IR 05000327/1989002
ML20247C737 | |
Person / Time | |
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Site: | Sequoyah ![]() |
Issue date: | 03/09/1989 |
From: | Jenison K, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20247C596 | List: |
References | |
50-327-89-02, 50-327-89-2, 50-328-89-02, 50-328-89-2, NUDOCS 8903300253 | |
Download: ML20247C737 (22) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISslOM
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-101 MAnlETTA STREET, N.W.
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ATLANTA, GEORGIA 30323 '
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' Report'Nos.:
50-327/89-02, 50-328/89-02 Licensee:
Tennessee Valley' Authority 6N:38A. Lookout Place-1101 Market Square Chattanooga, TN. 37402-2801
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Docket'Nos.:
50-327 and 50-328 License Nos.:
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Facility Name:
Sequoyah Units'Icand 2
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Inspection Conducted:
January-5,1989. thruiFeb'ruary 4',1989-Inspector:
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NM Vj/7 89
Jenison, f nio n esident Inspector !
Date Signed
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' Inspectors:'
P.'Harmon,. Senior Resident Inspector
.P. Humphrey, Resident Irispectbr E
'D.-Loveless, ResidentiInspector.
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D. Terao, Chief, Engineering Branch,(TVAPD/NRR.
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-T. Cheng, Senior Structural < Engineer,'TVAPD/NRR
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S. Tingen, Reactor Inspector, Test Programs Section-Approved by:
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L Natson,. Chief, Project Section 1 Date /SicJned TVA Projects Division
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Summary
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' Scope:
This announced inspection involved. inspection effort in~ the area.of
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operational: safety verification including operations ' performance, system lineups, radiation protection, safeguards, and housekeeping '
inspections.
Other areas inspected included maintenance observa-tions, surveillance testing observations, review of previous inspection findings,- follow-up of events, review of licensee identified items, Unit 2 Cycle 3 refueling activities, and review of inspectorL follow-up items.
This report includes the response to - Resident Action Item 88-01, Drawing System Verification, as-referenced in Regional Office Notice No. 2203.
Results:
No violations, deviations, or inspector follow-up items were identified.
Two unresolved items were identified:
URI. 327,328/89-02-01, Diesel Gene'rator LCO and UHI Discharge
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Corrective Actions and Issues l'
8903300253 090309
PDR ADOCK 05000327 PNUL O
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'URI 327,328/09-02-02, Bailey Meter Seismic Qualifications and Safety Evaluation The areas of Operational Safety Verification, Maintenance, and Surveillance Observation appeared to be adequate and fully capable to support current plant operations.
The observed activities of the Operations section, the control room operators in specific, were professional and well managed.
The drawing control system at Sequoyah was reviewed during this inspection period and was determined to be adequate.
Several weaknesses were identified during this inspection period.
These included problems encountered during a resin transfer activity discussed in Inspection Report No. 327,328/88-50 and high airborne activity in Unit 2 containment and the auxiliary building (paragraph 2.c.2.).
These two activities indicated weaknesses in management control in the radwaste and radiological environmental control' areas.
In addition, weaknesses were identified in LCO exit control (paragraph.3) and operator log entries (paragraph 2.a.).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J. Bynum, Vice President, Nuclear Power Production
- J. LaPoint, Site Director S. Smith, Plant Manager T. Arney, Quality Assurance Manager.
R. Beecken, Maintenance Superintendent E. Burke, Supervisor, Sequoyah Modifications Section
- M. Cooper, Compliance Licensing Manager
- P. Crabtree, Shift Operations Supervisor D. Craven, Plant Support Superintendent H. Elkins, Instrument Maintenance Group Manager R. Field, Civil Structural Engineer R. Fortenberry, Technical Support Supervisor J. Hamilton, Quality Engineering Manager D. Hatcher, Engineer Specialist
^J. Holland, Corrective Action Program Manager
- L. Martin, Site Quality Manager R. Miles, Modifications Manager
- J. Patrick, Operations Superintendent R. Pierce, Mechanical Maintenance Supervisor R. Proffitt, Nuclear Engineer, Licensing M. Burzynski, Acting Site Licensing Staff Manager
- A. Ritter, Engineering Assurance Engineer
- R. Rogers, Plant Support Superintendent
- M. Sullivan, Radiological Controls Superintendent S. Spencer, Licensing Engineer C. Whittemore, Licensing Engineer NRC Employees D. Terao, Chief, Engineering Branch, TVAPD/NRR T. Cheng, Senior Structural Engineer, TVAPD/NRR
- Attended exit interview Acronyms and initialisms used in this report are listed in the last paragraph.
2.
Operational Safety Verification (71707)
a.
Plant Tours The inspectors observed control room operations and reviewed the night order book, clearance hold order book, configuration log and TACF log.
No issues were identified with these specific log _
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During the inspection period the inspector reviewed the shift operator's daily log and noted several instances where single line entries were made with no supporting information included to detail the reason or rationale for the entry.
In addition, during the plant shutdown for Unit 2 refueling, no entries were made for such items as turbine trip, electrical swapover to off-site supply, load reduction rate, etc.
Operation supervisors discussed the program being implemented to upgrade the shift logs to eliminate these types of deficiencies with the inspector.
Subsequent to this discussion, the inspector found no examples of deficiencies similar to the above during shift log reviews.
The iicensee has exhibited substantial improvement in the documentation of control room activities following the ~ inspector's discussions with Operations Management on Shift Logs and an issue involving exiting a diesel generator LC0 (described in
. paragraph 3 as URI 327,328/89-02-01).
The inspectors also conducted discussions with control room operators, verified that proper control room staffing was maintained, observed shift turnovers, and confirmed operability of instruments-tion.
The inspectors verified the operability of selected emergency systems, and verified compliance with TS LCOs.
Tours of the diesel generator, auxiliary, control, and turbine buildings, were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibra-tions and plant housekeeping / cleanliness conditions.
The plant was observed to be clean and in adequate condition.
The inspectors walked down accessible portions of the following safety-related systems on Unit 1 and Unit 2 to verify operability and proper valve alignment:
Component Cooling Water System Emergency Gas Treatment System Upper Head Injection System (Unit 1)
No deviations or violations were identified.
b.
Safeguards Inspection In the course of the monthly activities, the inspectors 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 including: protected and vital area access controls; searching of personnel and packages; escorting of visitors; badge issuance and retrieval; and patrols and compensatory posts.
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In addition, the inspectors observed protected area lighting, and protected and vital area barrier integrity.
The inspectors verified interfaces between the security organization and both operations and
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maintenance.
Specifically, the Resident Inspectors:
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observed an emergency security plan drill which.took place on January 12, 1989.
The participants arrived at their respective stations within the required time period and resources appeared to be suited to meet the requirements of the emergency
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inspected security during outages
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observed site security management on several occasions making
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rounds in.the field and acting on security issues.
No violations or deviations were identified.
c.
Radiation Protection 1.
The inspectors observed HP practices and verified the implementa-
tion of radiation protection controls.
On a regular basis, RWPs-
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were reviewed and specific work activities were monitored to ensure the activities were being conducted in accordance with the applicable RWPs.
Selected radiation protection instruments were verified operable and calibration frequencies were reviewed. The following RWPs were reviewed in detail with no discrepancies noted:
RWP 89-1-009, Upper Containment RWP 89-2-207, Operations Inspection and Valve Alignment Inner and Outer Polar Crane Wall RWP 89-2-163, El 734 Auxiliary Building Transfer Canal Work 2.
During this inspection period the licensee experienced several periods of nigh airborne activity (Xenon and Iodine) in Unit 2 containment and the auxiliary building.
This condition resulted in several personnel contaminations, one auxiliary building evacuation and a negative impact on the outage schedule.
Management response at the plant manager level was quick and decisive.
However, first and second line managers were slow in developing an investigative plan to resolve the source of the airborne contamination and insufficient first line management activity in the field was a contributor to the length of time taken to implement an action plan.
On January 25, 1989, an eductor was installed to purge noble gases from the pressurizer to vent valve 1-68-594 which discharges into the ventilation clean-up system.
The discharge on the eductor was erroneously installed to discharge to the containment air return fans suction ducts in the top of the pressurizer enclosure.
Therefore, the eductor was connected via the containment air return ductwork to accumulator rooms no. 3 and 4 and two of the four steam generator enclosures.
When the eductor was placed in service, the noble gases purged from the pressurizer were distributed throughout the area causing the j
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containmentito:. be filled lwith aieborne contamination. -The situation was ~ discovered by 'the-licensee'and ' proper corrective f actions were ~ implemented.
No personnel exposure' rates were exce2ded.
'No violations or deviations were identified; With '. the exc'eption of the issue discussed in paragraph:2.c.2, positive trends were' identified in-the operational. safety verification area.
General conditions in the. plant were. improving, especially considering that one ' unit is in'a refueling outage. Radiation protection. and security:
are adequate to continue two unit operations.
'3.
Surveillance Observations and Review (61726)
Licensee activities :were ' directly observed / reviewed to ascertain that q
surveillance of safety-related systems and components was being conducted in accordance with TS requirements.
The inspectors verified that: testing was performed in. accordance with-
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- adequate procedures; test instrumentation was calibrated;:LCOs were met;
- test results met acceptance criteria requirements.and.were reviewed -by
. personnel. other than: the individual directing the test;-' deficiencies were
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~i testing were properly redewed and resolved by management' personnel; and system restoration was adwuate.
For completed tests, the inspector verified that testing fre Ancies were met and tests were performed by
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qualified individuals.
The.'following activities were observed / reviewed with no deficiencies identified except as noted:
SI-90.2, Revision 3, Reactor Trip /ESF Instrumentation Quarterly Functional Test (Racks 3 and 4).
SI-759, Revision 0, Testing and Setting of Main Steam Safety Valves.
g in Mode 1.
During the performance of this ASME Boiler and Pressure Vessel code related surveillance, the licensee identified several code safety valves that did not meet the test acceptance criteria.
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These valves (2-FCV-1-518, 524, 529, 531, 528, and 527) were j
dispositioned using test deficiencies, adjusted and then retested.
SI-102 M and SI-102 E/1.5Y, Diesel Generator (38 Months) Electrical Inspections i
IMI-99 RT N-41, Response Time Test Procedure for Power Range Neutron J
Flux Channel N-41 SI-673, Reactor Coolant System Level Verification Using Sightglass or Tygon Hose i
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SI-26.2A, Revision 20, Loss of Offsite Power with Safety Injection D/G 2A-A Containment Isolation Test.
The licensee encountered some problems during the performance of this SI which caused delays and
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Some of the delays were a result of conflicting work on equipment involved in the surveillance and others were caused by equipment failures.
In addition,. the test was aborted on one occasion and as a result, time expired on the eight-hour requirement -
to demonstrate operability of the remaining DGs, and Operations had to reperform SI-7.1, Revision 13, Diesel Generator AC Electrical Power Source Operability Verification.
On Jtnuary 21, 1989, a test deficiency was encountered during the perft,rmance of SI-26.2A.
The output voltage from the 2A-A diesel l
generator increased above that allowed by TS during the load shedding
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performance. This condition deficiency was later determined, in a TVA Quality Inspection Report (QIR), to be the result of an invalid test because the initial grid voltage was above that considered to be appropriate at the beginning of the test and the LC0 for an inoperable diesel was exited.
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After discussions with the NRC, the licensee requested a temporary waiver of compliance for TS surveillance req..srements 4.8.1.1.2.d.2 and 4. 8.1.1. 2. d. 3.
The temporary waiver was forwarded by letter
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(Liaw/Kingsley) dated January 26, 1989.
This letter was followed by an emergency TS change request and license amendments 99 to facility operating licenses DPR-77 and DPR-79, respectively.
Review of the final disposition of SI-26.2A and the process t erough which LC0 3.8.1.1 was exited by the Shift Operating Supervisor is identified as URI 327,328/89-02-01, Part 1.
No trends were identified in the area of surveillance performance during J
this inspection period.
The area of surveillance scheduling and manage-ment was observed to be aggressively addressed by the licensee and the completion of TS surveillance requirements was discussed at the highest
levels of the TVA onsite Nuclear Power organization.
No violations or deviations were identified.
4.
Monthly Maintenance Observations and Review (62703)
Station maintenance activities on safety-related systems and components l
were observed / reviewed to ascertain that they were conducted in accordance
with approved procedures, regulatory guides, inaustry codes and standards,
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and in conformance with TS.
The following items were considered during this review:
LCOs were met while components or systems were removed from service; redundant components were operable; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; procedures used were adequate to control the activity; troubleshooting activities were controlled and the repair
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L records accurately ' reflected the activities; ' functional testing and/or calibrations were performed prior-to returning components or systems'to service; QC records were : maintained; ' activities were. accomplished by qualified personnel; parts and materials used were properly certified;-
radiological controls were implemented; QC hold points were. established where required and were observed; fire '. prevenLion ' controls were implemented; ' outside contractor force activities' were controlled _in accordance :with the approved QA program;- and housekeeping Lwas actively pursued.
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a.
. Temporary Alterations (TACFs)
The following TACFs-were reviewed:
1-88-22-500 Jnd 2-88-2019-500, Insta11' an Aircraft Cable on the Bailey Meter Cabinets'(see paragraph 11)
No violations or deviations were identified.
b.
Work Requests The following work requests were reviewed:
WR B783400, Feedwater Seal Injection Pump Repair.
This WR directed the replacement af -the 1A seal injection pump motor and a damaged pump coupling.
The review included drawings 45N777-5 an ! 45N1752,
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and procurement nrder 5889007484.
No deficiencies were identified.
-WR B283687.and 8283827, Source Range Channels A and' B' Repair.
The-corrective action identified by the ' licensee in its outage maintenance and troubleshooting plan was ieviewed by the inspector and found to be adequate.
The plan appeared to have been completed only after it was requested by the NRC inspector.
The licensee is required to have two operable source range channels in' order to enter Mode 6.
This action plan may impact the licensee's outage schedule if additional corrective maintenance on the source range channel is required.
WR 8234785, Fuel Handling Upender Repair.
No violations or deviat1ons were identified.
c.
Ho)d Orders The ' inspectors reviewed the following H0s to verify compliance with AI-3, Revision 38, Clearance Procedure, and that the H0s contained adequate information to properly isolate the affected portions of the system being tagged.
Aciditionally the inspectors verified that the required tags were installed on the affected equipment.
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Hold Order Equipnient H0 1-89-86
"A" Main Feedwater Pump H0 2-89-60 Turbine Driven Auxiliary Feedwater Pump H0 2-89-013 ERCW Isolation Valve Cables to the Containment Lower Compartment Coolers H0 2-89-019 Seal Table Radiation Monitor H0 2-89-024 Fuel Handling Upender H0 2-89-182 RHR Flow on the A CCS Heat Exchanger.
This clearance was supported by safety evaluation USQD 89-001, Revision 1.
No violations or deviations were identified.
d.
Work Plans, Field Changes, Design Changes The following work plans, field changes, and designs changes were reviewed:
Work Plan, WP5198-02, was reviewed while activities were in' progress to remove ground jumpers _in the unit 1 computer input cabinets, racks 26 and 27.
These jumpers had been connected between the loop signal lead and the cabinet ground to eliminate computer input ground noise.
The inspector reviewed the work plan and determined that quality control inspections were required and had been complied with for the safety related work.
No deficiencies were noted.
DCR 2586 -
Air Suction from Containment.
FCR 6961 -
Differential Pressure Setpoint for PI-32-82 and 85.
DCR 2746 -
AFW to Auxiliary Air System Accumulator.
This DCR was written to resolve SCR-SQN-MEB-86-133.
No violations or deviations were identified.
5.
Management Activities in Support of Plant Operations TVA management activities were reviewed on a daily basis by the NRC inspectors.
Resident inspectors observed that planning, scheduling, work control and other management meetings were effective in controlling plant activities.
First line supervisors appear to be knowledgeable and involved in the day to day activities of the plant.
First line supervisor involvement in the field has been observed with the exception of the airborne activity corrective action process previously mentioned in paragraph 2.
With the exception of the airborne activity issue mentioned above, management response to those plant activities and events that occurred during this inspection period appeared timely and effective. An example of this management action was the professional approach to the immediate operability issue associated with the seismic qualifications of
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iilstruments modified under TACFs 1-88-22-500 and 2-88-2019-500
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(paragraphs l4.a~'and 11).
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-Site Quality Assurance Activities in Support of. Operations
- During. the inspection period, the site QA staff performed audits, inspections, and reviews.
These issues were reviewed by the. inspector,and.
found to be. adequately resolved by the licensee.
The following audits were performed:
l 1.7-1 Conduct of Testing 1.11 Operating Logs 1.23-1
, Preparation ~for Refueling Activities 1.23-2 Refueling Activities - Fuel Handling In addition to the above audits, the inspector discussed several recent issues with the Site QA-Manager and the QA Surveillance Group Manager.
The inspector determined that QA involvement in these issues was almost g
non-existent.
The Site QA Manager stated that he and the Plant Manager had reached an agreement on notification of plant events and participation with the Plant Operation's Review Staff in the investigation of plant issues.
The licensee committed to completely implement this agreement prior to June 1, 1989.
This appeared to be acceptable corrective action.
7.
NRC. Inspector Follow-up Items, Unresolved Items, Violations, Bulletins (92701, 92702)
(Closed) P2187-02, Regarding Follow-up On Defective MIS-5 Indicating Fuses.
By letter dated October 29, 1986, TVA reported an existing problem with MIS-5 actuating fuses supplied by Bussman under the requirements of 10 CFR 21.
The identifying event was reported in LER 327/86-045.
A report-update was issued by a letter dated September 16, 1987.
On July 20, 1987, TVA submitted LER 327/87-030 on Littlefuse Incorporated, j
FLAS-5 fuses, which also exhibited defects in lots two and three.
These
issues were reviewed by the NRC and published in Information Notice 87-62 on problems with indicating type fuses.
LER 86-45 was reviewed by the inspector and closed in IR 327,328/87-76
. with one issue remaining open on branch circuit fuses.
The branch circuit-fuse (86-57-01) was closed prior to the restart of Unit 2 in NRC
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inspection report 327,328/88-19. LER 87-030 was also reviewed and closed
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in IR 327,328/88-19.
TVA replaced all MIS-5 fuses and all FLAS-5 fuses from lot's two and three that were being used in safety related circuits prior to the restart of the respective units.
q The inspector reviewed the above referenced letters and the Information Notice and determined that no issues were discussed that were not resolved
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in irs' 327,328/87-76 and 327,328/88-19. Therefore, Part 21 Item 327,328/P2187-02 is closed.
(Closed) VIO 327,328/88-27-01, Long Term Corrective Action For Reactivity Changes.
The' inspector determined that TVA had failed ' to implement permanent corrective actions for events described in LER 87-078 involving reactivity changes prohibited by'TS.
In IR 327,328/88-27, the inspector reviewed and determined 'that the TVA corrective actions for the ' violation were acceptable.
In addition, NRC management discussed three problem areas associated with the issue in a letter dated July 7, 1988.
These areas were:
The Condition Adverse to Quality Report related to these events
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specified inadequate corrective action; was incorrectly closed based' on a temporary procedure change; and, did not require a root cause or recurrence control.
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~ The. Plant Operations Review Staff was apparently not knowledge-able of the corrective action status or actual actions accomplished at the time Revision 1 to LER 327/87-078 was prepared and issued.
The Corporate Commitment Tracking System closure procedure did
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not appear to contain adequate controls to assure that proper and complete actions had been taken prior to closure of the tracking item.
TVA responded to these areas along with the violation response and stated that an effective corrective action program and reliable reporting program were in place at Sequoyah.
TVA addressed each of the areas as follows:
The treatment of the subject CAQR was based on an inappropriate
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TVA interpretation of the definition of positive reactivity changes as stated in the TS.
Based on TVA's initial interpreta-tion the possibility of the situation ever existing again was remote.
Therefore, a. temporary procedure change that allowed administrative control over chemical additions was considered acceptable corrective action.
TVA surmized that the CAQR process was not at fault in this area.
TVA believes this to be an isolated case resulting from
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miscommunication and not indicative of program weaknesses.
P0RS engineers have been directed to verify that corrective actions have been adequately and correctly described when writing LERs.
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TVA discussed the controls over the CCTS and stated that the
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lead coordinator for the commitment is responsible for closing I
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the commitment.
Therefore, the commitment was closed based on the discussion in number 1 above.
The inspector reviewed the licensee's response and determined the response and corrective action to-be adequate and generally agree with the conclusions.
Additionally, during the restart effort, plant reporting, the CAQR process and the CCTS were all reviewed and. determined to be adequate by the NRC restart and operational readiness teams.
Therefore, VIO 327,328/88-27-01 is closed.
3.
Licensee Event Report Followup (92700)
UNIT 1 (Closed) LER 327/88-032, Calibration of Auxiliary Building Vent Radiation Monitor Resulted in an Auxiliary Building Isolation Due to Procedural Inadequacy.
Unit 1 experienced an ABI on September 3,1988 at 1:30 p.m., while the unit was in mode 5.
Before the event, at 8:04 a.m.
EDT, instrument maintenance technicians were performing SI-83, Channel Calibration for Radiation Monitoring System, for the C Channel of the Auxiliary. Building Vent Radiation Monitor, 0-RM-90-101.
The SI required handswitch 0-HS-90-136A3 to be placed in the 101C position to prevent the output of the C channel from causing an ABI during calibration. At 11:54 a.m.,
chemistry personnel placed the auxiliary sampling equipment in service to satisfy TS requirements for an inoperable radiation monitor.
After the instrument mechanic. completed the calibration of the radiation monitor, SI-83 required that the charcoal filters be reinstalled.
TI-16, Sampling Methods, which is used to accomplish installation of the charcoal filter, instructed operations personnel that changing the filter could result in an ABI and recommended that the B channel of 0-RM-90-101 be blocked while changing filters.
As a result, the C was unblocked to allow the B channel
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to be blocked.
The next section of SI-83 was for verification of the l
radiation indicator and the radiation recorder by step increasing the trip reference voltage of the radiation monitor.
At 1: 38 p.m.
, during the verification, the trip setpoint of the radiation monitor was exceeded and with handswitch 0-HS-90-136A3 set to block the B channel, the actuation of the C channel caused an ABI.
The root cause of this event was that the steps necessary to be completed to continue performance of SI-83 after installing the charcoal filters did not take into account the actions required by TI-16.
To prevent recurrence of this event, the licensee revised SI-83 to include a step to remove the control fuses when performing calibrations of l
0-RM-90-101.
In addition, a design change is to be implemented as an enhancement to provide a handwitch with a position to eliminate the need l
for removing the control fuses for performance of the SI.
The design change had a desired completion date of June 6, 1989.
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1 The inspector reviewed the above and found the corrective actions portaining to the revision of SI-83 and the proposed enhancement modification to be adequate.
This item is closed.
UNIT 2 I
(Closed) LER 328/88-041, Inadequate Vendor Document Control Resulted In Insufficient Seismic Qualification of Instrument Cabinets Containing Class 1E Devices.
On December 9,1988, TVA identified that instrument cabinets supplied by Bailey Meter Company did not meet seismic qualification requirements.
The seismic qualification of the cabinets required that two restraint bars be installed on each row of instrument modules in the cabinets.
Instead the cabinets were installed with only one restraint bar on each row of modules.
i Immediate corrective action consisted of installing a 3/64 inch aircraft cable across the front face of the instrument modules utilizing a TACF, 2-88-2019-500.
The incpectors reviewed the seismic qualifications of the Bailey Modules following the implementation of the TACF.
The USQD associated with the TACF, required by 10 CFR 50.59, stated that the seismic qualification of the modules was based on the retaining clip restraining the verticle motion of the Bailey instrument modules, the panel cutout and a rear guide restraining the module movement in the horizontal direction, and the aircraft cable keeping the clip and the module engaged to prevent the module from striking the panel door.
The inspector noted that the restraining clip was disengaging as the module moved forward within the confines of the aircraft cable.
10 CFR 50, Appendix A, Criterion 2, Design Bases for Protection Against Natural Phenomena, states that-I Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes...
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One method of qualification is to maintain the tested configuration.
The aircraft cable was not part of the tested configuration.
The modules had two restraining bars installed during the shaker table test.
A second i
method to establish the qualification of the components is to perform a
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safety analysis.
Because the analysis for seismic qualification dictated that the retaining clip remain in contact with the module, the inspector determined that the modules were not seismically qualified, and; therefore, were inoperable.
The licensee entered the action statement for LCO 3.0.3 at 5:00 p.m.
on February 1,1989 for Unit 1 because of this condition.
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The operators exited the LC0 at 7:45 p.m. based on a review performed by the TVA Division of Nuclear Engineering that determined the equipment was not required for safe shutdown and that the module required for accident mitigation was not required to operate during a seismic event.
The module contained a CS recirculation valve function that did not affect the operability of the CS System and an EGTS differential pressure function that already had a compensatory action associated with it.
The inspectors will further review this issue on the basis of the adequacy of the DNE USQD and TACF design.
Additionally, the licensee action plan to address the generic implications, which is' to be completed March 15, 1989, will be reviewed following its issuance.
This item will be tracked as URI 327,328/89-02-02.
This LER is closed.
9.
Drawing Control System Verification (Resident Action Item 88-01) (37702, 39702)
The specific areas of review identified by Resident Action Item 88-01 are discussed in order in the following paragraphs.
A.
Review of Critical Drawings 1.
The list of Critical Drawings is maintained by AI-25. Part II, Revision 8, Drawing Deviations.
2.
The inspector reviewed a sample of approximately 30 critical drawings in both the control room and the 1SC for legibility and current revision status.
All drawings reviewed were legible and revision status was correct.
3.
Operators were able to demonstrate that the current revision status was correct by means of the licensee's audit program for drawing status and the requirement to have the drawing issued prior to designating any work plan " Field Complete".
This effectively captures all plant modifications reflected in the Critical Drawings.
4.
The process for incorporating plant changes into the drawings prior to completing a change minimizes the potential for impacting the decision-making process during an emergency.
5.
New revisions to drawings do not readily identify the scope of the drawing change, but the change is required to undergo review by the cognizant engineer prior to its implementation.
6.
Revised drawings are required to be issued within 5 days of any identified deviation and prior to returning a system to service following modifications.
This requirement obviates the need to impose a limit on the number of outstanding changes prior to revising a drawing.
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7.
During this inspection period the licensee-completed validation
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of system logic prints and returned.them to the control room.
This was the culmination of significant TVA drawing improvement actions and NRC inspection effort-to assure that operators have correct logic diagrams to assist in wor, planning and system operability determinations.
B.
Review of the Drawing Change Process 1.
The procedure for updating the critical drawings is AI-25, Part I, Revision.
2.
The critical drawings receive priority over other drawings by means of a 5 day update requirement versus a 30 day ' update requirement for non-critical drawings.
3.
An annual audit is required for all critical drawing files.
4.
AI-25 implements the procedure for correcting drawing deviations.
5.
A screening of drawing deviations is performed by the STA for both operability and safety review.
6.
Control room drawings are typically updated within 2 days (update within 5 days required) of identification of a drawing deviation.
7.
Issuance of the revised drawing prior to completion of a Work Plan ensures Operations personnel have updated drawings prior to equipment turnover or return to operable status.
8.
For partially complete field changes held open longer than 30 days, AI-19, Part II, Revision 33, Plant Modifications: After Licensing, requires the reisssuance of a drawing reflecting the incomplete status of systems and equipment changes.
During the time prior to reissuance of the drawing, system and equipment status is tracked via the Configuration Control Log.
C.
As-Built Verification I
1.
The resident staff walked down Auxiliary Control Air and identified only minor drawing deficiencies which were discussed with licensee management (see paragraph 14).
10.
Preparation for Refueling (60705)
Administrative controls for refueling operations were implemented by the licensee prior to the refueling outage to insure that a clear definition of the lines of supervision, shift manning requirements, qualifications of
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identified in this review.
Administrative controls for plant conditions during refueling pertaining j
to water level control and containment integrity were reviewed and determined to be acceptable.
Implementation of plant controls during the
pre-outage and outage activities were reviewed by the inspector.
The site i
l management, notably the plant manager, was extremely active and involved in a positive manner in each of the outage activities.
Problem areas and areas where safety of personnel and the environment were an issue received special attention.
The inspector reviewed procedures performed for the receipt, inspection, and storage of new fuel for refueling outage activities.
In addition, this review included procedures for the fuel handling, transfer, core l
""ification, and handling and inspection of other core internals.
The
' ions of the completed instructions reviewed by the inspector we e i
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at Nrmined to be acceptable.
A formal assignment of accountability and activities was made to individuals in responsible positions for the outage work.
Daily meetings were held to discuss progress and problem areas.
11.
Refueling Activities (60710) (50095)
a.
Pre-Refueling Activities The licensee has implemented controls for the conduct of refueling operations and for establishing and maintaining plant configuration in accordance with TS and approved procedures.
These administrative controls, various completed TS surveillance, and fuel storage verification documents have been determined to be acceptable by the licensee for the various surveillance performed on the refueling equipment.
The inspector audited the licensee's review with no
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concerns identified.
The inspector verified that the licensee conducted a safety evaluation to ascertain that the reload core posed no unroiewed safety question or change to the TS. This was accomplished by a Reload Safety Evaluation, Sequoyah Unit 2, Cycle 4, performed by Westinghouse Corporation and evaluated by the licensee.
Hanpower pro.jections were determined prior to the outage and an attempt was made to have these craftsmen in reserve.
However, not all were available when needed, specifically the laborers, electricians, and asbestos workers since initially many of the available craftsmen did not meet the licensee's qualification criteria because (1) background reference checks had not been completed (2) acceptable GET testing results were not met and/or (3) fitness for duty results were not acceptable.
The licensee has completed actions to assure needed craftsmen are promptly availabl (
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The status of materials required for outage maintenance and modification activities was monitored by the licensee and updated on a daily basis to insure that on-going work activities would progress as scheduled.
Material deliveries which appeared to jeopardize schedules received daily management attention and direction to eliminate schedule problems.
A water management program was devised and implemented to insure that water needed for the various outage activities would be available when needed and that storage capacities were acceptable.
b.
Review of Events Associated with Refueling Activities During the process of depressu-izing the nitrogen accumulator in the Upper Head Injection system, the outside area and equipment located in that area adjacent to the UHI became contaminated from a spray of water residue from the accumulator.
A drain valve and temporary hose was utilized for the venting operation per AI-58, 85 normal Alignment Or Evolution Procedure For Plant Equipment, whicn allows a hand-written procedure to be used for operations which do not have an approved procedure.
50I-87-1, Upper Head Injection. Accumulator, is an approved procedure that governs the venting of the UHI accumulator from a connection at the accumulator top.
The operations staff made a _ decision to use another vent path, off the bottom of the accumulator, because the normal path contains a pressure breakdown orifice which substantially increases the time to vent the accumulator.
The process which should have been used is the Instruction Change Form (ICF) to the approved procedure.
When the venting process began, water started spraying from the hose attached to the bottom drain connection.
The hose had been routed through an adjacent door to an area outside the Auxiliary Building.
The hose was not tied down and secured, and began whipping around when the venting started, spraying water around the general area.
An ASOS involved in the process saw the water spraying from the hose and had the vent path isolated.
Approximately 100 gallons of slightly contaminated water is estimated to have been discharged.
The area was decontaminated and the hose was placed inside a barrel to complete the venting process.
This issue will be reviewed as part 2 of URI 327,328/89-02-01, Diesel Generator LC0 and UHI Issues.
12.
(Closed) TI-2515/95 88-04, Inspection for Verification of BWR Recirculation Pump Trip Multi-Plant Action Item C-02.
The inspector reviewed this temporary instruction and determined it is not applicable to Sequoyah Units 1 or 2.
This item is close _
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(Closed) TI2515/96 88-04', Inspection for Verification of Mark I 'BWR Drywell Vacuum Breaker Modifications Multi-Plant Action Item D-20.
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The inspector reviewed this test instruction and determined it is not-applicable to Sequoyah Units 1 or 2.
This item is closed.
14.
Detailed System Walkdown (71710)
A detailed walkdown of the Auxiliary Control Air System was conducted in order to confirm operability of the system.
During this process several outstanding work items and minor deficiencies were identified that were discussed with the system engineer and the system engineering group manager. These work items were:
Replacement of pressure switch 32-82 (WR B 271606)
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Duct Tape on pressure indicator 0-PI-32-66
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Leak on the aftercooler (WR B 271621)
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'011 level alarm availability (WR B271620)
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Moisture trap air leak (WR B271622)
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High differential pressure on the after filter (WR B280637)
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Inconsistent oil levels between the. A and 2 Auxiliary Air
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compressors. One machine had an oil level at the mid position of the visual wind ~.;.
This appeared to be consistent with~ the level mark.
The other machine was filled above the visual window.
This was discussed with the system engineers 'and determined not to be an operability problem.
Several solenoids for system valves were noted to be abnormally hot.
Several posted WR tags were not current in the WR system (WRs
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B285679, B264352 and D753412).
Separated instrument electrical. conduit.
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Electrical conduit was pulled apart and was exposed.
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Small bore piping was bent, dented, and was abraiding the frame
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of one of the air compressors
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The licensee is taking corrective action on the above issues.
There was no appearance that the operability of the Auxiliary Control Air System was affected.
No violations or deviations were identified and the inspector had no further questions.
15.
CCW Heat Exchanger Replacement (37702)
The inspectors reviewed the detailed analyses of the CCW and emergency raw cooling water (ERCW) piping associated with the interim period when the i
installation and removal of the CCW heat exchangers were being implemented as well as the analyses of the final piping configuration.
The replacement of the "B" heat exchanger undse ECN L6429 was selected for j
audit.
The new CCW heat exchangers are manufactured by Alfa-Laval. The replacement of the
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implemented in the succeeding two refueling outages.
In addition, the -
inspectors reviewed the seismic adequacy of the component supports for the replacement heat exchangers as documented in the final design l-configuration.
No interim supports were used on the replacement heat i
exchangers that would affect the seismic capability uf the CCW and ERCW piping in operation.
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The detailed analyses provided to the inspectors contained a comprehensive evaluation of the CCW system to justify continued operation of Unit I
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while the modifications were being implemented.
The details of the analyses demonstrated evidence of prior planning and control of activities during modifications.
The engineering records were extensively documented and readily available for staff audit.
The licensee exhibited a thorough understanding of the technical analyses and clearly explained the rationale for allowing continued operation of Unit 1 during the CCW heat exchanger change out.
No violations or deviations were identified.
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16.
Review of IE Bulletin 85-03, Motor Operated Valve Common Mode Failures (92703)
An in office review of Action Item e. of Bulletin 85-03, " Motor-0perated Valve Common Mode Failures During Plant Transients Due to Improve Switch Settings," was conducted by NRC Region II.
As requested the licensee
. identified the selected safety-related valves, the valves' maximum
.i differential pressures and the licensee's program to assure valve
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operability in their letters datec' fiay 12, 1986, September 11, 1986, and November 10, 1986.
Review of these responses indicated the need for additional information which was contained in NRC letter dated February 22, 1988.
Review of the licensee's April 22, 1988, response to this request for additional information indicates that the licensee's selection of the applicable safety-related valves to be addressed and the valves' maximum differential pressures meets the requirements of the bulletin end that the program to assure valve operability requested by Action Item e. of the bulletin is now acceptable, with the exception of providing justification in cases where testing with the exception of providing justification in cases where testing with maximum differential pressure cannot practicably be performed.
Prior to final acceptance, differential pressure testing will be examined more closely by the NRC.
The results of the inspections to verify proper implementation of this program and the review of the final response required by Action Item f. of the bulletin will be addressed in additional inspection reports.
17.
Exit Interview (30703)
The inspection scope and findings were summarized on February 5,1989, with those persons indicated in paragraph 1.
The Senior Resident Inspector described the areas inspected and discussed in detail the inspection findings listed below.
The licensee acknowledged the
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inspection findings and ' did not identify" as proprietary 'any of, the
- material reviewed by.the inspectors during the inspection.
- The licensec committed to: formally establish and fully implement a process to notify-QA of plant evolution reviews conducted by the P0RS staff by -
June 1,1989 to assure appropriate QA involvement.
No, violations', deviations, or. inspector follow-up items were identified.
Two' unresolved items,were identified.
327,328/89-02-01, Diesel Go.crator LC0 and UHI Issues.
327,328/89-02-02 Bailey Meter Seismic-Qualifications and1 Safety-l Evaluation During the reporting period, frequent discussions were held with the Site q
Director, Plant Manager and other managers concerning inspection findings.
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16. 'tist ofLAcronyms and Initialisms Auxiliary Building Gas Treatment System-ABGTS
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ABI Auxiliary Building Isolation
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Auxiliary Building Secondary Containment Enclosure AFW Auxiliary Feedwater
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Administrative Instruction A0I Abnormal Operating Instruction
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Auxiliary Unit Operator
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ASOS Assistant Shift Operating Supervisor
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American Society of Testing and Materials Boron Injection Tank BIT'
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Browns Ferry Nuclear Plant
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C&A
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Control and Auxiliary Buildings CAQR Conditions Adverse to Quality Report
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Component Cooling Water System CCS
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Centrifugal Charging Pump CCP
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CCTS
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Corporate Commitment Tracking System Code of Federal Regulations-CFR
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COPS Cold Overpressure Protection System
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Critical Structures, Systems and Components CSSC
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Chemical and Volume Control System Containment Ventilation Isolation CVI
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Direct Current Design Change Notice DCN.
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Diesel Generator Division of Nuclear Engineering DNE
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Engineering Change Notice ECN
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'ECCS
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Emergency Core Cooling System Emergency Diesel Generator EDG
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EI Emergency Instructions
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Emergency Notification System L
E0P Emergency Operating Procedure
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Emergency Operating. Instruction
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ERCW-Essential Raw Cooling Water.-
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ESF.
FCV-
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Engineered Safety Feature
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Flow Control Valve FSAR.
Final. Safety Analysis Report
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GDC General Design Criteria
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GOI General Operating Instruction
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GL Generic. Letter
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HVAC Heating Ventilation and Air Conditioning
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HIC Hand-operated Indicating Controller
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Hold' Order HP
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Health Physics ICF'
~ Instruction Change Form
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IDI
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Independent Design Inspection IN NRC Information Notice
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IFI
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Inspector Followup Item IM Instruma.t Maintenance
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IMI'
Instrument Maintenance Instruction
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IR Inspection Report-
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KVA Kilovo't-Amp
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KW Kilowatt
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KV Kilovolt
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LER Licensee Event Report
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LCO Limiting Condition for Operation
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LIV Licensee Identified Violation
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Loss of Coolant Accident MCR Main Control Room-
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MI Maintenance Instruction
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MR Maintenance Report
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MSIV Main Steam Isolation Valve
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NB
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NRC Bulletin NOV Notice of Violation
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NQAM Nuclear Quality Assurance Manual
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NRC
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Nuclear Regulatory Commission OSLA
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Operations Section Letter - Administrative OSLT
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Operations Section Letter - Training OSP Office of Special Projects
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Precautions, Limitations, and Setpoints-PM Preventive Maintenance
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PPM Parts Per Million
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PMT Post Modification Test
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Plant Operations Review Committee P0RS
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Plant Operation Review Staff i
PRO Potentially Reportable Occurrence
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Quality Assurance QC Quality Control
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QIR Quality Inspection Report
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RCDT Reactor Coolant Drain Tank
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RCP Reactor Coolant Pump
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RG Regulatory Guide
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Radiation Monitor
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R0
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Reactor Operator RPI.
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Reactor Protection Instrumentation
. Revolution Per Minute RPM
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Resistivity Temperature Device Detector
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Radiation Work Permit RWST
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Refueling Water Storage Tank SER
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Safety Evaluation Report SG Steam Generator
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SI Surveillance Instruction
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SMI Special Maintenance Instruction
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SOI
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System Operating Instructions SOS
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Shift Operating Supervisor SQM
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Sequoyah Standard Practice Maintenance SQRT Seismic Qualification Review Team
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SR
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Surveillance Requirements SR0 Senior Reactor Operator
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Safety Systems Outage Modification Inspection SSQE
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Safety System Quality Evaluation STA
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Special Test Instruction
'TACF Temporary Alteration Control Room
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TAVE Average Reactor Coolant Temperature
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Turbine Driven Auxiliary Feedwater TI Technical Instruction
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TREF Reference Temparats!ra
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TROI Tracking Open Items
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Technical Specifications TS
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Tennessee' Valley Authority UHI Upper Head Injection
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U0 Unit Operator
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Unresolved Item USQD Unreviewed Safety Question Determination
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VDC
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Volts Direct Current VAC Volts Alternating Current
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WCG
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Work Control Group WP Work Plan
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WR Work Request
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