NLS2003128, Revisions to the Strategic Improvement Plan

Revisions to the Strategic Improvement Plan

ML033650454
Person / Time
Site:	Cooper
Issue date:	12/23/2003
From:	Edington R Nebraska Public Power District (NPPD)
To:	NRC Region 4
References
NLS2003128
Download: ML033650454 (18)

Text

N Nebraska Public Power District Always there when you need us NLS2003128 December 23, 2003 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

Subject:

Revisions to The Strategic Improvement Plan Cooper Nuclear Station, Docket 50-298, DPR-46

Reference:

1.

Nebraska Public Power District letter NLS2002141 to Ellis W. Merschoff (U.S. Nuclear Regulatory Commission) dated November 25, 2002, "The Strategic Improvement Plan Revision 2"

2.

Letter to Clay C. Warren (Nebraska Public Power District) from Ellis W.

Merschoff (U.S. Nuclear Regulatory Commission) dated January 30, 2003, "Confirmatory Action Letter" The purpose of this letter is to inform the Nuclear Regulatory Commission (NRC) of changes to The Strategic Improvement Plan (TIP) Action Plans. On December 9, 2003, Paul V. Fleming, Licensing and Regulatory Affairs Manager at Nebraska Public Power District, discussed these changes with Kriss Kennedy, Chief, NRC Region IV Branch C. It was determined that the changes discussed herein would require a formal submittal to the NRC. On December 15, 2003, Mr. Fleming and members of the Cooper Nuclear Station Engineering organization further discussed Action Plans 5.3.1.2.g and 5.3.1.2.j with Mr. Kennedy and members of the NRC.

Reference 1 transmitted TIP, Revision 2, to the NRC and identified TIP actions that were appropriate for inclusion in a Confirmatory Action Letter (CAL) as regulatory commitments.

Reference 2 subsequently transmitted the CAL. Included among the CAL commitments identified in Reference 2 were TIP Action Plans 5.3.1.1, 5.3.1.2.b, 5.3.1.2.e, 5.3.1.2.g, 5.3.1.2.i, and 5.3.1.2j. Steps within these Action Plans have been revised and are the subject of this correspondence.

TIP Action Plan 5.3.1.1 addresses the Equipment Reliability Improvement Plan. Action Steps 3f, 5d, and 8 have been revised in this Action Plan. Step 3f requires development of an action plan to resolve high priority obsolescence issues. The end date for this step was extended from 4Q/03 to 1Q/04 to levelize station work activities in the fourth quarter in order to support ongoing plant activities. The deliverable was also revised to clarify that the high priority equipment COOPER NUCLEAR STATION A

J l

P.O. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5211 www.nppd.com

NLS2003128 Page 2 of 4 obsolescence issues will be integrated into system long-range plans. Step 5d requires establishment of a process to link individual system long-range plans to the station business plan.

The end date for this step was revised from 4Q/03 to 4Q/04 in order to link the integration of the system long-range plans with the implementation of the revised station business plan process being implemented in accordance with TIP Action Plan 5.1.1.1. Step 8 requires performance of an interim self-assessment to determine the effectiveness of actions taken to improve the equipment reliability process. The end date for this step was revised from 4Q/03 to 1 Q/04 to allow additional time to monitor the completed actions taken prior to performing an assessment.

TIP Action Plan 5.3.1.2.b addresses a long standing equipment issue related to Feedwater Check Valves. Action Steps 8, 9, 10, 11, 13, 14, and 15 have been revised in this Action Plan. The Action Plan was initially designed to implement the installation of new design Feedwater Check Valves in two phases. The initial phase was to involve the installation of two Inboard Feedwater Check Valves during Refueling Outage 22 (RE22) and the second phase was to involve the installation of two Outboard Feedwater Check Valves in RE23. As a result of this phased installation, a number of Action Steps were incorporated in the Plan as contingencies. However, a management decision has been made to install both the Inboard and Outboard Feedwater Check Valves during RE22. Therefore, Action Steps 8, 10, 13, 14, and 15 have been deleted and Action Steps 9 and 11 revised accordingly.

TIP Action Plan 5.3.1.2.e addresses a long standing equipment issue related to Water Sulfates.

Action Step 5 has been revised in this Action Plan. Step 5 previously stipulated that a Change Evaluation Document (CED) would be developed to allow vacuum priming tank effluent to be routed to the Circulating Water discharge canal. This step was revised to state that a CED would be developed to eliminate draining river water from the vacuum priming tank into the liquid radioactive waste system. The Action Step originally required a specific solution that may not be the best one to solve the existing technical problem. The CED process requires identifying possible solutions and evaluating these to arrive at the optimum solution. Therefore, the Action Step was revised to provide for flexibility in developing the specific CED solution.

TIP Action Plan 5.3.1.2.g addresses a long standing equipment issue related to Primary Containment Vacuum Breakers. Action Steps 2, 4, 5, 6, and 7 have been revised in this Action Plan. Step 2 requires the development and scheduling of Preventive Maintenance (PM) activities for air operator components. The end date for this step was revised from 4Q/03 to Q/04 to levelize Engineering work activities in the fourth quarter. However, this extension will not impact the performance of the PMs as they are required to be performed during a refueling outage and will be performed in RE22. Steps 4 through 7 are being deleted as the performance and reliability of the torus to drywell vacuum breakers have improved over the past two cycles such that replacement of the vacuum breakers is no longer warranted at this time. Corrective actions that have been implemented include the development of a new Maintenance Procedure providing instructions for performing inspection and maintenance of the torus to drywell vacuum breakers, training of Maintenance personnel on torus to drywell vacuum breaker maintenance, improvements to the surveillance testing procedure, and the performance (prior to startup from REI9) of necessary corrective maintenance to the vacuum breakers. In RE20 and RE21, all torus

NLS2003 128 Page 3 of 4 to drywell vacuum breaker valves passed their leakage tests. In addition, monthly position indication tests are performed and there has been only one valve indication failure since REl9.

Performance of the torus to drywell vacuum breakers will continue to be monitored by the System Engineer and the System Health Team and future replacement of the vacuum breakers will be pursued, if warranted, based upon system performance and evaluated in the context of other plant priorities as part of the Long Range Plan for the Primary Containment System.

Additional steps were also added to this Action Plan to compile test results from RE20, RE21, and RE22 and perform a final assessment of Action Plan effectiveness in 2005.

TIP Action Plan 5.3.1.2.i addresses a long standing equipment issue related to Air Systems.

Action Step 8b has been revised in this Action Plan. Step 8b requires the development of a CED to replace the Service Air Compressors. The end date for this step was revised from 4Q/03 to IQ/04 to levelize station work activities in the fourth quarter in order to support ongoing plant activities. The extension of the completion date provides additional time for Engineering to perform the required CED reviews and approvals and will not delay the installation of the new Service Air Compressors.

TIP Action Plan 5.3.1.2.j addresses a long standing equipment issue related to the KAMAN Radiation Monitors. Action Steps 3a, 3b, 4, 5, 6, 7, 8, 9, 10, 11, and 12 have been deleted and new Action Steps 2a, 2b, 2c, 2d, 2e, 2f, 2g, and 2h have been added to this Action Plan. This Action Plan originally contained two phases. Phase 1 required the implementation of a Short Term Action Plan to provide near term actions to improve performance of the KAMAN Radiation Monitors. Phase 2 required future replacement of the KAMAN Radiation Monitors.

While preparing to implement Phase 2 long term actions, it was determined that proceeding with wholesale replacement of the monitors may not be the best solution. Instead, a structured approach will be used to identify additional corrective actions to further improve the performance of the radiation monitors based on an assessment by the System Health Team augmented by industry expertise. A performance monitoring plan will be established to measure the performance and reliability of the KAMAN Radiation Monitors throughout the implementation of this revised Plan. If performance improvement is not obtained as specified by the monitoring plan, a contingency plan for monitor replacement will be implemented. Since the implementation of the Initial Short Term Action Plan, the availability trend for the KAMAN Radiation Monitors has demonstrated improvement, with the exception of the Multi Purpose Facility KAMAN. While some improvement has been achieved in KAMAN performance, it is recognized that the objectives of this Plan have not yet been met. Implementation of this revised Action Plan will provide for a systematic approach to improving the performance and reliability of the KAMAN Radiation Monitors. provides the specific revisions to the Action Plans discussed above.

The attached List of Regulatory Commitments contains those new or revised commitments within the scope of the CAL.

NLS2003128 Page 4 of 4 Should you have any questions concerning these revised TIP Action Plans, please contact Mr.

Paul Fleming at (402) 825-2774.

Sincerel AJ~AXkJ Ran all K. Edington Vice President - Nuclear and Chief Nuclear Officer

/lb Attachment cc:

U.S. Nuclear Regulatory Commission w/attachment Attn: Document Control Desk Washington, D.C. 20555-0001 Senior Project Manager w/attachment USNRC - NRR Project Directorate IV-1 Kriss Kennedy w/attachment Chief, Branch C U.S. Nuclear Regulatory Commission Region IV Senior Resident Inspector w/attachment USNRC NPG Distribution w/attachment Records w/attachment

NLS2003 1 28 Attachment I Page 1 of 12 REVISIONS TO THE STRATEGIC IMPROVEMENT PLAN ACTION PLANS

NLS2003 128 Page 2 of 12 Revisions to TIP Action Plan 5.3.1.1, Steps 3f, 5d, and 8 Equipment Reliability Improvement Plan NO.

ACTION START DATE END DATE DELIVERABLE 3f Develop an action plan to resolve high-priority 2Q/03 4Q/% 10/04 Action pl f

quIpmlt obsolescl ce sU obsolescence issues.

developed. High priority equipment obsolescence issues integrated into respective system long-range plans. (Ref: Action Step 5a) 5d Establish process to link individual system long-3Q/03 Q3 40/04 Process description for integration of long-range range plans to the station business plan.

plans and reconciliation with business plan. This process should be integrated with the station integrated business planning process (0-CNS-26) to ensure consistency of management approach for prioritization and approval of equipment-related

projects, 8

Monitoring - Self-Assessments 3Q/03 4-Q03 10/04 Performance of Interim Assessments to determine effectiveness of actions taken to improve the Form multi-discipline team and perform a Self-Equipment Reliability Process. Action Plan would Assessment to AP-913. Revise Action Plan based be revised to as required based upon results of the upon Interim Assessment, as required, to improve Interim Assessments.

effectiveness of the Equipment Reliability Process.

Self-Assessments to be performed in accordance with 0-CNS-25, Self-Assessment.

NLS2003 128 Page 3 of 12 Revisions to TIP Action Plan 5.3.1.2.b, Steps 8, 9,10,11, 13,14, and 15 Feedwater Check Valves (Long Standing Equipment Issue)

NO.

ACTION START DATE END DATE DELIVERABLE Devclo continlen.y work,ackag fr RE22 to 03

/34Q/01 Eonpletedovk ackages witl sope of wrk to le refU1 bv0h uutOiuai. FvWeVs in tle eveLl,uttl.

o.font+/-cd dS detenim.Led by iitial FrvlV T oi a..t valves fail LLRT inspection for ca FWCV that fails LLRT.

9 Perform AS FOUND LLRT and document results 4Q/04 I Q/05 Evaluation of AS FOUND LLRT results-toI) per the Monitoring Plan.

dleteninci f MlICL batfl Outboard F-WCv's i rast e tefmubtish.ed in RE22 an1 d 2) assess tl effctivc of MfurbiSlulclnt(S) co.pleted ;.. RE21) per the Monitoring Plan.

+

mDad upon te rsult s of LLRT, mpinent te 4Q/04

+Q*5 Satisfactory AS LEFT LLRT iesults for FWev tat enliti gerICy work pa~kages) equiLed to estome had faild t.c AS FOUND LLRT tlhe Ontthoard FW6Cv's ivlv'ed to an operabl, 11 Replace the twInboard and Outboard FWCVs 4Q/04 I Q/05 Installation of improved FWCVs (two-Inboard and with Swing Check Valves per the requirements of Outboard) and acceptable Post Modification Testing the CED developed in Action 4. Perform AS per the CED.

LEFT LLRT.

r-perLfn.m LL aIT i d doeti.nenit restlts pnen thu

+Q46 29Qz Evaluati= Of AS FOUND LLRT results and Nionito.;g Nair pierfornn ce of the Iniboard SWiIg Clheck Valves instalfed in RE22 and tlie Outboad Clheck Valvs

_igi__aly i.stallcd.

NLS2003 128 Page 4 of 12 NO.

ACTION START DATE END DATE DELIVERABLE

+4 ECondtiUt Manaemei n Re-vi w of LLRT IeUIts and HJ 2Q/O6 Maigemuent dcsioa 1 tu EXIT t1i Actio+/- P r

p

_ue fCmn.

of If

's. if At 11 '

_it'1 A t_._ 1-5 Plan Ojc~tives ae d&tCLllined to lbc satisfied, E-XIT this Actio P=

+5 Rcplae t two Outfboard FWeClv wi Sing

+Q06 2Q/Oi6 IwstallationJ of imp~roved FWC6Vs (two inovaid) he1e.k iv Pei te quirements f the OLD

_____develop i Action 4.

NLS2003 128 Page 5 ofl2 Revisions to TIP Action Plan 5.3.1.2.e, Step 5 Water Sulfates (Long Standing Equipment Issue)

NO.

ACTION START DATE END DATE DELIVERABLE 5

Develop Change Evaluation Document (CED) to 3Q/03 I Q/04 CED to install modification.

allow vacmuun Frifiung tank effluenit to b ruot.e to Ciclating at dischar

. camn eliminate draining river water from the vacuum priming tank into the liquid radioactive waste system.

NLS2003 128 Page 6 of 12 Revisions to TIP Action Plan 5.3.1.2.g, Steps 2, 4, 5, 6, 7, 8, and 9 Primary Containment Vacuum Breakers (Long Standing Equipment Issue)

NO.

ACTION START DATE END DATE DELIVERABLE 2

Develop and schedule Preventative Maintenance 3Q/03 4Q/& 1 0/04 Approved PM established and incorporated into Activities (PMs) for air operator components to schedule.

improve reliability.

4 Pniase

- RerxrlteLlt of Valvc 3Q/03 4Q/03 IdeLtification ofluroject for ffindin1 i 2004.

Pi epftc and present a plOjct plan to Integrated Managemnt eonvztte (?46) to obtai+/- fu 1ding fOL Enigineerinig w,k i 2004 to develop a 6hange Evaluation Doeutment (CED) to rclac te torus to dirweli v-attrl breaker. alves.

5 er~fOrril IsCCC y

jrnginerii g design activities to 2Q/04 IQ/OS Apyioved CED to fiutall iO reliable torus to dvlop and oUtai ar o v a of a CED to e

ladiy vtll ba akers the torus to drywll vactutn b,.ealk.e vrith a.lpn..

relial ae mlore ea5;1y s vced alve desigr.

6 Iumpiieten.t CED to ri.qae existiljg torus to

+Q/OG 2QI86 Ilstallation of neCw vaetUtnbii ezakers Cor.ieklted.

dryw.,ell vatwin bi eakets Wid! a reliable

-7 Pifon.i a Final Sef-Assessmnt follow.g 4Q/-7

-l-Q/

Fial Effcetivencss Assessrint.

Refuen _

24 (RE24) t dee.,.rnihi.

li acceptability of tlhe valves istalled in Refueuig Outage 23 (RE23) to..ntet tc rfoL.uanViC spcfcain i_

tf.:r fr deeOLICs Of ff

.re 8

Establish results of testing performed on the torus I Q/05 10/05 Results of the testing performed during RE20, RE2 1, to drywell vacuum breakers during RE20, RE21, and RE22 are compiled for assessment in Action and RE22.

Step 9.

NLS2003 128 Page 7of12 9

Perform a final assessment to determine the effectiveness of the actions taken in order to close this Action Plan.

Final assessment performed in accordance with O-CNS-25 in order to determine the effectiveness of this Action Plan.

NLS2003 128 Page 8 of 12 Revision to TIP Action Plan 5.3.1.2.i, Step 8b Air Systems (Long Standing Equipment Issue)

NO.

ACTION START DATE END DATE DELIVERABLE 8b Develop a CED to replace the SA Compressors 3Q/03 4Q/0 10/04 Approved CED to replace the current station air with current generation design units.

compressors.

NLS2003 128 Page 9 of 12 Revisions to TIP Action Plan 5.3.1.2.j, Steps 2a, 2b, 2c, 2d, 2e, 2f, 2g, 2h, 3a, 3b, 4, 5, 6, 7, 8, 9, 10, 11, and 12 KAMAN Radiation Monitors (Long Standing Equipment Issue)

NO.

ACTION START DATE END DATE DELIVERABLE 2a Establish Performance Monitoring Plan for IQ/04 IQ/04 Performance Monitoring Plan established for use in KAMAN Radiation Monitors. Establish in the performing the Quarterly Monitoring Assessments Performance Monitoring Plan:

and Effectiveness Assessments.

• Metrics to measure the performance and reliability of the KAMAN Radiation Monitors, and

• Criteria for determining when to implement Contingency Action Plan (Reference Action Step 2d) 2b Perform Interim Effectiveness Assessment per 10/04 10/04 Completed Interim Effectiveness Assessment in 0-CNS-25 to assess KAMAN performance accordance with -CNS-25.

following implementation of the initial Short Term Action Plan.

2c System Health Team (composed of Engineering.

10/04 10/04 Revised Short Term Action Plan developed, Maintenance, Operations, and Chemistry incorporating additional corrective actions to further augmented by industry expertise) determines improve performance of the KAMAN Radiation additional corrective actions to further improve Monitors.

performance of the KAMAN Radiation Monitors.

This determination will be based on a review that includes:

e Results of the Interim Effectiveness Assessment,

• Industry experience, Previous Notifications applicable to KAMANs, and Previous action plans identified by the System Health Team intended to resolve KAMAN concerns.

NLS2003 128 Attachment I Page 10 of 12 2d Contingency Action Plan 20/04 20/04 Contingency Action Plan is developed, including as required:

Prepare Contingency Action Plan to replace

• Replacement options.

Radiation Monitor(s) in the event that performance Preliminary time and cost estimates for improvement is not effective as demonstrated by replacement options.

the Quarterly Monitoring Assessments.

2e Implement the additional corrective actions in the 2Q/04 20/05 Corrective actions contained in the revised Short revised Short Term Action Plan to improve Term Action Plan are implemented.

performance of the KAMAN radiation monitors.

2f Perform Quarterly Monitoring Assessments to 20/04 20/05 Completed Quarterly Monitoring Assessments.

determine effectiveness of the corrective actions Initiate Contingency Action Plan if criteria met per specified in the revised Short Term Action Plan.

Performance Monitoring Plan.

Note: If at any time during the monitoring period, KAMAN performance is not demonstrably improved, as defined by the Performance Monitoring Plan, then implement the Contingenc Action Plan.

2g Perform a Final Effectiveness Assessment, ver 20/05 2Q/05 Completed Final Effectiveness Assessment. Based 0-CNS-25, to determine the effectiveness of the upon the results of the Final Effectiveness actions implemented by the Revised Short Term Assessment, a determination is made by Senior Action Plan to improve KAMAN performance.

Management to perform one of the following actions:

Exit the Action Plan based upon the criteria established for improved performance, or Execute the Contingency Action Plan.

2h If prescribed by Action 2f or 2g. implement the 20/05 40/06 Contingency Action Plan is implemented in Contingency Action Plan.

accordance with the applicable station procedures.

3a hifcizitt fpn&

o f acl faAan unit of,

.Kama..

Q.

I+Q/04 Quarterly nionitolng rCport consistent with t e folilwitg efurbiSluIeLtut as specified in the Sho rt Eg0lliittt Reliability Iiujtrovee uL.lCIt iitiative as Term11 Aution PIi=.

spectified i Sl 0 rt Termi Aution Plant. (Actin Plait n

i t

3.l

_.l' no A I ~-

NLS2003 128 Page 11 of 12

-31b Contiiue to mnonitor perfbnranee Of CaCI Kan=

C46ontintUe stUarteI y IlOnitOilig I CPOt C11iStC1it Witl aint UWt i StallatiO1l Of 11CW Radiation Ionitor ing the EquiLipmieint ReliaLility Inilovemnilt iLiative System.

uwtil intaiation Of NeW Radiation MonitOIig System. (AetO1 Plan 5.3.1.1) 4 PCf,+/-nt an EffCetiveness Review of tie.. Shoft 4Q43 ApPioved t epoit developed pe tlhe equii emients of Term Actioni Plat in.lemnented to iprove the O-CES-25 addeSSii te suitabulity Of te S1hort opeiratioial readiness of the RAMAN MOnitOLS Tenitl Action Plait to aChieVe inp10Vid operationI ot and min1AiCIte tnpiarnied er into E;sOa. Sf-the lkI.IAM 4 Monitors.

Assssetto be. pefne in aeLdai.e With 0-eNS--25, Self-Assessme~nt.

.5 Exit tle firmedliate Action PhastOf tlis Aetio

O1 1

+Q/03 IM aage11eC1t RVieW of t EffeetiveneC5 Rep~or Plait lased oil llpLeved p erfolinance of t anid Quarterly Monitoring Repots that denionstate CXisting IAMAN Moniitors.

iMUlLoved petfbityane and on-sejidule piOgCSS Of boxg Term~ 2ketivon5.

6 Phase 2 -

onl

'Terin Actio5 eo nipiete Ven d nfolllation eceived.

\\..ntniLiLicat. wifii pLotential vendors ("iCP, CANBERRA) in ordeL to obtain system and eqUiplmen.At iforiLdatioIl associated Withi their specific prodttt.

}

Establish a Priocjt Mariage i aecmodani.e with 0-Coml1pete Projeet Maniager assigncd.

C-NS-01 8, Projct Mfanageenit.

8 Prepate Piojeet Chart, get funding approval and Q4Q/0 BidS fioni vendois icived.

reqUCst ids f£om tfendVLS.

9 Awadontraet.

4Q/%

2Q/04 ContLaCt rp1lacc.

+8 Prejai hliaAAge Evaluation Dotimni..ts (CED) in 2Q/04 Appoved CLs.

aemoLdanlce withl Cvopi Nuelear SJtatiotI Entgineerinlg Piocedure 3.4, EConfigniatioI hage

++

Ilnstal, tst and ilease equipment to operations.

2Q/6 Required CLD Post Modiffatioii TeStilg MoLpleted ad.systeir.i dI la oplatioial.

NLS2003 128 Page 12 of 12

+-2 M onitor system l.Lfoiian.e to de111on1stratc that 2Q/07 Systems performiance iuets design requiremets the iodificationi was sucessfil and that the end establislCd f the upgpaded Radiation Monitor*

EObjective has been satisfied, ysem

I ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© I

Correspondence Number: NLS2003128 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing & Regulatory Affairs Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITTED DATE COMMITMENT OR OUTAGE Action Plan 5.3.1.1, Step 3f - Develop an action plan to resolve 1Q04 high-priority obsolescence issues.

Action Plan 5.3.1.1, Step 8 - Form multi-discipline team and perform a Self-Assessment to AP-913. Revise Action Plan based upon Interim Assessment, as required, to improve 1Q/04 effectiveness of the Equipment Reliability Process. Self-Assessments to be performed in accordance with O-CNS-25, Self-Assessment.

Action Plan 5.3.1.2.e, Step 5 - Develop Change Evaluation Document (CED) to eliminate draining river water from the IQ/04 vacuum priming tank into the liquid radioactive waste system.

Action Plan 5.3.1.2.g, Step 2 - Develop and schedule Preventative Maintenance Activities (PMs) for air operator 1Q/04 components to improve reliability.

Action Plan 5.3.1.2.i. Step 8b - Develop a CED to replace the IQ/04 SA Compressors with current generation design units.

Action Plan 5.3.1.2.j, Step 2a - Establish Performance Monitoring Plan for KAMAN Radiation Monitors. Establish in the Performance Monitoring Plan: metrics to measure the 1Q/04 performance and reliability of the KAMAN Radiation Monitors, and criteria for determining when to implement Contingency Action Plan.

Action 5.3.1.2j, Step 2b - Perform Interim Effectiveness Assessment per 0-CNS-25 to assess KAMAN performance IQ/04 following implementation of the initial Short Term Action Plan.

PROCEDURE 0.42 REVISION 14 PAGE 15 OF 17

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTSl Action Plan 5.3.1.2.j, Step 2c - System Health Team (composed of Engineering, Maintenance, Operations, and Chemistry augmented by industry expertise) determines additional corrective actions to further improve performance of the KAMAN Radiation Monitors. This determination will IQ/04 be based on a review that includes: results of the Interim Effectiveness Assessment, industry experience, previous Notifications applicable to KAMANs, and previous action plans identified by the System Health Team intended to resolve KAMAN concerns.

I PROCEDURE 0.42 l

REVISION 14 PAGE 16 OF 17