IR 05000244/2018002

LLC - Integrated Inspection Report 05000244/2018002

ML18214A673
Person / Time
Site:	Ginna
Issue date:	08/02/2018
From:	Christopher Cahill Reactor Projects Branch 1
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2018002
Download: ML18214A673 (18)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION ust 2, 2018

SUBJECT:

R.E. GINNA NUCLEAR POWER PLANT, LLC - INTEGRATED INSPECTION REPORT 05000244/2018002

Dear Mr. Hanson:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at R.E. Ginna Nuclear Power Plan, LLC (Ginna). On July 23, 2018, the NRC inspectors discussed the results of this inspection with Mr. William Carsky, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement; and the NRC Resident Inspector at Ginna. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Christopher G. Cahill, Acting Chief Reactor Projects Branch 1 Division of Reactor Projects Docket Number: 50-244 License Number: DPR-18

Enclosure:

Inspection Report 05000244/2018002

Inspection Report

Docket Number: 50-244 License Number: DPR-18 Report Number: 05000244/2018002 Enterprise Identifier: I-2018-002-0056 Licensee: Exelon Generation Company, LLC Facility: R. E. Ginna Nuclear Power Plant, LLC Location: Ontario, New York Inspection Dates: April 1, 2018 to June 30, 2018 Inspectors: N. Perry, Senior Resident Inspector J. Schussler, Resident Inspector H. Anagnostopoulos, Senior Health Physicist J. Furia, Senior Health Physicist K. Kolaczyk, Senior Resident Inspector J. Lilliendahl, Senior Emergency Response Coordinator L. Dumont, Reactor Inspector Approved By: C. Cahill, Acting Chief Reactor Projects Branch One Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring Exelons performance at

Ginna by conducting the baseline inspections described in this report in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC identified and self-revealing findings, violations, and additional items are summarized in the table below.

List of Findings and Violations Incorrect Scaling Factors in Reactor Vessel Level Monitoring System Instrumentation Uncertainty Calculation Cornerstone Significance Cross-Cutting Inspection Aspect Results Section Mitigating Green None 71152 Systems NCV 05000244/2018002-01 Closed The inspectors identified a Green non-cited violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, when Exelon failed to ensure that adequate design control measures existed to verify the adequacy of the Reactor Vessel Level Monitoring System (RVLMS) uncertainty calculation. Specifically,

Exelon failed to identify errors in the RVLMS uncertainty calculation which resulted in a reasonable doubt of operability for the system after a temporary modification was implemented.

PLANT STATUS

Ginna began the inspection period at 100 percent power. The unit remained at or near 100 percent power for the entire inspection period.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess Exelons performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.01 - Adverse Weather Protection Summer Readiness

The inspectors evaluated summer readiness of offsite and alternate AC power systems.

External Flooding (1 Sample)

The inspectors evaluated readiness to cope with external flooding on April 11 and 27, 2018.

71111.04 - Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) A spent fuel pool cooling on June 4, 2018

(2) B containment spray on June 20, 2018

(3) C safety injection on June 29, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the B motor driven auxiliary feedwater system on April 17, 2018.

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Relay room zone RR1 on May 1, 2018

(2) Screen house operating floor zone SH-1 on May 1, 2018

(3) Screen house basement zone SH-2 on May 1, 2018

(4) Turbine building basement zone TB-1 on June 22, 2018

71111.06 - Flood Protection Measures Internal Flooding

The inspectors evaluated circulating water level switches for internal flooding mitigation protections in the screen house basement and turbine building condenser pit on May 15, 2018.

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated a crew of licensed operators in the plants simulator during licensed operator requalification involving a scenario containing but not limited to a ground on a safety bus, failed nuclear instrument, steam generator tube leak and steam generator tube rupture on June 12, 2018.

Operator Performance (1 Sample)

The inspectors observed microprocessor rod position indication system alarm response and over pressure accumulator makeup on June 4, 2018, and reactor power reduction for turbine driven auxiliary feedwater testing on June 25, 2018.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Letdown line weld leak on reactor coolant system on May 3, 2018

(2) Offsite power failed current transformer on June 4, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) Planned maintenance on the B motor driven auxiliary feedwater train on April 12, 2018

(2) Planned maintenance on the B residual heat removal train on May 1, 2018

(3) Planned service test of the technical support center battery on May 3, 2018

(4) Planned testing and calibration of instrument bus A and reactor protection system channel 1 on June 4, 2018

71111.15 - Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) Component cooling water V727R socket weld leak on May 9, 2018

(2) Service water SWU-161 hanger failure on May 18, 2018

(3) Steam generator level transmitter 461 failure on May 29, 2018

(4) B emergency diesel generator relay flag indication on May 31, 2018

(5) Microprocessor rod position indication system, indicating errors on June 20, 2018

71111.18 - Plant Modifications

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change Package ECP-18-000090, Gag AOV-312 in Divert Position and Close V-311B on June 8, 2018

71111.19 - Post-Maintenance Testing

The inspectors evaluated post maintenance testing for the following maintenance/repair activities:

(1) B motor driven auxiliary feedwater pump preventive maintenance on April 13, 2018

(2) B residual heat removal pump preventive maintenance on May 2, 2018

(3) A spent fuel pit pump preventive maintenance on May 14, 2018

(4) A steam generator level repeater 461 unplanned replacement on May 29, 2018

(5) Diesel fire pump unplanned maintenance on May 31, 2018

(6) C service water pump planned maintenance on June 18, 2018

==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:

Routine==

(1) STP-E-10.8, technical support center battery service test on May 8, 2018

(2) CH-PRI-SAMP-SPECIAL, liquid sampling outside nuclear sample room on May 10, 2018

(3) STP-O-12.1, A emergency diesel generator on May 16, 2018

(4) CH-PRI-SAMP-ROOM Reactor coolant system activity on June 8, 2018

(5) STP-O-2.3.1M, containment recirculation fan cooler on June 27, 2018

Inservice (1 Sample)

(1) STP-O-16QT, turbine driven auxiliary feedwater on June 25, 2018

71114.06 - Drill Evaluation Emergency Planning Drill

The inspectors evaluated the conduct of a routine Exelon emergency planning integrated exercise on June 26, 2018. The exercise scenario involved declaration of a Site Area Emergency based on the loss of all onsite AC power, the declaration of a General Emergency based on loss of all onsite and offsite AC power, and a radiation release via the containment mini-purge valve.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Engineering Controls

The inspectors evaluated airborne controls and monitoring.

Self-Contained Breathing Apparatus for Emergency Use

The inspectors evaluated the Exelon self-contained breathing apparatus program.

==71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Radioactive Material Storage (1 sample)

The inspectors observed radioactive waste container storage areas and verified the postings and controls, and that Exelon had established a process for monitoring the impact of long-term storage of the waste.

Radioactive Waste System Walkdown (1 sample)

The inspectors walked down the following:

• Accessible portions of liquid and solid radioactive waste processing systems to verify current system alignment and material condition

• Abandoned in place radioactive waste processing equipment to review the controls in place to ensure protection of personnel

• Changes made to the radioactive waste processing systems since the last inspection

• Processes for mixing and transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers

• Current methods and procedures for dewatering waste

Waste Characterization and Classification (1 sample)

The inspectors identified radioactive waste streams and reviewed radiochemical sample analysis results to support radioactive waste characterization. The inspectors reviewed the use of scaling factors and calculations to account for difficult-to-measure radionuclides.

Shipment Preparation (1 sample)

The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness.

Shipping Records (1 sample)

The inspectors reviewed selected non-excepted package shipment records.

=71151 - Performance Indicator Verification The inspectors verified Exelons performance indicator submittals listed below.

(1) Safety system functional failures on June 12, 2018

(2) Reactor coolant system leak rate on June 12, 2018

(3) Reactor coolant system activity on June 12, 2018

71152 - Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed Exelons corrective action program for trends that might be indicative of a more significant safety issue.

Annual Follow-up of Selected Issues ===

The inspectors reviewed Exelons implementation of its corrective action program related to the following issues:

(1) Intermittent losses of position indication for Microprocessor Rod Position Indication (MRPI) -1-11 and rod control circuit card failures.

(2) Intermittent failure of TE-491A in the RVLMS.

INSPECTION RESULTS

Incorrect Scaling Factors in Reactor Vessel Level Monitoring System Instrumentation Uncertainty Calculation Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green None 71152 Systems NCV 05000244/2018002-01 Follow-up of Closed Selected Issues The inspectors identified a Green NCV10 CFR Part 50, Appendix B, Criterion III, Design Control, when Exelon failed to ensure that adequate design control measures existed to verify the adequacy of the RVLMS uncertainty calculation. Specifically, Exelon failed to identify errors in the RVLMS uncertainty calculation which resulted in a reasonable doubt of operability for the system after a temporary modification was implemented.

Description:

RVLMS uses several resistance temperature detectors (RTDs) to measure sensing line temperature for calculating specific gravity of the sensing line fluid. Due to the intermittent failure of one RTD (TE-491A), Exelon implemented a temporary modification on October 27, 2017, to use another RTD (TE-490A) in its place. The new RTD temperature is expected to trend similarly to the original RTD, but the new RTD may indicate differently since the new RTD is located at a different elevation in containment. Exelon calculated the largest temperature differential expected between the RTDs and determined that the increased error was acceptable based upon the available error margin in EWR2799-DA9DD, RVLMS System Uncertainty.

The inspectors identified that EWR2799-DA9DD (dated 1986) used different scaling factors than those calculated in EWR2799-DA12J, RVLMS Scaling and Calibration, (dated July 9, 1987). The scaling factors are used to determine the impact on signal errors as the errors propagate through RVLMS. For example, if a component were to double a signal, then any error would also double, so the scaling factor would be two.

When the correct scaling factors were applied to EWR2799-DA9DD, as corrected for the RTD temporary modification, the results showed negative, or inadequate, margin for instrumentation inaccuracy. The impact of inadequate instrumentation inaccuracy is that the reading for reactor vessel level in the control room could be too high or too low which would impact the operators response during an event.

Corrective Actions: On June 29, 2018, Exelon captured the issue in issue reports and performed an analysis which recalculated the instrumentation uncertainty after identifying and removing an additional error in the calculation, correcting the scaling factors, and removing excess conservatisms. The recalculation demonstrated adequate margin is available. The inspectors had no current operability concerns.

Corrective Action Reference: ARs 04146984, 04147229, and 04151833

Performance Assessment:

Performance Deficiency: Exelon failed to ensure that adequate design control measures existed to verify the adequacy of the RVLMS uncertainty calculation. Specifically, Exelon failed to identify errors in the RVLMS uncertainty calculations which resulted in a reasonable doubt of operability for the system after a temporary modification was implemented.

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the design control attribute of the Mitigating Systems Cornerstone Objective of ensuring the reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, this issue is similar to Example 3.j of IMC 0612, Appendix E, Examples of Minor Issues, issued August 11, 2009, because the engineering calculation error resulted in a condition where there was a reasonable doubt on the operability of the RVLMS component.

Significance: The inspectors assessed the significance of the finding using IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that this finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component, where the structure, system, or component maintained its operability or functionality. Specifically, the revised analysis by Exelon showed that sufficient margin exists. Therefore, the inspectors determined the finding to be of very low safety significance (Green).

Cross-Cutting Aspect: None. This finding is not indicative of current performance because the incorrect calculation, EWR2799-DA9DD, RVLMS System Uncertainty, has not been revised since 1986, and the calculation with the revised scaling factors, EWR2799-DA12J, RVLMS Scaling and Calibration, has not been revised since 1987.

Enforcement:

Violation: 10 CFR Part 50, Appendix B, Criterion III, Design Control," requires, in part that design control measures shall provide for verifying or checking the adequacy of design.

Contrary to the above, from July 9, 1987, until June 29, 2018, Exelon failed to ensure that adequate design control measures existed to verify the adequacy of the RVLMS uncertainty calculation. Specifically, Exelon failed to identify errors in the RVLMS uncertainty calculations which resulted in a reasonable doubt of operability for the system after a temporary modification was implemented.

Disposition: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

Observation 71152 Semi-Annual Trend Review The inspectors evaluated a sample of condition reports generated over the course of the first and second quarter of 2018 to determine whether issues were appropriately considered as emerging or adverse trends. The inspectors verified that these issues were addressed within the scope of the Corrective Action Plan or through department review.

The evaluation did not reveal any new trends that could indicate a more significance safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Exelon staff for potential trends at a low threshold, and resolved within the scope of the corrective action program. The inspectors noted minor adverse trends identified by Exelon staff in the area of diesel fuel oil sample particulates, control room recorder failures, rod drive cabinet temperature alarms, and vital battery monitoring alarms.

There were no safety consequences as a result of these low-level trend issues. Based on the overall results of the semi-annual trend review the inspectors determined that Exelon had properly identified adverse trends at Ginna before they became more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues. The inspectors determined that none of the conditions were deficiencies of greater than minor significance and, therefore, are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

Observation 71152 Follow-up of Selected Issues The inspectors assessed Exelons corrective actions related to the intermittent losses of position indication for MRPI I-11. Exelon concluded the likely cause of the losses was due to connection issues. The inspectors determined that Exelon conducted an appropriate review of the issue and had developed corrective actions to address the cause during the upcoming refueling outage. During this PI&R sample inspection the inspector also reviewed and assessed Exelon corrective actions related to rod control circuit card failures. These cards have been in operation since initial plant operation, approximatively 49 years. Ginna does not have a replacement PM for control rod circuit cards. No performance deficiency was identified because the inspectors did not identify a regulatory requirement or licensee self-imposed standard that was not met that was within the licensee ability to foresee and correct.

Specifically, there was no prior operating experience of the circuit cards, no vendor recommended replacement schedule, and vendor recommended four year PM activities were being performed. However, during the last four months the plant had experienced two rod control circuit card failures, and one of the failures was due to age related degradation. The inspectors determined that Exelon conducted an appropriate review of the failures and are developing corrective actions to replace the circuit cards.

EXIT MEETINGS AND DEBRIEFS

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

• On April 12, 2018, the inspectors debriefed the inspection results of the Problem Identification and Resolution sample associated with the intermittent losses of position indication for the I-11 Microprocessor Rod Position Indication.

• On April 20, 2018, the inspectors presented the Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation inspection results to Mr. J. Bement, Radiation Protection Manager, and other members of the licensee staff

• On June 14, 2018, the inspectors debriefed the inspection of the Annual Problem Identification and Resolution sample associated with Reactor Vessel Level Monitoring System to Mr. Paul Swift, Plant Manager and other members of the Ginna staff

• On June 27, 2018, the inspectors presented the In-Plant Airborne Radioactivity Control and Mitigation inspection results to Mr. W. Carsky, Site Vice President, and other members of the Exelon staff

• On July 23, 2018, the inspectors presented the integrated quarterly resident inspector report inspection results to Mr. W. Carsky, Site Vice President, and other members of the Ginna staff.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Procedures

O-23, Hot Weather Seasonal Readiness Walkdown, Revision 017

SC-3.17, Auxiliary Building Flood Barrier Installation/Removal/Inspection, Revision 00500

SC-3.17.1, SAFW Annex Flood Barrier Installation/Removal/Inspection, Revision 001

71111.04 - Equipment Alignment

Condition Reports (*initiated in response to inspection)

04148821*

71111.05 - Fire Protection

Procedures

A-54.7, Fire Protection Tour, Revision 38

FPS-3, Fire Barrier Inspection Program, Revision 3

FRP-21.0, Turbine Building Basement, Revision 014

71111.06 - Flood Protection Measures

Maintenance Orders/Work Orders

C91471809

C93301541

C93624270

C93624271

71111.11 - Licensed Operator Requalification Program

Procedures

HU-AA-1211, Pre-Job Briefings, Revision 11

OP-AA-101-113-1006, 4.0 Crew Critique Guidelines, Revision 9

TQ-GI-150-F31 (LORT), Ginna Site Specific License Operator Requalification Training Program,

Revision 5

71111.12 - Maintenance Effectiveness

Procedures

ER-AA-310, Implementation of the Maintenance Rule, Revision 11

ER-AA-310-1001, Maintenance Rule - Scoping, Revision 4

ER-AA-310-1002, Maintenance Rule Functions - Safety Significance Classification, Revision 3

ER-AA-310-1003, Maintenance Rule - Performance Criteria Selection, Revision 5

ER-AA-310-1004, Maintenance Rule - Performance Monitoring, Revision 14

ER-AA-310-1005, Maintenance Rule - Dispositioning Between (A)(1) and (A)(2), Revision 7

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Procedures

OP-AA-102-102, General Area Checks and Operator Field Rounds, Revision 15

OP-AA-108-117, Protected Equipment Program, Revision 5

OPG-PROTECTED-EQUIPMENT, Operations Protected Equipment Program,

Revision 18, 19, 20

WC-AA-101, On-Line Work Control Process, Revision 27

WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 2

WC-AA-104, Integrated Risk Management, Revision 25

Condition Reports (*initiated in response to inspection)

04144177*

Miscellaneous

Risk Management Document, RM G1-A4-026, SAFW HVAC Compensatory Measure Risk

Evaluation, Revision 0

71111.15 - Operability Determinations and Functionality Assessments

Procedures

OP-AA-108-115, Operability Determinations, Revision 21

Condition Reports

04135528

Drawings

C381-0358, Service Water Return from Component Cooling Heat Exchanger to Wall Col. Q

(EWR 2512), Revision 20

Miscellaneous

OPEVAL-18-002, MRPICRT, PPCS and MCB Alarm Window C-29, Revision 001

OPEVAL-18-003, CCW Piping Upstream 727R, Revision 001

OPEVAL-18-004, SWU-161, Revision 0

71111.18 - Plant Modifications

Maintenance Orders/Work Orders

C93654991

Miscellaneous

ECP-18-00090, Gag AOV-312 in Divert Position and Close V-311B, Revision 1

71111.19 - Post-Maintenance Testing

Procedures

STP-O-2.7.1-COMP-C, C Service Water Comprehensive Pump Test, Revision 005

STP-O-16-COMP-B, Auxiliary Feedwater Pump B - Comprehensive Test, Revision 013

STP-O-33A, Spent Fuel Pool Pump A, Revision 007

Maintenance Orders/Work Orders

C93620853

C93661667

71111.22 - Surveillance Testing

Procedures

CH-714, Gamma Isotopic Analysis of Crud and Degassed Primary Coolant, Revision 00500

CH-PRI-SAMP-ROOM, Sampling in the Nuclear Sample Room, Revision 03001

CH-PRI-SAMP-SPECIAL, Liquid Sampling Outside Nuclear Sample Room, Revision 06000

STP-O-12.1, Emergency Diesel Generator A, Revision 025

STP-O-16QT, Auxiliary Feedwater Turbine Pump - Quarterly, Revision 014

Condition Reports

04136616*

Maintenance Orders/Work Orders

C93615452

71152 - Problem Identification and Resolution

Procedures

PI-AA-120, Issue Identification and Screening Process, Revision 8

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 6

WC-AA-120, Preventive Maintenance (PM) Database Revision Requirements, Revision 18

Condition Reports (*initiated in response to inspection)

04011509 04104434 04131322*

04011603 04114571 04136217

04011653 04117980 04139500

04011980 04118072 04146984*

04036776 04123268 04147229*

04062010 04123759 04151833*

04062010 04124266

04097729 04130068

Maintenance Orders/Work Orders

C92243669 C93301612 C93498598

C93301588 C92597353 C93637163

C92305864 C93301668 C93640642

Calculations

EWR2799-DA9DD, RVLMS System Uncertainty, Revision 0 and 1

EWR2799-DA12J, RVLMS Scaling and Calibration, Revision 0

Letters

Letter from

R. Kober to C. Stahle regarding Inadequate Core Cooling Instrumentation, dated

9/18/87

Letter from B. Snow to C. Stahle regarding Implementation Report Reactor Vessel Level

Indication System, dated 5/3/88

Drawings

10904-374 Sh7, Micro Processor Rod Position Indication System, Revision 1

Miscellaneous

ECP-17-000674-001-F-02, Temp Mod to replace TE-491A with TE-490A, Revision 0 and

133013-2671, Reactor Vessel Level Measurement System Block Diagram, Revision 4

GIN-1-2017-0456, Simple Issue Risk Assessment Associated with Intermittent Loss of I-11RPI,

Revision 3

GIN-1-2017-0674, Simple Issue Risk Assessment Associated with Dropped Control Rod K07,

Revision 0

PMCR P-GIN-029323, MRPI Data and Display Cabinet Circuits Cards replacement Schedule

dated 6/26/2013

VT-W0120-4156, Technical manual Full Length Rod Control System Volume 1, Nov 1969

Enclosure