and the skimmer discharge line discharged at approximately 418 feet. A violation was cited.

3 5/30/1998 VIO/SL-IV IR 98011 NRC Engineering 4A The licansee failed to update the Final Safety Analysis Report to include the effects of Safety Evaluation T1-93-0152, documented in October 1993, which concluded that operation of the mini-purge system in lieu of the containment purge system did not involve an unreviewed safety question. A violation was cited.

4 2/23/1998 VIO/SL-IV 98005 NRC Engineering 4B A safety evaluation was not performed prior to venting the 28 charging (CV) pump into the volume control tank (VCT) and eventually venting the VCT to the gaseous waste processing system (GWPS) as discussed in Inspection Report No. 97022. This was not in accordance with the intended purpose of the GWPS system as described in the UFSAR. The item was unresolved pending further N9C review. The NRC review concluded that this matter constituted a violation of 10 CFR 50.59 for failure to conduct a safety evaluation prior to allowing a portion of the CV system to be vented to the VCT and ultimately to the GWPS. A violation was cited. (2/23/98) 5 2/16/1998 LER LER 50-455/98001 Licensee Engineering 2A Exceed Licensed Power Level due to Calorimetric Instrument Discrepancy. A discrepancy with steam generator blowdown flow totalizer recorder scaling was identified resulting in the actual flowrate being a factor of 0.9 less than indicated affecting the thermal power calorimetric calculation in a nonconservative direction. The ovE rall affect on power level was approximately 0.1% of rated thermal power. This also affected Unit 1, The cause was the instrument flow orfice plate being manfactured incorrectly and subsequently installed during original construction without being identified.

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23/98 PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column a *SALP* , SALP Area =

Engineering , Beginning Data = *10/1/97* , Erxfing Data = *10/1/98*

O DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 6 2/10/1998 VIO/SL-IV 98004 NRC Engineering 4A On February 26,1998, the team identified that corrective actions were not prompt for a degraded condition for the bolts and anchors for the AF battery rack. The condition was caused inpart by not having a requirement to walkdown completed DCPs. The DCP issued to correct this condition had not been completed since May 15,1996. A example of a violation for inadequate corrective action was issued (2/10/98).

7 2/10/1998 VIO/SL-IV 98004 NRC Engineering 4A On February 4,1998, the team identified that a field change performed on June 7,1996, was not subjected to design control measures commensurate with those applied to the original design. In addition, a AF battery rack was not installed as required by DCP #9600148 resulting in as-built drawings and seismic calculations that did not match the plant design. A violation was issued for inadequate design control. ,

(2/10/98).

8 2/10/1998 VIO/SL-IV 98004 NRC Engineering 4A The team identified concems relative to modification testing and modification package closure. A field modification of heat tracing essential service water chemical addition lines had not been properly evaluated, tested and signed off prior to placing the system back in service. An example of a violation for inadequate corrective actions was ;

identified in this area. (2/10/98) 9 2/10/1998 VIO/SI -IV 98004 NRC Engineering 4A The licensee failed to develop an instrument out-of-tolerance process to t address repetitive out-of-tolerance problems. A corporate procedure had not been implemented. An example of a violation was identified in this 1 area. (2/10/98) I 10 2/10/1998 Positive 98004 NRC Engineering 4B The emergency diesel generator (EDG) system engineer's interf ace with the Braidwood EDG system engineer during evaluations for previously ,

untested EDG switches and the subsequent identification of deficient control wiring in the EDG control panel was considered very positive.

(2/10/98) 11 2/10/1998 Positive 98004 NRC Engineering 4B The design and system engineers direct!y involved with the team in the discussions of technicalissues were generally found to be qua!ified and experienced in their respective positions. Further, the engineers demonstrated pride and ownership of their respective areas of

responsibilities. (2/10/98) 12 2/10/1998 Positive 98004 NRC Engineering 4C Overall, safety related modification packages reviewed by the team were of good technical quality. (2/10/98)

Page 2 of 5

w M/23/98 PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area =

Engineering" . Segirming Date = *10/1/97* ; Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 13 2/10/1998 VIOiSL-IV 98004 NRC Engineering 4C The inspectors determined that the licensee failed to establish an effective process for independent inspection and verification of modification activities affecting quality, such as field installations of safety related exempt changes. A violation was identified in this area.

(2/10/98) 14 2/10/1998 Weakness 98004 NRC Engineering 4C 5A The engineering self assessments reviewed by the team needed i improvement in quality, particularly in design engineering. More guidance was needed for follow up on the findings identified during these self assessments. This is conside ed a weakness. (2/10/98) .

15 2/10/1998 Positive 98004 NRC Engineering SA SC The audits / assessments conducted by SOV and outside auditors were done well and included several significant findings. The licensee generally followedup on audit findings adequately. (2/10/98) 16 22/19/1997 97024 NRC Engineering 4B A process for the identification, tracking, and resolution of nonconformances for the SGRP was successfully implemented and appeared to be effective. A potential weakness existed in that operations personnel were not involved in the nonconformance report review process (12/19/97). Self-Critical 17 12/19/1997 97024 NRC Engineering 4B The steam generator replacement project (SGRP) lead civil engineer and civil engineering staff were actively involved in the oversight of contractor personnel and were knowledgeable of the evolutions they observed (12/19/97). Teamwork / Skill Level 18 12/12/1997 Negative 98005 NRC Engineering 4A The inspectors concluded that the design control of the DG was poor in that the ful! load possibility was not considered in the modeling for the rep?acement governors. (12/12/97) 19 12/1/1997 97022 NRC Engineering 5B No corrective actions were taken for two problem identification forms (PIFs) written during the 28 CV pump work. Issues identified in the PlFs included a lack of a CV pump fill and vent procedure, an inadequate safety evaluation, and poor communications between departments. The corrective action program failed to capture the issues identified adequately and assign an appropriate investigation. (12/1/97) Self-Critical Page 3 of 5

/23/98 PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP* ; SALP Area =

Engineering * . Beginning Date = *10/1/97* , Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 20 10/23/1997 97022 Licensee Engineering SC System engineering identified that two vent valves were not included in the monthly Unit 1 emergency core cooling system (ECCS) venting surveillance test. The valves were discovered during a modification review for system enhancements. The system enhancements were part of actions taken fol lowing identification in May 1997 that a residual heat removal vent valve was not being included in the monthly Unit 1 ECCS venting surveillance test. (10/23/97) Self-Critical 21 90/16/1997 97020 NRC Engineering 28 The inspectors reviewed the temporary alterations program and determined that most of the temporary afterations were due to preparation for the Unit 1 steam generator replacement. The temporary alteration program was well controlled and the number of temporary alterations was justified (10/16/97). Involved Management 22 10/16/1997 97020 NRC Engineering 4B During the failed extraction steam bellows trending and planning for Unit 2 outage, the inspectors noted excellent system engineer knowledge level, trending, and communications with operators and station management. System engineering provided recommendations concerning continued unit operation and corrective actions. System engineering support for the failed bellows event was excellent (10/16/97). Teamwork / Skill Level 23 10/16/1997 97020 NRC Engineering 4B During the shutdown and subsequent startup, the inspectors observed the qualified nuclear engineer (QNE) perform shutdown margin calculations and dilution calculations. The ONE provided advice on control rod position to support ccatrol of flux distribution. The ONE remained out of the immediate area of the reactor controls, only entering the area to converse is necessa'y with the operators. Clear, formal communications between the O M anc the operators were observed.

QNE support was excellent (10A 0/97). Teamwork / Skill Level Page 4 of 5

PLANT ISSUES MATRIX "'2358 Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" , SALP Area =

Plant Support' ; Beginning Date = *10/1/97* : Ending Data = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 1 7/17/1998 Positive IR 98016 NRC Plant 1C 2A Security equipment observed during the inspection functioned as IR 98016 Support designed, and compensatory measures for equipment failure were seldom required. Inspector observed portions of annual testing of the perimeter alarm system confirmed that the testing was conducted in accordance with procedures.

2 7/17/1998 IR 98016 NRC Plant 1C 28 Security procedures reviewed were generally well-written. Records Support reviewed were accurate and complete, except for alarm history records for multiple alarms within a zone, a problem which also exists at other Comed sites.

3 7/17/1998 IR 98016 NRC Plant 1C 3B Security force members were knowledgeable of post requirements and Support performed their duties in an adequate manner. A significant reorganization of the contract security force occurred since the last inspection. The licensee went below the minimum armed security officer shift manning level for a short period of time.

4 7/17/1998 Positive IR 98016 NRC Plant 1C SA Regarding the physical security program,. self-assessment activities were Support effective in identifying potential problem areas.

5 7/13/1998 Positive IR 98014 NRC Plant 1C The inspectors concluded that the licensee's control of transient Support combustible material was significantly improved from previous inspection. In Inspection Report 98011, a number of examp!es of poor control were cited.

6 5/31/1998 Negative IR 98014 NRC Plant 1C 2A 3C The inspectors concluded that the operators were adversely impacted in Support performing rounds by the amount of contaminated area in the Auxiliarv Building, most notably in the emergency core cooling system equipment rooms. The licensee initiated corrective action to reduce contaminated areas to allow for easier operator rounds. In addition, the inspectors noted two tygon hoses crossed a contaminated area barrier and were not fastened at the barrier to preclude the spread of contamination. Licensee ,

verified that spread of contamination did not occur.

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Plant Support' , Beginning Date = *10/1/97* , Ending Date = *10/1/98*

~

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 7 5/8/1998 VIO/SL-IV IR 98013 Licensee Plant 1C 3A Two occasions occurred between May 22, and late December 1997, Support where FFD procedures were not complied with in a timely manner by one individual and two supervisors. The incidents pertained to reporting and evaluating the odor of alcohol on personnel working on shift. The lack of timely actions constituted a violation of the licensee's FFD procedures, and a notice of violation was issued. The individual involved in the May 22,1997 incident was FFD tested and was negative. The individual involved in the December 1997 incident did not require FFD testing. A violation was issued. The licensee's report of investigation (dated March 9,1998) was adequate in scope and depth. Implementation of identified corrective actions for the Nuclear Generation Group (all nuclear plants) should be adequate to prevent recurrence of the violation.

8 4/27/1998 Positive IR 98010 NRC Plant 1C The moisture carryover test was well implemented. Workers used good Support radiation protection practices and dose was kept low.

9 4/27/1998 Positive IR 98010 Self- Plant 1C While performing a turbine tube oil flush, the hose that was transporting Revealed Support oil disconnected and sprayed oil onto alllevels of the turbine building.

About 500 gallons of oil went into the condenser. Chemistry personnel performed a thorough assessment to determine how to remove the oil and to establish oil levels that would be acceptable for startup.

10 4/27/1998 Positive IR 98010 NRC Plant 1C The licensee had established an aggressive goal of 130 person-rem for Support the outage. Scurce term reduction efforts contributed to keeping doses low, and as-low-as-is-reasonably-achievable (ALARA) pre-job briefings were well implemented. The inspectors identified that there were no low dose waiting areas posted in containment; however, once pointed out to radiation protection supervision this was corrected.

11 4/27/1998 VIO/SL-IV IR 98010 Other Plant 1C Two instances of radioactive material being shipped offsite as non-Support radioactive material were identified by another NRC licensee when a survey was performed on the incoming shipments. One violation conceming the failure to properly implement the procedure for unconditional release of radioactive material was identified. A violation was issued.

12 4/27/1998 VIO/SL-IV IR 98010 NRC Plant 1C During the moisture carryover test, a failure to properly post a radiation Support area was identified. A violation was issued.

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PLANT ISSUES MATRIX "/23e :

Byron -

Search Sorted by Date (Oescending) and SMM Codes (Ascanding): Search Colurnn = *SALP" , SALP Area =

Plant Support" ; Beginning Date = *10/1/97* , Ending Data = *10/1/98*

l'V J

DATE TYPE SOURCE _ _ _ . _

7V SALP SMM CODES DESCRIPTION 13 4/27/1998 VIO/SL-IV IR 98010 NRC Plant 1C 3A 3C One violation conceming the failure to properfy implement the procedure Support for conduct in a radiologically posted area was identified. Multiple examples of poor radiation worker practices were observed by the inspectors. These poor practices resulted in a higher number of ,

personnel contamination events than in previous outages. Additionally, the inspectors were concemed that radiation protection supervision had not taken a more critical view of radiation worker practices and the resulting contaminations, and that radiation protection t echnicians in containment had not identified this problem. A violatio: sas issued.

14 4/27/1998 Positive IR 98010 Licensee Plant 1C SA SB The'recent self assessment performed by the quality and safety Support assessment department was thorough and provided good recommendations. Additionally, observations made by the auditor during the Unit 2 outage had identified similar problems with radiation worker practices that were ideniified by the NRC inspectors.

15 4/16/1998 LER LER 50- Self- Plant 1C 3A Interdepartment issues and OPEX Cause High RCS Activity and ESF 455/98003 1R Revealed Support Actuation. While flooding the refueling cavity during Unit 2 refueling 98011 outage B2R07, a valid high radiation signal was received. The abnormally high radiation levels were due to Co-58 in the RCS from an i inadequate cleanup following an induced crud burst. Two root causes were identified: (1) Inadequate RCS cleanup caused by Operations /Chemistiy coordination issues with contributing causes related to low letdown flow and communications concems, (2) Weak administrative controls to prevent floodup with high concentrations of Co-58 caused by a failure in the OPEX program.

16 3/9/1998 VIO/SL-IV IR98009 NRC Plant 1C The inspectors concluded that the licensee faW ,o post a contamination Support area in accordance with Byron Radiological Protection Procedure 5010-

1. A violation was issued (3/9/98). ,

17 3/6/1998 VIO/SL-IV 98008 NRC Plant 1C There were notable improvements in the conduct of chemistry sampling Support and analyses. Chemistry technicians, who were performing routine sampling evolutions demonstrated, proper procedure adherence, analytical techniques, and radiation protection practices. However, a i violation was identified conceming the failure to properly implement a chemistry procedure for the degassing of reactor coolant samples, which indicated that long standing procedure adherence problems had not been completely resolved (3/6/98).

2 Page 3 of 11 i

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Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP ; SALP Area = " Plant Support : Beginning Date = *10/1/97* ; Ending Date = "10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 18 3/6/1998 Positive 98008 NRC Plant 1C The material condition of the radioactive waste system equipment and i Support rooms was well maintained. Specifica!!y, the inspectors noted that the radioactive tanks and associated equipment showed no visible evidence i of leaks or integrity problems (3/6/98).

19 3/6/1998 Positive 98008 NRC Plant 1C The radiation protection staff properly packaged and classified radioactive Support material and waste shipments in accordance with regulatory requirements. The shipping documentation and low level waste manifests contained the information required by 49 CFR Part 172 and Appendix F of 10 CFR Part 20 (3/6/98).

20 3/6/1998 Positive 98008 tRC Plant 1C The radiation protection staff properly determined the activity of Support radioactive waste shipments via scaling factors. The inspectors mted that the radiation protection staff performed evaluations of radionuclide !

data and verified that the scaling factors accurately represented the waste ,

streams (3/6/98).

21 3/6/1998 NCV 98008 NRC Plant 1C A non-cited violation was identified conceming the failure to proper ly Support implement radiation protection procedures. The inspector identified that the licensee had failed to properly document the issuance of replacement dosimetry. A dosimetry issue log was required to be completed when replacement dosimetry was issued; however, examples were found where the replacement had not been documented on the log (3/6/98).

22 3/6/1998 Positive 98008 NRC Plant 1C The chemistry staff effectively identified and evaluated an elevated level Support of nickel impurities in the Unit 1 primary coolant system prior to plant startup. The licensee implemented appropriate actions to reduce the effect of the impurities on plant radioactive source term buildup (3/6/98).

23 3/6/1998 Positive 98008 Licensee Plant 1C SC '

The quality assurance organization and chemistry supervisors conducted Support several, critical observations of chemistry technician performance.

Although these observations concluded that the chemistry staff had significantly improved in procedural adherence, the inspectors ,

observations indicated that the problem had not been fully resolved +

(3/6/98).

24 2/25/1998 Positive 98007 NRC Plant 1C Security procedures were generally well-written. Records reviewed were ;

Support accurate and complete. A procedure for controlling a certain category (details considered Safeguards Information) of equipment entering the protected was lacking. (2/25/98)

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PLANT ISSUES MATRIX u/23sa .

Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = " Plant Support' , Beginning Data = *10/1/97* ; Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 25 2/25/1998 Positive 98007 NRC Plant 1C 28 Security equipment cbserved durinig the inspection functioned as Support desgined, and compensatory measures for equipment were seldom required. Although the security equipment testing program was generally very strong, some security related component capabilities were not being tested periodically. Some security equipment performance has been erratic. (2/25/98) 26 2/25/1998 Misc 98007 NRC Plant 1C 5A Self-assessment activities were multi-faceted and involved licensee and Support contractor personnel. (2/25/98) 27 2/23/1998 VIO/SL-IV 98005 NRC Plant 1C 3C Based on discussions with the Fire Marshal and seven inspector Support identified examples of failing to adhere to procedures, the inspectors concluded that the transient combustible material control procedures had been interpreted to allow various practices that were not in accordance with the procedures. The inspectors were concemed that fire protection procedures were not being followed due to the number of verbal interpretations that the inspectors identified. Three violations were cited.

(2/23/98) 28 2/10/1998 VIO/SL-IV 98004 NRC Plant 1C 3B The licensee failed to conduct annual physical exams whose results were Support used to assess the fire brigade for unrestricted activity. A violation was issued for failure to meet a license requirement per the UFSAR.

(2/10/98) 29 2/10/1998 VIO/SL-IV 98004 NRC Plant 1C 4A The pre-fire plans were not maintained to meet the criteria of 10 CFR 50, Support Appendix R, and the commitments of NRC branch technical position BTP CMEB 9.5-1 Appendix A, in that the drawings had not been updated for more than 10 years. A violation was identified for failure to follow a procedure requiring timely drawing updates. (2/10/98) 30 1/26/1998 98006 NRC Plant 1C The inventory, control and security of calibration and reference sources Support was adequate. However, the source controllog used to track source location and movement contained examples of incomplete and inaccurate information. Source and calibration facility security was adequate.

(1/26/98) Other/NA Page 5 of 11 I

PLANT ISSUES MATRIX "'2 88' Byron -

Search Sorted by Cate (Descendir'3) and SMM Codes (Ascending): Search Cdumn = *SALP* , SALP Area =

Plant Support ; Beginning Date = *10/1/97* , Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 31 1/26/1998 98006 NRC Plant 1C Overall, the survey program was well implemented. A few problems in Support the survey documentation and the adequacy of the review of the survey data were identified and resulted in a non-cited violation for a failure to follow procedures. The survey program ouality control checks performed by radiation protection department supervisors were thorough and identified areas forimprovement. (1/26/98) Teamwork / Skill Level 32 1/26/1998 98006 NRC Plant 1C Overall, radiation worker practices were good, however, fall protection Support appears to be an ongoing problem in containment with workers either not ;

wearing or not using fall protection equipment appropriately. Additionally, a weakness was noted with the posting of high radiation areas within containment. (1/26/98) Other/NA 33 1/26/1998 98006 NRC Plant 3C The procedure for the control and movement of materials for Support unconditional and conditional release from radiologically posted areas was comprehensive and generally wellimplemented. Station personnel i were knowledgeable of the program and survey instrumentation and survey practices were appropriate. One minor incident occurred involving items conditionally released and transferred to the wrong area of the plant. (1/26/98) Other/NA 34 1/25/1998 Positive 98007 NRC Plant 1C 3B Security force members were knowledgeable of post requirements and Support performed their duties in an adequate manner. Security shift supervisors '

were very effective in monitoring security activities. A recent increase in security force personnel errors was identifed. (1/25/98) 35 1/23/1998 98006 NRC Plant 1C There was little presentation of possible non-radiological con *ingencies Support (such as mechanical failures, crane problems, etc.) during the pre-job briefing for the reactor head set job. This shortcoming, however, was counteracted effectively by very strong participation and questions from the personnel attending the briefing. In addition, the containment video surveillance system was used extensively by the job participants to indicate personnel stations, equipment placement and orientation, and job progression. (1/23/98) Other/NA 36 1/19/1998 98006 NRC Plant 1C The radiological response to an unusual event involving a potentia!!y Support contaminated and injured worker transported to an offsite medical facility <

was prompt and appropriate. (1/19/98) Teamwork / Skill Level Page 6 of 11

1 /23/98' PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descend #ng) and SMM Codes (Ascending): Search Column = "SALP" ; SALP Area = " Plant Support' , Beginning Date = *10/1/97* , Erxing Date = *10/1/98"

DATE l TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 37 1/12/1998 98003 NRC Plant 1C General security st.pport for the Steam Generator Replacement Project Support was very good. Overtime demands for the security force were challenging but effectively monitored by the security staff. Compensatory measures, except as noted below, were property implemented.

Logg%fe security events were not excessive, and the general workforce ;

demonstrated a good understanding of security responsibilities.

(1/12/98) Teamwork / Skill Level 38 1/11/1998 98006 Licensee Plant Radiological controls during radiography operations were generally well Support implemented. Radiography operation pre-job briefings were clear and comprehensive, and included a high level of participant feedback and questioning. Though access controis and postings for these evolutions were executed in accordance with plant procedures, the licensee identified one instance in which a plant contractor crossed a radiography boundary on January 11,1998, in violation of plant procedures. Thi,.

resulted in a non-cited violation for a failure to follow procedures.

(1/11/98) Personnel Performance Deficiency 39 1/9/1998 98002 NRC Plant 1C The Emergency Pla7 implementing Procedures reviewed were clear and '

Support easy to use. Documeatation reviewed was complete. Problems had been properly entered into the Problem Identification Form system when considered to exceed the threshold for entrance to the system.

Corrective actions on several PlFs remained to be fully determined. The EP staff had proactively analyzed the impact a major steam generator project would have on the site EP program. The Public Information i Brochure had recently been distributed. (1/9/98) Self-Critical 40 1/9/1998 98002 NRC Plant 2A Overall, the emergency response facilities, equipment, and supplies were Support very we!! maintained. All emergency equipment requested to be demonstrated was verified operab!e. The prompt alert and notification system sirens were well maintained. (1/9/98) Other/NA 41 1/9/1998 98002 NRC Plant 3B Overall, EP training was effective. Interviewed key emergency response Support personnel demonstrated competent knowledge of responsibilities and emergency procedures. Training records indicated that the program for tracking emergency responder qualifications was effective. Training modules were properly updated with one minor exception. An effective program for defining and tracking respirator qualifications fer emergency responders had been proactively developed. (1/9/98) Teamwork / Ski!!

Level Page 7 of 11 n . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -_ _ - _ _ _ _

"' 'S8' PLANT ISSUES MATRIX Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = *SALP" ; SALP Area = " Plant Support" ; Beginning Date = *10/1S7* , Ending Date = *10/1/98*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 42 1/9/1998 98002 Licensee Plant SA Both the annual audit and Peer Review recommended that the EP trainer Support should report to the EP Coordinator as a means of strengthening the program through increased communication and cooperation. (1/9/98)

Self-Critical 43 1/9/1998 98002 NRC Plant SC The licensee's 1997 EP audits and surveillances, and 1997 EP Program Support Self-Assessment Report were effective and satisfied the requirernents of 10 CFR 50.54(t). The audit and program self assessment were of good scope and depth. Identified issues were appropriately tracked and resolved. Corporate efforts in assessing the overall program added value. (1/9/98) Self-Critical 44 12/24/1997 97024 NRC Plant 3C The inspectors concluded that the methods for controlling the use of a Support drinking water station in a high radiation / contaminated area on December 24,1997, created a potential problem. Although there had not been any known contamination events attributable to the manner in which the drinking water station was controlled, an individual could potentially be contaminated due to the lack of direct control by RF technicians, the general access to the water station, and the lack of personal surveys.

(12/24/97) Inadequate Procedure / Instruction 45 12/18/1997 97023 Self- Plant 1C Radiation protection personnel's protocol for projecting dose was sound.

Revealed Support The lower than expected SG AP and outage dose was due in part to lower than expected dose ..es in containment. The low dose rates were attributed to successful source term reduction efforts. The overa!!

projected dose goal of 425.6 person-rem for the outage is reasonable and expected to be achieved. (12/18/97) Teamwork / Skill Level 46 12/18/1997 97023 NRC Plant 1C The licensee effectively implemented work planning, radiological controls, "

Support and as-low-as -reasonably-achievable (ALARA ) initiatives during the Unit 1 steam generator replacement project (SGRP). (12/18/97)

Teamwork / Skill Level Page 8 of 11

PLANT ISSUES MATRIX M/23/98^

Byron -

Search Sorted by Date (Descending) and SMM Codes (Ascending): Search Column = "SALP" , SALP Ama = Pant Support , Beginning Date = *10/1/97" , Erwing Date = *10/1/98*

fDATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 47 12/18/1997 97023 NRC Plant 3A A procedural violation was identified for workers that were toitering (one Support was sleeping) in containment. The inspectors expressed concem about the workers supervisor who allowed them to wait in containment for an indeterminate time. Acceptable corrective actions were taken to prevent recurrence; however, the licensee's initial review of this matter had not sufficiently considered the inappropriate performance of the supervisor who instructed the workers to wait. (12/18/97) Personnel Performance Deficiency 48 12/17/1997 97024 NRC Plant 1C The security force properly controlled the fence penetration during the Support transport of an old SG on December 17,1997. Good access control of personnel leaving and retuming to the protected area through the fence penetration existed. Security supervision was present. The protected area penetration was well controlled (12/17/97). Teamwork / Skill Level 49 12/17/1997 97024 NRC Plant 1C During the transport of an old steam generator (SG) to the old SG storage Support facility, a moving radiciogical area existed. The radiological protection (RP) technicians controlled both the number of personnel near the old SG and the distance between nonessential personnel and the old SG.

Radiation Protection Supervision also ensured that the transport evolution was properly controlled (12/17/97.) Teamwork / Skill Level 50 12/3/1997 97024 NRC Plant 1C The increased amount of transient combustibles during the refueling Support outage was not always aggressively controlled. Two instances of poorly controlled combustibles were identified. A 55-gallon barrel containing oil soaked rags and 13 containers of a flammable liquid were both identified by the inspectors. Two violations of a failure to follow Byron Administrative Procedure (BAP) 1100-9, " Control Use, and Storage of Flammable and Combustible Liquids and Aerosols," were cited (12/3/97). Personnel Performance Deficiency 51 11/24/1997 97022 NRC Plant 3A A worker struck contaminated stairs staged in the fuel handling building Support three timt s with the uncontaminated handling equipment while using an overhead hoist. Radiological response was appropriate; however, the repeated striking of contaminated equipment showed poor radiological work practices and a disregard for contamination arca postings by personnel. (1124/97) Personnel Performance Deficiency Page 9 of 11

'1/23/9 PLANT ISSUES MATRIX Byron <

Search Sorted by Date (Descerdng) and SMM Codes (Ascerdng): 5earch Column = "SALP" ; SALP Area = " Plant Support' ; Beginning Date = *10/1S7* ; Erong Data = *10/1S8*

DATE TYPE SOURCE ID BY SALP SMM CODES DESCRIPTION 52 11/23/1997 97023 NRC Plant 3C Due to inspector concems, the licensee reevaluated a personal dose Support assigned to a worker from a radioactive hot particle. As a result, the licensee found that the initial dose assessment was incorrect. Although the initial dose assessment was conservative, the inspectors noted that it was not sufficiently thorough. (11/23/97) Personnel Performance Deficiency 53 11/8/1997 97023 Licensee Plant SC The inspectors reviewed a potential locked high radiation area egress Support incident and the licensee's investigation. The licensee's investigation of this matter found that workers had not been denied egress from the area.

However, as a result of the investigation, the licensee implemented actions to avoid the potential for anyone to becomo locked within the missile barrier. (11/8/97) Self-Critical 54 10/16/1997 97020 NRC Plant 1C Radiation protection personnel property performed and documented Support surveys of the new fuel and shipping containers. The receipt of new fuel was well supported by the radiation protection personnel (10/16/97).

Teamwork / Skill Level 55 10/16/1997 97020 Licensee Plant 3B A no-response violation was cited for failure to comply with escort Support requirements within the protected area. The incident demonstrated a lack of sufficient knowledge of escort requirements by both a visitor and an escort (8/15/97). Personnel Performance Deficiency 56 10/16/1997 97020 NRC Plant 3B Observed worker contamination control practices were good and the Support transition from a three step off pad program to a single step off pad program was successfully implemented (10/1/97). Teamwork / Skill Level ,

Page 10 of 11

11/23/96 GENERAL DESCRIPTION OF PIM TABLE LABELS .

A counter number used for NRC intemal editing.

DATE The date of the event or sigruficant issue. For those items that have a clear date of occurrence use the actual date. If the actual date is not known, use the date the issue was identified. For issues that do not have an actual cate or a date of identification use the LER or inspection report date.

TYPE The categorization of the issue - see the TYPE ITEM CODE table.

SOURCE The document that contains the issue information: IR for NRC Inspection Report or LER for Licensee Event Report.

ID CY Identification of who discovered the issue - see table.

SALP SALP Functional Area Codes - Engineering, Maintenance, Operations, Plant Support anu A!!! Multiple (i.e., more than one SALP area affected).

SMM CODES Senior Manager Meeting Codes - see table.

DESCRIPTION Details of the issue from the LER text or from the IR Executive Summaries.

TYPE ITEM CODE NOTES SENIOR MANAGEMENT MEETING CODES DEV Deviation from NRC Requirements

Eels are apparent violations of NRC 1 Operational Performance:

ED Escalated Discretion - No Civil Penalty requirements that are being considered for A - Normal eel

Escalated Enforcement Issue - Waiting Final NRC Action escalated enforcement action in accordance B - During Transients LER License Event Report to the NRC with the " General Statement of Policy and C - Programs and Processes Licensing L.icensing issue from NRR Procedure for NRC Enforcement Action (Enforcement Policy), NUREG-1600. 2 Material Condition:

Misc Miscellaneous (Emergency Preparedness Finding. etc.) However, the NRC has not reached its final A - Equipment Condition NCV Non-Cited Violation enforcement decision on the issues B - Programs and Processes Negative Individual Poor Licensee Performance identified by the Eels and the PIM entries 3 Human Performance:

Prsitive individual Good Licensee Performance may be mod;fied when the final decisions A - Work Performance Strength Overall Strong Licensee Performance are made. Before the NRC makes its B - Knowiedge, Skills, and Abilities enforcement decision, tf.e licensee will be URl" Unresolved Inspection item C - Work Environment provkfed with an opportunity to either VIO/SL-1 Notice of Violation - Severity Level I (1) respond to the apparent violation or 4 Engineering / Design:

VIO/SL-Il Notice of Violation - Severity Level 11 (2) request a predecisional enforcement A - Design VIO/SL-ill Notice of Violation - Severity Level ill conference. B - Engineering Support VIO/SL-IV Notice of Violation - Severity Level IV ** URis are unresolved items about which C - Programs and Processes Weakness * ", '

Overall Weak Licensee Performance 5 Problem Identification and Resolution:

h rh u in ques sa acceptable item, a deviation, a A - Identification nonconformance, or a violation. However, B - Analysis ID BY the NRC has not reached its final C - Resolution Liennsee The licensed utility conclusions on the issues, and the PIM NRC The Nuclear Regulatory Commission entries may be modified when the final Self-R Evealed identification by an event (e.g., equipment breakdown) conclusions are made.

Other Identification unknown Page 11 of 11

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ML20197K007

Text

SUBJECT:

Enclosures:

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