IR 05000327/2011006
| ML111920159 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/08/2011 |
| From: | Nease R NRC/RGN-II/DRS/EB2 |
| To: | Krich R Tennessee Valley Authority |
| References | |
| IR-11-006 | |
| Preceding documents: |
|
| Download: ML111920159 (35) | |
Text
July 8, 2011
SUBJECT:
SEQUOYAH NUCLEAR PLANT - NRC TRIENNIAL FIRE PROTECTION INSPECTION REPORT NO. 05000327/2011006 AND 05000328/2011006
Dear Mr. Krich:
On February 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Sequoyah Nuclear Plant, Units 1 and 2. The enclosed inspection report documents the inspection results, which were discussed with Mr. M. Skaggs, Site Vice President, and other members of your staff. As a result of post-inspection analysis of the inspection findings by the NRC and your staff, the nature of the results changed from that discussed on February 11, 2011, and these changes were discussed by telephone with Mr. G.
Cook, Site Licensing Manager, and others on March 25, 2011, and again with Mr. M. Skaggs, and others on June 13, 2011. On July 8, 2011, a final exit meeting was conducted to discuss the results of this inspection with Mr. G. Cook, and other members of your staff.
The inspection examined activities conducted under your licenses as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your licenses. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The report documents two NRC-identified findings of very low safety significance (Green) which were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report.
However, because of the very low safety significance and because the findings were entered into your corrective action program, the NRC is treating the violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC, 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-001; and the NRC Resident Inspector at the Sequoyah Nuclear Plant.
In addition, if you disagree with the cross-cutting aspects assigned to the findings in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, RII, and the NRC Senior Resident Inspector at the Sequoyah Nuclear Plant.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS)component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov./reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Rebecca L. Nease, Chief
Engineering Branch 2
Division of Reactor Safety
Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79
Enclosure:
Inspection Report 05000327/2011006, 05000328/2011006 w/Attachment: Supplemental Information
REGION II==
Docket Nos.:
50-327, 50-328
License Nos.:
Report Nos.:
05000327/2011006, 05000328/2011006
Licensee:
Tennessee Valley Authority (TVA)
Facility:
Sequoyah Nuclear Plant, Units 1 and 2
Location:
Soddy-Daisy, TN 37379
Dates:
January 24 - 28, 2011 (Week 1)
February 7 - 11, 2011 (Week 2)
Inspectors:
J. Dymek, Reactor Inspector
R. Fanner, Reactor Inspector
N. Merriweather, Senior Reactor Inspector
L. Suggs, Reactor Inspector
M. Thomas, Senior Reactor Inspector (Lead Inspector)
Accompanying E. Bowman, Senior Project Manager, Office of Nuclear Personnel:
Reactor Regulation (Week 1 only)
J. Montgomery, Reactor Inspector (Week 2 only)
Approved by:
R. Nease, Chief Engineering Branch 2 Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000327/2011-006, 05000328/2011-006; 01/24 - 28/2011 and 02/7 - 11/2011; Sequoyah
Nuclear Plant, Units 1 and 2; Fire Protection.
This report covers an announced two-week triennial fire protection inspection composed of five regional inspectors. Two Green non-cited violations were identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, ASignificance Determination Process@ (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after U.S. Nuclear Regulatory Commission (NRC) management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
- Green.
The inspectors identified a non-cited violation of Sequoyah Operating License Conditions 2.C.(16) and 2.C.(13) for Units 1 and 2, respectively, for failure to establish compensatory measures for an obstructed sprinkler system. Specifically, scaffolding installed in auxiliary building fire area FAA-054/Room A01 was in a configuration which obstructed sprinkler heads A198 and A208. The licensee entered this issue into the corrective action program as Problem Evaluation Report 321911 and implemented compensatory measures (fire watches) in accordance with the approved fire protection program.
This finding was determined to be a performance deficiency because the licensee did not provide the required compensatory measures (fire watch) for sprinkler heads that were obstructed or blocked by scaffolding. This finding was more than minor because it affected the reactor safety mitigating systems cornerstone attribute of protection against external factors (i.e., fire) and it affected fire protection defense-in-depth strategies involving suppression systems. Failure to provide compensatory measures for obstructed sprinkler heads A198 and A208 would have reduced the licensees ability to quickly extinguish a fire in the area. The inspectors evaluated this issue in accordance with Inspection Manual Chapter (IMC) 0609, Appendix F,
Fire Protection Significance Determination Process, and determined that this finding was of very low safety significance (Green). The finding category of fixed fire protection systems was assigned, based upon that element of the plant fire protection program being impacted. The inspectors assigned a low degradation rating that reflected the severity of the observed deficiency. This rating was based upon meeting the criteria described in IMC 0609, Appendix F, Attachment 2 for fixed fire detection and suppression degradation. Specifically, less than 10% of the sprinkler heads were non-functional, there were functional heads within 10 feet of the combustibles of concern and the system was nominally code compliant. This finding was determined to have a cross cutting aspect in the Human Performance Area,
Work Practices Component, because the licensee failed to define and effectively communicate expectations regarding procedural compliance and requirements for personnel to follow procedures (H.4.(b)). (Section 1R05.03)
- Green.
The inspectors identified a non-cited violation of Operating License Conditions 2.C.(16) and 2.C.(13), for Units 1 and 2 respectively, for failure to install the automatic suppression system (sprinkler system) in the auxiliary building corridor 690 foot elevation, in accordance with applicable National Fire Protection Association (NFPA) Standard No. 13, Automatic Sprinkler Systems. Specifically, NFPA 13-1975 required sprinklers to be installed within 12-inches of the ceiling. Portions of the auxiliary building sprinkler system were installed greater than 12-inches below the ceiling. As a result, the actuation of the fusible link type sprinklers would have been slower than originally intended after fire ignition. The licensee entered this issue into the corrective action program as Problem Evaluation Report 147467 and implemented compensatory measures (fire watches) in accordance with the approved fire protection program.
This finding was determined to be a performance deficiency because the licensee did not locate the sprinkler heads according to the applicable Code of Record for the facility. The finding was more than minor because it was associated with the reactor safety mitigating systems cornerstone attribute of protection against external factors (i.e. fire). It affected the objective of ensuring the reliability and capability of systems that respond to initiating events. The inspectors evaluated this issue in accordance with Inspection Manual Chapter (IMC) 0609, Appendix F, Fire Protection Significance Determination Process, and determined that this finding was of very low safety significance (Green). Pursuant to IMC 0609, Appendix F, the finding category was fixed fire protection systems. The finding was of very low safety significance because of the limited number of sprinkler heads improperly installed, the proximity of the existing sprinklers to combustibles of concern, and the suppression system was nominally code compliant for all other aspects of design and installation. The inspectors determined that there was no cross-cutting aspect associated with this finding because the condition has existed since initial plant licensing and was not reflective of present performance. (Section 4OA5.1)
Licensee Identified Violations
A violation of very low safety significance that was identified by the licensee has been reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the licensees corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R05 Fire Protection
This report documents the results of a triennial fire protection inspection (TFPI) of the Sequoyah Nuclear Plant (SQN) Units 1 and 2. The inspection was conducted in accordance with NRC Inspection Procedure (IP) 71111.05T, Fire Protection (Triennial),issued September 30, 2010. The objective of the inspection was to review a minimum sample of 3 risk-significant fire areas (FAs) to verify implementation of the fire protection program (FPP) and to verify site specific implementation of at least one B.5.b mitigating strategy as well as the storage, maintenance, and testing of B.5.b mitigating equipment.
The three FAs chosen for review were selected based on available risk information as analyzed onsite by a senior reactor analyst from Region II, data obtained in plant walk downs regarding potential ignition sources, location and characteristics of combustibles, and location of equipment needed to achieve and maintain safe shutdown (SSD) of the reactor. Other considerations for selecting the FAs were the relative complexity of the post-fire SSD procedure, information contained in FPP documents, and results of prior NRC TFPIs. In selecting the B.5.b mitigating strategy sample, the inspectors reviewed licensee submittal letters, safety evaluation reports, licensee commitments, B.5.b implementing procedures, and previous NRC inspection reports. Section 71111.05-05 of the IP specifies a minimum sample size of three FAs and one B.5.b implementing strategy for addressing large fires and explosions. This inspection fulfilled the requirements of the IP by selecting three FAs and one B.5.b mitigating strategy. The three FAs chosen were:
- Fire Area FAC-012 / Room C04, Unit 2 Auxiliary Instrument Room
- Fire Area FAA-054 / Room A01, Corridor (Unit 1 area)
- Fire Area FAA-081 / Room A24, 6.9KV Shutdown Board Room B (Units 1 and 2)
For each FA selected, the inspectors evaluated the licensees FPP against the applicable NRC requirements. Specific licensing basis documents reviewed by the inspectors are listed in the Attachment.
.01 Protection of Safe Shutdown Capabilities
a. Inspection Scope
The inspectors reviewed the licensees post-fire SSD analysis and abnormal operating procedures (AOPs) to verify the ability to achieve hot and cold plant shutdown from the main control room (MCR) with or without the availability of offsite power for a postulated fire in FAs FAA-054 or FAA-081 of the auxiliary building. The inspection activities focused on those systems and components that were required for SSD and provided the functions for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation, and related support systems.
The inspectors reviewed those portions of the licensees Fire Protection Report (FPR)and Fire Hazards Analysis (FHA) Calculation SQN-26-D054/EPM-ABB-IMPFHA which described the licensees SSD analysis for a fire in the selected fire areas. The SSD analysis identified both affected and available components and the safe shutdown compliance strategies for fires in the selected fire areas. Through a combination of design information review and in-plant inspection, the inspectors ascertained whether the fire protection features in place to protect the SSD systems and components satisfied the requirements of the FPP which committed to meet the requirements of 10 CFR 50 Appendix R, Sections III.G, III.J, III.L, and III.O.
Section III.G.2 of 10 CFR 50 Appendix R specifies the separation and design requirements to protect one train of cables and equipment necessary to achieve and maintain hot shutdown conditions from fire damage when redundant trains are located within the same fire area. In cases where the separation requirements of Section III.G.2 were not met and local operator manual actions (OMAs) were utilized by the licensee in lieu of protection, the inspectors verified that the OMAs were implemented in accordance with the approved FPP, which may have required prior NRC approval. The inspectors reviewed the OMAs to verify that they were feasible, consistent with the guidance provided in Section 02.02.j.2 of IP 71111.05T. Another objective for reviewing the SSD analysis was to understand its details so it could be determined whether the operations post-fire shutdown procedures were consistent with the analysis.
b. Findings
Introduction:
The inspectors identified an unresolved item (URI) related to the licensees failure to protect cables and equipment required to achieve hot shutdown to ensure that one train was free of fire damage in accordance with the requirements of the approved fire protection program as described in SQN Operating License Conditions (OLCs)2.C(16) and 2.C(13) for Units 1 and 2 respectively.
Description:
The inspectors reviewed the licensees post-fire SSD methodology for a fire in FA FAA-054/Room A01 or FA FAA-081/Room A24. Post-fire SSD for either of these FAs would be achieved from the MCR using AOP-N.01, Plant Fires, and AOP-N.08, Appendix R Fire Safe Shutdown. During this review the inspectors noted that in lieu of protecting the cables of equipment identified by the licensee as being required for post-fire SSD (i.e., provide barriers and spatial separation with detection and suppression),the SQN SSD methodology (for the above two FAs and numerous other FAs) also credited the use of OMAs. These new OMAs were not submitted to the NRC for review and/or approval prior to incorporation into the plant AOPs. Sequoyah added these new OMAs to their FPP in 2002 without seeking prior NRC approval because they believed their current OLCs (approved by NRC SER dated August 12, 1997 and applicable to plants licensed after January 1, 1979) allowed them to make these changes without prior NRC approval if they could demonstrate that the changes had no adverse impact on SSD. Sequoyah Units 1 and 2 were both licensed to operate after January 1, 1979. The SQN evaluation (dated March 2002) which added the OMAs concluded that adding the OMAs did not adversely affect SSD because the licensee determined at that time that the OMAs were feasible. The inspectors concluded that the licensees methodology of allowing fire damage to occur (instead of protecting SSD cables and equipment) and relying on OMAs to achieve post-fire SSD would adversely affect the ability to achieve and maintain SSD in the event of a fire. The inspectors reviewed the SQN evaluation which added the OMAs and concluded that the evaluation was not adequate to support the conclusion that adding the OMAs did not adversely affect post-fire SSD because the evaluation did not address defense-in-depth. During this inspection, SQN personnel stated that there were no plans at the time to implement modifications or submit the OMAs added in March 2002 for NRC review and approval. Subsequent to the onsite inspection, the licensee submitted additional information to the inspectors in support of their conclusion that the OMAs added in 2002 did not affect SSD. Additionally, the licensee initiated Problem Evaluation Report (PER) 324757 to address this issue. The inspectors are reviewing this information relative to the SQN licensing basis. This issue is identified as unresolved item (URI) 05000327, 328/2011006-01, Use of Operator Manual Actions in Lieu of Protecting Cables and Equipment Required for Post-Fire Safe Shutdown. This issue is unresolved pending further NRC review of this information and the Sequoyah fire protection licensing basis.
.02 Passive Fire Protection
a. Inspection Scope
For the selected FAs, the inspectors evaluated the adequacy of fire barrier walls, ceilings, floors, mechanical and electrical penetration seals, fire doors, fire dampers and electrical raceway fire barrier systems (ERFBS). The inspectors walked down accessible portions of the selected fire areas to observe the material condition of fire barriers. The inspectors reviewed the configuration of the installed ERFBS to the TVA G-98 Installation & Modification Specification for ERFBS to confirm that the appropriate materials and construction methods were used to assure that the respective fire barriers met their intended design function. The inspectors reviewed SQN-26-D054/EPM-ABB-IMPFHA Fire Hazards Analysis Calculations for the selected fire areas to verify that the plant fire loading used by the licensee was appropriate for the stated fire resistance rating of the fire barrier enclosures. The inspectors reviewed fire protection penetration seal details analysis against penetrations within the selected fire areas. The inspectors also reviewed a representative sample of completed surveillances for fire doors, fire dampers, penetration seals and ERFBS performed since the last TFPI in June 2008.
b. Findings
No findings were identified
.03 Active Fire Protection
a. Inspection Scope
For the selected FAs, the inspectors performed in-plant observations of the material condition and operational lineup of fire detection, fire protection water supply, automatic water and carbon dioxide fire suppression systems, and manual fire hose and standpipe systems. The inspectors observed the performance of surveillance test 0-SI-FPU-026-192.M, Motor Driven Fire Pump A Operability Test. The inspectors reviewed the fire detection and suppression methods for the types of fire hazards existing in the selected FAs. The inspectors also compared the fire detection and fire suppression systems to the applicable National Fire Protection Association (NFPA) Standard(s) for the selected FAs by reviewing design documents and observing their as-installed configurations as part of performing the in-plant walkdowns. The inspectors compared the testing and maintenance program for the fire detection and suppression systems to the testing and maintenance requirements of the Sequoyah FPP.
For the selected FAs, the inspectors compared fire fighting pre-plan strategies to existing plant layout and equipment configuration and to the fire response procedures. The inspectors assessed the condition of fire fighting and smoke control equipment by inspecting equipment located at fire brigade staging and dress out areas. The inspectors evaluated fire brigade staffing, qualification and training, and reviewed all drill records for 2009 and 2010. The current mutual aid contract between TVA and the Soddy Daisy Fire Department was reviewed as well as the most recent fire drills with off-site responders. Specific attributes of fire brigade conduct was evaluated by the inspectors which included selection and implementation of appropriate strategy and tactics, command and control, communications, and use of fire brigade equipment.
b. Findings
Introduction:
The inspectors identified a Green non-cited violation (NCV) of SQN OLCs 2.C.(16) and 2.C.(13) for Units 1 and 2, respectively, for failure to establish compensatory measures for an obstructed sprinkler system. Specifically, scaffolding installed in FA FAA-054/Room A01 was in a configuration which would have blocked the water spray pattern of sprinkler heads A198 and A208.
Description:
During an inspection of FA FAA-054-A01, the inspectors noted that continuous, solid metal scaffolding had been erected between auxiliary building water chillers CHR-313-662 A and CHR-313-662B. The scaffolding was erected approximately 8 ft. above the 714 ft. floor elevation between column lines A3/T and A4/T. The scaffoldings dimensions were 11 ft. wide and 15 ft. long. The observed scaffolding was placed directly below a ceiling level pre-action sprinkler system installed to protect in-situ and transient combustibles in the FAA-054-A01 Corridor. Due to the dimensions of this scaffolding, the water spray pattern of sprinkler heads A198 and A208 would have been blocked. This would have degraded the suppression capability of the sprinklers for fires involving transient combustible materials left under the scaffolding or from a possible in-situ chiller oil reservoir spill on the floor.
The scaffolding was installed to support the removal and reinstallation of water pipe insulation covered under work order 08-776667-000. Two sections of scaffolding approximately 3 ft. wide by 15 ft. long were installed parallel to each other immediately adjacent to chillers CHR-313-662 A and CHR-313-662B with an approximate 5 ft. gap between them. A third section of scaffolding was subsequently installed such that the overall scaffold system configuration resulted in sprinkler system heads A198 and A208 being inoperable due to the heads being blocked by the scaffolding. No review by fire operations personnel was performed and the blocked sprinkler heads were not identified.
The SQN FPR, Part II, Section 14.3 requires that with one or more of the required spray and/or sprinkler systems inoperable (e.g., sprinklers blocked), establish a continuous fire watch within one hour with backup fire suppression equipment for those areas in which redundant systems or components could be damaged. The scaffolding configuration blocking sprinkler heads A198 and A208 existed from when it was first installed on February 1, 2011, until identified by the inspectors on February 9, 2011. When it was confirmed by fire operations that the scaffolding had not been previously reviewed, nor compensatory measures established, licensee personnel immediately established the required fire watch and initiated removal of the scaffolding. The licensee initiated PER 321151 to document this condition and enter it into the corrective action program (CAP).
Analysis:
This finding was determined to be a performance deficiency because the licensee did not provide the required compensatory measures (fire watch) for sprinkler heads that were obstructed or blocked by scaffolding. This finding was more than minor because it affected the reactor safety mitigating systems cornerstone attribute of protection against external factors (i.e., fire) and it affected fire protection defense-in-depth strategies involving suppression systems. Failure to provide compensatory measures for obstructed sprinkler heads A198 and A208 would have reduced the licensees ability to quickly extinguish a fire in the area. The inspectors evaluated this issue in accordance with Inspection Manual Chapter (IMC) 0609, Appendix F, Fire Protection Significance Determination Process, and determined that this finding was of very low safety significance (Green). The finding category of fixed fire protection systems was assigned, based upon that element of the plant fire protection program being impacted. The inspectors assigned a low degradation rating that reflected the severity of the observed deficiency. This rating was based upon meeting the criteria described in IMC 0609, Appendix F, Attachment 2 for fixed fire detection and suppression degradation. Specifically, less than 10% of the sprinkler heads were non-functional, there were functional heads within 10 feet of the combustibles of concern and the system was nominally code compliant.
This finding was determined to have a cross cutting aspect in the Human Performance Area, Work Practices Component, because the licensee failed to define and effectively communicate expectations regarding procedural compliance and requirements for personnel to follow procedures. (H.4.(b))
Enforcement:
Sequoyah Operating License Conditions 2.C.(16) and 2.C.(13) for Units 1 and 2 respectively, state in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program referenced in the SQN Final Safety Analysis Report (FSAR) and as approved in NRC SERs contained in NUREG-0011, Supplements 1, 2, and 5; NUREG-1232, Volume 2; NRC letters dated May 29 and October 6, 1986; and the Safety Evaluation issued on August 12, 1997. Sequoyah FSAR Section 9.5.1, Fire Protection System, states that the fire protection system and fire protection features are described in the SQN FPR, and the FPR should be referred to for a detailed description of the FPP. The SQN FPR, Part II, Section 14.3 states that with one or more of the required spray and/or sprinkler systems (e.g., sprinkler heads)inoperable, establish compensatory measures (i.e., a continuous fire watch) within one hour with backup fire suppression equipment for those areas in which redundant systems or components could be damaged.
Contrary to the above, between February 1, 2011 and February 9, 2011, the licensee did not implement all provisions of the approved fire protection program in that they failed to establish adequate compensatory measures (i.e., continuous fire watch) for sprinklers blocked by scaffolding erected in FA FAA-054-A01, Auxiliary Building Elevation 714 ft.
Corridor. Because this violation was of very low safety significance (Green) and has been entered into the licensees corrective action program as PER 321151, this finding is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy and is identified as NCV 05000327, 328/2011006-02, Failure to Establish Compensatory Actions for Blocked Sprinklers.
.04 Protection From Damage From Fire Suppression Activities
a. Inspection Scope
The inspectors evaluated whether the installed automatic CO2 system, the pre-action sprinkler systems or manual fire fighting activities for the selected FAs could adversely affect equipment credited for SSD, inhibit access to alternate shutdown equipment, or adversely affect local operator actions required for SSD. The inspectors considered the consequences of a rupture, inadvertent operation or actual operation of a fire suppression system concurrent with manual fire fighting activities as could result from a fully involved fire in one of the selected fire areas. The inspectors reviewed the supporting hydraulic drainage calculation nos. SQN-77-D053/2-M2-MLV-063085-3 for FAA-054 and SQN-77-D053/2-M2-MLV-063085-4 for FAA-081. The inspectors reviewed SQN evaluation SER-3-98, Fire Protection System Water Hammer. This evaluation addressed applicable portions of Information Notice (IN) 98-31, Fire Protection System Design Deficiencies and Common Mode Flooding of Emergency Core Cooling System Rooms at Washington Nuclear Project Unit 2. The inspectors reviewed pre-fire plans and fire AOPs which address the opening of doors to drain water so that OMAs may be performed. The inspectors reviewed the potential impact of a failure, mal-operation or actual discharge of the CO2 system protecting FAC-012. It was noted that the low pressure multi-ton CO2 storage tank and the associated master selector valve for the system is located in a vault outside the power block. Fire areas protected by CO2 have ventilation systems installed to remove CO2 discharged to these areas. Because CO2 is odorless, the CO2 system has a wintergreen odorizer that is mixed into the CO2 as it discharges into the fire area. Pre-fire plans address the possible operation of the CO2 system and specifically address precautions, ventilation methodology and post fire considerations such as re-occupation of the area.
b. Findings
No findings were identified.
.05 Alternative Shutdown Capability
a. Inspection Scope
The inspectors reviewed the licensees SSD analysis and evaluated the licensees ability to achieve and maintain hot and cold plant shutdown with and without the availability of offsite power for a postulated fire in FA FAC-012/Room C04 of the control building. The inspection activities focused on ensuring the adequacy of systems and components required for reactivity control, reactor coolant makeup, reactor heat removal, process monitoring instrumentation, and support system functions.
Operational Implementation
The inspectors walked down FA FAC-012/Room C04 and examined the material condition of the fire detection, suppression, and fire area boundaries. The inspectors reviewed the FPR and FHA to verify that equipment required for post-fire safe shutdown was adequately protected from fire damage in accordance with the FPP. The inspectors reviewed cable routing information for a selected sample of SSD components credited for use during this shutdown method to evaluate if the components and cables would remain free from fire damage or that acceptable OMAs had been established in the operating procedures. In cases where local OMAs were credited in-lieu of cable protection of SSD components, the inspectors verified that the OMAs were feasible utilizing the guidance of NRC IP 71111.05T.
The inspectors reviewed selected job performance measures for licensed and non-licensed operators to verify that the training reinforced the shutdown methodology in the SSD analysis and abnormal procedures for the selected FAs. The inspectors also conducted interviews, reviewed shift turnover logs and shift manning to verify that personnel required for SSD using alternative shutdown systems and procedures were available onsite, exclusive of those assigned as fire brigade members.
The inspectors performed a tabletop review of abnormal operating procedure AOP-C.04, Shutdown From Auxiliary Control Room, and also performed a walk-through of selected procedure steps to ensure the implementation and human factors adequacy of the procedure. The inspectors walked down the in-plant location of selected OMAs specified in the AOP with operations personnel to evaluate the environmental conditions, relative difficulty and operator familiarization associated with each OMA. The inspectors reviewed the systems and components credited for use during this shutdown method to verify that they would remain free from fire damage. The inspectors reviewed selected operator actions to verify that the operators could reasonably be expected to perform the specific actions within the time required to maintain plant parameters within specified limits.
The inspectors reviewed surveillance tests records for some of the transfer switches that were required to transfer plant controls from the MCR room to the auxiliary control room to verify that the transfer switches were functional. The test program was implemented by periodic test instructions which included steps for the verification of remote shutdown transfer capability. The test program tested 25% of the transfer switches every outage with all credited switches tested over a 72 month period. The inspectors reviewed the last two completed surveillances performed on Units 1 and 2. By reviewing the records, the inspectors confirmed that testing was performed to demonstrate functionality of the Appendix R transfer switches, and that test deficiencies were documented and addressed in the corrective action program. Reviews also included verification that alternative shutdown could be accomplished with or without offsite power.
b. Findings
No findings were identified.
.06 Circuit Analyses
a. Inspection Scope
A sample of SSD components important to safe shutdown were selected to evaluate if the existing fire emergency procedures were adequate for a postulated fire in any of the selected FAs. The cables examined were based upon a list of SSD components selected by the inspectors after a review of the FHA, SSD systems mechanical flow and control diagrams, cable routing data, wiring diagrams, block diagrams, and plant fire response procedures. The inspectors reviewed the electrical block and control wiring diagrams and identified the cables associated with the SSD components and examined in detail the cable routing and potential for fire damage and the effects on the circuit.
The components important to SSD credited in the alternative shutdown procedures were reviewed to verify that the transfer switches associated with these components would adequately transfer control and power from the main control room to the auxiliary control room. Cable routing data was also reviewed for these components to verify that the cables for the sampled transfer switches were not routed in the selected fire areas or were adequately protected by electrical isolators. The inspectors noted that the licensee has completed an analysis for multiple spurious circuit faults utilizing NRC and industry guidance and identified several items in the corrective action program for resolution. A list of the components selected for review is included in the Attachment.
b. Findings
No findings were identified.
.07 Communications
a. Inspection Scope
The inspectors assessed fixed and portable plant communication capabilities to evaluate the availability of the communication systems to support plant personnel in the performance of OMAs to achieve and maintain safe shutdown. The inspectors assessed the capability of the sound powered phones and reviewed cable routing for plant radios and plant phones to verify that communication equipment would not be affected by a fire in the selected FAs. The inspectors also verified, by walkdown, that the location of communications equipment would not be affected by a fire. The inspectors reviewed preventative maintenance and surveillance test records to verify that the communication equipment was being properly maintained.
b. Findings
No findings were identified.
.08 Emergency Lighting
a. Inspection Scope
The inspectors inspected maintenance and design aspects of the fixed 8-hour battery pack emergency lighting units (ELUs) required by the licensees FPP. The inspectors performed plant walkdowns of the post-fire SSD procedures for the selected FAs to observe the placement and coverage area of the ELUs throughout the selected FAs.
The inspectors also evaluated the adequacy of the ELUs to illuminate access and egress pathways and any equipment requiring local operation and/or instrumentation monitoring for post-fire SSD. The inspectors reviewed preventive maintenance procedures and completed surveillance tests to verify that adequate surveillance testing was in place. The inspectors reviewed vendor manuals to ensure that the ELUs were being maintained consistent with manufacturers recommendations. Work orders and PERs were reviewed to ensure that ELU surveillance test failures were addressed appropriately.
b. Findings
No findings were identified.
.09 Cold Shutdown Repairs
a. Inspection Scope
The inspectors verified that the licensee was capable of making necessary repairs to proceed to cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the selected III.G.2 fire areas. The inspectors reviewed Special Maintenance Instruction SMI-0-317-18, Appendix R - Casualty Procedures, Revision 10, and sections of FHA Calculation SQN-26-D054/EPM-ABB-IMPFHA for III.G.2 fire areas FAA-054 Section 1 and FAA-081 to confirm that adequate procedures were available for the repair of equipment required to achieve and maintain cold shutdown. The inspectors found that the necessary cold shutdown repairs were outlined in the casualty procedures for each of the selected fire areas. Based on a review of the documentation and a physical inspection of the repair kits, the inspectors verified that the equipment needed to make the specified repairs were available onsite and included in the Appendix R Equipment Inventory stored in the warehouse.
b. Findings
No findings were identified.
.10 Compensatory Measures
a. Inspection scope
The inspectors reviewed the administrative controls for out-of-service, degraded and/or inoperable fire protection features (e.g. detection and suppression systems and passive fire barriers). The inspectors reviewed selected items from the impairment list and compared them to the FAs selected for the inspection. The inspectors also observed performance of a fire protection surveillance activity, including implementation of compensatory measures.
The inspectors interviewed continuous fire watch personnel stationed in control building elevations 706 ft. and 732 ft. that were posted for fire suppression systems made inoperable by the closing of valve 0-FCV-26-211. The inspectors reviewed the issuance of Hot Work Permit No. 111003140 for welding and cutting in the cable spreading room and observed the performance of the fire watch required for such work.
b. Findings
No findings were identified.
.11 B.5.b Mitigating Strategy
a. Inspection Scope
The inspectors reviewed, on a sample basis, the licensees spent fuel pool external spray mitigation measures for large fires and explosions to verify that the measures were feasible, personnel were trained to implement the strategies, and equipment was properly staged and maintained. The inspectors reviewed the licensees established program, applicable SERs and submittals which supported the elements outlined by the license condition. The inspectors reviewed inventory, surveillance testing, and maintenance records of required equipment. Through discussions with plant staff, documentation review, and plant walk-downs, the inspectors verified the engineering basis to establish reasonable assurance that the makeup capacity could be provided using the specified equipment and water sources. The inspectors reviewed the licensees capability to provide a reliable and available water source and the ability to provide the minimum fuel supply. The inspectors performed a walk-down of the storage and staging areas for the B.5.b equipment to verify that equipment identified for use in the current procedures was available and maintained. The inspectors reviewed training records of the licensees staff to verify that operations and security personnel training/familiarity with the strategy objectives and implementing guidelines were accomplished according to the established training procedures.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Identification and Resolution of Problems
a. Inspection Scope
The inspectors reviewed recent independent licensee audits for thoroughness, completeness and conformance to requirements. Requirements for the independent audits are contained in Generic Letter 82-21 Technical Specifications for Fire Protection Audits and the licensees Quality Assurance Program, as well as Appendix A to BTP APCSB 9.5-1 Guidelines for Fire Protection for Nuclear Power Plants, Section C.10, Audits. The inspectors reviewed other corrective action program documents, including completed corrective actions documented in selected PERs, and operating experience program documents to verify that industry-identified fire protection problems potentially or actually affecting the plant were appropriately entered into and resolved by the licensees CAP. The inspectors included NRC Regulatory Issue Summaries, information notices, industry and vendor-generated reports of defects and noncompliance under 10 CFR Part 21, and vendor information letters in their review of operating experience program effectiveness. The inspectors reviewed the timeliness, apparent cause determination, proposed corrective action, and other attributes associated with a sample of PERs. The PERs reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
(Closed) Licensee Event Report (LER) 05000327/2009-001-00: Appendix R Unanalyzed Condition Affecting Safety Related Shutdown Boards
On January 28, 2009, during an audit of the Fire Protection Program, the licensee identified a postulated Appendix R fire scenario that could defeat essential breaker coordination between the load and feeder breakers required to protect the power supply to the 6900-volt shutdown boards. This scenario involves a fire in Fire Area 1, Elevation 669, Auxiliary Building Corridor or Fire Area 29, Elevation 690 Auxiliary Building General Area, that could potentially cause a loss of power to fire safe shutdown equipment required to achieve and maintain hot shutdown for compliance with 10 CFR Part 50, Appendix R.
The scenario occurs when the load breakers 125-volt direct current (DC) control circuit is damaged in the fire and could potentially open the control circuit fuses, subsequently disabling the breakers trip circuit containing the over-current relay protection. After the over-current protection has been disabled, the same fire could damage the 6900-volt power cables causing a phase-to-phase fault. The load breaker would not be able to clear the fault with the trip circuit control power fuses blown. Therefore, the feeder breaker would be the next protection device to clear the fault. However, opening the feeder breaker causes a loss of the 6900-volt shutdown board and all associated electrical boards fed from that bus.
In FAs 1 and 29, the power cables were routed in close proximity to the 125-volt DC control circuit cables for the local control hand switch for pumps fed from the 6900-volt shutdown boards. The licensees post fire safe shutdown strategy did not account for the loss of any auxiliary power boards in either of the affected fire areas. The licensee entered this issue into their corrective action program under PER 162189, Potential Unanalyzed Condition Affecting 6900V Shutdown Boards and immediately initiated hourly fire watches for Fire Areas 1 and 29 in accordance with the SQN FPR, Part II, Section 14.6. Subsequently, the licensee initiated DCN D22367 to remove the local hand switches and spare associated cables to the pumps related to this scenario. The inspectors concluded that the licensees corrective actions were appropriate and reasonable. Enforcement aspects of this LER are discussed in Section 4OA7 of this IR.
The documents reviewed are listed in the Attachment. This LER is closed.
4OA5 Other Activities
.1 (Closed) URI 05000327, 328/2008006-02, Sprinkler System in Room 690.0-A1 of the
Auxiliary Building has NFPA Code Deviation
a. Inspection Scope
This URI concerning the design of the sprinkler system in the eastern portion of the Auxiliary Building elevation 690 ft. (Room 690.0-A1, FA FAA-029) was opened during the 2008 TFPI (IR 05000327, 328/2008006) to determine if the as-built configuration had been approved by the NRC, and to review the capacity and capability of the as-built configuration to suppress fires. The inspectors reviewed the licensing basis documents listed in OLCs 2.C.(16) and 2.C.(13) for Units 1 and 2 respectively, and could not identify where the NRC had reviewed and approved the installed sprinkler head configuration, nor did the inspectors find where the NRC had approved a deviation from the NFPA Code of Record (NFPA 13-1975) for FA FAA-029.
b. Findings
Introduction:
The inspectors identified a Green NCV of OLCs 2.C.(16) and 2.C.(13), for Units 1 and 2 respectively, for failure to install the automatic suppression system (sprinkler system) in the Auxiliary Building elevation 690 ft. Corridor, in accordance with applicable NFPA Standard No. 13, Automatic Sprinkler Systems. Specifically, NFPA No. 13-1975 requires sprinklers to be installed within 12-inches of the ceiling. Portions of the Auxiliary Building sprinkler system located between column lines A6-A10/U and A6-A10W were installed greater than 12-inches below the ceiling. As a result, the actuation of the fusible link type sprinklers would be slower than originally intended after fire ignition.
Description:
Fire Area FAA-029, between column lines A6-A10/U and A6-A10/W was described as an access corridor. It contained a limited number of ignition sources, identified in drawings and by walkdowns as three electrical panels immediately adjacent to column A7/V. Cable trays were located in the overhead spaces approximately 14 ft.
to 20 ft. above the floor. The ceiling was 22 ft.-6 inches above the 690 ft. floor elevation.
Fire Area FAA-029 contained a large equipment hatch, an elevator, and an open stairwell, designated as stair No. 3. The equipment hatch and stairwell were originally protected by sprinklers that extended slightly into the open vertical space at elevation 710 ft.-6 inches, or approximately two ft. below the ceiling. These were installed to protect against combustibles that may have been in transit in the hatch area or the stairwell. Additional sprinklers were installed adjacent to or above cable trays to protect the conductors against the spread of fire, both vertically and horizontally, within the trays below. These sprinkler heads were installed at elevation 706 ft.-6 inches or approximately six-feet below the ceiling. The design of the sprinkler system for the auxiliary building elevation 690 ft. specified a minimum design density of 0.16 gpm/sq. ft.
and a maximum coverage area of 130 sq. ft. per head. The floor area between column lines A6-A10/U and A6-A10W was 53 ft. by 42 ft. which was 2226 sq. ft. This area was protected by 23 sprinkler heads. The actual coverage area was conservatively designed to approximately 96 sq. ft. per head. The Code of Record, NFPA 13, 1975 edition, Section 4-3.1 requires that ceiling level sprinklers be installed within 12-inches of smooth ceiling construction. The sprinkler heads were standard release upright pendant type heads, with a rating of 212 degree F (intermediate class). The installed sprinkler heads within the A6-A10/U and A6-A10W grid were outside their laboratory tested configurations and NFPA-13 installation requirements, which would likely lead to a slower sprinkler response for heads installed under the projected ceiling jet and outside the fire plume.
Analysis:
This finding was determined to be a performance deficiency because the licensee did not locate the sprinkler heads according to the applicable NFPA code of record for the facility. The finding was more than minor because it was associated with the reactor safety, mitigating systems cornerstone attribute of protection against external factors (i.e. fire). It affected the objective of ensuring the reliability and capability of systems that respond to initiating events. The risk significance of the finding was determined in accordance with IMC 0609, Appendix F, Fire Protection Significance Determination Process. Pursuant to IMC 0609, Appendix F, the finding category was fixed fire protection systems. The nature of the degradation of the water based suppression system was related to the response time of the sprinkler system. The installed configuration of these heads would likely result in a response time slower than that meeting the installation requirements of NFPA 13. Using Attachment 2 of IMC 0609, Appendix F, a degradation rating of Low was assigned. This was based upon the following three criteria: 1) the licensees identification of 20 out of 361 installed sprinkler heads being out of conformance with NFPA 13 for the sprinkler system protecting the 690 ft. elevation of the auxiliary building. This met the Low degradation screening threshold of less than 10% of heads non-functional. 2) Functional sprinkler heads were located within 10 ft. of combustibles of concern. Sprinkler heads C282, C284 and C286 were installed above each of the electrical panels (combustibles of concern) within approximately 18-inches horizontally from the panel edges. This placed the sprinklers within the fire plume zone of influence as shown in IMC 0609 Appendix F Table 2.3.3 for any of the fire heat release rate (HRR) values for a fire located near a wall for either the thermoplastic cables. For this reason these three heads were considered functional for protection against combustibles of concern and therefore met the Low degradation criteria of functional heads being within ten feet of combustibles of concern. 3) The system was considered nominally code compliant for all other aspects of installation, other than the location of the sprinklers below the ceiling. The maximum area of coverage was conservatively averaged for 96 sq. ft./head vs. 130 sq. ft./head allowed. Within the area of concern between column lines A7-A8/U and A6-A10W, a total of 14 sprinkler heads provided coverage for an area of approximately 795 sq. ft.
The average area of coverage per sprinkler head between column lines A7-A8/U and A6-A10W was 56 sq. ft. per head. Due to this close proximity, these heads were fitted with square metal caps to prevent water spray from one fused head cooling the link of the adjacent head. The sprinkler system was installed to an NFPA pipe schedule type hydraulic design. Systems designed by this method typically result in their installed average sprinkler discharge density being greater than the specified minimum design density (0.16 gpm/sq. ft.) over the hydraulically most limiting point of the system. Except as noted, the system was considered to be nominally code compliant and therefore met the low degradation criteria for water based suppression systems. As a result of this qualitative screening, the finding was assigned a low degradation rating. The finding screened to Green, and no further analysis was required. There was no cross-cutting associated with this finding because the condition has existed since initial plant licensing and was not reflective of current licensee performance.
Enforcement:
Sequoyah OLCs 2.C(16 ) and 2.C(13) for Units 1 and 2 respectively, require that TVA implement and maintain in effect all provisions of the approved fire protection program referenced in the SQN FSAR. FSAR Section 9.5.1.1 states that the fire protection system and fire protection features are described in the FPR. Part VI, Section 3.3 of the FPR states that NFPA 13-1975, Automatic Sprinkler Systems, is the code used to evaluate the adequacy of the sprinkler systems. NFPA 13, Section 4-3.1 requires that ceiling level sprinklers be installed within 12-inches of smooth ceiling construction.
Contrary to the above, the licensee failed to implement all provisions of the approved fire protection program in that, the east portion of auxiliary building 690 ft. elevation did not have sprinklers installed within 12-inches of the ceiling between column lines A6-A10/U and A6-A10W. This condition has existed since initial plant licensing. The inspectors noted that modifications to restore the sprinkler system to compliance were being implemented by design change notice D22408, Stage 1. Because this finding was of very low safety significance (Green) and was entered into the licensees CAP as PER 147467, this finding is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy. This finding is identified as NCV 05000327, 328/2011006-03, Sprinkler System in Room 690.0-A1 of the Auxiliary Building has NFPA Code Deviation.
4OA6 Meetings, Including Exit
On February 11, 2011, the lead inspector presented the inspection results to M. Skaggs, SQN Site Vice President, and other members of the licensees staff. The licensee acknowledged the findings. The inspection results were updated in a telephone call on March 25, 2011, with G. Cook, Site Licensing Manager, and members of the licensees staff. The inspection results were updated again in a telephone call on June 13, 2011, with M. Skaggs and other members of the licensees staff. A final exit meeting was conducted on July 8, 2011, with G. Cook and other members of the licensees staff.
Proprietary information is not included in this report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements, which meet the criteria of the NRC Enforcement Policy, for being dispositioned as an NCV.
- Sequoyah Fire Protection License Condition 2.C.(16) for Unit 1 requires that TVA implement and maintain in effect all provisions of the approved fire protection program referenced in the Sequoyah Nuclear Plants Final Safety Analysis Report (FSAR) as described in the Fire Protection Report (FPR). Part III of the FPR states that SQN must comply with 10 CFR 50 Appendix R, Section III.G.
Section III.G.2 requires that where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area means of ensuring that one of the redundant trains is free of fire damage shall be provided.
Contrary to the above, on January 28, 2009, the licensee identified that cables associated with the Unit 1 6900-volt power supply in fire areas FAA 1 and 29 would not be free of fire damage to support safe shutdown (see Section 40A3).
This violation is of very low safety significance (Green). This issue was determined to be of very low safety significance based on the results of the IMC 0609, Appendix F, Fire Protection Significance Determination Process, Phase II Quantitative Screening Approach. This violation was documented in the licensees CAP as PER 162189.
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- S. Bowman, Licensing Engineer
- B. Carrier, Operations Support
- T. Carson, Director of Projects
- I. Collins, Engineering Programs Manager
- P. Colman, Safe Shutdown Contractor
- G. Cook, Site Licensing Manager
- E. Craig, Mechanical Design
- R. Egli, Fire Protection/Appendix R Program Owner
- D. Green, Corporate Licensing Manager
- R. Detwiler, Director, Safety and Licensing
- J. Furr, Quality Assurance Manager
- P. Johnson, Fire Protection Supervisor
- K. Langdon, Plant Manager
- D. Porter, Operations Procedures
- R. Proffitt, Licensing Supervisor
- B. Simril, Corporate Fire Protection Manager
- M. Skaggs, Site Vice President
- T. Skiba, Mechanical Design Engineering Manager
- D. Sutton, Licensing Engineer
- N. Thomas, Licensing Engineer
- R. Thompson, Safety and Licensing
- E. Turner, Electrical Design Engineer
- B. Wetzel, Sequoyah Licensing Manager
- K. Wilkes, Operations Support Superintendent
- J. Williams, Site Engineering Director
NRC personnel
- H. Christensen, Deputy Division Director, Division of Reactor Safety, Region II
- M. Speck, Resident Inspector
- C. Young, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000327, 328/2011006-01 URI Use of Operator Manual Actions in Lieu of Protecting Cables and Equipment Required for Post-Fire Safe Shutdown (Section 1R05.01.b)
Opened and Closed
- 05000327, 328/2011006-02 NCV Failure to Establish Compensatory Actions for Blocked Sprinklers (Section 1R05.03.b)
- 05000327, 328/2011006-03 NCV
Sprinkler System in Room 690.0-A1 of the Auxiliary Building has NFPA Code Deviation (Section 4OA5)
Closed
- 05000327, 328/2008006-02 URI
Sprinkler System in Room 690.0-A1 of the Auxiliary Building has NFPA Code Deviation (Section 4OA5)
- 05000327/2009-001-00
LER
Appendix R Unanalyzed Condition Affecting
Safety related Shutdown Boards (Section 4OA3)
LIST OF COMPONENTS REVIEWED (Refer to Report Section 1R05.01 / 1R05.05 / 1R05.06 - Circuit Analyses)
Component Identification
Description
Valves 2-FCV-062-090
Charging Flow Isolation Valve 2-FCV-062-091
Charging Flow Isolation Valve
2-FCV-062-093
Charging Header Flow Control Valve
Pump Motors
2-PMP-062-104
Centrifugal Charging Pump (CCP) 2B-B
2-PMP-062-108
0-PMP-067-432
ERCW Pump J-A 0-PMP-067-436
ERCW Pump K-A
0-PMP-067-440
ERCW Pump L-B
0-PMP-067-444
ERCW Pump M-B
0-PMP-067-452
ERCW Pump N-B
0-PMP-067-456
ERCW Pump P-B
0-PMP-067-460
ERCW Pump Q-A
0-PMP-067-464
ERCW Pump R-A
2-PMP-3-118
2-PMP-3-128
Process Instruments 2-L-003-174
Steam Generator (SG) 1 Level Loop
2-L-003-173
SG 2 Level Loop
2-L-003-172
SG 3 Level Loop
2-L-003-175
SG 4 Level Control Loop 2-L-003-164
SG 1 Level Loop
2-L-003-156
SG 2 Level Loop
2-L-003-148
SG 3 Level Loop
2-L-003-171
SG 4 Level Loop
2-XI-092-5
Source Range Flux Monitor
2-PI -1-1C
SG Pressure Loop 1
2-PI-1-8C
SG Pressure Loop 2
2-PI-1-19C
SG Pressure Loop 3
2-PI-1-26C
SG Pressure Loop 4
2-LI-68-325C
Pressurizer Level
2-LI-68-326C
Pressurizer Level
2-P-68-337C
Pressurizer Pressure
2-P-68-336C
Pressurizer Pressure
2-T-68-1C
RC Hot Leg Temperature (Loop 1)
2-T-68-24C
RC Hot Leg Temperature (Loop 2)
2-T-68-43C
RC Hot Leg Temperature (Loop 3)
2-T-68-65C
RC Hot Leg Temperature (Loop 4)
Generator Controls
2-GENB-082-002A-A
EDG Emergency Start/Stop
2-GENB-082-002B-B
EDG Emergency Start/Stop