IR 05000259/2020002
| ML20219A108 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/06/2020 |
| From: | Tom Stephen NRC/RGN-II/DRP/RPB5 |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2020001, IR 2020002 | |
| Download: ML20219A108 (16) | |
Text
August 5, 2020
SUBJECT:
BROWN FERRY NUCLEAR PLANT - INTEGRATED INSPECTION REPORT 05000259/2020002, 05000260/2020002, 05000296/2020002, AND 07200052/2020001
Dear Mr. Barstow:
On June 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Brown Ferry Nuclear Plant. On July 24, 2020, the NRC inspectors discussed the results of this inspection with Steven M. Bono, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Thomas A. Stephen, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket Nos. 05000259, 05000260, 05000296, and 07200052 License Nos. DPR-33, DPR-52, and DPR-68
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000259, 05000260, 05000296, and 07200052 License Numbers: DPR-33, DPR-52, and DPR-68 Report Numbers: 05000259/2020002, 05000260/2020002, 05000296/2020002, and 07200052/2020001 Enterprise Identifier: I-2020-002-0063 and I-2020-001-0118 Licensee: Tennessee Valley Authority Facility: Brown Ferry Nuclear Plant Location: Athens, Alabama Inspection Dates: April 01, 2020 to June 30, 2020 Inspectors: C. Fontana, Emergency Preparedness Inspector N. Hobbs, Resident Inspector M. Kirk, Senior Resident Inspector N. Peterka, Resident Inspector S. Sanchez, Senior Emergency Preparedness Insp Approved By: Thomas A. Stephen, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Brown Ferry Nuclear Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. On May 4, 2020, the unit reduced power to 75 percent at the request of transmission operators due to grid loading after de-energizing the Maury 500kV line due to a component failure in the switchyard. Following repairs, the unit was returned to rated thermal power level on May 5, 2020 and operated at or near this power level for the remainder of the inspection period.
Unit 2 began the inspection period at rated thermal power. On May 9, 2020, the unit incrementally lowered power to approximately 68 percent power to support testing. The unit returned to rated thermal power on May 13, 2020. On May 19, 2020, the unit was shutdown for a planned forced outage due to an increase in unidentified leakage. The leak was identified and repaired, and the unit was restarted on May 22, 2020. The unit operated at approximately 85 percent power until June 6, 2020, when the unit was shutdown for a planned forced outage to make repairs to the condenser. Repairs were completed and the unit returned to rated thermal power on June 15, 2020 and operated at or near rated thermal power for the remainder of the inspection period.
Unit 3 began the inspection period during power ascension activities following the completion of a refueling outage. On April 1, 2020, the unit achieved rated thermal power. On April 2, 2020, the unit was shutdown for a forced outage due to an increase in unidentified leakage greater than technical specifications. The unit remained in the forced outage until repairs were completed and returned to rated thermal power on April 9, 2020. On April 20, 2020, the unit incrementally lowered power to approximately 60 percent power to support testing. The unit returned to rated thermal power on April 27, 2020 and operated at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time the resident inspectors performed periodic site visits each week and during that time conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of summer temperatures for the following systems from June 12 through June 23, 2020:
- Offsite and backup alternating current (AC) power systems
- Condenser circulating water (CCW) system
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 3, Diesel Generator (DG) fuel oil system during the week of April 27 to May 1, 2020
- (2) Unit 1, Residual Heat Removal (RHR) system Loop II during planned maintenance on Loop I on May 7, 2020
- (3) Units 1, 2, and 3, Loop 1 Residual Heat Removal Service Water (RHRSW) during D3 RHRSW surveillance on May 12, 2020
- (4) Unit 1, Main bank battery #1, safety-related unit batteries on June 11, 2020
- (5) Unit 1, Standby Liquid Control (SLC) system on June 23, 2020
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Units 1 and 2, Fire Area 04, 4kV shutdown board room 1B on April 29, 2020
- (2) Units 1, 2, and 3, Fire Area 25-1, B and D RHRSW pump rooms on May 4, 2020
- (3) Unit 3, Fire Area 16-O, Auxiliary instrument room #3 on May 27, 2020
- (4) Unit 1, Fire Area 17, Battery and battery board room on May 12, 2020
- (5) Units 1, 2, and 3, Fire Area 16-A, Cable spreading room A on June 5, 2020
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the Control Room:
- Unit 2 shutdown for forced outage, F206, on May 19, 2020
- Unit 2 shutdown for forced outage, F207, on June 6, 2020
- Unit 2 restart following forced outage, F207, on June 10-11, 2020
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) Inspectors observed and evaluated licensed operator requalification in the simulator on April 21, 2020.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) Maintenance Rule 12th Periodic Report (January 2018 to December 2019)
- (2) Unit 1, 2, and 3, Function 573-B, Source of control and motive power for engineered safeguards systems, main bank batteries
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Fuel oil and lube oil quality control processes for safety-related systems
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed;
- (1) Units 1 and 2, Elevated risk associated with planned maintenance on B DG and shutdown board B batteries during the week of April 27 to May 1, 2020
- (2) Units 1 and 2, Risk associated with emergent, unplanned maintenance associated with an inoperable shutdown board B and B DG out of service for planned maintenance from May 1 to May 4, 2020
- (3) Unit 3, Risk associated with planned maintenance on main bank battery 3 on June 24, 2020
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) Unit 3, Rod Worth Minimizer (RWM) system following degraded performance during startups on April 3 and April 5, 2020
- (2) Unit 1, SLC system following lowering trend in tank level and pump 1A packing leakage on April 15, 2020
- (3) Unit 1, 1A RHR heat exchanger prompt determination of operability following higher than expected differential pressures on May 5, 2020
- (5) Unit 3, Amperage difference between inboard and outboard main steam isolation valve solenoids on April 10, 2020
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Unit 3, BFN-3-2020-068-002, Temporary cooler for 3B recirculation pump seal flush water
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated the following post maintenance test activities to verify system operability and functionality:
- (1) Unit 2, Post maintenance test following replacement of the C1 RHRSW pump auto start relay on April 09, 2020
- (2) Units 1 and 2, Post maintenance test following replacement of the C DG watt meter on May 12, 2020
- (3) Unit 1, Post maintenance test following Loop II RHR system outage on May 15, 2020
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (3 Samples)
- (1) The inspectors evaluated Unit 3 forced outage activities (F310) from April 2 to April 6, 2020, to identify and repair leakage associated with the 3A recirculation pump.
- (2) The inspectors evaluated Unit 2 forced outage activities (F206) from May 19 to May 22, 2020, to make repairs to main feedwater piping that was leaking inside the drywell.
- (3) The inspectors evaluated Unit 2 forced outage activities (F207) from June 6 to June 11, 2020, to make repairs associated with balance of plant equipment.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) Unit 2, 2-SR-3.5.3.3, Reactor Core Isolation Cooling (RCIC) system rated flow at normal operating pressure on April 8, 2020
- (2) Unit 3, 3-SR-3.5.1.8. High Pressure Coolant Injection (HPCI) main and booster pump set developed head and flow rate test and 150 psig reactor pressure on April 15, 2020
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) Units 1, 2 and 3, 0-SI-4.5.C.1(B1), RHRSW pump B1 IST group A quarterly pump test before and after a planned impeller gap adjustment on May 11, 2020
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
- (1) Unit 3, Increased unidentified leakage identified on April 1, 2020
71114.02 - Alert and Notification System Testing
Inspection Review (IP Section 02.01-02.04) (1 Sample)
- (1) The inspectors evaluated the maintenance and testing of the alert and notification system during the week of May 4, 2020.
71114.03 - Emergency Response Organization Staffing and Augmentation System
Inspection Review (IP Section 02.01-02.02)
The inspectors evaluated the readiness of the Emergency Response Organization (ERO)during the week of May 4, 2020. However, the inspectors were unable to complete this inspection procedure (IP) in its entirety. The aspect that remains to be inspected is the verification of a sample of key ERO personnels training qualifications and response times from home to the site. The necessary documentation used by the inspectors to verify this information is considered personally identifiable information, which the inspectors chose not to handle while performing this inspection remotely. Completion of the remainder of this IP will be determined at a later date..
71114.04 - Emergency Action Level and Emergency Plan Changes
Inspection Review (IP Section 02.01-02.03) (1 Sample)
- (1) The inspectors evaluated submitted Emergency Action Level, Emergency Plan, and Emergency Plan Implementing Procedure changes during the week of May 4, 2020. This evaluation does not constitute NRC approval.
71114.05 - Maintenance of Emergency Preparedness
Inspection Review (IP Section 02.01 - 02.11)
The inspectors evaluated the maintenance of the emergency preparedness program during the week of May 4, 2020. However, the inspectors were unable to complete this IP in its entirety. The aspects that remains to be inspected are the verification of radiation monitors used in the EALs to ensure proper scale readout of the instrumentation, emergency response facilitys readiness, including field monitoring team vehicles and go-kits used for emergencies. Completion of the remainder of this IP will be determined at a later date.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
EP01: Drill/Exercise Performance (IP Section 02.12) ===
- (1) April 1, 2019, through March 31, 2020
EP02: ERO Drill Participation (IP Section 02.13) (1 Sample)
- (1) April 1, 2019, through March 31, 2020
EP03: Alert & Notification System Reliability (IP Section 02.14) (1 Sample)
- (1) April 1, 2019, through March 31, 2020
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) (3 Samples)
- (1) Unit 1 - April 1, 2019 - March 31, 2020
- (2) Unit 2 - April 1, 2019 - March 31, 2020
- (3) Unit 3 - April 1, 2019 - March 31, 2020
MS07: High Pressure Injection Systems (IP Section 02.06) (3 Samples)
- (1) Unit 1 - April 1, 2019 - March 31, 2020
- (2) Unit 2 - April 1, 2019 - March 31, 2020
- (3) Unit 3 - April 1, 2019 - March 31, 2020
MS08: Heat Removal Systems (IP Section 02.07) (3 Samples)
- (1) Unit 1 - April 1, 2019 - March 31, 2020
- (2) Unit 2 - April 1, 2019 - March 31, 2020
- (3) Unit 3 - April 1, 2019 - March 31, 2020
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends in Intermediate Range Monitor (IRM) half-scrams and battery degradation that might be indicative of a more significant safety issue.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Unit 3, 3A recirculation pump cover vent line leakage and repairs from April 1, 2020 to April 5,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants Operation of an Independent Spent Fuel Storage Installation at Operating Plants
- (1) The inspectors evaluated the licensees activates related to long-term operation and monitoring of their independent spent fuel storage installation.
- (2) The inspectors evaluated the licensees independent spent fuel storage installation cask loadings from May 26, 2020 to June 30, 2020. Specifically, the inspectors observed the following activities:
- Fuel selection and fuel loading
- Heavy load movement of the Hi-Trac and multi-purpose canister (MPC)
- Drying and backfill evolutions
- Closure welding and non-destructive weld evaluations
- Transfer and transport evolutions of the Hi-Storm
- Radiological field surveys
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On July 24, 2020, the inspectors presented the integrated inspection results to Steven M. Bono, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
60855.1 Calculations CDQ042020031120 Evaluation of Cask Transporter Haul Route (HOLTEC Revision 5
Report HI-2022947 For the Dry Cask Storage Project)
NDQ007920050009 BFN ISFSI and Haul Route Fire Hazards Analysis Revision 12
Calculation
Drawings 0-47E201-2 ISFSI Fire Hazards Analysis Compensatory Actions HI- Revision 5
STORM 100 System
Miscellaneous Independent Spent Fuel Storage Installation 10 CFR Revision 5
2.212 Report of Evaluations for the HI-STORM FW
System
Procedures HPP-2244-100 HI-STORM FW/MPC Pre-Operation Inspection Revision 10
MPC-BFN-003 Holtec HI-STORM FW Cask Loading Procedures Revision 5
MSI-0-000-LFT001 Lifting Instructions for the Control of Heavy Loads Revision 76
MSI-0-000- Inspection of ANSI N14.6 Special Lifting Devices for Dry Revision 2
LFT004(FW) Cask Storage (HI-STORM FW)
MSI-0-079- HI-TRAC (VW) Initial Inspection Revision 2
DCS019(VW)
MSI-0-079- ISFSI Abnormal Conditions Procedure for HI-STORM (FW) Revision 0
DCS036(FW) System
MSI-0-079- Dry Cask Preparation and Startup Revision 4
DCS200.1(FW)
MSI-0-079- Alternate Cooling Water System Operation Revision 1
DCS300.2(FW)
MSI-0-079- Cask Transporter Operation Revision 7
DCS300.5
71111.01 Corrective Action CR 1612009,
Documents 1616108, 1617191,
1579775, 1616025,
1617363
Drawings PIP-02-03 AC Electrical Distribution System Browns Ferry Nuclear 07/30/2019
Plant
Procedures 0-AOI-57-1E Grid Instability Revision 11
0-GOI-200-3 Hot Weather Operations Revision 15
Inspection Type Designation Description or Title Revision or
Procedure Date
0-OI-57A Switchyard and 4160V AC Electrical System Revision 166
71111.04 Corrective Action CR 1559725,
Documents 1541715,
1516033,1546875
CR 1599915,
1600580, 1580535,
1585501, 1288222
CR 1605285,
1598798, 1603161
CR 1606454,
1606323, 1606335
CR 1614622,
1610842, 1608968,
1602547, 1600969,
1600516, 1314233,
1585569, 1575115,
1558694, 1555508
Drawings 1-47E811-1 Flow Diagram - Residual Heat Removal System Revision 47
1-47E854-1 Flow Diagram Standby Liquid Control System Revision 17
3-47E858-1 Flow Diagram RHR Service Water System Revision 34
3-47E859-1 Flow Diagram Emergency Equipment Cooling Water Revision 43
3-47E861-8 Flow Diagram - Cooling System & Lubricating Oil System Revision 20
Standby Diesel Generator 3D
Miscellaneous BFN-50-7200C 250V DC Power Distribution System Revision 8
BFN-VTD-C173- Standby Battery Vented Cell Installation & Operating Revision 6
20 Instructions
Procedures 1-OI-74 Residual Heat Removal System Revision 106
1-SR-3.8.4.1(1) Weekly Check for 250V Main Bank Number 1 Battery Revision 17
1-SR-3.8.6.2(1) Quarterly Check of 250 Volt Main Bank Number 1 Battery Revision 17
Work Orders WO 121273435,
119710351,
21284198
WO 121314668
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.05 Corrective Action CR 1595160,
Documents 1594925, 1515097
Fire Plans FPR-Volume 2 Fire Protection Report Volume 2 Revision 67
71111.12 Corrective Action CR 1314233,
Documents 1542269, 1603082,
1605473, 1608968,
1610842, 1613338
Engineering C&D Technologies Inc, Cover Crack Project - Summary 05/15/2013
Evaluations Report
Miscellaneous U0 Function 573-B, Source of Control and Motive Power for Revision 1
Engineered Safeguards Systems, Main Bank Battery 5,
(a)(1) Plan
Browns Ferry Nuclear Plant Units 1, 2, and 3 Maintenance Revision 0
Rule 12th Periodic Report
Procedures 0-SR-3.8.3.5 Identification and Removal of Water from Unit 0 Diesel Revision 3
Generator's 7-Day Storage Tank Fuel Oil Supply
0-TI-196 Lube Oil Sampling Methodology Procedure Revision 6
CI-636 Bright and Clear Test (Diesel Fuel Oil) Revision 8
71111.13 Drawings 0-45E724-2 Wiring Diagram 4160V Shutdown Bd B Single Line Revision 48
0-45E765-14 Wiring Diagrams 4160V Shutdown Aux Power Schematic Revision 7
Diagrams
Procedures BFN-ODM-4.18 Protected Equipment Revision 24
NPG-SPP-07.1.4 Work Management Prioritization - On Line Revision 11
NPG-SPP-07.3 Work Activity Risk Management Process Revision 29
71111.15 Corrective Action CR 1534651,
Documents 1597804, 1598798,
1601637, 1603161
CR 1540385,
1594642, 1596375,
1606323, 1607193,
1606995
CR 1598095,
1599302, 1599496,
1597342, 1600549,
Inspection Type Designation Description or Title Revision or
Procedure Date
1601699
Drawings 1-47E854-1 Flow Diagram Standby Liquid Control System Revision 17
1-47E858-1 Flow Diagram RHR Service Water System Revision 72
Miscellaneous BFN-VTD-U055- Vendor Manual: Union Pump Co. Instruction Manual for Revision 4
20 Installation and Operating TD-60 Power Pump
Procedures 0-GOI-300-1/ATT- Unit 3 Operator Auxiliary / Backup Instrument Operator Revision 209
15.17 Round Log
0-TI-63 RHRSW Flow Blockage Monitoring Revision 27
Work Orders WO 121222360
WO 121231867,
21255128,
20816465
71111.18 Corrective Action CR 1600956,
Documents 1601424, 1602413
Engineering BFN-3-2020-068- Install Temporary Cooler for 3B Recirc Seal Flush Water Revision 0
Changes 002
Procedures NPG-SPP-09.3 Plant Modifications and Engineering Change Control Revision 33
NPG-SPP-09.5 Temporary Modifications Temporary Configuration Revision 19
Changes
Work Orders WO 121290056
71111.19 Corrective Action CR 1607665
Documents
Procedures 0-SR-3.8.1.1(C) Diesel Generator C Monthly Operability Test Revision 59
1-SR- RHR System MOV Operability Loop II Revision 23
3.6.1.3.5(RHR II)
1/2-ETU-SMI 4- Transducer and Indicating Meter Calibrations on Diesel Revision 7
DGC Generator C
Work Orders 120133763
WO 121282212
71111.22 Corrective Action CR 1607175,
Documents 387889
Miscellaneous Operator Logs 4/1/2020
Procedures 0-SI-4.5.C.1(B1) RHRSW Pump B1 IST Group A Quarterly Pump Test Revision 13
Inspection Type Designation Description or Title Revision or
Procedure Date
2-SR-3.5.3.3 RCIC System Rated Flow at Normal Operating Pressure Revision 72
3-SR-2 Instrument Checks and Observations Revision 83
3-SR-3.5.1.8 3-SR-3.5.1.8 - HPCI Main and Booster Pump Set Revision 22
Developed Head and Flow Rate Test at 150 psig Reactor
Pressure
Work Orders WO 119644388
WO 121133604,
20133805,
20607047
71152 Corrective Action CR 1611208,
Documents 1553492, 1610841,
1611648
Procedures NPG-SPP-22.300 Corrective Action Program Revision 17
14