IR 05000155/1980003

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IE Insp Rept 50-155/80-03 on 800228-29 & 0310-14.No Noncompliance Noted.Major Areas Inspected:Training, Surveillance & Calibr Programs,Small Break LOCA Procedures & IE Bulletin,Circular & LER Followup
ML19309H778
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 03/27/1980
From: Baker K, Ridgway K, Wright G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19309H773 List:
References
50-155-80-03, 50-155-80-3, NUDOCS 8005190705
Download: ML19309H778 (16)


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R 005190 706

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U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

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Report No. 50-155/80-03 Docket No. Sr.155 License No. DPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:

Big Rock Point Nuclear Plant Inspection At:

Big Rock Site, Charlevoix, MI Inspection Conducted:

February 28-29 and March 10-14, 1980 Inspectors: K (March 10-13, 1980)

3/,24,/fr3 eca G. C. Wrig t J/ff/[d B N cting Chief 3/?(/ Co ApprovedByhProjectsSection3-2

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Inspection Summary Inspection on February 28-29 and March 10-14, 1980 (Report No.

50-155/80-03)

Areas Inspected:

Routine unannounced inspection of the licensee's train-ing and retraining program; surveillance activities; calibration program; procedure changes and training with regard to Small Break Loss of Coolant Accident (SBLOCA); and followup actions relative to IE Bulletins, IE Circulars, and Licensee Event Reports. The inspection involved 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> onsite by two NRC inspectors.

Results: One deviation was identified in one of the ten areas inspected.

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DETAILS

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1.

Persons Contacted

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C. J. Hartman, Plant Superintendent

  • D. E. DeMoor, Technical Engineer R. E. Schrader, Technical Superintendent
  • A. C. Sevener, Operations Supervisor J. J. Popa, Maintenance Engineer T. K. Pence, Shift Supervisor C. F. Sonnenberg, Shift Supervisor F. J. Valade, Shift Supervisor
  • T. C. Bordine, QA Superintendent C. R. Abel, Nuclear Safety Technical Engineer W. Clark, Construction Representative M. J. Malec, Senior Clerk, Document Control Center

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J. A. Johnson, I&E Supervisor E. B. Mosley, Assistant I&E Supervisor

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W. Doan, Training Coordinator D. D. Herboldsheiser, Maintenance Scheduler E. McNamera, Training Instructor G. L. Fox, Chemistry and Radiation Protection Supervisor

  • L. Oostermeyer, Senior Secretary The inspectors contacted several other licensee employees, including members of the technical, operations, and administrative groups.
  • Denotes those attending the management exit interview on March 13, 1980.

2.

Training The inspector reviewed Administrative Procedure Chapter 13, the Master Training Plan Volume 18 and corresponding training records.

The training program was reviewed to ascertain whether the overall training activities for new employees and the retraining of non-licensed personnel are in conformance with Technical Specification (T.S.) requirements. The inspectors verified that formal training and retraining programs have been established for new employees, temporary or service personnel, non-licensed / licensed personnel, technicians and craft personnel; that the formal training program for the personnel listed above covers administrative controls and procedures, radiological health and safety, industrial safety, con-trolled access and security procedures, emergency plan, and quality assurance; that the retraining program for technicians and craft personnel includes on-the-job training, formal tecianical training, and fire fighting training; that responsibilities have been

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assigned to assure that training program requirements have been met;

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and that all female employees are provided instructions concerning prenatal radiation exposure.

During the procedure review the inspector noted two discrepencies in the Master Training Plan Volume 18.

First; AP 1.13 section 1.a3.-A.2.2 states that Radiation Protection retraining will be conducted annually whereas Volume 18 makes reference to both annual and bi-annual retraining depending on which functional group the em-ployee belongs to.

Secondly; Regulatory Guide 8.13 states that female employees should be asked to sign a statement indicating they have received the information contained in Regulatory Guide 8.13 on pre-natal r..diation exposure, the licensee's procedure in this area does not require this signature.

Volume 18 Chapter 1 section 5.2.1 states that " Initial training shall consist of a program covering those general headings and subtopics listed below".

Included in the general heading is "Qua-lity Assurance Indoctrination".

In reviewing records of selected employees approximately six individual folders were identified where QA indoctrination was not indicated as being received.

Volume 18 Chapter 1 section 5.2.2 states that " Refresher training should be completed within two years of initial training.

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reviewing records the inspector identified two individuals who had last received Radiation Protection training in 1977.

The above '. o examples along with other isolated examples, which were brought to the licensee's attention, indicate that the general employee training requirements of Volume 18 are not being adhered to by the licensee.

The licensee indicated that the above items would be taken under advisement and evaluated during the bi-annual program review this spring (155/80-03-01).

No items of noncompliance were identified.

3.

Licensed Operator Requalification Training The requalification program was reviewed to ascertain whether the licensed operator requalification training program is effective and in conformance with Regulatory requirements. The inspector verified that an operator requalification training program has established and includes preplanned lectures, attendance documentation and identification of specific training aids to be used in lieu of an instructor; the on-the-job training requirements have been specified to include control manipulations, discussion / review of changes in facility design, procedures, and license; and that records of licensed individuals are maintained to include completed course and yeanly examinations, documentation of manipulations, documentation of

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required simulations of emergency and abnormal conditions, results

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of supervisory evaluatices and observation of manipulations and simulations identified above, documentation of individual study, and documentation of accelerated requalification training.

The inspectors reviewed the records of licensed Senior Reactor Operators and licensed Reactor Operators to verify that the licen-see's approved requalification training program was being properly implemented.

No items of noncompliance or deviations were identified.

4.

Surveillance The inspector selected and reviewed surveillance tests performed during the past year upon equipment in seven safety related systems.

The systems and surveillance tests were:

a.

Reactivity Control and Power Distribution: TR-45 Channel Assembly and Control Rod Blade Inspection, Rev. 3, July 18, 1979.

b.

Instrumentation:

IPIS-2, Calibration and Test of Reactor Pressure Core Spray, Rev. 7, October 11, 1977.

IPIS-2 Cali-bration and Test of Reactor Enclosure High Pressure Sen-sors-Enclosure Spray, Rev. 4, January 30, 1979.

c.

Reactor Coolant System: T1-04 (T7-10), T1-05(T7-11) and T1-06, Primary Coolant Sampling and Analysis, Rev. 2, January 17, 1978.

d.

Emergency Core Cooling System: T90-09, Core Spray Instrument Trip Verification, Rev. 1, January 19, 1979. T90-12, RDS Depressurizing Valve Test Operation, Rev. 1, January 25, 1980.

e.

Containment Systems: T180-1, Containment Sphere Component Leak Rate, Rev. 20, August 22, 1979.

f.

Plant and Electrical Power Systems:

T7-21, Standby Diesel Generators Start and Run, Rev. 4, December 12, 1979. T90-10, Diesel Fire Pump Fuel Sample and Analysis.

g.

Fire Protection-Prevention Systems: T30-26, Electric and Diesel Fire Pump Test, Rev. 4, November 21, 1978. T30-34, Fire Protection Surveillance Test, Rev. 9, October 2, 1979. T180-16, Functional Test of the Fire Detection System. Rev. O, March 30, 1978.

The above surveillance tests were reviewed to determine that:

a.

The tests conformed to Technical Specification requirements.

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b.

Test results were reviewed, approved and any required cor-

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rective actions taken, c.

Tests were performed on schedu12 by qualified personnel;.

d.

Test procedures covered prerequisites and preparations,

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acceptance criteria, and instructions to insure that equipment is returned to operational status.

On March 13, 1980, the inspector observed the automatic startup and operation of the Emergency Diesel Generator, to determine that the test was carried out according to procedure T7-01, and that test prerequisites were met.

No items of noncompliance were identified.

5.

Calibration The inspector selected and reviewed various calibrations made on components and equipment associated with cafety related systems. The sjstems and calibrations selected were:

a.

Reactivity Control and Power Distribution:

TR-47, Accumulator Pressure Switch Calibration, Rev. 3, December 6, 1978, Complet-ed February 24, 1979 and October 15, 1979.

b.

Plant Auxiliary Systems:

ICDS-1, Calibration of Condensate Storage Tank Level Transmitters LT-3161 and LT-3104, Rev. O, December 21, 1979, completed February 24, 1979.

c.

Reactor Coolant System:

IRPS-2, Calibration and Test of Re-actor Water Level Sensors, RE09A,B,C,D,E,F,G,H, completed Februa ry 13, 1979 and November 2, 1979.

d.

Emergency Core Cooling System: TR50 Post Incident Flow and Differential Pressure Instrument Calibrations, Rev. 3, May 23, 1978, completed April 24, 1979 and September 10, 1979.

e.

Containment Systems: RIP-15, Calibration of Emergency Conden-ser Vent Monitors, Rev. 4, August 28, 1979, completed November 26, 1979, December 26, 1979, Janua ry 28, 1980 and February 21, 1980.

f.

Plant and Electrical Power Systems:

IRPS-7, Reactor Protection System Undervoltage Breaker Test, Rev. 3, June 12, 1979, com-pleted September 13, 1979.

The inspector also selected calibrations of equipment associated with safety related systems but not required by Technical Specifica-tions. These were:

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a.

INTE-11, Calibration of a Pressure Guage.

In revision.

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b.

IFWS-3, Steam Flow Transmitter Calibration, Rev. O, Februa ry 22, 1977, completed February 6, 1979.

c.

IFPS-2, Ionization Detector Cleaning and Calibration, Rev.

O, May 23, 1978, completed August 16, 1979.

d.

IMTE-1, Calibration and Inspection of Precision Tools, Rev.

8, June 13, 1978, completed on Torque Wrench 3700-00027 on Feburary 5, 1980.

e.

PD-01, 02, 06, Calibration Test of Protection Re. lays-Elec-tric Laboratory Procedure Manual, completion records not available.

Confirmed calibration of six relays by telephone to Traverse City.

The above calibration procedures were reviewed to determine that they included:

a.

Stepwise instructions b.

Acceptance Criteria c.

Review and approval d.

Adherence to any Limiting Condition of Operation requirements in T.S.

e.

Return of components to normal operating condition following the calibration.

The inspector reviewed the calibrations listed above to determine that:

a.

Required frequenc -s were met.

b.

Qualified personnel performed the work.

c.

Calibration results were reviewed and approved.

d.

Cuages and instruments used in the above calibrations:

(1) Had been calibrated and calibration accuracy was traceable to the National Bureau of Standards.

(2) Were stored and handled properly.

The inspector expressed concern that the test and calibration of Big Rock Point safety related electrical equipment performed by the licensee's Electrical Laboratory in Traverse City, MI had not been

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reviewed by the Big Rock Point organization and records of tests

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were not available. The licensee acknowledged this concern and indicated they would review this matter.

No items of noncompliance were identified.

  • 6.

Followup on Licensee Event Reports (LER's)

The inspector reviewed the following LER's to determine if the reports were correct and if the evaluations performed and corrective actions taken were appropriate and complete as stated in the LER.

a.

(Closed) LER 50-155/80-01, Emergency Condenser Outlet Valve, M0-7053,leakedandLoopNo.2wasiso1pegjas permitted by This particular valve has leaked 9 - while an identical T.S.

valve, M0-7063, on Loop No. I has never leaked. The licensee plans to have the manufactures representative onsite during the next outage to study this problem and make recommendations.

b.

(Closed) LER 50-155/80-02, Failure of Battery Cell 14 in RDS Channel C to meet Technical Specificaton. The cell was re-placed.

c.

(Closed) LER 50-155/80-03, Failure of a component in the test circuit of RDS channel C that prevented testing of the channel but not the operation. The component was replaced.

d.

(Closed) LER 50-155/80-04, A one quarter-inch copper control air line from Remote Control Valve RMC 5515, in the Control Room to Control Valve CV4029, which supplys Reactor Cooling Water (RCW) (similar to a Closed Cooling Water System) to the No. 1 Shutdown Heat Exchanger.

Cause of the broken line was not determined.

Insulating work by an outside contractor was being carried out above the air line where it enters contain-ment and a workman may have stepped on or dropped a tool on the small line, breaking it.

The position change of CV 4029, caused by the leak, change 6 RCW flows and pressures to other auxiliary systems. This resulted in temperature changes which were noted by operations. They located and repaired the break.

Control air pressure in the tube can be varied from 3-15 psig and the break provided a potential for a small containment leak if containment pressure exceeded 15 psig. There was no release since the control air flow was into containment.

1/ IE keport No. 50-155/79-03

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2/ IE Report No. 50-155/80-01

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7.

Followup of I&E Bulletins

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a.

(Closed) IE Bulletin 79-26, Boron Loss from BWR Control Blades.

The licensee had confired by destructive examination of.the highest exposed control blade that most of the absorber-tubes hadcrackingintheupperhalfandthattheBCloggfromthe

crackedtubesoccurredmainlyjgtheareaswhereB depletion exceeded fifty percent. The B depletion has been monitored onallBRPbladesandindicatesthat15ofghe16 interior

blades will have greater than 34 percent B depletion by the end of the present fuel cycle (cycle 16). The licensee has ordered 16 replacement blades which will be installed during the next refueling.

b.

(Closed) IE Bulletin 79-23, Potential Failure of Emergency Diesel Generator Field Exciter Transformer. The licensee had determined that connections between generator neutral and the

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neutral of the primary windings of the excitation power trans-former do not exist. A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test at 190 1 10KW is being scheduled and will be completed before the next refueling.

This test will be carried as an open inspection item, (155/80-03-02).

c.

(Closed) IE Bulletin 79-18, Audibility Problems Encountered on Evacuation of Personnel From High-Noise Areas. By test con-ducted November 18, 1979 the licensee had detected five areas where the plant siren or public address system were marginal inaudibility. Modifications have been completed to give these marginal areas adequate coverage. A test conducted March 1980 confirmed adequate coverage in the five areas.

8.

Followup on Open Inspection Item (011)

(Closed) OII-321. 3/ A previous review of the licensee's a.

review and audit program had determined that QA Program Pro-cedure (QAPP) for Operations 5-51, Development of Documents Controlling Quality-Related Activities During Operations and QAPP 5-1, Department Procedures for Design and Construction did not enclude reviews by the Plant Review Committee. QAPP 5-51 had recently been revised and Ter.porary Change No. 1-80 had added a paragraph requiring reviews as specified by Technical Specifications. The licensee had reviewed QAPP 5-1 and deter-mined that the QAPP Vol. III procedure change would be adequate to assure the review of major construction activities at the operating faciltities.

b.

(Closed) OII-351. bl Concerning the completion of a review of cause, effect and corrective actions following a primary 3/ IE Inspection Reports 50-155/77-11 and 80-01 4/ IE Inspection Report 50155/78-07

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system over pressurization that occurred September 5,1978. The inspector reviewed the completed Deviation Report No. 78-75 concerning this matter and determined that the investigation and corrective actions taken were adequate to prevent recur-rence.

c.

(Closed) 011-361,El Concerning the inclusion of ANSI Standard 18.7 requirements for housekeeping and component cleanlinesc in operating and maintenance procedures. The licensee has estab-lished housekeeping and cleanliness evaluation requirements in ACP 1.5, Maintenance Department Administrative Procedures.

9.

!<eview of TMI Lessons Learned Small Break Loss of Coolant' Accident (SBLOCA) Considerations a.

Procedure Review (1) The following procedures were reviewed:

EMP 3.3 Loss of Reactor Coolant, rev. 11, dated February 25, 1980.

ONP 2.31 Reactor Scram, rev. 4, dated February 26, 1980.

ALP 1.2 NSSS Annunciator No. 1, rev. 7, dated February 25, 1980.

ALP 1.3 NSSS Annunciator No. 2, rev. 6, dated January 9, 1980.

ALP 1.4 Station Service Annunicator, rev. 10, dated January 28, 1980.

ALP 1.10 Rad Waste Annunciator, rev. 7, dated January 9, 1980.

ALP 1.14 Reactor Bldg. Vent Annunciator, rev. 3, dated January 9, 1980.

ALP 1.16 Relief Valve Monitoring Annunciator. rev. O, dated January 11, 1980.

(2) Procedures have been reviewed and approved as required by Technical Specification 6.8.

5/ IE Inspection Report 50-155/79-11

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(3) The procedure conforms to the guidelines contained in ANSI STD.

18.7 and Administrative Procedure 1.4.A.5.3.

(4) The procedures appear to be concise and do not require numerous cross references which could lead to operator confusion.

(5) Proper precautions are provided in the procedures. Where appro-priate they are repeated.

(6) Procedural protection is provided against activating the RDS manually without adequate core spray coolant pressure.

(7) The procedure does not call for the isolation of the'recircula-tion loops.

(8) Table 1 lists the instrumentation / equipment / valves / systems the licensee uses in the procedures. The table also identifies the licensee's evaluation of environmental qualifications and redundancy.

(9) The inspectors discussed improvements that could be made to the procedures to relocate same warning statements, delete the use of a temperature instruments that would be inaccessible during a LOCA, to identify breaker alignments needed in case of off-site power loss as " subsequent operator action", and to include a warnine to assure core spray pressure prior to manual actuation of the RDS.

(10) The manual switch over from fire water core spray cooling to recirculation from Containment was also included in referenced procedures and was reviewed for workability, i

b.

Operator Training and Operator Interviews During January 1980, the licensee had provided formal training to all licensed operators, shift technical advisors, "On Duty" superintendents, and auxillary operators on the actions to be taken follow a SBLOCA. The inspector verified by training records and interviews that the training had been presented.

c.

Operator Interviews The inspector interviewed four licensed operators. The opera-tors interviewed were one shift supervisor, on. SRO who stands shift work and two shift RO's.

The operators interviewed:

(1) Knowledgably discussed the symptoms and transient response characteristics of the plant with respect to a SBLOCA.

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(2) Demonstrated a knowledge of the procedures to be used for a SBLOCA, including the immediate actions required.

(3) Were knowledgable in the importance of heat sink, recogni-tion of adequate subcooling and core voiding indications

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of inadequate core cooling, and implementation of natural circulation.

d.

Miscellaneous Considerations (1) The emergency diesel does not sequence loads at this plant. On undervoltage the diesel starts and picks up all loads connected to the 2B bus.

(2) Facility design requires a switchover from injection to recirculation. Water level in the containment is not permitted to exceed 590 feet elevation to protect the core spray sensors and control circuits from flooding.

(3) Containment isolation and reset features have been in-stalled which require manual reset to open automatic isolation valves following an isolation trip.

10.

Independent Inspection Effort The inspector attended an onsite meeting between representatives from DOR and the licensee on February 28 and 29, 1980 during which specific items from NUREG 0578 and the licensee's specific commit-ments were discussed.

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Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection.' The inspectors summarized the scope and findings of the inspection.

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TABLE 1 SBLOCA Equipment 1#

E#

Env. Qual.A#

NOTES Generic Name ID NO.

LOC REDUNDANT Cora Sprgy'(CS)

Fira Pumps Elect P-6

C Diesel **

M 91

C

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CS Valves MO 7051&7061 C

C Y

Vriva rctuators LS RE09, ABCD C

C Y

ACS Vrives MO 707057071 C

C Y

Vriva rctuators LS RE09, EFGH C

C Y

CS Flow Ind.

FT 2162 C

P Y

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CS High Flow FS 2522

P N

CS Low Press PS 793-6,789-92

C N

CS H ut Exc. Inlet Valve MO 7066

P For location CS Firewater Inlet

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Valve MO 7072

P CS Low Press PS 680

N N

CS Prrs: Trans.

PT 186 C

P Y

CS H :t Exc. High dp PDIS 7814

N N

Emerg ncy Cond. (EC)

EC Laval Low LT 3150 e/p3401 C

N N

LS 3550 C

N N

LI 3305 cr

N N

Strim outlet valves MO 705367063 C

C Y

Temp TE 1773&l774 C

E N

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.11 b valves

P

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R911~.f Valve

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Pos. Ind.

Ca 5000,1,2,3, 45,46 C

C N

Charge amplifier not (160 F)

to be replaced by 1/1/81

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TABLE 1 SBLOCA Equipment Generic Name ID NO.

LOC 1#

d#

Env. Qual.A#

NOTES REDUNDANT Fudwiter (W)

W Crnt. Valve CV 4000, 4012

P N

W Low suction press PS 600

P N

Cend. Hot well low LS 3572-

P N

Cond. St. Tk Level LR 3104

P N

R.C. Pump vibration VS 1 & US 2 C

E N

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R::::ctor water level LS/RE09A,B,C,D, E,F,G,H C

C Y

Stram Drum water level LS/RE06A,B C

C Y

RE20A,B

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LS-ID28A,B Ytrw2y Ref. Leg Temp.

C C

N R:; actor Pressure PS/RE07,A,B,C,D PS/ID 28E PT 183 Scram PS/IA 106 A&B C

C N

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R*cctor Depressuriza-

tion System (RDS)

RDS Valves CV 4180,81,82, C

C Y

SV 4984,85,86, C

C Y

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TABLE 1 SBLOCA Equipment 1#

E#

Env. Qual.2#

NOTES Generic Name ID NO.

LOC REDUNDANT RDS Velve Pos. Ind.

POS 6680-6683 C

C Y

POS 6684-87 C

C Y

RDS Disc. Pipe Temp.

TE 1880,81,82,

C E

N RDS Stm. Drum Level LT 3184,85,86,

C C

Y-LI 3384,85,86,

0 C

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RDS R ictor Level LT 3180,81,82,

C C

Y LI 3380,81,82,

0 C

N RDS Containment LT 118 & I

.3 C

E N

Dneuation LS 3580-81

E N

MSIV MO 7050 C

P Y

By type test.

ifurb Bldg. Vent. ISO.

CV 4190

N N

lampir fontainment, Reactor Bldg. (R.B.)

RB VI:nt Inlet CV 4096 & 4097

C Y

RB Vent Exhaust CV 4094 & 4095

C Y

RB Pr:=ure Scram PS 664,665,666, 667

C N

RB Pr::snure Ann.

PIS173-187

P N

PI 173

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TABLE 1 SBLOCA Equipment 1#

E#

Env. Qual.A#

NOTES Generic Name ID NO.

LOC REDUNDANT RB High Temp TR9623}

N N

TS 9628.)

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TE 9605-09 C

E N

RB Spri.ys valve MO 7064 C

P Y

Flow FT 2164 C

P Y

Flow Ann.

FS 2520

P N

Ind.

FI 2333

P N

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RB brckup sprays trans FT 2161 C

P Y

flow FS 2521

P N.

RB Backup sprays valve MO 7068 C

P Y

RB liquid level Cont.

LI 3400

N N

LT 3171 C

N N

RB clean sump high ann LS 3540 C -i LT 3172 C

P N

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RB Dirty LS 3524 C

LT 3173

.C Radwante LS 3528 C

N N

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RB Ev:c. Alarm

E N

RB Rad Monitors 20 Detectors C

E N

RB Crit. Mon

RB V nt Exh. Mon.

Stack Gas Mon

N N

RB Humidity Dew Pt.

TS 9629,TR9623

P.CPRM Dew Pt.

g g -15 g

g g

Enclo ure Sump Level LS 35,62,63,64,

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C NP Y

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TABLE 1 SBLOCA Equipment Qual. !

'nnric Name ID NO.

LOC - !

REDUNDANh Env.

NOTES Core D.P. Cuage DPT 1A01

1A-88 1ADI Trans C

N N

RC pressure PI/1A05

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Relief PT/lA07C J C

E Y

R cire Pumps

" Inlet Vs

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"

" Outlet Va.

C E

N

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Shutdown Sys.

C E

N Pump submerged fcr long term cooling.

RB Isolation Valves Ciren Sump Discharge CV 4031 C

E Y

Valves CV 4102

E N

Dirty sump pump Disch CV 4025 C

E Y

Valve D=in. water CV 4105

E N

Clarnup Demin. Resin Sluce CV ?.091,92,93 C

E Y

Treated waste return to Fuel Pool CV 4049 C

E Y.

Rerctor and Fuel Pool CV 4027 C

E Y

Drain CV 4117

E

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J_/ LOC - location, inside containment (C); outside containment (O).

2/ REDUNDANCY - Alternate method provided in procedure (P), redundant equipment provided (E), redundant equipment provided which licensee' states will meet loss of off site power and single failure criteria. (C).

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3/ E:lVIP.ONMENTAL QUALIFICATION - Not (N); licensee believes to be environmentally qualified (Y).

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