IR 05000255/1996010

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Insp Rept 50-255/96-10 on 960907-1018.Violations Noted. Major Areas Inspected:Conduct of Operations,Conduct of Maint & Conduct of Engineering
ML18066A745
Person / Time
Site: Palisades Entergy icon.png
Issue date: 12/05/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML18066A743 List:
References
50-255-96-10, NUDOCS 9612120516
Download: ML18066A745 (17)


Text

U.S." NUCLEAR REGULATORY COMMISSION REGION III.

Docket No.:

License No.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

9612120516 961205 PDR ADOCK 05000255 G

PDR 50-255 DPR-20 50-255/96010(DRP)

Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Palisade~ Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 September 7 through October 18, 1996 M. Parker, Senior Resident Inspector P. Prescott, Resident Inspector L. F. Mill er, Jr., Chief Reactor Projects Branch 6

  • EXECUTIVE SUMMARY Palisades Nuclear Generating Plant NRC Inspection Report 50-255/96010 This inspection reviewed aspects of licensee operations, maintenance, engineering and plant suppor The report covers a 6-week period of resident inspectio Operations

Operators failed to perform post maintenance functional tests on low pressure safety injection {LPSI) pump motor breakers, as required by licensee procedures, due to weaknesses in the work order packages and weaknesses in operator knowledge of the requirement The operators used an alternate method to verify proper re-energization of the breaker An NCV was identifie {Section 01.2)

Maintenance

The inspectors concluded that most maintenance activities were effectively planned and executed during this inspection perio {Sections Ml.I and Ml.2).

The licensee determined that the governor servo booster which opens the fuel ~ack during start up contained degraded consumable seals and diaphragm The inspectors determined that no preventive maintenance had been performed on the governor servo booster seals since EOG installation. {Section Ml.2)

A maintenance outage for the boric acid transfer pump took longer than expected because of weaknesses in the pre-planning effort. While observing post maintenance testing, the inspectors noted that the boric acid flow indicator was non-functional, that this condition complicated the licensee's performance tracking and monitoring process for the rebuilt boric acid transfer pump, and that the licensee was slow in responding to the degraded material condition. {Section Ml.3)

Engineering

The inspectors concluded that the licensee's response tu IN 96-45,

"Potential Common-Mode Post Accident Failure of Containment Coolers,"

. was slo Jhe licensee COJlside".'s the Palisades containment coolers to be operable but degraded, based upon the information in the I A Violation for failure to promptly initiate a Condition Report, as required by plant procedures, was identifie An Unresolved Item was opened to track NRC review of the licensee's initial and final operability determinations. {Section El.I).

The licensee perfonned an extensive, multi-disciplined, analysis of an indication of high current on one phase of a HPSI pump breake No significant problems were found with the breaker or syste {Section El.2).

Plant Support

The inspectors noted good teamwork, co11111unication, and management oversight during a maintenance related removal of the fuel transfer carriage from the tilt pi An Inspector Followup Item was opened to track subsequent maintenance activities to repair the carriage. {Section Rl.2).

  • Report Details Summary of Plant Status The unit operated at full power during the inspection perio I. Operations

Conduct of Operations 01.1 General Co11111ents £71707)

Using Inspection Procedure 71707, the inspectors conducted frequen reviews of ongoing plant-operations. The conduct of operaiions was good; specific events and noteworthy observations are detailed belo.2 P-678 Low Pressure Saf~ty Injection lLPSI) Pump Operability Test Inspection Scope {71707 and 61726)

The inspectors interviewed Operations staff and reviewed records and'

procedures associated with maintenance activities on motor operated valves (MOVs) in the two trains of the low pressure safety injection (LPSI) syste Observations and Findings On September 11, 1996, the licensee removed the "A" train of LPSI from service so that maintenance could be performed on LPSI system suction valves M0-3189 and M0-319 The "B" train of LPSI was functionally tested prior to removing the "A" train of LPSI from service, as required by Technical Specification (TS) 3.4.2. The work order package for the two suction valves required that the "A" LPSI pump, P-67A, be de-energized while the two sources of suction for the train were isolate The licensee removed the control power fuses from the P-67A breakerd 152-206, in order to ensure that P-67A could not be energized. After completing maintenance on the MOVs, the licensee staff reinstalled the power control fuses in the P-67A breaker, and verified that the applicable breaker indication light in the control room was illuminate The control room indication light was designed to prov)de positive indication that the pump breaker was energize The licensee closed the work order package, and declared the pump to be operabl On September 12, 1996, the licensee removed the "8" train of LPSI from service so that maintenance could be performed on MOVs M0-3189 and M0-319 A functional test of the "A" train of LPSI was performe The control power fuses were removed from the P-678 breaker, 152-111, in order to prevent an inadvertent start of pump P-67 The power control fuses were reinstalled in breaker 152-111 following completion of the maintenance on the MOVs.. The applicable breaker indication lights in 4 the control room were verified as indicating correct fuse installatio The work order package was closed, and the pump was declared to be operabl On September 13, 1996, a member of the Operations Support staff identified that Procedure 4.02, "Control of Equipment,"

Rev 12, step 9.3.lc.2., required that functional testing of breakers be performed following any occurrence of a breaker's power control fuses being remove Functional tests of the breakers for pumps P-67A and P-678 had not been performed prior to closure of the work order packages and declaration that the pumps were operabl The breaker for pump P-67A was functionally tested prior to removing the "B" train of LPSI from servic The licensee subsequently performed a functional test of the breaker for pump P-67 The inspectors determined that the upper tier procedural requirement to performance test breakers following each occurrence of power fuse removal was not incorporated into the LPSI HOV work order packages or recognized and implemented by the operations staf The inspectors concurred with the licensee's informal undocumented assessment that the beaker indication lights in the control room provided reasonabl assurance that the LPSI pump breakers were operable. Operations management discussed this error with the operators who made it, and all licensed SROs, and reinforced their expectation that the requirement to perform breaker testing per Administrative Procedure 4.02 be followe The inspectors noted that the licensee's procedural policy to performance test breakers following each occurrence of power fuse removal appeared to be an appropriate method of achieving the gr~atest assurance that power fuse re-installation was performed correctly. Based upon the minor safety significance associated with this event, the failure to performance test the two LPSI pump breakers as required by plant procedures is being characterized as a licensee-identified and corrected Non-cited Violation (50~255/96010-01) of 10 CFR 50, Appendix B, Criterion V, consistent with Section VII.B.l of the NRC Enforcement Poli C Conclusions The inspectors concluded that a weakness in the post maintenance testing (PMT) specifications for the* LPSI Mov work packages, and a weakness in operators' knowledge of the licensee's procedure for the control of equipment, existe ~-

II. Maintenance Ml Conduct of Maintenance Ml.I General Co11111ents Inspection Scope {62703 and 61726} The inspectors observed all or portions of the following work activities:

Work Order No:

  • *
  • * * * *
  • *

24613235:

24514040:

24511857:

24613042:

24611630:.

24611628:

24612659G:

24610198:

24512941:

24412679:

246126590:

24610777:

24673391:

Fuel transfer carriage removal from south tilt pit Fuel reconstitution P-56A, boric acid pump driver replacement and alignment EOG 1-1, vent fan to be provided alternate feed for Appendix R requests Coupling and cleaning of pump cooler strainer PMs Preventive Maintenance on EOG 1-1 air compressor Remove/replace fuel injection nozzles on EOG 1-1 EOG 1-1 generator check and collector ring PM Replace electronic governor and linkage rebuild on EOG 1-1

  • Replace Viking switches for EOG fuel oil belly tank with new type per Functional Equivalent Substitution (FES} 94-141 Clean/inspect tube side of lube oil/jacket water on EOG 1-1 Troubleshoot EOG 1-1 excessive start times Troubleshoot high. pressure safety injection (HPSI)

pump P-66A "y" phase instantaneous overcurrent relay Surveillance Activities

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T-192:

Q0-32:

Q0-19:

Auxiliary Feedwater Pump P-8A Performance Closure Verification of HPSI Trains 1 and 2 and low pressure safety injection (LPSI}

injection check valves HPSI Pump and Essential Safety Systems (ESS} Check Valves Operability Test For P-66A Observations and Findings The inspectors found the work performed under these activities to be thoroug All work observed was performed with the work package present and in active us The inspectors frequently observed supervisors and system engineers monitoring job progres When applicable, appropriate radiation control measures were in plac:.

c. Conclusions The inspectors observed good procedure adherence practice In addition, see the specific observations detailed belo M Emergency Diesel Generator CEOGl 1-1 Reliability Maintenance Oytage Inspection Scope (62703 and 61726)

The inspectors observed pre-job planning meetings, maintenance and surveillance testing in connection with the EOG 1-1 reliability maintenance outage. Over 20 work orders were completed, four of which were corrected during this outag Observations and Findings The licensee performed a maintenance outage on EOG 1-1 in order to improve the reliability of EOG 1-1 prior to the November 1996 refuel outage {refout), when EOG 1-2 was scheduled for a major overhau The inspectors' overall assessment of the EOG 1-1 maintenance outage was that the licensee pl.anned and executed it wel The outage was large in scope. A project manager had been assigned due to the large scope of the outag The project manager maintained good oversight of outage*

meeting The meetings had good attendance and participation of all departments involved.

The inspectors observed the pre-job brief and the majority of the maintenance complete With so mu.ch work. to be done, the EOG 1-1 room was quite crowde However, the inspectors noted good cooperation among the various work group Foreign material exclusion (FME) control was noted as goo During post maintenance testing (PMT), the EOG did not start and come up to speed within the 10 seconds specified in TS 4. The licensee determined that the slow start was attributable to degradation of consumable seals and diaphragms in the governor servo booste The governor servo booster received an air pressure input when the pneumatic starter was activated, and converted this to a hydraulic force which opened the fuel rack until the governor hydraulic system could assume EOG speed contro The licensee determined that the governor servo booster had never been replace The inspectors determined that the governor servo booster was not covered in the licensee's EOG preventive maintenance progra The NRC's 1994 Diagnostic Evaluation Team (OET) inspection of Palisades identified that the licensee did not effectively implement vender

  • reconunendations for the maintenance of the EDGs (Inspection Report 50-255/940014, Paragraph 2.3.5.d.3). The inspectors reviewed the details of the OET finding and the recommended maintenance contained in supplement MI-11005E "Stationary and Marine Maintenance Schedule," of the ALCO EOG vendor's manual to determine whether the licensee's corrective actions for the DET findings had been appropriate and

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effective. The inspectors also reviewed the vendor's parts replacement documen Although the vendor made no reco11111endations about which parts should b~ considered consumable, the-leather seals for the oil piston and the neoprene seal for the air piston have a limited service lif The inspectors concluded that no violation of NRC requirements had been cormnitted in the licensee's failure to perform maintenance on the EDG governor servo booster, but did consider the lack of maintenance to be an indication of a lack of thoroughness in the licensee's preventive maintenance (PH) progra *

Palisades forwarded the lessons learned regarding governor servo booster degradation to the applicable nuclear EOG owner's group for incorporation into this group's manual on recommended maintenanc c. Conclusions The inspectors concluded that the licensee's maintenance outage for EDG 1-1 was effectively planned and executed, with the exception of the EDG governor servo booster maintenanc The inspectors concluded that the failure to perfor~ ~reventive maintenance on the EDG governor servo booster resulted in the EDG not meeting its TS required start time during a PH Although no violation of NRC requirements was identified, the inspectors considered the omission of this PH to be a weakness in the progra M P-56A Boric Acid Transfer Pump Maintenance Inspection Scope (62703 and 37551)

The inspectors observed the performance of maintenance on the P-56A, boric acid transfer pump, and hel~ discussions with the system engineers, maintenance, and planning personnel in reference to _the P-56A pump maintenance outag The inspectors.also reviewed the work order package for pump P-56 Following completion of the maintenance activity, the inspectors monitored the licensee's thoroughness in identifying and documenting lessons learne Observations and Findings The P-56A boric acid pump maintenance was performed under a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limiting condition of operation (LCO) time clock per TS 3.2.3. The licensee replaced a significant portion of the P-56A pump, including the impeller, the pump seals, and the gear box ("power end unit").

The inspectors observed most of these activities, as well as the performance of_ post maintenance testin~.

The inspectors considered the performance of the P-56A maintenance outage to have been generally well planned and executed, but observed several issues which were of concern because they delayed, or had the potential to delay, the completion of the maintenance within the outage perio These observations included:

the pump baseplate and hold down bolts were carbon steel, and were therefore susceptible to chemical attack by boric acid. Boric acid crystals were observed on the baseplate and bolts prior to the outage, but no preplanning was performed for the potential need to replace the bolts or retap the baseplate mounting hole *

maintenance technicians almost used the wrong drill to prepare baseplate holes for retappin *

while realigning the pump, motor, and power end unit, the maintenance foreman noted that the technicians had improperly installed the alignment equipment on the couplings rather than the shafts. A lead technician took over the task and completed the alignment properl *

the new power end had slightly different outside casing dimensions, which required modifying the pump heat trace/insulation boxe The planner had known about the dimension differences, but failed to incorporate plans for the modifications in the work orde *

Post maintenance testing included performance of pump baseline testing. While observing the performance of the pump testing, the inspectors noted that the flow instrument, FE-0211, in the boric acid pump discharge line was non~functional. The licensee indicated that FE-0211 had not been functional for some time, and that pump differential pressure was normally used to determine pump performanc PMT test results showed a drop in differential pressure from 108.0 psid {old impeller) to 98 psid {new impeller)

during a normal system line-up test, but an integrated functional test using the boric acid pump and the charging pump indicated that all system design bases criteria were me The licensee declared the pump operable based upon the results of the integrated functionil test. After review of the licensee's technical basis for the operability determination, the inspectors concluded that it appeared to be reasonable. After dis~ussion wtth the inspecto~s, the licensee indicated that FE-0211 would be repaired so that a direct indication of P-56A's performance would be availabl Following the completion of P-56A maintenance activities, the system engineer pr~pared a work order sununery to identify lessons learned so that problems encountered could be corrected in. future boric acid transfer pump rebuilds. Maintenance management also performed a review of the task, and discussed issues and planned corrective actions with the inspectors. The inspectors concluded that these self assessments were t~o~ti~gh and accurate.

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= Conclusions El El. l The inspectors concluded that several minor weaknesses in the licensee's

~lanning effort for the P-56A maintenance activity resulted iri the pump being in the TS LCO for several hours longer than necessary, but that these weaknesses were effectively documented in the licensee's lessons learned progra The inspectors identified that the licensee's boric acid syslem flowmeter was non-functional, and that the licensee had accepted.this condition for an extended period of tim The inspectors did not identify any violation associated with the flowmeter's condition, but were concerned that the lack of a functional flowmeter complicated the licensee's performance tracking and monitoring process for P-56 *

III. Engineering Conduct of Engineering Licensee Response To Information Notice (INl 96-45 Inspection Scope (37551 and 92700)

The inspectors reviewed the licensee's preliminary response to IN 96-45

"Potential Conunon-Mode Post Accident Failure Of Containment Coolers."

The inspectors discussed the issue with. the involved engineering and licensing personne Observations and Findings The NRC issued IN 96-45 to document a generic concern associated with the potential susceptibility of containment air coolers (CACs) to water hammer induced failure during a postulated design basis loss of cool*ant accident (LOCA) with a concurrent* loss of offsite powe The design function of the Palisades CACs was to help maintain containment integrity by reducing post accident containment pressure.

through the condensation of steam and removal of heat. This function relied on the transfer of heat from the containment atmosphere to a cooling medium inside the CAC coils. According to the licensee's operability evaluation at Palisades, the CAC cooling medium was essential service water (ESW).

During a LOCA with a concurrent loss of offsite power, the ESW pumps and the CAC fans would lose powe As the emergency diesel generators (EDGs) were sequentially lo<<ded, the CAC fans would start first, followed by the ESW pump This could force*

high temperature containment air over the CAC coils for several second$

with no ESW flo The stagnant ESW in the CAC coils could boil, ther~by creating steam void When the ESW pumps restarted, the ESW entering the CAC coils would collapse the steam voids and might create a waterhanuner which could damage the CAC coils or ESW piping, and impair the operability of the CAC ~'

\\.*. The NRC issued IN 96-45 on August 12, 199 The licensee received a copy of IN 96-45 on August 1 On September 15, the inspectors inquired about the progress made in response to IN 96-4 On September 16, personnel from Palisade's Engineering and Licensing staffs informed the inspectors that they believed that Palisades might be vulnerable to CAC waterhammer, but indicated that more analysis was require The inspectors asked if a condition report (CR) had been written. The licensee staff stated that no CR had yet been written, but that one would be considere On September 18, the licensee issued CR PAL-96-1063 to document the potential waterhammer problem with the CAC On September 19, licensee management discussed the issue with the inspectors, and indicated that the plant might be vulnerable to the potential for waterhammer in the ESW system and that a complete engineering evaluation was being pursue Pending completi-0n of the evaluation, the.licensee considered the CACs operable but degrade On October 2, the inspectors learned that the engineering evaluation had not actually been initiated yet, but that bids were being accepted from engineering contractors for performance of the complete evaluatio The inspectors consider the adequacy of the licensee's operability determination to be an Unresolved Item (50-255/96010-02) pending receipt of the licensee's completed engineering evaluation and*additional technical review by the NRC staff of the initial and final operability determination Licensee procedure 3.03, "Corrective Action Process," Revision 15, Paragraph 7.1, required that upon discovery of any condition requiring a CR, an individual shall initiate a CR and immediately hand carry the CR to the individual's supervisor. Procedure 3.03, Attachment 10,

"Condition Report Guidelines," Revision 15, required, in part, "That a condition report should be written whenever: Information from external sources (eg, vendors, INPO, NRC) that (sic) indicates a potential problem at Palisades."

At some point between receipt of IN 96-45 on August 13, and their discussion with the inspectors on September 16, Licensee staff identified Palisade;s potential susceptibility to water hammer in the CACs, as described in IN 96-4 A CR was not written until September 1 The inspectors considered the failure to write a CR upon discovery that the condition described in IN 96-45 represented a potential problem at Palisades to be a Violation (50-255/96010-03) of 10 CFR 50, Appendix B, Criterion Conclusions The inspectors considered the failure to promptly initiate a CR in accordance with the plant's corrective action process procedure in response to IN 96-45 to be of concern. Also, the adequacy of the licensee's operability determination will be tracked as an unresolved ite El.2 High Pressyre Safety Injection CHPSI> Pump Breaker Troubleshooting Inspection Scope (62703 and 37551)

An auxiliary operator identified that the flag indicator for one phase overcurrent relay of a HPSI pump breaker was dropped in, but that the overcurrent trip relay was not actuate The inspectors followed the licensee's troubleshooting activities to assess the licensee's determination of root caus The inspectors also reviewed the past work order history for the plant's breakers to determine whether a generic problem existe Observations and Findings On October 2, 1996, an auxiliary operator found the red flag dropped in on the "y" phase instantaneous overcurrent relay for breaker 152-207, but the breaker was not tripped. This was the breaker for the P-66A HPSI pum The licensee performed an extensive diagnostic analysis of breaker 152-207, utilizing a ~ulti-disciplined team which included contracted.

specialists. The team concluded that the flag had dropped in on the initial pump start instantaneous amperage spike, and had not reset, as it should have, because of mechanical bindin The breaker was found to be functionally operable, and no generic issues were identified. The inspectors found that there was no history of similar problems documented in the plant's work order syste Conclusions The inspectors determined the licensee responded properly. A good questioning attitude and thorough root cause analysis was note The engineering and maintenance personnel conununicated and supported each other in a positive manne IV. Plant Support RI Radiological Protection and Chemistry Controls Rl.l Maintenance Outages and Daily Radiological Worker Practices Inspection Scope (83750)

The inspectors observed radiological worker activities during the various applicable maintenance outages detailed in this in~pec_tion_

report; and also monitored radiological practices during daily plant tour Observations and Findings During the applicable maintenance outages radiatio~ technicians were visible at the job sites. The technicians took appropriate actions and surveys in accordance with good ALARA practice c. Conclusions The inspectors concluded that radiological practices observed during the maintenance outages and plant daily walkdowns were adequat The inspectors had no cbncern Rl.2 Fuel Transfer Carriage Removal From Tilt Pit Inspection Scope (83730) The inspectors observed aspects of the removal of the fuel transfer carriage from the tilt pit, including monitoring the pre-job brief and observing the entire performance of wor The inspectors also held discussions with several individuals involved, to ascertain their understanding of what was required of them from a job performance and ALARA standpoin Observations and Findings The licensee moved the fuel transfer carriage from the tilt pit to the decontamination pit so that maintenance could be performed on the carriage wheels and so that the carriage rails could be re-aligned. The inspectors followed this work closely because a 700 Rem hot spot on the carriage posed ALARA concerns, and because the tight clearances in the tilt pit posed potential difficulties in lifting and moving the carriag The inspectors observed the pre-job brief and concluded that a good questioning attitude was exhibited, and that beneficial suggestions were brought up by the personnel involved in the jo The inspectors observed the entire task of preparing and removing the carriage from the tilt pit, and concluded that the health physics technician's coverage of the job was thoroug No significant problems were identifie An assessment of the maintenance activities performed on the carriage after its transfer to the decontamination pit will be tracked as an Inspector Follow-up Item (50-255/96010-04).

Conclusions The inspectors concluded this job was a good example of teamwork, communication and management oversigh The job had the potential for serious radiological consequence Good planning and preparation were evident:

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V. Management Meetings

~Xl Ex;t Meeting Sunaary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on October 18, 199 No proprietary information was identif;ed.

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. A. Fenech, Vice President, Nuclear Operations T. J. Palmisano, Plant General Manager K. P. Powers, Nuclear Services General Manager G. B. Szczotka, Nuclear Performance Assessment Manager H. L. Linsinbigler, Design Engineering Manager T. C. Bordine, Licensing Manager D. W. Rogers, Operations Manager* *

J. P. Pomeranski, Maintenance and Construction Manager D. P. Fadel, System Engineering Manager D. G. Malone, Shift Operations Supervisor D. J. Malone, Chemical & Radiation Protection Services Manager K. M. Haas, Training Manager S. Y. Wawro, Planning & Scheduling Manager M. E. Parker, Senior Resident Inspector, Palisades P. F. Prescott, Resident Inspector, Palisades

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,_

IP 37551:

IP 61726:

IP 62703:

IP 71707:

IP 83750:

IP 92700:

IP 92702:

INSPECTION PROCEDURES USED Onsite Engineering Surveillance Observations Maintenance Observation Plant Operations Occupational Radiation Exposure Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities Followup on Corrective Actions for Violations and Deviations ITEMS OPENED 50-255/96010-01 NCV Motor breakers not functionally tested following removal of power control fuses 50-255/96010-02 URI * NRC review of the adequacy of operability determinations on containment air coolers (IN 96-45)

50-255/96010-03 VIO Failure to initiate CR upon discovery of potential problem with containment air coolers 50-255/96010-04 IFI Maintenance activities on fuel transfer carriage ITEMS CLOSED 50-255/96010-01 NCV Motor breakers not functionally tested following removal of power control fuses A LARA AO ASME CAC CFR CR DRP EOG ESS ESW FME FSAR HPSI IN IP IR LOCA LPSI LCO.

MIC MOV NRC NRR PCS PDR PM LIST OF ACRONYMS USED As Low As Reasonably Achievable Auxiliary Operator American Society Of Mechanical Engineers Containment Air Cooler Code of Federal Regulations Condition Report Division of Reactor Projects Emergency Diesel Generator

Inspection Report

Loss Of Coolant Accident

Low Pressure Safety Injection

Limiting Condition of Operation

Microbiologically Induced Corrosion

Motor Operated Valve

Nuclear Regulatory Conunission

Office of Nuclear Reactor Regulation

Primary Coolant System

Public Document Room

Preventative Maintenance

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PSID

PSIG

RE FOUT

REM

SE

SOP

SIRW

SRO

SS

SW

TS

WO

Pounds Per Square Inch Differential

Pounds per Square Inch Gauge

Refuel Outage

Roentgen Equivalent Man

Shift Engineer

System Operating Procedure

Safety Injection Refueling Water

Senior Reactor Operator

Shift Supervisor

Service Water

Technical Specification

Work Order