IR 05000029/1990002
| ML20012D523 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/12/1990 |
| From: | Anderson C, Thomas Koshy, Roy Mathew NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20012D517 | List: |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 50-029-90-02, 50-29-90-2, NUDOCS 9003280010 | |
| Download: ML20012D523 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report-No'.
50-29/90-02 Docket No. -50-29.
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J License No. DPR-3:
. Licensee: Yenkee Atomic Electric Company 580 Main = Street
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Bolton, Massachusetts 01740-1398
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Facility Name: Yankee,Rowe-Inspection'At:
Rowe, Massachusetts Inspection Conducted: February 5-9, 1990 (Inspectors:
b k. th 3 + 70 R. K. Matiew,; Reactor Engineer, Plant Systems date Section, EB, DRS 0 M k hWa 3'b #10 T. Koshy, Senior Reactor Engineer, Plant date Systems Sec ion,.EB, DRS f
Approved by:
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C. J<. Anderson, Chief, Plant Systems Section, date Engineering Branch, DRS i
' Inspection-Summary: ' Inspection on February-5-9, 1990 (Report No.50-29/90-02
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Areas Inspected: A special announced inspection of the post-accident monitoring instrumentation ;in accordance with Regulatory Guide (RG) 1.97.
I Results: The licensee has implemented and/or provided justification for not
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meeting the recommendations of RG 1.97 for Category 1 post-accident monitoring instrumentation except for the deviation on equipment identification as described in section 6.0.
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DETAILS 1.0 Persons Contacted I
l '.1 Yankee Atomic Electric Company
- T. Henderson, Acting Plant Superintendent
- J. Kay, Technical Services Manager D. King,. Maintenance Support. Supervisor
- R. Mitchell, Maintenance Manager
-1.2 U.S. Nuclear Regulatory Commission
- M. Markley, Resident Inspector
- Denotes personnel present at exit meeting of February 9,1990.
2.0 Background The purpose of this inspection was to review the licensee's implementation of Regulatory Guide 1.97, Revision 3, regarding instrumentation systems for assessing plant conditions during and following the course of a postulated accident.
These systems were inspected to determine if they were installed in accordance
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with Generic Letter No. 82-33, " Requirements for Emergency Response Capabilities"
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(Supplement 1 to NUREG-0737). This letter, issued on C cember 17, 1982, specifies
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emergency response capabilities that have been appron-s the NRC for implemen-tation. This letter also discusses,.in part, the appi.tation of RG 1.97 to the
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emergency response f acilities, including the control room (CR), the technical support center (TSC) and the emergency response facility (EOF) at power plants.
Regulatory Guide 1.97 identifies the plant variables to be measured and the instrumentation criteria for assuring acceptable emergency response capabilities
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during and following the course of an accident.
- Regulatory Guide 1.97 divides the post-accident instrumentation into three (3)
categories and five (5) types. The three~ categories are noted as 1, 2, and 3.
Category I has the most stringent design requirements, whereas category 3 the least' stringent. The five types of instrumentation identified in the Regulatory Guide are types A, B, C, D, and E.
Type A variables are plant specific and e
classified by the licensee for initiating emergency actions; type B variables
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provide information to indicate that plant safety functions are being accomplished;
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type C variables provide information on the breach of barriers for fission
product release; type D variables indicate the operation of individual safety l
systems; and type E are those that indicate and determine the magnitude of the
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release of radioactive materials.
Each variable type can be any design category,
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except for type A which can only be category 1.
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C l2.1 Correspondence The licensee responded to generic letter 82-33 by letters dated April 19, 1983, August 30,1983, January 19, 1984, October 22, 1985 and September 30. 1986.
-Additional information was provided to the NRC by letter dated October 1,.1987.
Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March of 1983, to answer licensee questions and concerns regarding the NRC policy for implementation of RG 1.97.
At these meetings, it'
was noted that the NRC review would be limited to explicit exceptions to the guidance of Regulatory Guide 1.97.. Where the licensee explicity ' states that the instrumentation systems conform to the provisions of the guide, it was noted that no further staff review would be necessary.
The NRC Safety, Evaluation Report dated December 9, 1986 stated that the existing deviations for lack of redundant power supply and environmentally qualified instruments for neutron flux at Yankee Rowe were unacceptable. The NRC staff position.was that the licensee should install. instrumentation that meets the requirements of RG-1.97.
In response, the licensee prepared a probabilistic-risk assessment to justify these deviations.
The NRC review of this study is not complete.
-The specific references used to assess the licensee's response to RG 1.97 are identified in Attachment 1 to this report.
E 3.0 Inspection Scope and Details The following instrument channels, used to provide information required for operator controlled actions, have been classified by the-licensee as type A
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Reactor Coolant System (RCS) Pressure i
Pressurizer level
Steam' generator level
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core exit temperature
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safety injection tank level a
All of the above variables, except the Safety Injection Tank Level are also included as-type B, C or D variables. All are characterized as Category 1, consistent with the requirements for type A variables.
The NRC inspection of the above instrument channels included: equipment qualification;(seismic and environmental), redundancy of power supplies, independence and separation of electrical circuits, measured variables, display and recording methods used, range and overlapping features of multiple instrument-indicators, direct and indirect measurements of parameters of interest, equipment identification'for RG 1.97 instruments, service, test and surveillance frequency.
The safety related Q and EQ master equipment list were reviewed for the instruments selected, to determine if they had been evaluated and tested to the appropriate environmental, quality assurance (QA) and seismic qualification requirements.
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The QA procurement of these instruments was also reviewed.
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The inspectors held discussiont with various members of the licensee's staff, reviewed drawings and procedures, and selected variables for physical inspection.
A walkdown was performed for the display instruments in the control room to assess the implementation of RG 1.97.
The instrument variables reviewed for Yankee Rowe are described in the paragraphs below. A list of the documents
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reviewed is provided in Attachment 2.
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4.0 Regulatory Guide 1.97 Variables Evaluated 4.1 Reactor Coolant' System (RCS) Pressure
The licensee has identified this as a type A variable and has provided three channels of instrumentation.
Pressure transmitters PT100, 200 and 300 are-located
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in the harsh environment and are environmentally qualified.
The indicators for
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-these transmitters are located on the main control board. A dedicated recorder, MC-PLR-101 is also provided on the main control room from pressure channel PT100.
-The display-instruments meet the RG 1.97 recommended range of 0-3000 psig. All of the above instrument loops were found to be in calibration as evidenced by the calibration and loop test records. These channels are powered from safety related vital bus VB1 and VB2. All three channels are recorded in the SPDS system through qualified isolators.
No deficiencies were identified for this variable.
4,2 Pressurizer Level L
.The licensee has identified this as a type A variable.
Regulatory Guide 1.97 recommends instrumentation with a range from top to the bottom of the pressurizer (0 to 408 inches) for Category 1 variables.
The licensee has installed three instrument channels LT-6, LT 705 and LT-8 with ranges from 20 to 360 inches and 40 to 160 inches. The transmitters are installed in a harsh environment and are environmentally qualified. The instrumentation provided for this variable does not indicate the volume in the hemispherical ends of the vessel. This l
deviation was reviewed by the NRC and determined to be a minor deviation.
This deviation is documented and found acceptable in the RG 1.97 Safety and Technical
Evaluation Report. The display instruments (indicator and recorder) LI705, PLR-101, LI8 and PTR100 are located in the main control board and are powered
. tat vital bus VB1 and VB2, All of the above instrument loops were found to be in calibration as evidenced by the calibration records. No deficiencies were
. identified for this variable.
4.3 : Steam Generator Level The licensee has identified this as a type A variable.
It is used to detect steam generator tube ruptures, to monitor the steam generator level following a feedwater line break, and to ensure a useable reactor heat sink.
Four steam generator wide range level channels LT1004, 1104, 1204 and 1304 with ranges 1.5 to 25 feet are installed to monitor this variable and are powered by vital buses-VB1 and VB2. Regulatory Guide 1.97 recommends instrumentation with a range from the tube sheet to the separators. The licensee's instrumentation range is 18 inches above the tube sheet to the separators. At 18 inches above the tube
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sheet,=the steam generator is ess;...Lially empty. This deviation is minor with respect to the overall range accuracy.
The existing range is adequate to monitor
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this variable during all accident and post-accident conditions.
The transmitters
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are located in a harsh post-accident environment and are qualified.
The display instruments.LIl004, 1204 and 1304 are located on the main control board. All
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four channels are recorded in the SPDS system. The signals to the SPDS are
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isolated from the safety related loops by a qualified isolator.
- The licensee has also provided narrow range instrument channels LT1003,1103, 1203 and 1303 and respective indicators on the main control board. These channels-are all powered by one vital bus,_VB1 and hence they are not redundant. The instrument range -15 to +15 inches covers the control range of steam generator level. This range is not required to be monitored during and following an
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accident. The inspectors noted that these instruments are listed as available instruments for type A variables in the licensee's submittal.
The licensee is planning toLrevise the documentation for this variable. All of the above p
instrument loops were found to be in calibration as evidenced by their
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calibration records.
No deficiencies were identified for this variable.
4.' 4 Core Exit Temperature The licensee has identified this as a type A variable.
Regulatory Guide 1.97 recommends Category 1 instrumentation for this variable. The licensee has installed 13 environmentally qualified thermocouples.with a range of 0-2300 F.
These thermocouples are installed such that a minimum of 2 thermocouple indications will be available per quadrant of the core. These thermocouples are indicated in the control room via multipoint digital displays TI-1,2 and 3 l
(0-2300*F range) and recorded on narrow range recorders TR1, 2, 3 and 4 (0-700 F range). The primary recording of this variable is provided by the SPDS system covering a range of 0-2300 F.
The inspector noted that the range meets the RG 1.97 recommended range of 200 F to 2300 F.
All of the above instrument loops were found to be in calibration. The i
instrumentation loop is powered by vital buses VB1 and VB2, The acceptability of this variable was reviewed by the NRC as part of their review of NUREG-0737, item 11.F.2.
No unacceptable conditions were identified for this variable.
4.5 Safety Injection Tank Level The licensee has identified this as a type A variable.
Instrument channel LT-1 and indicator LT-1 (0-30 ft range) provides tank level indication for one channel in the control room.
This channel is powered by vital bus VB2.
The transmitter is located in a mild _ environment. This channel is also recorded in the SPDS system.- The redundant channel LIT 401 is a pneumatic channel and the indicator LI 401 provides indication in the control room.
The pneumatic channel has a back up nitrogen supply from an accumulator tank and meets the redundancy crits.ria.
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All of the above instrument loops were found to be calibration. No unacceptable conditions were identified for this variable.
4.6 Containment Pressure The licensee has determined that this is a Category 1, type B/C variable. Two instrument loops are provided to measure containment pressure.
This category 1 instrumentation is used to monitor post-accident containment conditions.
It detects the potential for or the actual breach of the containment vessel. The range recommended by RG 1.97 is from -5 psig to 4 times the design pressure for steel > containments. Two loops (PT 243 and PT 244) cover the full range -10 to 140 psig. The transmitters are environmentally qualified.
Indicators PI 243
'and 244 are located in the main control board. The variable is recorded on recorder, LPHR 200 and in the SPDS. The instrument loops are powered by vital buses VB1 and VB2 and were found to be in calibration.
These channels meet the Category I recommendations specified in Regulatory Guide 1.97.
4.7 Containment Isolation Valve Position Regulatory Guide 1.97 recommends that the containment isolation valve position indication system be designated Category 1.
The licensee has determined that this is a Category 1 type B variable. They identify 24 air operated valves with high/ low position switches powered from 125 yde, battery 3 power source for this instrumentation.
There is only one channel for each valve and the redundant channel is a check valve that has no position indication.
Position indication of check valves is specifically excluded by Table 3 of RG 1.97.
This variable meets the RG 1.97 recommended range for position indication.
Containment isolation is achieved through the closure of containment isolation valves. Valve position instrumentation at Yankee Rowe was reviewed and accepted by the NRC staff during the Systematic Evaluation Program review of Yankee Rcwe.
No unacceptable conditions were identified for this variable.
4.8. Containment Sump Water level Wide Range The licensee has identified this as a Category 1 type B/C variable.
Two instrument loops (LT 241 and 242) are provided to measure containment sump water level.
Indicators LT 241 and 242 cover a range of 0-201t and are located on the main control board. The signal from Channel LT 242 is recorded in recorder LPR-200 and also both channels are recorded in the SPDS computer.
Review of the-licensee's records indicates that these instruments meet the requirements for environmental qualification and loop calibration. The instrument loops are powered by redundant class IE power sources VB1 and VB2.
No unacceptable conditions were identified for this variable.
5.0 Isolation Where a Category 1 or 2 signal is used as input to a non-safety related system, Regulatory Guide 1.97 specifies the use of a qualified isolation device. The inspectors examined the circuits and found that the isolation, as well as the separation criteria, have been properly implemented. The instrument loops
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i reviewed by the inspectors provide an input to the non-safety related SPDS system and are isolated by a qualified isolator. The annunciator input in the instrument; loops is isolated from safety-related circuits using coil to contact relays.
No unacceptable conditions were identified in this review.
6.0 Physical Walkdown of Control Room The inspectors examined the RG 1.97 display instruments located in the control room to determine compliance with Regulatory Guide 1.97 for electrical and
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physical. separation, instrument identification,~ range and calibration. The
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instrumentation verified was installed in accordance with the plant design
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- drawings and. loop diagrams.
No deficiencies were identified in the areas of electrical or physical separation or the RG 1.97 recommended instrument range.
- The inspectors observed that the Category 1 and 2 instruments had not been identified as specified by RG 1.97.
However, the licensee has identified environmentally qualified instruments in the control room under the EQ program.
These instruments include most of_ the accident monitoring instrumentation.
Regulatory Guide 1.97, Table 1 item 8 states that types A, B, C instruments designated < as categories 1 and 2 should be specifically identified with a common
- designation on the control panels so that the operator can easily discern that they are intended for use under accident conditions.
The-licensee responses to the Regulatory Guide 1.97 did not identify any exceptions or deviations to this requirement; Subsequent to the issuance of generic letter, 82-33, the NRC held several meetings. At these meetings, it was noted that the NRC review would be limited to explicit exceptions to the guidance of the Regulatory, Guide 1.97.
This is a deviation from the Regulatory Guide 1.97
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(50-29/90-02-01)
.The licensee acknowledged this deficiency and stated that
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they will reevaluate the technical basis for identifying the post accident
- monitoring instrumentations for Category 1 and 2 instruments as specified by RG 1.97.
L The inspectors observed that the RG 1.97 instruments listed in their original
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submittal dated August, 1983 were never updated. The existing list shows all
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the instruments available for a particular variable even though some of these instruments are not intended for post accident monitoring.
The licensee committed to update and document the instrument list for maintaining the quality of the RG 1.97 instruments.
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7.0 Surveillance, Testing and Calibration
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. The inspectors' reviewed the licensee's surveillance, testing and calibration
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program to assure that the monitoring instrumentation is maintained adequately
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L to perform 'its intended capability.
The licensee stated that they have a computerized data base for instrument calibration.
Part of the function of
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l this data base is to_ generate repetitive maintenance task orders for recalibra-
tion of instruments.
Instrument channel calibration and testing is done every
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refueling outage.
The inspectors reviewed the latest calibration and testing
records for all of the Category 1 instruments.
No abnormalities were noted.
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8.0 Seismic Qualification Regulatory Guide 1.97 recommends seismic qualification for all Category.1 instrumentation.
The licensee identified in their submittal dated September 30, 1986 thatLthe RG 1.97 instrumentation in the control room is not seismically qualified. The instrumentation required for hot shutdown is qualified to this requirement and is located in a different location.
The licensee identified six systems (pressurizer level and pressure, core exit thermocouples, cold leg temperature and steam generator level and pressure) that require seismic qualifi-cation at Yankee. They are installed as a seismic upgrade of the p; ant for
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safe shutdown systems in accordance with Integrated Plant Safety Assessment program. The NRC reviewed the Yankee Seismic design criteria during the Syste-matic Evaluation Program (SEP) and the design modifications are monitored by.
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the NRC.
9.0 Exit Meeting The inspectors met with licensee representatives at the conclusion of the inspection on February 9,1990. The inspectors summarized the' scope of the inspection and the inspection findings at that time.
l No written information was provided to the licensee during this inspection.
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ATTACHMENT 1 RG 1.97 References Regulatory Guide 1.97, Revisions 2 and 3, " Instrumentation for
Light-Water-Cooled Nuclear Power-Plants to Assess Plant and Environs Conditions During and Following an Accident".
' NUREG-0737 Supplement No. 1, " Clarification of TMI Action Plan L
Requirements, Requirements for Emergency Response Capability" dated
- Janua ry, 1983.
i YAEC Letter to USNRC "NUREG-0737, Supplement I - Proposed Integrated Plan
- for Emergency Response Capability" dated April 19, 1983.
YAEC Letter to USNRC " Revised Schedule for Regulatory Guide 1.97 Report"
dated August 1, 1983.
USNRC Letter to YAEC " Order Conforming Licensee Commitments On Emergency
Response Capability (Generic Letter 82-33 Supplement I to NUREG-0737)"
dated July 5, 1984.
YAEC Letter to USNRC " Environmental _ Qualification of Equipment Important
to Safety" dated July _ 16,-1984.
USNRC Letters to YAEC " Request for Additional Information - Conformance
to RG 1.97" dated August 6,1985, July 28,1986 and September 30, 1986.
Final SER dated December 9, 1986
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YAEC Letter to USNRC "RG 1.97 - Response to Safety Evaluation" dated
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February 13,_1987 l-YAEC Letter to USNRC "RG 1.97
"Probabilistic Risk Assessment Response
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' to USNRC Safety Evaluation" dated October 1, 1987.
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l USNRC Letter to YAEC " Evaluation of the Implementation of Category ' A'
Lessons Learned Requirements" dated April 18, 1980.
USNRC Letter to YAEC " Inadequate Core Cooling Instrumentation - TMI
Action Item II.F.2" l
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cy ATTACHMENT 2
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Documents Reviewed During the Inspection
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~ Drawing No. 9699-CE-80FA, Pressurizer Pressure Channel Drawing No. 9699-FE-9Y, Wiring Diagram, Vital Bus #1 Distribution Panel Drawing No. 9699-FE-9Z,' Wiring Diagram, Vital Bus #2 Distribution Panel Drawing No. YR-E-40-158, Wiring Diagram - SPDS Misc. Isolator Details
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Drawing No. 9699-FE-107, Safe Shutdown System Instrument Panel Wiring Diagram
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Drawing No. E-7064, Mimic Arrangement for Safe Shutdown Instrument Panel
Drawing No. 9699-CE-80GB, Loop Diagram for Feedwater Steam Generator No._2
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Wide Range Level s
Drawing No. YR-E-40-156, Connection Diagram for Main Coolant Pressure to Drawing No. 9699-CE-80AA, Main Coolant LTOP Channel Drawing No. 9699-FE-17N, One-Line Diagram, ICC Thermocouple System.
Drawing No. 9699-FE-17K, Core Exit and Reactor Vessel Head Thermocouples -
o Wiring Diagram, Vital Bus 1
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Drawing No. 9699-FE-17L, Core Exit and Reactor Vessel Head Thermocouple -
Wiring Diagram, Vital Bus 2
~ Drawing No. 9699-CE-80FC, Functional Diagram, Pressurizer Narrow / Wide Range Levels and Pressurizer Wide Range Pressure PR-L-6, PR-L-8 and PR-P-700.
Drawing No. 9699-CE-80GF, #2~ Steam Generator Narrow Range Level RPS Channel Drawing No. 9699-CE-80FB, Pressurizer Wide Range Level Drawing No. 9699-CE-80DH, Vapor Container Loop Diagram VC Pressure 80DG, 80DF, i
80DE
Drawing No. 9699-CE-80EL, Safety Injection - Loop Diagram SI Tank Level Drawing No. 9699-CE-80GD, Loop Diagram for Feedwater Steam Generator No. 4 Wide Range Level Drawing No. 9699-CE-80GC, Loop Diagram for Feedwater Steam Generator No. 3 Wide Range Level Drawing No. YR-E-40-170, MCB Vital Bus Distribution
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