IR 05000266/1998022

Insp Repts 50-266/98-22 & 50-301/98-22 on 981208-10.No Violations Noted.Major Areas Inspected:Maint Rule Program

ML20198K704
Person / Time
Site:	Point Beach
Issue date:	12/24/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198K695	List: IR 05000266/1998022 ML20198K691
References
50-266-98-22, 50-301-98-22, NUDOCS 9812310133
Download: ML20198K704 (15)

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l U.S. NUCLEAR REGULATORY COMMISSION i

. REGION ll1 Docket Nos: 50-266;50-301  !

License Nos: DPR-24; DPR-27 Report Nos: 50-266/98022(DRS); 50-301/98022(DRS)

! Licensee: Wisconsin Electric Power Company Facility: Point Beach Nuclear Plant, Units 1 & 2 i

Location: 6610 Nuclear Road Two Rivers, WI 54241 Dates: December 8 - 10,1998 l

Inspector: M. J. Farber, Reactor Engineer, Rlli Approved by: J. A. Gavula , Chief Engineering Specialists Branch 1

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9812310133 981224

! PDR ADOCK 05000266 l- G PDR o

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EXECUTIVE SUMMARY Point Beach Nuclear Power Plant, Units 1 & 2 NRC Inspection Reports 50-266/98022(DRS); 50-301/98022(DRS)

This inspection was a follow-up to the Maintenance Rule Baseline Inspection conducted October 15 - December 15,1998, which examined the licensee's implementation of 10 CFR 50.65," Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

The report covers a three-day on-site inspection by one regional inspecto The inspector concluded that while the maintenance rule program at Point Beach was adequately implemented as of December 1997, corrective actions for the findings of the baseline inspection improved the progra Maintenance

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The licensee's corrective actions for the violations identified during the maintenance rule baseline inspection were acceptable, adequately documented, and properly implemente Follow-up items and weaknesses that were identified during the baseline inspection as needing additional attention by the licensee were properly complete An unresolved item involving evaluation of functional failures in the Component Cooling Water system did not constitute a violatio .

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Report Details Summarv of Plant Status Unit 1 was operating at full power; Unit 2 was in a refueling outage (U2R23).

Introduction .

This inspection was a follow-up to the maintenance rule baseline inspection (reports number 50-266/97025(DRS); 50-301/97025(DRS)), conducted October 15 through December 15,1997, which examined the licensee's implementation of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This report covers a three-day on-

! site inspection by one regional inspector.

l 1. Maintenance M1 Conduct o' Maintenance (62706)

M1.1 Backaround Insoection Scope The maintenance rule baseline inspection identified several violations, an unresolved item, and severalinspection follow-up items. The follow-up inspection was conducted to evaluate the licensee's corrective actions for the formal findings and for program weaknesses identified in the repor Findinas and Observations The licensee's response to the violations contained appropriate immediate and long-term corrective actions. The details of the response to the violations, remaining formal findings, and weaknesses noted in the report were documented on Condition Reports, Nuclear Plant Memos, Action item Status reports, and through procedure change Conclusions l

The licensee's corrective actions were adequately documente M1.2 'Scooina inspection Scoce The baseline inspection disclosed a violation involving the failure to include the Facade Freeze Protection system and 345kV Switchyard Control Building within the scope of the maintenance rule program. The inspector reviewed the licensee response to the notice

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of violation, corrective action documents, and revised scoping documents to determine l the scope and adequacy of the response to these issue Observations and Findinas on Scooina The licensee's immediate corrective action, as stated in the response to the Notice of )

Violation, was to place the Facade Freeze Protection system and the 345kV Switchyard  !

Control Building in the maintenance rule scope. A review of Appendix A to NP 7.7.4, the licensee's scoping procedure, confirmed that the corrective action was completed. In I addition, the licensee's response indicated that preliminary results of a review of the Facade Freeze Protection system revealed several additional functions that should be considered within the scope of the rule. The baseline inspection had identified the

, impact of a freeze protection failure on Refueling Water Storage Tank Level

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instrumentation; the licensee's review identified impacts on Main Steam pressure transmitters, blowdown flow indicators, and auxiliary building ventilation indications. A review of the Maintenance Rule System Function List showed that these functions were now within the program scope. Appropriate performance criteria for the Facade Freeze Protection system were also established. The list of structures within scope revealed l that the 13.8kV Switchyard Building had been included in the program as stated by the

! licensee's response. The review of Appendix A, discussed above, did not reveal any other systems or functions inappropriately omitted from the program scope. The violation associated with scoping (VIO 50-266/97025-01(DRS); 50-301/97025-01(DRS))

is close Conclusions l

! The scoping deficiencies identified during the baseline inspection were properly corrected, which included incorporating other functions of the Facade Freeze Protection i system into the program and establishing acceptable performance criteria for the syste M1.3 Performance Criteria j Insoection Scope The baseline inspection disclosed a violation involving the reliability criteria for the l 120VAC Electrical system and a flaw in the sensitivity analysis which supported the '

program's reliability criteria. The inspector reviewed the licensee's response to the violation, NP 7.7.5, Revision 4, " Determining, Monitoring, and Evaluating Performance Criteria for the Maintenance Rule," dated April 8,1998, and Nuclear Plant Memo (NPM)

, 98-0361," Maintenance Rule Performance Criteria Review," dated March 25,1998. The

' Issue was also discussed with the Maintenance Rule Coordinator. The inspector discussed the flaw in the sensitivity analysis and the corrective action with a Probabilistic Safety Assessment engineer, and confirmed that a new sensitivity analysis had been developed.

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b.1 Observations and Findinas on Reliability Criteria The original performance criteria did not provide a measure of the overall reliability of the emergency lighting system and would have allowed an undetected 50 percent overall failure rate. On November 20,1997, an overall 5 percent failure rate was adopted, l based on failure of an 8-hour battery test. The team considered this conservative and l acceptable. On June 25,1998, the allowed failure rate was raised to 15%, based on l consistency with other utilities. The inspector discussed this change with the l Maintenance Rule Coordinator and considered the change acceptable, though less

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conservativ After the baseline inspection, the Maintenance Rule Coordinater conducted a complete l review of all performance criteria. The inspector examined NPM 98-0361, which documented the results of this review. The review was conservative and concluded that

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! all but six of the in-scope systems needed some revisions to performance criteria to clarify their intent, eliminate ambiguities, or ensure inclusion of support system reliability and availability. These revisions were developed by the responsible system engineers, based on guidance provided by the Maintenance Rule Coordinator.

! NP 7.7.5 was revised to clarify requirements for monitoring at the train or system level, to ensure that performance criteria considered the interrelationship of systems, and to usure the consiJeration of support system unavailability. Administrative requirements .

for in-process review and documentation to ensure consistency were also incorporated l Into the revised procedur I The revised criteria were subsequently reviewed and approved in accordance with the j revised NP 7.7.5. The inspector reviewed the revised performance criteria and found

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that the changes adequately addressed the findings listed in NPM 98-0361. The violation associated with inadequate performance criteria (VIO 50-266/97025-02(DRS); i

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50-301/97025-02(DRS)) is closed.

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l b.2 Observations and Findinas on Sensitivity Studies l

The Probabilistic Safety Assessment engineer stated that recalculating the erroneous

, failure rates was started but was stopped when it was realized that completion of the l updated analysis (PSA96) was imminent. The erroneous failure rates were teed on the

! information in the old analysis (PSA93). The team had identified that implementation of

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the maintenance rule using PSA93 was a weakness, because PSA93 did not reflect recent plant modifications since 1993 or updated operating experience data since 199 The licensee elected to delay recalculating the sensitivities until PSA96 was complete Another consideration was that performance criteria were being revised in response to the violation; the licensee elected to delay recalculation of the sensitivities until the revised performance criteria were approved. The internal events portion of PSA96 was approved on June 23,1998. The extemal events' portion was completed on November 10,1998; the delay was the result of problems with the fire analysis. On completion of the extemal events, recalculation of sensitivities was completed and was approved on December 10,1998. The inspector considered that the delay in

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reperforming the sensitivity study to incorporate the most accurate information available was acceptable. The inspection follow-up item (IFl 50-266/97025-03(DRS);

50-301/97025-03(DRS)) associated with the performance criteria sensitivity study is close ! Conclusions '

l The licensee's corrective action for the performance criteria violation was appropriate I and not only addressed the specific example but resulted in general improvement in the performance criteria. Completion and approval of PSA96 corrected a weakness, '

identified by the team during the baseline inspection, in the licensee's implementation of the maintenance rule. Postponing recalculation of the performance criteria sensitivity study to include the newest analysis and revised performance criteria was pruden M1.4 Documentation Discrecancies Insoection Scope During the baseline inspection, the inspection team identified a large number of discrepancies in both the scoping and performance criteria basis documents. The team was concerned by the number of errors and the potential for introducing mistakes in maintenance rule program data. As noted in the baseline report, an earlier licensee self-assessment had raised a simi;ar concern. The inspector reexamined the scoping and performance criteria documents, and a December 8,1998 printout of the MRLIN computer database to ensure that they had been properly corrected and were consisten Observations and Findinas on Documentation Discrepancies The review of the performance criteria bases was documented in NPM 98-0361, which was discussed earlier. This review identified and addressed the types of documentation deficiencies discussed in the baseline inspection report. As the performance criteria and the bases were revised, they were reviewed by engineering management, and then independently reviewed by the site regulatory services organization for accuracy. The inspector reviewed the performance criteria bases which were contained on copies of PBF-7029 for each system, and compared them to the MRLIN computer database. No discrepancies were identifie Following the baseline inspection, the Maintenance Rule Coordinator reviewed and corrected the scoping documentation. This was reviewed by the site regulatory services organization for accuracy. The scoping bases were printed from the MRLIN database on December 9,1998, and reviewed by the inspector; no documentation discrepancies were identifie The inspection follow-up item ( IFl 50-266/97025-04(DRS); 50-301/97025-04(DRS))

associated with documentation discrepancies on the performance criteria and scoping bases documents is close . .. .- .- .- ~ . ...-

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The actions taken by the licensee to correct documentation deficiencies were effective; independent review by the site regulatory services organization was an effective I second-check, i

M1.5 Goals and Monitorina Inspection Scope l The baseline inspection disclosed a violation involving the establishing of inappropriate goals for the Reactor Coolant and Residual Heat Removal systems. The inspector examined the licensee's response to the violation, NP 7.7.5 (discussed earlier), and copies of PBF-7029, the " Documentation of Maintenance Rule Performance Criteria," for both the Reactor Coolant and Residual Heat Removal systems. This form was specified in NP 7.7.5. The inspector also reviewed NPM 98-1264, " Reactor Coolant System (a)(1)

Classification Summary and Action Plan," dated October 6,1998, and discussed this with the Maintenance Rule Coordinato Observations and Findinas on Goals and Monitorina As discussed in section M1.3, NP 7.7.5 was revised to improve the selection of performance criteria. Paragraph 9.15 of NP 7.7.5 addressed the establishing of goals and monitoring for (a)(1) systems and required the documentation of goals on PBF-702 During 'the baseline inspection, the goals for the Reactor Coolant system were considered inadequate because they did not address one of the systems functions (reactor vessel level indication) and would have allowed an excessive failure rate for the Low Temperature Overpressure Protection function. The goals were initially revised on December 5,199, to add a vessellevelindication function and allow no failures of the low temperature overpressure protection function. This was confirmed on a PBF-7029 on June 25,1998, and was noted in the recently issued NPM 98-1264. The current goals were considered appropriate and the violation associated with this goal (VIO 50-266/97025-05a(DRS); 50-301/97025-05a(DRS))is closed NPM 98-1264 was issued following identification of a maintenance preventable functional failure which rendered a power operated relief valve inoperable. The inspector noted that additional corrective actions were specified. The inspector also noted that operating experience from both Calvert Cliffs and Ginna had been considered in the revision of the corrective action plan. This was confirmation that the licensee had satisfactorily addressed a weakness observed during the baseline inspection with regard to the use of operating experience in establishing goals and action plans for (a)(1)

systems.

! During the baseline inspection, the unavailability goal for the Residual Heat Removal

! system was considered inadequate because it was tied exclusively to the pumps and did l

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not consider other portions of the system. The goal was revised on December 5,1997,

. to expand the unavailability to include all the components in a train. This was considered appropriate. The inspector examined two PBF-7029 forms, genera *ed as a result of '

functional failures, for establishing goals for the Residual Heat Removal system and ;

noted that the goals were consistent and appropriate. The violation associated with this goal (VIO 50-266/97025-05b(DRS); 50-301/97025-05b(DRS)) is close The inspector examined the action plan for the 13.8kV electrical distribution system. The '

. system was classified (a)(1) as the result of a bus duct failure on January 8,1998. The corrective actions were adequate, goals were appropriate, ano operating experience was explicitly addressed. This confirmed the effectiveness of the licensee's corrective action Conclusions i

Deficient goals identified during the baseline inspection were corrected. Revisions to the l procedure for setting performance criteria and goals were demonstrated to be effective in i establishing adequate goals and addressing the weakness in use of operating experienc M1.6 Structure Monitorina l l Insoection Scope l

The baseline inspection noted that the criteria for moving structures from between categories (a)(1) and (a)(2) were missing from the structure monitoring procedure. The licensee said that the criteria had been inadvertently omitted from the revision and that the procedure would be reissued with the criteria replaced. The inspector examined the structure monitoring procedure to verify that the criteria had been properly incorporated, Observations and Findinas on Structure Monitorina NDE-751, Revision 5, " Structural Surveillance of Containments and General Structures,'

dated October 31,1997, was the controlling procedure for structure monitoring during the baseline inspection. The missing criteria were to have been incorporated into a forthcoming revision of this procedure. Subsequently, the licensee determined that a new procedure for structure monitoring was needed and that the missing criteria would be contained in the new procedure. NP 7.7.9, Revision 0, " Facilities Monitoring Program," was issued on September 9,1998. The criteria, drawn from NUREG 1.160, ,

for evaluating maintenance rule classification of structures, were found in paragraph j 4.5.5. The procedure was comprehensive, listing all of the structures in the program, personnel qualifications for structural inspectors, examination methods and criteria, a schedule of inspections, and documentation and evaluation requirements. The inspection follow-up item (IFl 50-266/97025-06 (DRS); 50-301/97025-06 (DRS)) is close ,

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. Conclusions The criteria for assessing reclassification of structures were included in NP 7.7.9, fulfilling the licensee's commitment to incorporate them in a forthcoming revision to the structure monitoring procedure. NP 7.7.9 was a comprehensive, well-organized procedur M1.7 Functional Failure Evaluations Insoection Scope The baseline inspection noted that there had been two occurrences of intersystem leakage between the Unit 1 and Unit 2 Component Cooling Water systems caused by cyclic fatigue induced cracking of piping. These had not been identified as functional failures. The team requested that the licensee conduct a functional failure evaluation and determine whether or not the Component Cooling Water systems had exceeded performance criteri The inspector reviewed Condition Reports 97-3835, dated November 20,1997, and 98-2731, dated July 13,1998; both were related to the leakage in the Component Cooling Water systems, Observations and Findinas on Functional Failure Evaluations Condition Report 97-3835 was issued on November 20,1997, as a result of the questions raised by the baseline inspection team. The licensee continued to evaluate this issue and on February 8,1998, concluded that the intersystem leakage between Units 1 and 2 comprised a Maintenance Preventible Functional Failure because of the potential for impacting recirculation phase cooling after an accident. The condition report documented the licensee's efforts at assessing the leakage for functional failure, the decision to classify both unit's Component Cooling Water systems as (a)(1), the development of an action plan with (a)(1) goals, and the identification of pump suction cross-connect valve CC-722A as the cause of the intersystem lea Condition Report 98-2731 was issued on July 7,1998 to document the recurrent problem with CC-722A and to track the classification of Component Cooling Water as an (a)(1)

system. Modification 97-082 was developed to add another valve to the system and will be installed during the next Unit 1 refueling outage under Work Order WO 980567 These corrective actions appeared appropriat . The unresolved item questioned whether or not a violation for failure to properly monitor a system as (a)(1) occurred as the result of failing to properly evaluate a maintenance preventable functional failure. The inspector considered the licensee's conclusion that the leakage constituted a maintenance preventable functional failure as extremely conservative in that no actual loss of the function occurred. Likewise, classifying Component Cooling Water systems as category (a)(1) was extremely conservativ Consequently, the inspector determined that no violation occurred and the unresolved item (URI 50-266/97025-07(DRS); 50-301/97025-07(DRS)) is close _ . _ _ __ .. . _ _ _ _ _ _ . _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _

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. Conclusions The licensee conservatively concluded that the Componem Cooling Water intersystem i leakage represented a maintenance preventable functional 0ailure and classified both the !

Unit 1 and Unit 2 systems as (a)(1) although no actual loss of function occurre M7 Quality Assurance in Maintenance Activities (40500)

l M7.1 Licensee Self-Assessments of the Maintenance Rule Proaram 1 Insoection Scooe

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During the baseline inspection, the team observed that closure of several

! self-assessment findings and observations was beyond due-dates. On raising this issue, the team was informed that licensee was similarly concerned. Given the number of remaining open findings, the team elected to open an inspection follow-up item to track and review their closure. The inspector reviewed ten Quality Condition Reports (listed at the end of this report) and assessed the timeliness and completeness of closure. The inspector also reviewed NP 10.3.7, Revision 0, "On-line Safety Monitor," dated ,

December 9,199 Observations and Findinas on Licensee Self-Assessments

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The ten Quality Condition Reports covered 29 action items addressing individual findings. Twenty-seven items had been completed; nine were closed beyond the initial due date, although about half of these were only slightly overdue. Two items remained

open. Periodic activity was evidem on all items; none of the items appeared to have

been allowed to languish unaddressed for substantial periods of time. Extensions were periodically obtained for those items past their due dates. The two items still open involved implementation of the on-line safety monitor and development of maintenance rule training for operators. Implementation of the on-line safety monitor was progressing satisfactorily. This was constrained by approval of PSA96 which was delayed as discussed in section M1.3. Progress was evidenced by the issuance of licensee's procedure for the on-line safety monitor (NP 10.3.7) during the inspection. The licensee planned to begin with schedulers using the monitor to minimize risk during work planning and scheduling in early 1999. The licensee anticipated that operators would begin using the program some time later to assess real-time risk associated with emergent wor NP 10.3.7 was reviewed and appeared to be an appropriate administrative procedure for goveming the use of the on-line safety monitor. The remaining item involved development of general maintenance rule training for operators. The licensee evaluated the need for this training and concluded that this was appropriate for the forthcoming cycle of operator requalification training. Consequently, development of this training material was postponed and the due date extended. Because the operators

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inspector determined that this was reasonable. The inspection follow-up item associated l with audit findings (50-266/97025-08(DRS); 50-301/97025-08(DRS)) is close .

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l j- Conclusio0g While a portion of the findings were closed after their initial due date, it was clear that all of the items were being addressed and closure actively pursued. Acceptable progress was being made on one remaining open finding and the reason for postponement of L action on the second finding was sound.

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M8 Miscellaneous Maintenance issues (92902)

l M8.1 (Closed) VIO 50-266/97025-01(DRS): 50-301/97025-01(DRS): Scoping deficiencies This item was discussed in section M1.2 and is close )

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M8.2 ' (Closep) VIO 50-266/97025-02(DRS): 50-301/97025-02(DRS): 120 VAC system -

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This item was discussed in section M1.3 and is close .

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M8.3 (Closed) IFl 50-266/97025-03(DRS): 50-301/97025-03(DRS): Flawed sensitivity analysis

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This item was discussed in section M1.3 and is closed.

L M8.4 (Closed) IFl 50-266/97025-04(DRS): 50-301/97025-04(DRS): Documentation i discrepancies

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L This item was discussed in section M1.4 and is closed.

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M8.5 (Closed) VIO 50-266/97025-05a(DRS): 50-301/97025-05a(DRS): Reactor Coolant system goals This item was discussed in section M1.5 and is close M8.6 (Closed) VIO 50-266/97025-05b(DRS): 50-301/97025-05b(DRS): Residual Heat Removal system goals

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This item was discussed in section M1.5 and is close M8.7 (Closed) IFl 50-266/97025-06(DRS): 50-301/97025-06(DRS): Structure monitoring procedure revisions y

L This item was discussed in section M1.6 and is close M8.8 - (Closed) URI 50-266/97025-07(DRS): 50-301/97025-07(DRS): Component Cooling Waterintersystem leakage l

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This' item was discussed in section M1.7 and is closed.

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M8.9 (Closed) IFl 50-266/97025-08(DRS). EQ-301/97025-08(DRS): Self-Assessment

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follow-up l This item was discussed in section M7.1 and is closed.

, ll Manaosment Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on December.10,1998. The liansee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered propietary. No proprietary information was identified.

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i PARTIAL LIST OF PERSONS CONTACTED J

Licensee J. Flannagan, Maintenance Support Services Manager F. Flentje, Sr. Regulation and Compliance Specialist l J. Gadzala, Licensing Manager A. Guenther, Quality Verification Engineer ,

C. Jilek, Maintenance Rule Coordinator '

J. Knorr, Regulation and Compliance Manager i R. LaRhette, Quality Assurance Manager

- R. Mende, Plant Manager C. Peterson, Director, Engineering M. Reddemann, Site Vice President G. Rozga, Probabilistic Safety Assessment Engineer J. Schweitzer, Site Engineering Manager >

S. Yuen, Sr. Project Engineer

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INSPECTION PROCEDURES USED IP 62706 Maintenance Rule IP 92902 Followup - Maintenance  ;

ITEMS CLOSED 50-266/97025-01(DRS); 50-301/97025-01(DRS) VIO Scoping 50-266/97025-02(DRS); 50-301/97025-02(DRS) VIO 120 VAC system performance criteria 50-266/97025-03(DRS); 50-301/97025-03(DRS) IFl Flawed Sensitivity Analysis 50-266/97025-04(DRS); 50-301/97025-04(DRS) IFl Documentation Discrepancies 50-266/97025-05a(DRS); 50-301/97025-05a(DRS) VIO Reactor Coolant system goals 50-266/97025-05b(DRS); 50-301/97025-05b(DRS) VIO Residual Heat Removal system goals 50-266/97025-06(DRS); 50-301/97025-06(DRS) IFl Revised Structure Monitoring Procedure 50-266/97025-07(DRS); 50-301/97025-07(DRS) URI intersystem Leakage Evaluation 50-266/97025-08(DRS); 50-301/97025-08(DRS) IFl Audit Follow-up

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I l i ' LIST OF ACRONYMS USED I CFR - Code of Federal Regulations DRS' Division of Reactor Safety IFl Inspection Follow-up Item PSA Probabilistic Safety Assessment SSO Structures, Systems, or Components  ;

URI Unresolved item i VIO Violation i

! LIST OF DOCUMENTS REVIEWED ,

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' Procedures

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NP 7.7.4, Revision 4, " Scope and Risk Significant Determination for the Maintenance  !

Rule," dated April 8,1998

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NP 7.7.4, Revision 5, " Scope and Risk Significant Determination for the Maintenance Rule," dated August 12,1998 l

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NP 7.7.5, Revision 4, " Determining, Monitoring, and Evaluating Performance Criteria for l l- the Maintenance Rule," dated April 8,1998 i

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NP 7.7.9, Revision 0," Facilities Monitoring Provam," dated September 9,1998 ,

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NP 10.3.7, Revision 0,"On-line Safety Assessment," dated December 9,1998

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CR 97-3219, "U1/U2 Component Cooling Water (CC) Surge Tank Intersystem Leakage,"

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CR 97-3835, "CC system A(1) Status under Maintenance Rule MPFF Criteria," dated L November 20,1997 l '

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CR 97-3866, " Unit 1 and Unit 2 Facades & Switchyard Control Buildings in Maintenance Rule Scope," dated November 21,1997

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- CR 98-2731,"CC-722A CCW Suction Crossconnect Valve Leaking as MPFF during U1R24," dated July 13,1998 Quality Condition Reports

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OCR 97-0090, " Potential Noncompliance with 10 CFR 50.65," dated May 22,1997 i i

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QCR 97-0091, " Maintenance Rule (a)(1) Classified Systems Concem," dated May 22, 1997

QCR 97-0094, " Potential for not Properly identifying a Maintenance Preventable Functional Failure," dated May 22,1997

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QCR 97-0096, "VLCO Me'.rix Does Not Support Assessing Non-outage Plant Safety,"

dated May 22,1997

QCR 97-0097, " incomplete Periodic Evaluation Report for Maintenance Rule implementation," dated May 22,1997 a

QCR 97-0098, "PSA Update Not Reviewed for Maintenance Rule Risk Rankings impact,"

dated May 22,1997

_ QCR 97-0099," Discrepancies in Determination of Risk Significance for Maintenance

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Rule," dated May 22,1997-a QCR 97-0100, " Maintenance Rule ' Scoping Decisions not Adequately Documented,"

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dated May 22,1997'

QCR 97-0101, " Maintenance Rule Scoping Criteria Applied Inconsistently," dated May 22,1997

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OCR 97-0102," Plant Personnel Awareness of Maintenance Rule Program is Weak,"

dated May 22,1997 Other a

NPM 97-1011, " Maintenance Rule Overview Expert Panel Charter," dated November 14, 1997

NPM 98-0361, " Maintenance Rule Performance Criteria Review," dated March 25,1998

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NPM 98-1264," Reactor Coolant System A(1) Classification Summary and Action Plan" dated October 6,1998

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