IR 05000302/1990024

Insp Rept 50-302/90-24 on 900707-0810.Violation Noted.Major Areas Inspected:Plant Operations,Security,Radioligical Controls,Lers & Nonconforming Operations Repts,Facility Mods & Licensee Action on Previous Insp Items

ML20059G602
Person / Time
Site:	Crystal River
Issue date:	08/31/1990
From:	Bradford W, Crlenjak R, Holmesray P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059G597	List: IR 05000302/1990024 ML20059G594 ML20059G600
References
50-302-90-24, NUDOCS 9009130033
Download: ML20059G602 (13)

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NUCLEAR RE!ULATCRY COMMICION  !

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RaoioN W 101 MARIETTA STRE ET, , ,

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Report No: 50-302/90-24 ,

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-Licensee: Florida Power Corporation  :

3201 34th Street, South'  !

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,St.; Petersburg, FL 33733 , e

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. Docket No: 50-302 ' . License No.:'DPR-72 -

, Facility Name: Crystal River 3 .

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Inspection Conducted: July 7'- August 10,.1990 *

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,<- 'Inspecto : - * i P. Holmes-Ray, Senior Resident Inspector '

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W. Bradford, Resident Inspector s

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' Accompanying Personnel; R. Spence -

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Approved by: .

4A / 70 1 R. Crlen,Jakdection Chief f '

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. Division of Reactor Projects r- .

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SUPMARY l

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[ This' routine inspection was conducted by two resident inspectors in'the areas

'of plant operations, security, radiological controls,' Licensee Event Reports

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y Land Nonconforming Operations Reports, facility modifications : and licensee  ;

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action on previous inspection items. Numerous facility. tours were conducted  !

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,and facility operations observed. Some of these tours and observations were .

M' A  : conducted on.backshifts, c .

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L Results:

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i One violation of failure to follow procedure was; identified in paragraph '

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REPORT. DETAILS Persons Contacted Licensee Employees j

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• Bandhauer, Nuclear Operations Superintendent G. Boldt, Vice President Nuclear Production  :

• J. Brandely, Nanager, Nuclear Integrated Planning  !

• J. Colby, Principle Nuclear Mechanical Engineer '

• M. Collins, Nuclear Safety and Reliability Superintendent i

• G. Cowles, Senior Nuclear Results Engineer '

• B. Hickle, Manager, Nuclear Plant Operations

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• G. Longhouser, Nuclear Security Superintendent

• P. McKee, Director, Nuclear Plant Operations ,

• S. Robinson, Nuclear Chemistry and Radiation Protection

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i Superintendent  !

• V. Roppel, Manager, Nuclear Operations Maintenance and Outages '

' *W. Rossfeld, Manager. Nuclear Compliance

• F. Sullivan, Manager, Nuclear Plant Systems Engineering _

• L. Tiscione. Senior Nuclear Instrumentation and Control Engineer .t R. Widell, Director, Nuclear Operations Site Support 1-

• M. w iliams, Nuclear Regulatory Specialist l

Other licensee employees contacted included office, operations, l engineering, maintenance, chemistry / radiation and corporate personnel.

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• Attended exit interview Acronyms and initialisms used throughout this report are listed in the ;

- last paragrap : Review of Plant Operations (71707)

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The plant continued in power operation (Mode 1) for the duration of this ,

inspection period.

! Shift Logs and Facility Records The inspector reviewed records and discussed various entries with operations personnel to verify compliance - with the Technical Specti') cations (TS) and the licencee's administrative procedures, e- ,

The following records were reviewed: ,

Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-0f-Service Log; Shif t Relief Checklist; Auxiliary Building .

Operator's Log; Active Clearance Log; Daily Operating Surveillance Log; Short Term Instructions (STI); and Selected Chemistry / Radiation ,

Protection Log ,

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In addition to these record reviews, the inspector independently verified clearance order tagouts, ' Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations and' maintenance activities in progress. Some operations and maintenance activity observations were conducted during backshif ts. Also, during this inspection period, licensee meetings were attended by the inspector to observe planning and management activitie The facility tours and observations encompassed the following areas:

security perimeter fence; control room; e.nergency diesel generator room; auxiliary building; intemediate building; battery rooms; and, electrical switchgear room The inspectors also observed conditions in the following areas:

(1) Monitoring Instrumentation The following instrumentation and/or indications were observed to verify that indicated parameters were in accordance with the TS for the current operational mode:

- Equipment operating status;

- area atmospheric cnd liquid radiation monitors;

- electrical system lineup; reactor operating parameters; and

- auxiliary equipment operating parameter (2) Shift Staffing

' The inspector verified that operating shift staffing was in accordance with TS requirements and that control room operations were being conducted in an orderly and professional manner. In addition, the inspector observed shift turnovers on various occasions to verify the continuity of plant status, operational problems, and other pertinent plant infomation during these turnover (3) Plant Housekeeping Conditions Storage of material and components, and cleanliness conditions of various areas throughout the facility were observed to determine whether safety and/or fire hazards existed. The condition of the plant is improving as the schedule of area clean up is worked. The areas that have been cleaned now set a new standard to maintai <

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(4) Radiological Protection Program

! Radiation protection control activities were observed to verify that these activities were in conformance with the facility policies and procedures, and in compliance with regulatory-requirements. These observations included:

- Entry to and exit from contaminated areas, including step-off pad conditions and disposal of contaminated

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clothing;

- Area postings and controls;

.- Work activity within radiation, high radiation, and contaminated areas;

- Radiation Control Area (RCA) exiting practices; and,

- Proper wearing of personnel monitoring equipment, protective clothing, and respiratory equipment.-

Area postings were independently verified for accuracy by the inspector. The inspector also reviewed selected Radiation Work i Permits' (RWPs) to verify that the Rk? was current and that the controls were adequate.

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(5) Security Control L In the course of the monthly activities, the inspector included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily activities to include: protected and vital area access controls; searching of personnel, packages, and vehicles; badge issuance and retrieval; escorting of visitors; patrols; and compensatory posts, in addition, the inspector observed the operational status of Closed Circuit Television (CCTV) monitors,- the Intrusion Detection system in the central and secondary alam stations, protected area i

lighting, protected and vital area barrier integrity, and the l

security organization interface with operations and maintenanc (6) Fire Protection 1- Fire protection activities, staffing and equipment were observed

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to verify that fire brigade staffing was appropriate and that.

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fire alarms, extinguishing equipment, actuating controls, fire l fighting equipment, emergency equipment, and fire barriers were operabl On August 1,1990, the inspector found Nuclear Services Closed Cycle Cooling System (SW) valves. SWV-97 and 99 in their open proper operating position, but unsealed contrary to OP-408. On August 3,1990, the inspector found Fire System Valve FSV-167 in its proper position, but unsealed contrary to SP-366. The licensee promptly investigated and i sealed these non-safety-related valves after they were brought to their attention. Sealing these valves is an administrative control and does not l

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affect system operability, therefore, the safety significance of these j

' valves not being sealed is minima l r

The insgctor; as a result of routine plant tours and various operatio1a1 ,

observations, detemined that the general plant and system material conditions were being satisfactorily maintained, plant security program -

i was being effective, and that the overall perfomance of plant operations was good. No. violations or deviations were identifie :

i O ReviewofMaintenance(62703)andSurveillance(61726) Activities l

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Surveillance tests were observed to verify that approved procedures were

! being used; qualified personnel were conducting the testu tests were ;

adequate to verify equipment operability; calibrated equipment was utilized; and TS requirements were followed, j The following. tests were observed and/or data reviewed:

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- SP-157A, Meteorological System Surveillance Daily;

- SP-310, loose Parts Monitoring Subsystem Channels Assessment;

- SP-312A, Daily Heat Balance Power Comparison;

- SP-333, Control Rod Exercises;

- SP-349A, Emergency Feedwater Pump EFP-1 Operability Demonstration; and i

- SP-354A, Monthly Functional Test of the Emergency Diesel .

Generator EDG-1 l

l In addition, the inspector observed maintenance activities to verify that

^ correct equipment clearances were in effect; work requests and fire i prevention work permits, as required, were issued and being followed- ;

L quality control personnel were available for inspection activities as .

requireo; and, TS requirements were being followe Maintenance was observed and work packages were reviewed for the following j maintenance activities:

- Service water heat exchanger 1A; L' i

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High energy);line break - Auxiliary feedwater pump area (T MAR 90-06-04-01 #

- "B" Diesel- Generator - Various PMs included oil leak repairs, air 1eaks, flange gasket replacement, tighten injection pump fittings and strainer cleaning;

- PM-133 Equipment Lubrication Procedure and Cleanliness Inspection; 1

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- Re-racking "B" spent fuel pool with high density fuel racks;

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- MP-126, Make-Up Pump Maintenance; and )

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- Make-Up Pump 1B L - WR 270312 - bearing oil leak

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- WR 270311 - cyclone separator fitting leak  ;

- WR 220120 - alignment

- WR 270314 - gear oil cooler gasket leak '

- WR 270310 - bearing inspectio ,

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The inspectors attended the pre-maintenance meeting on Make-Up Pump (MVP)

1 The meeting was conducted in a professional manner. The meeting addressed availability of parts, ALARA considerations, work precautions, the maintenance procedure, the actual work to be accomplished, QC hold points, and post maintenance testin After the work was completed and the pump had been returned to service, there was a post maintenance meeting which the inspectors attended. This meeting covered all aspects of. the completed work. The cause of the oil leak on the pump bearing was analyzed. The maintenance work procedure was analyzed as to any procedure changes which should be made based on the-actual work encountere These meetings serve a very good purpose. They are conducted in a professional manner. All personnel involved participated freely in the meetings. The inspectors consider these meetings to be a asset to the licensee's maintenance progra The inspectors determined that the above testing activities were performed in a satisfactory manner and met the requirements of the T No violations or deviations were identifie Review of Licensee Event Reports (92700) Licensee Event Reports (LERs) were reviewed for potential generic impact, to detect trends, and to detennine whether corrective actions appeared appropriate. Events that were reported immediately were reviewed as they occurred to determine if the TS were satisfie LERs were reviewed in accordance with the current NRC Enforcement Policy. LERs 88-16 and 88-27 are close (1) (Closed) LER 88-16: Operating outside the design basis due to the failure to treat the high energy line break analysis as an on-going design criter i (2) (Closed) LER 88-27: Violation of 10 CFR 50.59 due to design failure to consider cracks in the auxiliary steam line in the auxiliary buildin ' These LERs concern the effects of high e..ergy line breaks in the auxiliary building and intermediate building The licensee has initiated temporary modifications which are designed to protect certain vital instrumentation against the effects of the high energy line brea The licensee has stated in correspondence with the NRC that the above interim resolution is intended to resolve the problem until the end of Refuel 8. The fire suppression system will be actuated in the event of a steam line break. The licensee also stated that a permanent fix has not yet been selected

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' but that the permanent fix will be selected and implemented before the end of Refuel 8. The perunent modifications will be defined and presented to the NRC by October 1, 199 Based on the aMye actions and commitments between the licensee and the comission, the resident inspectors consider LERs 88-16 and 88-27 close . Design,DesignChangesandModifications(37828)

Installation of new or modified systems were reviewed to verify that the changes were reviewed and approved in accordance with 10 CFR 50.59, that the changes were performed in accordance with technically adequate and

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approved procedures, that subsequent testing and test results met-acceptance criteria or deviations were resolved in an acceptable manner, and that appropriate drawings and facility procedures were revised as necessary. This review included selected observations of modifications and/or testing in progres On July 25, 1990, plant modification (MAR 89-0905-01) was implemented on

"B" emergency diesel generator. This modification was to remove solenoid operated valve EGV-42 and to replace the valve with a straight run of stainless steel tubing. The work was to be done under WR 115381. The diesel generator was tagged out and was inoperable. This valve serves as a vent valve in the diesel starting air line. The instructions in step 14E of the MAR directed that electrical leads between teminals 9 and 10 be lif ted en relay 4A. This circuit is a series circuit from point to point. Lifting these leads would render the diesel generator stop control circuit to be inoperable from the control room. The craftsmen performing the work recognized the error in the MAR instructions and proceeded to correct the MAR by restoring the work to original configuration. This corrective action was in accordance with section 4.7.S.1 of Al-602, Re . " MAR 1mplementation and Nonconfomance Reporting."

The MAR had been generated as a result of information from the d:esel generator vendor. The MAR was initiated in accordance with NU;1 ear Engineering Procedure (NEP) 211, Rev. 4 " Modification Approval I nords."

NEP-211 requires that the MAR be reviewed and approved by a veri fication enginetr and a supervisor. The supervisor's signature constiwtes approval of the design packsge. The design engineer based the MAR on the

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utility drawings. These drawings did not reference the vendor drawings which showed the rest of the circuit to EGV-42. This was also overlooked by the reviewer The expertise of the licensee's craftsmen in their discovery of the error is comendable. In discussions with Engineering supervision this event was used as an example to stress the need for comprehensive reviews of MARS prior to issu '

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7-6.; - Loss' of.1.istrument Air-(71707)

The licensee experienced a partial- loss of instrument air pressure at

' approximatelyi7:00 a.m., on July 10, 1990. The instrument' air pressure The control room operators decreased to 45 PSI from-a normal 120 PS were alerted to the situatior, by low instrument air pressure alarms. The_ .

-inspector observed operator action to restore instrument air using .

energency procedure AP-470. " Loss of- Instrument Air", to protect the reactur.1 Operator action was prudent and timel Theinstrumentairdryer'hadbeenremovedfromserviceformaintenahceand'

was tagged .out under WR- 90-07-036, The tagging order listed the dryer

, bypass valve as the. first valve to be manipulated. This valve was'to-be opened ind tagged in' the open position so that instrument air would not be

• interrupted.- The remainder of the tagout isolated the dryer - for mair'a nc When the work was completed and the work request was cleared, the system .

m was to be restored to normal in a prescribed manner so as not to interrupt-the instri nent air suppl Compliance Procedure (CP) 115, "Nuc1 ar Plant Clearance Orders", section:

4.8.3, states that "when a clearance order is released, tags should be removed in'the reverse sequence in which they were hung."

Since the dryer bypass valve was the first valve to be positioned and tagged open, it should_have been the last-valve to be closed.' This:would have . placed the air dryer back in service without a interruption- in instrument air. _ The plant was placed into a potentially -hazardous -

evolution as a result of failure to follow CP-115, Nuclear Plant' Clearance-

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Orders procedure,- in that the proper order was not followed. This is a violatio Violation (50-302/S0-24-01): Failure to follow procedure CP-11 . Turbine Governing Valve Position Switch Failure (71707)

, On August 7,1990, at 8:36 a.m., number 1 turbine governor valve position indicator broke whila the unit was at full loa This' failure gave the appearance to the EHC system-that number 1 governor valve was going closed.- The EHC system, sensing the valve was closed, opened the valve. This caused steam header pressure to decreas ~

Governor valves 2 and 3 started closing to bring steam pressure back to the setpoint. The operators took prompt manual control of the turbine and stabilized the plant. The generator load decreased approximately 85 M The quick operator action kept the plant from tripping. Maintenance personnel repaired the valve position indicator and the indicators on the other three governor valves were inspecte The operators restored the plant to normal at 9:45 a.m. the same da . . _ _ _ _ . _ _ _ _ _ , . .

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' This' evolution happened. very fast. However, the operators - handled the situation in a professional manner. The maintenance personnel responded quickly and repairs. were' made in a effective manner. The rapid and-effective response accounts for the short recovery tim . -NUREG 0737i TMI Task Action Plan Item Review (TI 2515/065)

n, The following^ TMI Task Action Plan items were reviewed and applicable

• installations verified to determine the status of completion: Item II.E.1.1, NUREG 0737 - Emergency Feedwater System Evaluatio Item-II.K.2.8, NUREG 0737 - Upgrade the Emergency Feedwater Syste In Inspection Report 85-41, this item was raported completed with the exception of the -insteilation of an emergency feedwater tank and issuance of the Crystal River 3 Probabilistic Risk Assessment .(PRA).

The emergency feedwater tank was installed on MAR 82-09-19-01 during Kefuel VI. . The PRA was first issued in July 1987:and has .been updated several times. -In 1990 a PRA summuy document was issued to provide a summary update of the original CR-3 PRA. This item is-close Item II .E.4.1.2 (II.E.4.1.1.B), NUREG 0737 - Hidrogen Control Procedures Reviewed and Upgrade The procedure for installation of the recombiner (MP-575, Rev 0)'was issued May-7, 1990. The operating procedure (0P-417B) is' scheduled-for. issue in September 1990. This' item will remain open pending the

. issue-of'the operating procedure. The procedure for Hydrogen Purg OP-417, most recently revised as rev. 54, dated June' 21,1990, Item II.F.2.2, .NUREG 0737 - Instrumentation - for Detection of

. Inadequate-Core Cooling (ICC) - Subcool Meter In Inspection Report 85-41, P tm II.F.2 (now Item II.F.2.2) was closed with the exception c4 % completion of the MAR for functiona testing of.ICC instrumentation. This outstanding item was tracked as-IFI 85-41-07. In Inspection Report 96-35, IFI 85-41-07 was reported closed. Therefore, this item is close Item II.K.2.9, NUREG 0737 - Failure Mode Effects Analysis (FEMA) on the Integrated Control System (ICS).

In NRC letter dated April 19, 1982, the NRC stated that the information provided by FPC and B&W Report BAW-1564 was reviewed and concluded that Crystal River 3 design meets all current regulatory requirements and no control system failures or actions were ideatified that would lead to unacceptable consequence This letter also states that NUREG 0737, Item II.K.2.9 is resolved for Crystal 4 River Unit 3. This item-is close ._

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' Item II.K.3.1, NUREG 0737<- Automatic PORY Isolatio NRC letter' dated September 30, 1983, statesE that; the NRC) has

completed their' review of. FPC responses to_ the subject NUREG-0737 itams including the B&W Owners Group. Report. Findings are containe '{

in the Safety : Evaluation (SE) with the ' contractor's --(Franklin Research Center)-Technical Evaluation Report (TER) evaluating the dats contained in the B&W Report. Based upon the NRC review, it'was

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found that the requirements of NUREG-0737 Item II.K.3.2 are met with:

the- existing PORY safety valve and reactor high-pressure ; trip , . o-setpoints and that an automatic PORV isolation system is not required for Crystal River Unit 3. This completes' the staff's review of the-J ' subject NUREG-0737 items for the CR 3 facility. This item is close , Temporary Instruction 2515/101 - Loss of Decay Heat Removal (Generic = '

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Letter 88-17)

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L; l The inspectors reviewed the licensee's response .to Generic Letter'

L 88-17 toidetermine that licensee actions described in the response  !

l. cc met the acceptance criteri Licensed operators receive training on loss of decay heat removal  ;

during lowered loop operation as a part. of -the requalification trainina cycle.. Special training on RCS reduced inventory operation prior <to refueling or other outage is directed by Night-Order Log LO-90-04 '

_g The licensee has ' procedures and administrativ'e controls in place to cover containment building closure: for mitigeinn of radioactive L releases. Operation of the plant.unoer this con 6ition is-governed by ,

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the following procedures: ,

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- OP-417, Containment Operating Procedural

- OP-103, Filling and Venting Reactor Coolant System; OP-303, Draining and Nitrogen Blenketing of the RCS;

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- OP-404, Decay Heat Removal System;  ;

n; - OP-360, Loss of Occay Heat Removal; and 1

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- EP-290, Inadequate Core Coolin l The reactor temperature is monitored every 15 minutes by at least two l

incore thermocouples during times when the reactor vessel level is it less than.129 feet 6 inches and the reactor vessel head is in plac '

These thermocouple read outs are located ir, the control room. ~This '

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is required by OP-404, section 3.2. :

The reactor vessel -level is. monitored by control room instrumentation W ,

every 15 minutes when the RCS level is less than 132 feet. There is '

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a local level indication in the reactor building which is checked every 15 minutes and the level is called into the control room each hour. This is required by OP-404, section 3.2.2 '

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t The operators are cautioned to avoid perturbations to the RCS: support l systems while the- RCS-is in a reduced inventory condition. This is'

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covered in OP-404 and is also covered in licensed operator; ~

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requalification_ trainin .

' . Reactor. coolant inventory can be maintained by -other than normal isystems as specified in OP-404. The licensed operators receive

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training in this area during requalification trainin .:

1 The licensee actions to prevent and;to respond to a loss of. decay' i

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heat- cooling during operations with -the reactor- coolant system '

partially drained are judged to meet the requirements of Generic l

Letter 88-1 ,s

.1 Licensee Action on Previously Identified Inspection Findings (92702 - r i

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92701) '

n (Close'd). Violation 302/88-34-01 - The specific procedure for .

calibration :of power range nuclear . instrumentation was changed by revision 48 of SP-113, to state the~ acceptance criteria directly with-no calculation required. Also AI-400 was revised to insure an b independent review of a completed procedure prior to' transmittal to' '

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document controi. This item is closed.

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b.- (Closed) Deviation 302/88-14-01 - MAR 88-09-01-01 was completed- in ; '

Refuel 7, which- installed a hot gas bypass on each of the control f

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l complex chillers. Operations found the MAR acceptable and signed the closure on June 23, 1990. This item'is close ,

, (Closed) IFI 302/88-11-03 - During Refuel 7 the sodium hydroxide was J pumped out of BST-1; leaks were repaired and the sodium hydroxide was

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pumped back into BST-1. ' This was completed and signed off on June 13, 199 .

& (Closed) UNR 302/88-26-03 - The licensee believed that the FSAR

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clarification to ANSI N45.2.2-1972 Section 6.5, exempted storage !

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controls from safety-related materials during the time period after

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issuance from the warehouse and prior to installation in the final

> locatio In a Quality Programs Surveillanca Report the licensee. determined :'

.' that FPC's approved programs do not confom to the requirements of P ANSI N45.2.2-1972 in that adequate controls are not established to .

L ussare that the status of material issued from the warehouse and not h installed in the final . location within the- plant is know ,

controlled, and appropriately depositioned.

l The not installed safety related equipment was removed from the fl L

FPC maintenance shop and properly depositioned. Also the shop H personnel were made aware of the sensitivity to proper handling of safety-related equipment during the time from issue to installation.

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- AppropriateLprocedures have been changed te state the ! storage and handling'-requirements - for material after issueJ and prior to:-

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installation.- For example: . Rev. 6 to CH-499 incorporates the

- provisions for safety-related. lithium' hydroxide storage, inspection,.

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' -control of storage areas, verification of shelf life. -disposallo unacceptable' chemicals, and'special handling of the chemical.: This ,

item is close H

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11 '. ExitInterviewl(30703)

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The inspector met with licensee representatives (denoted in paragraph 1)-.

at the conclusion' of the inspection on August 10 1990. During this

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meeting, the inspector summarized the scope and findings of the inspection as they are detailed. in this report with particular emphasis on the

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violation.-

The licensee representatives acknowledged the inspector's comments and di ]

not identify as:propriat9ey any of the materials provided to or reviewed - j by the inspectors. durk .his inspection.

Y ltem Number Description and Reference 50-302/90-24-01 Violation - Failure to follow procedure ()

CP-11 l 12. . Acronyms and Abbreviations

. AI- - Administrative Instruction

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AFW - Auxiliary: Feedwater System

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-ALARA - As' Low as Reasonably Achievable B&W - Babcock & Wilcox .. 1

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CCTV - Closed Circuit Televisio CFR - Code of Federal Regulations

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.CP - Compliance Procedure DEY - Deviation' 1 ECCS - Emergency-Core Cooling System (s) l EDG - Emergency Diesel Generators .)

EFP' - Emergency Feedwater Pump ,

- Emergency Generator Valve a EGV EHC. - Electric Hydraulic' Control FEMA - Failure Mode Effects Analysis ,!

Te 4 FSAR - Final Safety Analysis Report

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, 180 - Instrumentation and Control ICC - Inadequate Core Cooling ICS - Integrated Control System

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IFI - Ins'pector Followup Item ISI - Inservice Inspection 1

.IST - Inservice Test LER - Licensee Event Report MAR - Modification Approval Record

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N, MP: - Maintenance Procedure MVP - Make-Up Pump'

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NEP- :- Nuclear Engineering Procedure NRC - Nuclear Regulatory Commission OP~ - Operating Procedure PM- - Preventive Maintenance PORY - Power Operated Relief Valve PRA '- Probabilistic Risk Assessment PSI _ - Pounds.Per Square Inch

, QC1 - Quality Control

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Quality Assurance-diation Control Area Stor Coolant System

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c ctor Ope-Ator F.adiation Work Permit

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SE- - !afety' Evaluatio iteam Generator

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S/G S harveillance Procedurt ST .' c : Short Term Instruction SW - - Nuclear Services Closed Cycle Cooling System-

-TER - Technical Evaluation Report

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TS - Technical Specification ViG - - Violation WR- - Work _ Request

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