IR 05000327/2020012
| ML20294A177 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/20/2020 |
| From: | Scott Shaeffer NRC/RGN-II/DRS/EB2 |
| To: | Jim Barstow Tennessee Valley Authority |
| References | |
| IR 2020012 | |
| Download: ML20294A177 (15) | |
Text
October 20, 2020
SUBJECT:
SEQUOYAH NUCLEAR PLANTS - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000327/2020012 AND 05000328/2020012
Dear Mr. Barstow:
On September 9, 2020, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Sequoyah Nuclear Plants. On August 31, 2020, the NRC inspectors discussed the results of this inspection with Mr. Scott Hunnewell and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; the Director, Office of Enforcement; and the NRC Resident Inspector at Sequoyah Nuclear Plants.
If you disagree with a cross-cutting aspect assignment 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region II; and the NRC Resident Inspector at Sequoyah Nuclear Plants. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Scott M. Shaeffer, Chief Engineering Br 2 Div of Reactor Safety Docket Nos. 05000327 and 05000328 License Nos. DPR-77 and DPR-79
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000327 and 05000328 License Numbers: DPR-77 and DPR-79 Report Numbers: 05000327/2020012 and 05000328/2020012 Enterprise Identifier: I-2020-012-0012 Licensee: Tennessee Valley Authority Facility: Sequoyah Nuclear Plants Location: Soddy Daisy Inspection Dates: June 07, 2020 to August 28, 2020 Inspectors: P. Braaten, Reactor Inspector J. Dymek, Reactor Inspector J. Montgomery, Senior Reactor Inspector D. Strickland, Reactor Inspector Approved By: Scott M. Shaeffer, Chief Engineering Br 2 Div of Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Sequoyah Nuclear Plants, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Inadequate Surveillance Procedure Allowed Preconditioning of Alternative Safe Shutdown Transfer Switches and Controls Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.21N.
Systems NCV 05000328/2020012-01 Resources 05 Open/Closed The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Sequoyah Unit 2 Operating License Condition 2.C(13) when the licensee failed to comply with procedure NPG-SPP-06.9.2, Surveillance Test Program," by providing operators with inadequate surveillance procedures that preconditioned alternative safe shutdown transfer switches and controls.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)
The inspectors verified that the following systems credited in the approved fire protection program could perform their licensing basis function:
a. Review deficiencies or open fire protection impairments for the selected system, including any temporary modifications, operator workarounds, or compensatory measures.
b. Verify that operator actions can be accomplished as assumed in the licensees FHA, or as assumed in the licensees fire probabilistic risk assessment (FPRA)analysis and SSA.
c. Review repetitive or similar maintenance work requests which could be an indicator of a design deficiency and could affect the ability of the components to perform their functions, when needed.
d. Ensure that post maintenance and/or surveillance activities are performed as scheduled.
e. Perform a walkdown inspection to identify equipment alignment discrepancies.
Inspect for deficient conditions such as corrosion, missing fasteners, cracks, and degraded insulation.
f. Ensure the selected SSCs that are subject to aging management review (AMR)pursuant to 10 CFR Part 54 are being managed for aging (e.g., loss of material, cracking, reduction of heat transfer) in accordance with appropriate aging management programs. Verify that the licensees aging management program activities (such as, Fuel Oil Analysis or Selective Leaching Aging Management Program) associated with FP equipment are being implemented.
g. If a review of operating experience issues will be completed for the selected inspection sample, verify that the licensee adequately reviewed and dispositioned the operating experience in accordance with their processes.
The team selected the following SSCs as samples.
- Unit 2 Reactor Coolant System
- Unit 2 Steam Generator Atmospheric Relief Valves
- Unit 1 12v DC Power System
- CO2 System in Unit 1 Auxiliary Instrument Room and Required Fire/Smoke
Dampers Fire Protection Program Administrative Controls (IP Section 03.02) (1 Sample)
The inspectors verified that the following fire protection program administrative controls were implemented in accordance with the current licensing basis:
- Combustible Control Program
Fire Protection Program Changes/Modifications (IP Section 03.03) (1 Sample)
The inspectors reviewed the following changes to ensure that they did not constitute an adverse effect on the ability to safely shutdown post-fire and to verify that fire protection program documents and procedures affected by the changes were updated.
- Engineering Modification to Replace Unit 1 Pressurizer Power Operated Relief Valves
INSPECTION RESULTS
Inadequate Surveillance Procedure Allowed Preconditioning of Alternative Safe Shutdown Transfer Switches and Controls Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.1] - 71111.21N.0 Systems NCV 05000328/2020012-01 Resources 5 Open/Closed The inspectors identified a Green finding and associated Non-cited Violation (NCV) of Sequoyah Unit 2 Operating License Condition 2.C(13) when the licensee failed to comply with procedure NPG-SPP-06.9.2, Surveillance Test Program," by providing operators with inadequate surveillance procedures that preconditioned alternative safe shutdown transfer switches and controls.
Description:
To support inspection of the Unit 2 Pressurizer PORVs and their credit for fire safe shutdown, inspectors reviewed records for the last completion of surveillance test procedure 2-PI-OPS-000-010.D, "Verification of Remote Shutdown Transfer Switches." This test procedure verifies the operation of remote shutdown transfer switches and controls that are credited to meet the alternative shutdown requirements of 10 CFR 50, Appendix R, Section III.G.3. In reviewing this surveillance test procedure, inspectors discovered a sequence of test steps that appeared to constitute preconditioning of the Pressurizer PORVs under surveillance.
For PORV 2-PCV-68-334, after operators receive authorization from the SRO to perform the surveillance, the test directs operators to cycle transfer switch 2-XS-68-334C at least three times to clean contacts. The next step is to cycle control switch 2-HS-68-334C at least three times to clean contacts.
NRC Technical Guidance Part 9900, Maintenance - Preconditioning of Structures, Systems, and Components Before Determining Operability, gives guidance on the acceptability of preconditioning SSCs before the performance of surveillance testing. This document states that the NRC expects surveillance and testing processes of SSCs to be evaluated in an as-found condition. This guidance is echoed in TVA fleet procedure NPG-SPP-06.9.2, Surveillance Test Program. NPG-SPP-06.9.2 states, Surveillance sequences and alignment activities that are implemented prior to a surveillance test should be intended to facilitate testing or prevent unnecessary wear and damage to equipment and/or systems.
Test procedure steps that exercise equipment prior to testing activities are not allowed unless they provide a specific benefit, such as improved safety, reduced wear and tear, or facilitate better test methods. The potential of such activities to unintentionally mask degradation must be considered. Cycling electrical contacts repeatedly to clean them does not specifically facilitate test performance or provide any specific benefit. Further, cleaning the contacts before performing the continuity checks and resistance readings of the surveillance could unintentionally mask degradation of the circuit and the contacts.
Inspectors noted that the steps for PORV 2-PCV-68-340 were structured the same. The last performance of the surveillance for these two valves was November 23, 2018. Inspectors also reviewed the test procedure for other examples of this test sequence, and found that the surveillances for the 4 Main Steam Isolation Valves, the main Charging Header flow control valve (FCV) 62-93, multiple 6.9kV Shutdown Board feeder breakers, and the FCV for RHR Hot Leg injection to loops 1 & 3 (2-FCV-63-172) all contained the same, or similar steps to clean the electrical contacts before performing the continuity checks and resistance readings of the surveillance.
Corrective Action References: CR 1616116
Performance Assessment:
Performance Deficiency: The licensees failure to establish adequate surveillance test instructions in accordance with TVA fleet procedure NPG-SPP-06.9.2 was a performance deficiency. Specifically, surveillance test procedure 2-PI-OPS-000-010.D directed operators to cycle transfer and control switches to clean the contacts before performing the continuity checks and resistance readings to determine whether the surveillance acceptance criteria had been met. Those procedure steps constitute unacceptable preconditioning of the SSCs.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the failure to determine the as-found condition of the transfer switches and controls reduced the ability of the licensee to provide reasonable assurance that the licensee's alternative shutdown capability would have been available between tests.
Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Using IMC 0609, Appendix F, Attachment 1, the inspectors determined the issue was of very low safety significance (Green) because the finding did not adversely affect the ability to reach and maintain hot shutdown/hot standby conditions using the credited safe shutdown success path (Question 1.4.7-C).
Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety.
Specifically, leaders did not ensure that a set of procedures were in place that ensured preconditioning did not take place.
Enforcement:
Violation: Sequoyah Unit 2 Operating License Condition 2.C(13) requires, in part, that TVA shall implement and maintain in effect all provisions of the approved fire protection program referenced in Sequoyah Nuclear Plant's Final Safety Analysis Report (FSAR). Section 9.5.1 of the FSAR states that the Fire Protection System and fire protection features are described in the Fire Protection Report. Part II of the Fire Protection Report is the Fire Protection Plan, and Section 6.0 of the Fire Protection Plan states that the QA program for fire protection uses the applicable parts of the TVA Nuclear Quality Assurance Plan. Fleet procedure NPG-SPP-18.4.5, "Fire Protection QA Program" requires that activities shall be conducted in accordance with the applicable TVA Nuclear Power Group (NPG) programs to provide controls for modification, installation, surveillance, maintenance, operation, and program administration. The NPG Test Program is described in NPG-SPP-06.9, and child procedures.
NPG-SPP-06.9.2, "Surveillance Test Program," requires that Surveillance sequences and alignment activities that are implemented prior to a surveillance test should be intended to facilitate testing or prevent unnecessary wear and damage to equipment and/or systems.
Test procedure steps that exercise equipment prior to testing activities are not allowed unless they provide a specific benefit, such as improved safety, reduced wear and tear, or facilitate better test methods. The potential of such activities to unintentionally mask degradation must be considered.
Contrary to the above, from August 3, 2018 to June 12, 2020, the licensee used a surveillance test procedure that directed operators to exercise equipment prior to surveillance testing activities, without a specific benefit.
Enforcement Action: This violation is being treated as an non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On August 31, 2020, the inspectors presented the triennial fire protection inspection results to Mr. Scott Hunnewell and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.21N.05 Calculations 26D54EPMABBIMPFHA Sequoyah Nuclear Plant - Fire Hazards Analysis Rev. 145
Calculation
2-92743 Seismic Analysis of 24 Ton CO2 Tank Rev. 0
APS2068 Appendix R - Post Fire RCS Cooldown and Rev. 2
Depressurization
B25850329800 Fire Protection Pipe Support Calculation for 03/27/1985
Cantilevered 1-inch Pipe
D2SDJ-P213350 Analysis of the Auxiliary Power System for 10 Rev. 64
CFR 50, Appendix R
EDQ0009992017000385FHA Sequoyah Nuclear Plant - Fire Hazards Analysis Rev. 3
Calculation -
FSSD Compliance Mitigation Strategy
MDN000NA2019000628 SQN Fire PRA - Fire Risk Quantification Rev. 1
MDQ0026-97001 Motor Driven Fire Pump Replacement Sprinkler 06/25/2018
Calculation
MDQ0026-97001B Control Valve(s) 0FCV-26-151 & 0FCV-2066 12/03/2013
HPFP Sprinkler Calculation
MDQ0026-97001D Flow Testing to Support Pipe Degradation 12/24/1997
MDQ0026-980041 HPFP Sprinkler Calculation, Boric Acid Tank 12/16/1998
Room, 690.0' AB, Sprinkler Addition
SQN-APPR-1 Analysis of AC/DC Instrument & Control (I&C) Rev. 20
Power Systems to Identify Associated Circuits -
CFR 50 Appendix R
SQN-APS-003 480VAC APS Class 1E Load Coordination Rev. 108
Study
SQN-DC-V-10.7 Design Criteria Document - 10CFR50, Appendix Rev. 4
R, Type I,II, & III Circuits
SQN-DC-V-24.0 Design Criteria Document - Fire Protection for Rev. 10
Appendix R Requirements
SQN-DC-V-43.0 Design Criteria Document - High-Pressure Fire Rev. 9
Protection Water Supply System
SQN-DC-V-7.5 Design Criteria Document - Fire Protection Rev. 14
Inspection Type Designation Description or Title Revision or
Procedure Date
Systems
SQN-DC-V-7.6 Design Criteria Document - Proprietary Rev. 4
Protective Signaling Systems for Fire Alarm and
Supervisory Service
SQNAPPR10 Appendix R Hot Short Analysis for Non Rev. 25
High/Low RCS Pressure Interfaces and Non-
High Impact Circuits
XDN00000020110001 OMAs for 10 CFR Appendix R III.G.2 1/27/2014
Compliance
Corrective 1072726 Appendix R Fire Concern Regarding Smoke 8/7/2019
Action Migration
Documents 1440822 Appendix R Control Building Issue for RHR 08/20/2018
Pumps
1581033 NRC Triennial Fire Protection Inspection (TFPI) 02/24/2020
Readiness Self-Assessment
1610002 Appendix R Lighting Deficiency Created by 6/8/2020
Design Change
27936 Light heads misaimed 8/4/2020
Corrective 1590413 SA-1581033 2020 TFPI Deficiencies in testing 06/09/2020
Action for remote shutdown transfer switches
Documents 1613748 Alternate shutdown transfer switch testing 06/10/2020
Resulting from deficiencies
Inspection 1616116 NRC identified issue related to transfer switch 06/12/2020
testing
CR1632843 Fire Door C-22 Missing Screws from Plate on 08/25/2020
Door
CR1632915 Abandon Office Chair Staged in Auxiliary 8/26/2020
Building Equipment Room
Drawings 1,2 45W1699-50 Conduit & Grounding, Floor El.734.0, Details Rev. 3
Sheet 12
1,2 46W-455-1 Architectural Door Frames and Details Rev. 1
1,2 46W454-4 Architectural Door and Hardware Schedule Rev. 1
1,2 46W454-7 Architectural Door and Hardware Schedule Rev. 0
1,2 47W494-4 Fire Protection Compartmentation-Fire Cells Rev. 15
Inspection Type Designation Description or Title Revision or
Procedure Date
Plan El. 734.0'
1,2 47W494-6 Fire Protection Compartmentation-Fire Cells, Rev. 7
Plan El. 669.0' & 685.0'
1,2 47W850-27 Flow Diagram-High Pressure Fire Protection Rev. 11
1,2-45N639-1 Wiring Diagrams CO2 Fire Protection System Rev. 3
Schematic Diagrams Sh-1
1,2-45N639-2 Wiring Diagrams CO2 Fire Protection System Rev. 3
Schematic Diagrams Sh-2
1,2-45N639-3 Wiring Diagrams CO2 Fire Protection System Rev. 15
Schematic Diagrams Sh-3
1,2-45N703-1 Wiring Diagrams - 125V Vital Battery Board I Rev. 85
Single Line Sheet 1
1,2-45N703-2 Wiring Diagram - 125V Vital Board Battery Rev. 45
Board II Single Line Sheet 2
1,2-45N703-3 Wiring Diagrams - 125V Vital Battery Board III Rev. 49
Single Line Sheet 3
1,2-45N703-4 Wiring Diagrams - Vital Battery Board IV Single Rev. 51
Line Sheet 4
1,2-45N749-1 Wiring Diagrams 480V SD Board 1A1-A Single Rev. 54
Line
1,2-47W801-1 Flow Diagram - Main & Reheat Steam Rev. 120
1,2-47W813-1 Flow Diagram-Reactor Cooling System Rev. 58
1-3591A12 Breaker Setting Sheet 480V S/D Bd 1A1 Rev. 3
1-3591A13 Breaker Setting Sheet 480V Shutdown Board Rev. 4
1A1
2-47W809-1 Flow Diagram - Chemical & Volume Control Rev. 77
System
Engineering 22644 Replace Pressurizer PORVs Due to Current 07/18/2018
Changes Valves Being Obsolete and Reaching End of
Life
Engineering Fire Protection Report Rev. 37
Evaluations
Fire Plans Aux 0-734-02 Fire Protection Pre-Plan, Auxiliary Building El. Rev. 9
734.0
Inspection Type Designation Description or Title Revision or
Procedure Date
AUX-0-734.00 Fire Protection Pre-Plan Auxiliary Building El. Rev. 4
734.0
Aux. 0-734-01 Fire Protection Pre-Plan, Auxiliary Building Rev. 10
Elevation 734.0'
CON 0-685-00 Fire Protection Pre-Plan, Control Building El. Rev. 7
685.0'
Miscellaneous FOR 200283 Fire Protection Impairment Permit 7/15/2020
FOR 200302 Fire Protection Impairment Permit 08/03/2020
FOR 202030 Fire Protection Impairment Permit 1/28/2020
QIR-SPQ-SQN-88-182 CO2 Discharge Times Pre-Operational Test 02/11/1988
SQN-VM-4085 Vendor Manual for Protect-O-Wire Special Rev. 1
Hazards Application
SQN-VM-4534/VD-P115- Peerless Pump Vendor Manual Rev. 6
4534
TCE 2020-12 Transient Combustible Permit 05/01/2020
TCE 2020-20 Transient Combustible Permit 10/03/2020
TCE 2020-21 Transient Combustible Permit 10/03/2020
Procedures 0-MI-FPU-000-001 General Maintenance Instructions for Fire Rev. 15
Protection Systems
0-PI-FPU-317-537.Q Fire and Medical Emergency Equipment Rev. 23
Inventory
0-SI-EBT-250-100.1 Vital Battery Quarterly Inspection 4/9/2020
0-SI-EBT-250-100.3 Vital Battery I and Charger Annual Inspection 8/6/2018
0-SI-EBT-250-100.6 U0 Spare 125 v Vital Batt Charger #1 5/24/2016
Performance Test
0-SI-FPU-0026-002.Y Auxiliary and Diesel Generator Building System 09/26/2019
Flow Test
0-SI-FPU-0026-200R Diesel Engine RPM Factory Test Settings (2100 11/11/2000
RPM)
0-SI-FPU-0026-201R Flow Test Surveillance for Motor-Driven Fire 01/19/2018
Pump
0-SI-FPU-013 Fire Detection Panel 0-L-632 Test Rev. 13
0-SI-FPU-026-201R Flow Test Surveillance for Motor-Driven Fire 06/25/2019
Pump
Inspection Type Designation Description or Title Revision or
Procedure Date
0-SI-SXV-000-206.0 U2 PMT for Vlvs During Refueling 4/10/2020
0-SI-SXV-068-201.0 U2 Stroke Pzr PORVs 11/2/2018
119684884 0-SI-FPU-026-200.R Diesel Driven Fire Pump B 06/22/2019
Month Flow Test
2-PI-OPS-000-0033.0 Periodic Stroking of U2 Time Critical Valves 10/28/2018
AOP-N.08 Fire Safe Shutdown
NPG-SPP-01.3 Housekeeping Rev. 8
NPG-SPP-03.6 Fire Protection Program Change Regulatory Rev. 10
Reviews
NPG-SPP-06.9 Testing Programs Rev. 2
NPG-SPP-06.9.1 Conduct of Testing Rev. 12
NPG-SPP-06.9.2 Surveillance Test Program Rev. 9
NPG-SPP-09.3 Plant Modifications and Engineering Change Rev. 33
Control
NPG-SPP-18.4.5 Fire Protection Quality Assurance Rev. 3
SI-237.1 Powerhouse CO2 Fire Protection System Test 09/30/2019
TVA-NQA-PLN89-A Nuclear Quality Assurance Plan (NQAP) Rev. 38
(Quality Assurance Program Description)
Self- DCP-SQN-18-011 Fire Protection Program Regulatory Review for Rev. 0
Assessments DCN-SQN18-011 (Detection)
None Fire Protection Program Health Report 06/30/2020
None System Health Report (System 26) HPFP 03/31/2020
QA-SQ-19-013 Off-Year Fire Protection Assessment 08/23/2019
Work Orders 115342170 0-PI-FPU-026-122.Y HPFP Yard Flow Test 08.06/14
116401835 2-PI-OPS-000-010.B Verification of Remote 12/10/2015
Shutdown Transfer Switches
117675098 2-PI-OPS-000-010.C Verification of Remote 05/23/2017
Shutdown Transfer Switches
118187526 0-PI-FPU-026-122.Y HPFP Yard Flow Test 06/10/2017
118573914 0-SI-FPU-026-202.R Diesel Fire Pump 18 05/31/2018
Month Inspection
118573915 0-SI-FPU-026-200.R Diesel Driven Fire Pump B 07/23/2018
Month Flow Test
Inspection Type Designation Description or Title Revision or
Procedure Date
119198061 2-PI-OPS-000-010.D Verification Of Remote 12/04/2019
Shutdown Transfer Switches
119684878 0-SI-FPU-026-202.R Diesel Fire Pump 18 06/14/2019
Month Inspection
2027921 0-SI-FPU-026-193.M Motor Driven Fire Pump B 02/06/2020
Mini-Flow Test
203140059 2-PI-OPS-000-010.A Verification of Remote 05/02/2020
Shutdown Transfer Switches
20403941 0-SI-FPU-026-192.M Motor Driven Fire Pump A 03/12/2020
Operability Test
20469066 0-SI-FPU-026-193.M Motor Driven Fire Pump B 04/09/2020
Mini-Flow Test
20501411 0-SI-FPU-026-192.M Motor Driven Fire Pump A 04/16/2020
Operability Test
WO119605602 Power House CO2 Fire Protection System test
WO120314291 Visual Inspection of Fire Dampers for 0-SI-FPU-
031-001R
2