IR 05000269/1990009
| ML15224A665 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/10/1990 |
| From: | Belisle G, Taylor P, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15224A664 | List: |
| References | |
| 50-269-90-09, 50-269-90-9, 50-270-90-09, 50-270-90-9, 50-287-90-09, 50-287-90-9, GL-89-04, GL-89-10, GL-89-4, IEB-85-003, IEB-85-3, NUDOCS 9004250203 | |
| Download: ML15224A665 (14) | |
Text
REG,,
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-269/90-09, 50-270/90-09, and 50-287/90-09 Licensee: Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.: 50-269, 50-270, License Nos.: DPR-38, DPR-47, and and 50-287 DPR-55 Facility Name:
Oconee Nuclear Station, Units 1, 2, and 3 Inspection Conducted: March 5-9, March 12-16, 1990 Inspectors: 7i2,f-,
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P.Tra 1,'
Date Signed Approved by:
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G. A. Belisle, fhtief Date Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted in the areas of inservice testing, complex surveillance, and action on previous inspection finding Results:
In the areas inspected, no violations or deviations were identifie In the area of inservice testing the following items were noted:
Neither the licensee's TSs nor administrative controls require ASME Code,Section XI pump and valve relief requests to be approved by the NRC or submitted to the NRC prior to their implementation, paragraphs 3 and Check valve full stroke exercising, power operated valve stroke timing, and a lack of instrumentation to measure certain pump test quantities as required by the code were identified as open issues during an NRC review of the licensee's program in 1984. These issues have not been resolved, paragraphs 3, 4, and < 0042504
A weakness was identified in the area of check valve full-stroke exercising in that the licensee's current IST program was full stroke exercising fewer check valves than were full-stroke exercised during the previous 10 year interval, paragraph Strengths in the areas of IST test personnel qualifications and the addition of non-design, based accident valves and pumps to the IST program were identified, paragraph REPORT DETAILS 1. Persons Contacted Licensee Employees
- W. Foster, Maintenance Superintendent
- D. Hubbard, Performance Engineer
- E. LeGett, Regulatory Compliance
- B. Millsaps, Maintenance Engineer
- G. Rothenberger, Integrated Scheduling Superintendent
- D. Sweigart, Operations Superintendent Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, technicians, and administra tive personne NRC Resident Inspectors
- P. Skinner, Senior Resident Inspector
- L. Wert, Resident Inspector
- Attended exit interview 2. IST Introduction (73756)
10 CFR.50.55 a(g) and TS Surveillance Requirement 4.0.4 require that ASME Code Classes 1, 2, and 3 pumps and valves be inservice tested in accordance with Section XI of the ASME Boiler and Pressure Vessel Cod The licensee is committed to the requirements of the ASME Code,Section XI, 1980 Edition through the Winter 1980 Addend During this inspection, the inspectors reviewed the licensee's inservice test program, implementing procedures, and test results that accomplish Section XI pump and valve IS The details of this review are stated in paragraphs 3 through 5. Pumps and valves that are in the HPI, LPI, and RBS systems were reviewed during this inspectio The licensee is in the second ten year ISI interval, and has not received an approved SE Per GL 89-04 Guidance on Developing Acceptable Inservice Testing Programs, the licensee is not scheduled to get an approved SE During the review of the licensee's IST program, several strengths were identifie The licensee has dedicated personnel in the Performance Group, whose sole responsibility is to accomplish plant and inservice testing. The inspectors observed several pump and valve tests conducted by Performance Group personnel and noted that they were knowledgeable, independent, conscientious, and experience This is identified as an IST program strengt In addition the licensee added pumps and valves to the ISI program that were beyond the scope of the FSAR, Chapter 15, design accident. Check Valve Full-Stroke Testing (73756)
The inspectors reviewed the full-stroke and reverse-flow IST methods and results for the following check valves located in the HPI, LPI, CF, and RBS systems:
LP57 HP126 LP31 CF12 BS19 LP55 HP127 LP47 CF13 BS5 HP1O1 HP194 LP48 CF14 BS6 HP102 LP29 HP152 BS7 BS16 HP113 LP30 HP153 BS9 HP109 LP33 HP188 BS11 HP105 LP35 CF11 BS14 The inspectors reviewed the following procedures which performed IST on the above check valves:
PT/2/A/0204/07, Change 26, RBS System Performance Test PT/3/A/0150/22A, Change 25, Operational! Refueling Valve Functional Test PT/1/A/0251/09, Change 4, LPI/HPI Check Valve Functional Test PT/O/A/0251/12, Change 4, LPI Check Valve Operability Test PT/O/A/0150/226, change 5, Reactor building Spray System Check Valve Operability Test PT/O/A/0201/03, Change 5, Core Flood System PT/O/A/0251/15, Change 3, Building Spray Check Valve Functional Test PT/1/A/0203/06, Change 40, Low Pressure Injection System Performance Test PT/L/A/0202/11, Change 36, High Pressure Injection System Performance Test Requirements for full stroke and reverse flow exercising check valves are contained in Section XI, Subsection IWV-3520 of the Cod In addition, IWV-3520 requires check valves to be routinely exercised to the position in which they perform their safety function, open and/or close Of the 32 check valves reviewed by the inspectors, 7 valves; B7, B9, LP31, LP47, LP48, LP33, and LP35 were full stroked exercised ope The remaining 25 check valves were only partial stroked exercised ope Full stroke exercising of check valves has been an open issue with the licensee since November 198 In November 1984, NRR and its consultant, EG&G, Idaho, Inc., met with the licensee to discuss the iST program for pumps and valves (second ten year interval) for Oconee Nuclear Station Units 1, 2, and 3. The minutes of the November 1984 meeting were published by the NRC in a letter dated January 28, 198 The NRC position was that relief from the Code would not be granted for not full stroke exercising check valves that perform functions important to safet During the inspection the licensee informed the inspectors that they viewed the items in the January 28, 1985, letter as areas for discussion and were not binding since an SER was not subsequently issue In addition, the licensee stated that the first ten year interval IST program was approved by the
NRC and allowed partial stroking as an acceptable alternative to full stroke exercisina check valve Since partial stroke exercising check valves was a previously approved alternative, the licensee considered that the NRC did not have justification to change positions between the first and second ten year IST interval GL 89-04, Positions 1 and 2, provide guidance in the area of check valve full stroke exercising. The licensee has committed to respond to the NRC in regards to conformance with the GL 89-04 Positions by November 199 Resolution of check valve full stroke exercising is dependent on how the licensee responds to GL 89-04 and how the IST program is manage The licensee's IST program requires that check valves HP113, HP109, HP105, HP126, HP153, HP152, HP194, and HP188 be full stroke exercised each RF Results of the review of the implementing procedures indicated that these valves were not full stroke exercised in accordance with the licensee's IST program or Cod Procedure PT/1/A/251/09 provided instructions to exercise these valves each RF PT/1/A/251/09 required a flow rate of 40 gpm to stroke test these check valves. During the review, the inspectors noted that the implementing procedure previously required a flow rate of 150 gpm but was changed to required a flow rate of 40 gp Since the accident flow rate through these valves was significantly higher than 40 gpm, the inspectors questioned if these check valves were being full or partial stroke exercise Per the licensee, 40 gpm did not fully stroke exercise these valve Prior to the last RFO in each unit, procedures were changed to 40 gpm from 150 gpm due to LTOP restriction When implementing procedures were changed, IST personnel were aware that the IST program would require a change and a relief request to recognize partial in lieu of full stroke exercising. The inspectors were informed that it was station policy to change implementing procedures and then, following the RFO, revise the IST program to recognize the changes previously made to the implementing procedure When the program was revised, a Code relief request would be generate The inspectors identified that no licensee administrative controls revise the IST program and submit relief request first, then change the implementing procedure During the inspection, the licensee initiated corrective action to more closely track implementing procedure revisions that effected the IST program made in between IST program revision Due to higher licensee priorities, the IST program was not changed following the previous RFOs in all three Units; however, the licensee was planning to eventually revise the IST progra As previously discussed, check valves HP113, HP109, HP105, HP126, HP153, HP152, HP194 and HP188 were being partial flow exercised in lieu of full flow exercised without prior NRC approval or notificatio The inspectors also noted another example where check valves were partial in lieu of full stroke exercised without prior NRC approval or notificatio On January 13, 1986, Revision 10 to the licensee's IST program was issue One of the Revision 10 changes was to partial in lieu of full stroke exercise check valves HP1O1 and HP102. This relief request was submitted
to the NRC on November 6, 1987, approximately twenty months late The licensee stated that prior NRC approval or notification of relief requests was not required prior to implementation, and that it was station policy to provide to the NRC the latest revision to the IST program when requeste The licensee stated that NRC approval or notification was not required prior to implementing changes to the IST program because TS 4. is different than standard TSs in that prior written NRC approval is not required to implement relief request Also, 10 CFR 50.55(a)(g)(5)(iv)
states that approval of IST program relief requests is not required until 12 months after the expiration of the current ten year cycle; therefore, the licensee considered that relief requests did not have to be submitted to the NRC for review until after the end of the current ten year cycl The inspectors reviewed the SER, dated March 25, 1982, that approved the licensee's first ten year IST interval progra Results of this review were that of the 32 check valves reviewed during this inspection, a larger number of these check valves were full stroke exercised under the first ten year interval program than are presently full stroke exercised under the second ten year interva Under the first ten year IST program, 18 of the 32 check valves reviewed were full stroke exercise Under the current IST program, 7 of the 32 check valves were full stroke exercise Check valves HP101, HP102, HP113, HP109, HP105, HP126, HP127, HP194, HP152, HP153, and HP188 were full stroke exercised during the first ten year interval but are presently partial stroke exercised. These check valves were full stroked exercised under the first ten year interval during RFOs while the reactor vessel head was removed. Due to scheduling restraints and the possibility that running accident flow through these lines may create crud bursts, the licensee has elected to no longer perform full flow exercising with the reactor vessel head remove The inspectors concluded that despite the NRC initiatives to full stroke exercise check valves in accordance with the Code, the licensee has moved in the opposite direction by full flow exercising fewer valves. This was identified as a weakness in the licensee's IST progra One method utilized by the licensee to full stroke exercise check valves was to calculate the minimum flow required to open the valve and use this value to full stroke exercise the check valve without measuring differential pressure across the check valve. Manufacture data, based on the characteristics of a brand new check valve, was used to calculate the minimum flo For example, the licensee calculated that 103 gpm was required to full stroke exercise valve HP113. During a large break LOCA, 450 gpm would be required to flow through valve HP11 Although the licensee was partial stroke exercising check valve HP113 with 40 gpm, previous practice was to full stroke exercise valve HP113 with 150 gpm without measuring differential pressure across the valve. It appeared the licensee used this method to full stroke other check valves in the IST program. The inspectors questioned if flow rates less than accident flow rates utilized to full stroke exercise check valves without measuring
differential pressure across a check valve was a valid full stroke exercise test. This method of check valve full stroke exercising should be reevaluated when the licensee reviews their IST program using GL 89-04 Positions 1 and 2 for check valve full stroke exercisin The licensee did have a relief request in their IST program to not measure differential pressure when full stroke exercising check valve Within the areas inspected, no violations or deviation were identifie. Power Operated Valves (73756)
The inspectors reviewed IST for the following power operated valves:
BS3 LP5 BS1 BS4 HP24 BS2 LP21 HP25 LP5 HP98 LP21 HP93 LP22 HP100 The inspectors interviewed licensee personnel regarding the general methods used to stroke time power operated valve The inspectors also reviewed appropriate relief requests and reviewed the following implementing procedures for the IST of the previously listed valve Units 1, 2, and 3 Stroke Time Logs PT/2/A/0204/07, Change 26, RB Spray System Performance Test PT/3/A/0150/22A, Change 25, Operational/Refueling Valve Functional Test PT/1/A/0203/06, Change 40, Low Pressure Injection System Performance Test The criteria for the IST of power operated valves is contained in subsection IWV-3400 of Section X The results of the power operated valve IST review indicated that valves were tested in accordance with the licensee's IST program in the areas of stroke timing methods, frequencies, and corrective action In the area of stroke-timing valves, the licensee's acceptance criteria for excessive stroke times was not in accordance with the Code, GL 89-04 position 6, or the 1984 IST meeting minute However, the licensee did have a relief request in the IST program stating the modified acceptance criteria for
"fast acting valves".
Generic Relief Request 3.5.b stated that valves with stroke times less than 2 seconds will be defined as "fast acting valves."
Corrective action will be required when a "fast acting valve" stroke time is 3 seconds or greater. Position 6 of GL 89-04 and Comment 4 to the 1984 IST meeting minutes stated that when 2 seconds is exceeded, the valve be declared inoperable and corrective action shall be take Comment 4 of the 1984 IST meeting minutes also stated that all power operated valves other than "fast acting valves" be stroke timed to the code requirement In lieu of stroke timing all remaining power operated valves in accordance with the code, the licensee had a relief request in their IST program, Relief Request 3.5.i, that allows pneumatic valves with stroke times of 5 seconds or less to be allowed to have stroke time increases of 3 seconds with no penalt All valves that fall into this category were limited by an absolute maximum of 9 seconds or les The Code requires that corrective action be taken if a valve with a stroke time of 10 seconds or less increases its stroke time by 50 percen For example, if a pneumatic valve stroke time went from 4 seconds to 6 seconds then the code would require corrective action to be taken; however, per the licensee's IST program no corrective action would be required. The licensee's basis for Relief Request 3.5.i was that due to the spring tension, pneumatic valves' stroke times can vary by 3 seconds each time the valve is stroke As previously discussed in the check valve section of this report, the 1984 IST meeting minutes were not legally binding and relief requests do not require prior NRC approval; therefore, the licensee was meeting the approved requirements of TSs and 10 CFR 50.55a(g).
The licensee response to Position 6 of GL 89-04 may resolve these stroke timing issue Within the areas inspected, no violations or deviations were identifie. Pump Testing (73756)
The inspectors reviewed inservice testing for the motor driven emergency feedwater pumps, low pressure injection pumps, high pressure injection pumps, and the reactor building spray pumps to determine if periodic testing of these components was being performed in accordance with the ASME Code,Section XI, Subsection IWP requirements, 1980 Edition through Winter 1980 Addenda. The licensee's IST program for pump testing differs from the Code in the area of installed instrumentation used to measure various test quantities (e.g.,
inlet pressure, flow, differential pressure) as required by IWP-3100, Table IWP-3100- Instrumentation not installed was identified in pump Relief Requests 4, 5, 6, and 7. An NRC letter dated January 28, 1985, noted these relief request as an open ite Resolution of this open item should be addressed in the licensee's response to GL 89-0 The inspectors reviewed implementing procedures and completed test results for the following pump PT/3/A/0204/07, Change 35, Reactor Building Spray System Performance Test PT/1/A/0202/11, Change 36, High Pressure Injection System Performance Test PT/3/A/0600/13A, Change 19, Motor Driven Emergency Feedwater Pump Test PT/1/A/0203/06, Change 40, Low Pressure Injection System Performance Test
The inspectors verified that these implementing procedures incorporated ASME Code requirements regarding IWP acceptance criteria, test frequency, test duration, instrument calibration, the time period for analyzing test results and corrective action had been prescribed if measured test quantities entered the alert or required action rang The inspector reviewed maintenance activities for the high pressure injection pumps and noted that appropriate past maintenance testing was identified and completed following maintenanc The inspectors witnessed the performance of the following inservice pump test PT/2/A/0204/07, Change 26, RB Spray System Performance Test, Pump 2A PT/1/A/0600/13, Change 9 Motor Driven Emergency Feedwater Pumps, Pump 1A The inspectors noted that the test procedure being used to conduct the test was the latest revision. Prior to the test, the inspectors observed that initial conditions, prerequisites, and instrumentation calibration were properly establishe During the conduct of the test, plant personnel in charge were observed to be following procedural steps, precautions, recording test data, and assessing the test results for acceptance based on the provided acceptance criteri Within the areas inspected, no violations or deviations were identifie. Complex Surveillance (61701)
TS Surveillance Requirement 4.2.6 requires that the PORV used for LTOP protection of the reactor coolant system be demonstrated operable by performing an operability test prior to each startup from cold shutdown, performing a calibration of the actuation circuit each refueling outage, and performing an inspection of the PORV at least every two refueling cycles. The inspectors reviewed the following procedures that accomplish these surveillance requirements:
IP/0/B/200/9, Change 41, Reactor Coolant System Narrow Range Pressure Instrument Calibration PT/0/A/201/04, Change 1, PORV Operability Test WYLE Laboratories Test Report 40862-0, dated, December 6, 1989, Power Operated Relief Valve Recertification Test Program For Oconee Nuclear Plan Results of the inspectors' review of TS 4.2.6 requirements were that all requirements were met. All portions of the PORV mechanical and electrical circuits were properly tested. Although not required to be tested by TSs, the PORV in each Unit also has a function during normal operation to relieve reactor coolant system pressure in order to prevent challenges
to the pressurizer safety relief valve The licensee's procedures also tested all portions of this circuitr Within the areas inspected, no violations or deviations were identifie. Action on Previous Inspection Findings (92701) (Closed)
IFI (269, 270, 287/88-16-01):
Bulletin 85-03 Valve Differential Pressure Stroke Testing Bulletin 85-03, Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings, required licensee's to differential'pressure test a select group of MOV The licensee has performed some limited MOV differential pressure testin The licensee will complete MOV differential pressure testing under the guidelines of GL 89-10, Motor Operated Valve Testing and Surveil lanc (Closed)
IFI (269, 270, 287/88-16-02):
Bulletin 85-03 Valve Post Maintenance Testin In response to Bulletin 85-03, the licensee committed to perform motor load diagnostic testing following minor MOV maintenanc Due to difficulties with using the motor load unit, the licensee was unable to test MOVs following minor maintenance with the motor load unit as committed. The licensee is still experiencing trouble with the motor load unit and will resolve this problem under the guidelines of GL 89-1 c. (Closed) IFI (269, 270, 287/88-16-03):
Administrative Documentation of MOV Post Maintenance Testin This concern involved documentation on work order cover sheets that diagnostic testing was required following MOV minor maintenanc This concern will be resolved under the guidelines of GL 89-1 (Closed)
IFI (269, 270, 287/88-16-04):
Determine and Report Operability of Underthrusting Valve LER 269/90-03, dated March 13, 1990, reported the details of six MOVs that were not producing adequate thrusts that was discovered during the performance of Bulletin 85-03 action item (Closed)
IFI (269, 270, 287/88-16-05):
Corrective Action For Overthrusting MOV During the performance of Bulletin 85-03, the licensee discovered that several MOVs were overthrustin The licensee was in the process of evaluating if the actuators were degraded due to overthrusting. This will continue to be evaluated and resolved under the guidelines of GL 89-1 f. (Closed)
IFI (269, 270, 287/88-16-06):
Placement of Valve in Mid Position Prior to Torquing Valve to Actuator Fastener Licensee procedures that remove and install MOV actuators have been changed to ensure that the valve is in the mid position prior to torquing the valve to actuator fastener g. (Closed) URI (269, 270, 287/88-17-03): Failure of Valves with Short Stroke Times to Meet ASME Section XI During a previous inspection, and inspector noted that the licensee's stroke time acceptance criteria for valve 2LWD2 was not in accordance with IWV-3400 of Section X At that time, the licensee's IST program allowed valves with stroke times equal to or less than five seconds to be treated as "fast acting valves", and that corrective action would not be required until the stroke time exceeded six seconds. During the 1984 IST meeting between the licensee and NRC, the licensee was informed by the NRC that only valves with stroke times with two seconds or less could be treated as "fast acting valves", and that corrective action would be required if a "fast acting valve" stroke time exceeded two second The inspector who identified this URI was concerned that the licensee did not change their program to recognize the 1984 IST meeting NRC position on "fast acting valves."
This subject has been previously discussed in this report and as stated, since an SER was never issued following the 1984 IST meeting, the meeting minutes were not binding. The issue of
"fast acting valves" is thoroughly discussed in GL89-04 and the licensee has committed to respond to the NRC in writing their conformance with the G h. (Closed) IFI (269/88-18-01):
Determine Reason for Valve 1LPSW516 to Repeatedly Fail Code Inservice Testin Valve 1LPSW516 had repeatedly failed to open automatically during quarterly inservice testin On July 27, 1988, the licensee discovered that the air operator to the valve stem adapter was too tigh This excessive friction prevented the air operator from exerting adequate torque to operate the valv Flats on the stem were filed and paint was removed from the inside of the stem adapter to increase clearance The inspectors reviewed IST results dating back to July 27, 1989 and no 1LPSW516 failures had occurred since the July 27, 1989 repair wor i. (Closed) IFI (269, 270, 287/89-16-01): Review Licensee's Evaluation For Conservative Leak Rate Testing of Purge Valve This item involved containment leak rate Type C testing 48 inch Pratt Whitney butterfly containment isolation purge valves in the direction opposite to be accident pressure. The containment side of the disk has 180 degree of the value seating surface and the remaining 180 degrees of the valve seating surface is on the opposite
side of the dis The inspectors' concern was that the Type C test pressurized the non accident side of the disk which would provide different seating characteristics than pressurizing the accident side of the valve dis The inspectors were informed that during containment testing, the outboard and inboard containment isolation valves are shu While the containment is pressurized the inboard purge valve is pressurized in the accident directio A vent is opened between the inboard and outboard purge valves and leakage is monitore The inspectors considered that this was adequate to verify that reverse leak testing was acceptabl In addition the licensee obtained a letter from the valve vendor stating that these type of valves did not exhibit direction dependent leakage characteristic The vendor's letter explained that the valve disk shaft runs through the center of the disk which applies equal forces on each half of the disk preventing the disk from unseating while under pressur j. (Closed)
IFI (269/88-13-08):
Corrective Action For Valve 1LP21 Multiple Failure Since 1985, the stroke times for MOV 1LP21 varied between 15 and 16 seconds. This was a problem because 1LP21 limiting stroke time value was 15 second Packing replacement, stem lubrication and limit switch adjustments did not solve this problem. In November 1989 the valve was diagnostically tested and the motor was discovered to be not rotating at the correct speed. The motor was rotating too slo A new motor was installed and the valve subsequently stroked in 13 second The valve was stroke timed again on January 31, 1990, with a stroke time of 13 seconds. It appears that the motor rotating too slow was the problem, but the valve will continue to be monitored via routine IST stroke time testin (Closed)
URI (269, 270, 289/88-17-04):
Mis-Classification of QA Condition Valves During a previous inspection, an inspector questioned why the QS-condition block on a work order for valve 1LPSW516 was annotated as"non-QA."
This valve is located in the EFW pump motor cooler LPSW discharge pipin This discharge piping was Class G and valve 1LPSW516 was non-QA. The inspector then questioned whey the piping was Class G in lieu of Class The licensee has evaluated this concern and considered that the LPSW discharge piping from any safety related pump cooler was properly classified as Class The requirement was for cooling water to be supplied to the motor cooler and this could be satisfactorly accomplished regardless of where the cooling water discharges t.
Exit Interview The inspection scope and results were summarized on March 16, 1990, with those persons indicated in paragraph The inspectors described the areas inspected and discussed in detail the inspection results listed belo Proprietary information is not contained in this repor Dissenting comments were not received from the license Licensee management was informed that the following items were closed:
IFI 269, 270, 287/88-16-01, 02, 03, 04, 05, and 06, Paragraph 7 URI 269, 270, 287/88-17-03, Paragraph 7 IFI 269/88-18-01, Paragraph 7 IFI 269, 270, 287/89-16-01, Paragraph 7 URI 269, 270, 287/88-17-04, Paragraph 7 IFI 269/88-13-08, Paragraph 7 Check valve full stroke exercising, power operated valve stroke timing, and a lack of instrumentation to measure certain pump test quantities as required by the code were identified as open issues during an NRC review of the licensee's program in 1984. These issues have not been resolved, paragraphs 3, 4, and On March 28, 1990, a telephone conversation was conducted between the inspector and licensee representative K. Chea. The licensee was informed that their methods for IST relief request approval and submittal and changing IST implementing procedures prior to changing the IST program were determined to be within existing regulations. The licensee was also informed of the weakness involving full stroke exercising fewer check valve.
Acronyms and Abbreviations ASME American Society of Mechanical Engineers CF Core Flood CFR Code of Federal Regulation FSAR Final Safety Analysis Report EFW Emergency Feed Water GL Generic Letter gpm gallons per minute HPI High Pressure Injection IFI Inspector Followup Item IST Inservice Testing LER Licensee Event Report LOCA Loss of Coolant Accident LPI Low Pressure Injection LPSW Low Pressure Service Water LTOP Low Temperature Overpressure Protection MOV Motor Operated Valve NRC Nuclear Regulatory Commission PORV Power Operated Relief Valve QA Quality Assurance
RFO Refueling Outage RBS Reactor Building Spray SER Safety Evaluation Report TS Technical Specification URI Unresolved Item