IR 05000333/2024004
| ML25041A282 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick |
| Issue date: | 02/11/2025 |
| From: | Jason Schussler Division of Operating Reactors |
| To: | Rhoades D Constellation Energy Generation |
| References | |
| IR 2024004 | |
| Download: ML25041A282 (1) | |
Text
February 11, 2025
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - INTEGRATED INSPECTION REPORT 05000333/2024004
Dear David Rhoades:
On December 31, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at James A. FitzPatrick Nuclear Power Plant. On February 6, 2025, the NRC inspectors discussed the results of this inspection with Alex Sterio, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
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, Jason E. Schussler, Chief Projects Branch 1 Division of Operating Reactor Safety
Docket No. 05000333 License No. DPR-59
Enclosure:
As stated
Inspection Report
Docket Number:
05000333
License Number:
Report Number:
Enterprise Identifier: I-2024-004-0032
Licensee:
Constellation Energy Generation, LLC
Facility:
James A. FitzPatrick Nuclear Power Plant
Location:
Oswego, NY
Inspection Dates:
October 1, 2024 to December 31, 2024
Inspectors:
E. Miller, Senior Resident Inspector
V. Fisher, Resident Inspector
H. Anagnostopoulos, Senior Health Physicist
D. Beacon, Senior Project Engineer
P. Cataldo, Senior Reactor Inspector
B. Edwards, Health Physicist
M. Hardgrove, Senior Project Engineer
D. McHugh, Reactor Inspector
N. Mentzer, Senior Project Engineer
A. Turilin, Reactor Inspector
Approved By:
Jason E. Schussler, Chief
Projects Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at James A. FitzPatrick Nuclear Power Plant, 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
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000333/2023-004-00 Misaligned Spacer Prevented Tie Breaker Closing Coil Armature Operation on a Magne-Blast for EDG A Subsystem 71153 Closed LER 05000333/2024-002-00 Reactor Protection System Electric Power Monitoring System Trip Caused Primary Containment Isolation 71153 Closed LER 05000333/2024-002-01 Reactor Protection System Electric Power Monitoring System Trip Caused Primary Containment Isolation 71153 Closed
PLANT STATUS
FitzPatrick began the inspection period at rated thermal power. On December 6, 2024, operators reduced reactor power to 73 percent to perform a control rod pattern adjustment and turbine valve testing. The unit was returned to rated thermal power the next day and operated at or near rated thermal power for the remainder of the inspection period.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Control room emergency ventilation air system on October 7, 2024
- (2) Standby gas treatment system on November 4, 2024 (3)
'A' low pressure coolant injection motor operated valve independent power supply system on November 4, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Motor generator set room 300', fire area/zone IA/MG-1 on October 7, 2024
- (2) Emergency diesel generator spaces north 272', fire area/zones VI/EG-3, EG-4, and EG-6 on October 7, 2024
- (3) Crescent area west 227' and 242', fire area/zone XVIII/RB-1W on October 8, 2024
- (4) Standby gas filter room 272', fire area/zone XX/SG-1 on October 8, 2024
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on December 17, 2024.
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)
- (1) The inspectors observed operations personnel during the 'B' and 'D' emergency diesel generator 8-hour full load surveillance test on November 4, 2024, and during a control rod pattern adjustment and power reduction on December 6 and 7, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed a simulator scenario evaluation that included a reactor water cleanup leak, loss of 10500 bus, main condenser air leak, and torus leak on October 29, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended functions:
- (1) Reactor protection system motor generator sets on November 20, 2024
- (2) Reactor building exhaust effluent radiation monitor, 17RM-452A, on November 26, 2024
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) Elevated risk during 'A' emergency service water (ESW) pipe replacement following a through-wall leak on December 12, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)13MOV-16, reactor core isolation cooling steam supply isolation valve following refuel outage stem coefficient of friction and motor voltage evaluation on November 6, 2024 (2)13MOV-16, following a steam leak after a seal weld repair on November 13, 2024
- (3) ESW supply pipe through-wall leak on 66UC-22C, west crescent area unit cooler on November 19, 2024 (4)71DSC-10011, 115 kilovolt (KV) manual disconnect switch following broken gear on November 22, 2024
- (5) Rod block monitor on December 9, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) Permanent Modification: Compressed Air System Hardening: Installation of Air Dryer Bypass Line and 39BAS-2 Internals Removal on October 25, 2024
- (2) Temporary Modification: 13MOV-16(OP) Reactor Core Isolation Cooling Steam Supply Outboard Containment Isolation Valve Weld Temporary Repair on November 6, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (7 Samples)
- (1) Main steam safety relief valves 'C,' 'E,' 'K,' and 'L' following replacement on October 2, 2024
- (2) Bypass instrument air dryer following excessive blowdown on October 22, 2024
- (3) Service air isolation valve 39FCV-110 following failure to close on October 22, 2024 (4)29AOV-86B and 29AOV-86C main steam isolation valve following actuator replacement on October 28, 2024
- (5) Reactor pressure vessel hydrostatic test following planned refuel and maintenance outage on November 4, 2024 (6)13MOV-16 reactor core isolation cooling steam supply isolation valve following seal weld temporary leak repair on November 7, 2024
- (7) ESW following 'A' pipe replacement due to a leak on December 17, 2024
Surveillance Testing (IP Section 03.01) (4 Samples)
- (1) ST-2F, Low Pressure Coolant Injection Simulated Auto Actuation Test, on October 7, 2024
- (2) ST-6M, Standby Liquid Control Recirculation Injection Test, on October 7, 2024
- (3) ST-2HB, Low Pressure Coolant Injection Logic System 'B' Functional Test, on October 15, 2024
- (4) ST-9CB, 'B' Division Loss of Offsite Power Test and Loss of Coolant Accident Test, on November 6, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) ST-24J, Reactor Core Isolation Cooling Flow Rate and Inservice Test (IST), on December 18, 2024
Containment Isolation Valve (CIV) Testing (IP Section 03.01) (1 Sample)
- (1) ST-39B, Main Steam Isolation Valve Local Leak Rate Test, on October 2,
RADIATION SAFETY
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Main stack exhaust radiation monitor 17RM-50A
- (2) Reactor building perimeter drain sump and sampling system (west outfall)
- (3) Turbine building ventilation exhaust radiation monitor 17RM-432
- (4) Liquid radwaste radiation monitor 17RM-350
Sampling and Analysis (IP Section 03.02) (4 Samples)
Inspectors evaluated the following effluent samples, sampling processes and compensatory samples:
- (1) Collection and analysis of the weekly particulate sample for the refuel floor exhaust pathway
- (2) Collection and analysis of the weekly iodine sample for the refuel floor exhaust pathway
- (3) Collection and analysis of the weekly liquid sample from the reactor building curtain drains
- (4) Collection of the weekly particulate and iodine sample from the main stack exhaust
Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) Permit number G-20240402-13542-C, stack particulate/iodine, continuous release
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15)===
- (1) For the period of October 1, 2023 through September 30, 2024 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) For the period of October 1, 2023 through September 30, 2024
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Issue Report (IR) 04803804 - Automatic Voltage Regulator (AVR) Response Following Reactor Scram
- (2) IRs 04669409 and 04550060 - 4160-Volt Circuit Breaker Corrective Actions
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the FitzPatrick corrective action program to identify potential trends that might be indicative of a more significant safety issue.
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensees event reporting determinations to ensure it complied with reporting requirements.
- (1) Licensee Event Reports (LERs) 05000333/2024-002-00 and LER 05000333/2024-002-01, Reactor Protection System Electric Power Monitoring System Trip Caused Primary Containment Isolation (ADAMS Accession Nos.
ML24327A097 and ML24327A097, respectively). The inspectors determined that the cause of the conditions described in these LERs were not reasonably within the licensee's ability to foresee and correct, and therefore were not reasonably preventable. No performance deficiency nor violation of NRC requirements was identified. These LERs are Closed.
- (2) LER 05000333/2023-004-00, Misaligned Spacer Prevented Tie Breaker Closing Coil Armature Operation on a Magne-Blast for EDG A Subsystem (ML23335A068). The inspectors reviewed the updated LER submittals. The inspection conclusions associated with this LER are documented in the Inspection Results of Inspection Report 05000333/2023002 (ML23219A114). This LER is Closed.
Personnel Performance (IP Section 03.03) (2 Samples)
- (1) The inspectors evaluated the degrading instrument air header pressure following excessive purge flow on the bypass dryer system, and the licensee's performance, on October 22, 2024.
- (2) The inspectors evaluated the 'A' reactor water recirculation pump speed decrease, and the licensee's performance, on November 27, 2024.
Reporting (IP Section 03.05) (2 Samples)
- (1) Condensate storage tank valve pit monitoring well water sample results on October 29, 2024 (IR 04813216). The event was reviewed to determine if reporting requirements were met and should have been reported by the licensee.
- (2) Thermal Overload Relay Interim Part 21 (EN 57437) on November 22, 2024. The event was reviewed to determine if reporting requirements were met and should have been reported by the licensee.
INSPECTION RESULTS
Minor Performance Deficiency 71152A IRs 04669409 and 04550060 - 4160 Volt Circuit Breaker Corrective Actions
The inspectors performed a review of corrective actions associated with 4 KV breaker failures that were documented in NRC Inspection Report 05000333/2023002 (ML23219A114).
FitzPatrick staff completed a level 2 cause evaluation, a corrective action program evaluation (CAPE), in IR 04550060. The inspectors reviewed the results of the CAPE, which determined the station was not implementing preventive maintenance consistent with the Constellation fleet preventive maintenance template, and that maintenance procedures did not contain adequate instructions to perform the maintenance for a 4 KV breaker cubicle. The stations review of internal operating experience also determined there were several missed opportunities to identify the inadequacies with breaker cubicle alignment procedures dating back to cause evaluations performed in 2012 (CR-JAF-2012-06868) and 2013 (CR-JAF-2013-02237).
The inspectors identified that three action items (ACIT) to conduct procedure revisions for maintenance procedures MP-054.01, 4.16 KV Magne-Blast Breaker, and MP-054.02, 4.16 KV Bus and Metal-Clad Switchgear Maintenance, were not completed after the action items were closed in the system. The inspectors found the following ACITs were not completed after they were closed: 0455060-22, 0455060-28 and 0455060-32. The station captured the failure to complete the ACITs in IRs 04824708, 04828294 and 04830431.
The inspectors also identified the breaker cubicle for 71-10650, 4KV breaker feed to 10P-3C(M) residual heat removal pump C motor did not receive the corrective maintenance that was performed on the other safety-related 4 KV circuit breakers. This issue was entered into the corrective action program as IR 04830101.
The inspectors determined that the stations failure to properly update and implement effective breaker cubicle maintenance procedures was a performance deficiency. Specifically, by closing the ACITs without issuing properly updated procedures the station remained vulnerable to additional 4 KV breaker failures. The inspectors determined this was also a violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. Title 10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to this requirement, procedures used at FitzPatrick to service and inspect safety-related 4 KV breaker cubicles did not include appropriate quantitative or qualitative acceptance criteria to ensure that the breakers and breaker cubicles were properly aligned to prevent interference during breaker operation. As discussed earlier, the station generated IRs 04824708, 04828294, and 04830431 to ensure the breaker maintenance procedures are updated and properly issued. This failure to comply with 10 CFR Part 50, Appendix B, Criterion V constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
Screening: The inspectors determined the performance deficiency was minor. Specifically, Constellation has not experienced an additional failure since performing the corrective actions in the CAPE. Also, many of the breakers are cycled periodically during surveillance testing and no new failures have been identified. In addition, Constellation has performed corrective maintenance on all safety-related 4 KV breaker cubicles in response to the CAPE. The prior failures were evaluated by inspectors and dispositioned in NRC Inspection Report 05000333/2023002.
Observation: Automatic Voltage Regulator Response Following Reactor Scram on September 23, 2024 71152A In October of 2020 a fleet modification was implemented at FitzPatrick to install a new AVR for the main generator. The modification was developed by the fleet for all Constellation stations. The testing for the AVR consisted of a factory acceptance test (FAT) and a site acceptance test once installed. The FAT was performed with the setting for the minimum field current limiter enabled. During post-modification installation testing, the station performed testing to ensure settings were correct that would protect the main generator. Following satisfactory testing and incorporation of fleet operating experience, the minimum field current limiter was disabled.
The inspectors conducted a review of available information and found that although some information was captured in accordance with IP-ENG-001, Standard Design Process, FitzPatrick staff did not include specific detail to understand the disabling of the minimum field current limiter. The inspectors found through interview that it was understood through post-modification testing, additional data and fleet operating experience that additional under-excitation limiters would provide redundant protection.
The inspectors concluded that although a scram may have occurred due to the minimum field current limiter being disabled, this was not reasonable to foresee and prevent because the grid conditions were beyond any previous analysis performed. Constellation is continuing to study the grid conditions experienced and plans to make any necessary changes to their main generator protection system.
Minor Performance Deficiency 71152S Semi-Annual Trend
The inspectors evaluated a sample of issues and events that occurred over the third and fourth quarters of 2024. The evaluation did not reveal any new trends that could indicate a more significant safety issue. The inspectors determined that, in most cases, the issues were appropriately evaluated by Constellation staff for potential trends at a low threshold and resolved within the scope of the corrective action program.
The inspectors identified a trend associated with leaks from the ESW system pipes and heat exchangers. Since September of 2024, three through-wall ESW pipe leaks and two-unit cooler tube leaks occurred. Three of the five leaks were identified by the NRC inspectors. The station documented the trend in IR 04823124.
The NRC inspectors also identified a trend associated with ineffective corrective actions that have resulted in repeat failures of equipment. Equipment issues included the A reactor building exhaust radiation monitor sample pump failure, an instrument air alternate dryer failure, A reactor water recirculation motor generator set unexpected minor changes in speed, and failures of the B reactor protection system motor generator set power supply.
Constellation generated IRs to document the trends in IRs 04823091, 04819213, and 04813835.
Screening: The inspectors determined the performance deficiency was minor. The inspectors determined that Constellations failure to address the leak trend with a trend IR was minor because each issue was entered individually into the corrective action program and addressed. In addition, the inspector reviewed each equipment issue to determine if the issue was more than minor. The inspectors determined that each issue did not impact safe plant operation or affect the safety function of the associated system. Based on the overall results of the semi-annual trend review, the inspectors determined that Constellation had generally identified adverse trends before they could become more significant safety problems. The inspectors independently evaluated the deficiencies noted above for significance in accordance with the guidance in IMC 0612, Appendix B, Issue Screening, and Appendix E, Examples of Minor Issues, and determined them to be minor.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On February 6, 2025, the inspectors presented the integrated inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
- On October 10, 2024, the inspectors presented the radiation protection inspection results to Alex Sterio, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
Flow Diagram Control and Relay Rooms Heating and
Ventilation System 70
600V One Line Diag-S
- H. 14 71mcc-332, 342, 155 and 165
Flow Diagram Standby Gas Treatment System 01-125
Procedures
MA-JF-731-001
SGTS, CREVAS, and TSCVASS Testing
LPCI 71BAT-3A Battery Monthly Surveillance Test
001
LPCI Independent Power Supply System
Control Room Ventilation and Cooling
Relay Room Ventilation and Cooling
Fire Plans
Crescent Area-West Elev. 227', 242' Fire Area/Zone
XVIII/RB-1W
Standby Gas Filter Room Elev. 272' Fire Area/Zone XX/SG-
Motor Generator Set Room Elev. 300' Fire Area/Zone
IA/MG-1
Emergency Diesel Generator Spaces-North Elev. 272' Fire
Area/Zone VI/EG-3, EG-4, EG-6
Procedures
Fire Drill Performance
71111.11Q Procedures
EDG B and D Full Load Test
Corrective Action
Documents
04670001
04680732
04721539
04774208
04785661
04788292
Corrective Action
Documents
Resulting from
Inspection
04819203
04819213
Procedures
Preventive Maintenance Program
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Equipment Classification
Reactor Building Gaseous Effluent Monitors
Corrective Action
Documents
04822877
04823124
Corrective Action
Documents
04801389
04803911
04804112
04818300
04819086
Engineering
Changes
2449
Evaluation of Voltage Needed to Close 13MOV-16 in DBA
Work Orders
05581552
Corrective Action
Documents
04803500
Engineering
Changes
635997
Compressed Air System Hardening: Installation of Air Dryer
Bypass Line and 39BAS-2 Internals Removal
2527
13MOV-16 Seal Weld Temporary Repair
Corrective Action
Documents
04801976
04803001
04811081
04811081
04811082
04814994
04814997
Drawings
Flow Diagram Reactor Core Isolation Cooling System 13
Miscellaneous
C684-0289
Crane Operation and Maintenance Manual
Procedures
Motor Operated Valve Maintenance and Testing Guidelines
Air Operated Valve Categorization
Air Operated Valve Testing Requirements
Test Equipment Set Up for 10500 and 10600 Emergency
Bus Sequencing Test ST-9C*
Post Maintenance Testing
Standby Liquid Control Explosive Valves (IST)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SEP-IST-007
Inservice Testing (IST) Program Program Plan
29
Manual Safety Relief Valve Operation System Test (IST)
RCIC Flow Rate and Inservice Test (IST)
LPCI and LPCI MOV Power Supply Simulated Automatic
Actuation Test
LPCI Initiation Logic System B Functional Test
Type B and C LLRT of Containment Penetrations (IST)
Type C Leak Test Main Steam Line A MSIVS (IST)
Type C Leak Test Main Steam Line B MSIVS (IST)
Type C Leak Test Main Steam Line C MSIVS (IST)
Type C Leak Test Main Steam Line D MSIVS (IST)
RPV System Leakage Test
Standby Liquid Control Recirculation, Injection Test (IST, ISI) 15
EDG B and D Load Sequencing Test and 4KV Emergency
Power System Voltage Relays Instrument Functional Test
Work Orders
05310039
05311049-01
05311051-01
05311053-01
05311056-01
05311158
05311434
05312802
05312969
05322361
05325243
05325246
05338573
05372539
05372540
05377513
05580109
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
05590970
05591036
05600848
05605976
Corrective Action
Documents
04686903
04708932
04731298
04803804
Procedures
Issue Identification and Screening Process
Corrective Action Program (CAP) Procedure
Corrective Action Program Evaluation Manual
Corrective Action
Documents
04811081
04811082
04813216
04820129
Miscellaneous
Procedures
Unplanned Power Change
Unexpected Change in Core Flow
41