IR 05000400/1992002

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Insp Rept 50-400/92-02 on 920118-0214.Noncited Violations Noted.Major Areas Inspected:Plant Operations,Radiological Controls,Security,Fire Protection,Surveillance & Maint, Design Mods,Cold Weather Preparations & Event Repts
ML18010A563
Person / Time
Site: Harris 
Issue date: 02/24/1992
From: Christensen H, Shannon M, Tedrow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18010A561 List:
References
50-400-92-02, 50-400-92-2, NUDOCS 9203100145
Download: ML18010A563 (19)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

10'l MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323 Report No.:

50-400/92-02 Licensee:

.Carolina Power and Light Company P.

0.

Box 1551 Raleigh, NC 27602 Docket No.:

50-400 License No.:

NPF-63 Inspectors:

J.

edro

,

enior Resident Inspector

. Shannon, Resident Inspector Fac>lsty Name.

Harris

Inspection Conducted:

January 18 - February 14, 1992 ate Signed z ~/ M Date S gned Approved by:

~H.

r stensen, ection ie Divis on of Reactor Projects zzgf+

a e

igned Scope; SUMMARY

'I This routine inspection was conducted by two resident inspectors in the areas of pl ant operations, radi ol ogi cal control s, securi ty, fire protecti on, surveillance observation, maintenance observation, design changes and modifications, cold weather preparations, licensee event reports, and licensee action on previous inspection items.

Numerous facility tours were conducted and facility operations observed.

Some of these tours and observations were conducted on backshifts.

Results:

A non-cited violation is discussed in paragraph 3.b regarding a failure to document an identified deficiency with a motor operated valve.

A weakness was identified in paragraph 3.a regarding an improperly connected pressure gage during the performance of a surveillance test.

The l'icensee's pre-planning for the installation of a modification in the component cooling water system was considered to be good, paragraph 5.

9203100145 920224 PDR ADOCK 05000400

PDR

REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • J. Collins, Manager, Operations C. Gibson, Manager, Programs and Procedures
  • C. Hinnant, General Manager, Harris Plant B. Neyer, Manager, Environmental and Radiation Monitoring
  • R. Morgan, Manager, Harris Project Assessment
  • T. Norton, Manager, Maintenance
  • J. Nevill, Manager, Technical Support'.

Olexik, Manager, Regulatory Compliance A. Powell, Manager, Harris Training Unit

  • R. Richey, Vice President, Harris Nuclear Project H. Smith, Manager, Radwaste Operation E. Willett, Manager, Outages and Modifications W. Wilson, Manager, Spent Nuclear Fuel Other licensee employees contacted, included office, operations, engineering, maintenance, chemistry/radiation and corporate personnel.

Nuclear Regulatory Commission M. Glasman, Project Engineer

  • D. Roberts, Resident Inspector Intern
  • Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph..

2.

Review of Plant Operations (71707)

The plant continued in power operation (Mode 1) for the duration of this inspection period.

a

~

Shift Logs and Facility Records The inspector reviewed records and discussed various entries with operations personnel to verify compliance with the Technical Specifications (TS)

and the licensee's administrative procedures.

The following records were reviewed:

Shift Supervisor's Log; Control Operator's Log; Night Order Hook; Equipment Inoperable Record; Active Clearance Log; Jumper and Wire Removal Log; Temporary Modification Log; Chemistry Daily Reports; Shift Turnover Checklist; and selected Radwaste Logs.

In addition, the inspector independently verified clearance order tagout In general, the inspectors found the logs to be readable, organized, and:-.provided sufficient information on plant status and events.

A deficiency regarding the logging of a valve problem was noted and is discussed in paragraph 3.b.

Clearance tagouts were found to be properly implemented.

No violations or deviations were identified.

b.

= Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations, surveillance, and maintenance activities in progress.

Some of these observations were conducted during backshifts.

Also, during this inspection period, licensee meetings were attended by the inspectors to observe planning and management activities.

The facility tours and observations encompassed the following areas:

security perimeter fence; control room; emergency diesel generator building; reactor auxiliary building; waste processing building; turbine building; fuel handling building; emergency service water building; battery rooms; electrical switchgear rooms; and the technical support center.

During these tours,'he following observations were made:

( 1)

Monitoring Instrumentation

-

Equipment operating status, area atmospheric and liquid radiation monitors, electr'ical system lineup, reactor operating parameters, and auxiliary equipment

'operating parameters were observed to verify that indicated parameters were in accordance with the TS for the current operational mode.

(2)

Shift Staffing - The inspectors verified that operating shift staffing was in accordance with TS requirements and that control room operations were being conducted in an orderly and professional manner.

Operator overtime audi ts were reviewed for 1991, particularly for the refueling outage and emergency exercise which involved increased usage of overtime to meet shift demands.

The inspectors verified'hat overtime usage was controlled in accordance with AP-012, Control of Overtime Hours.

In addition, the inspector observed shift turnovers on various occasions to verify the continuity of plant status, operational problems, and other pertinent plant information during these turnovers.

(3)

Plant Housekeeping Conditions

-

Storage of material and components, and cleanliness conditions.of various areas

. throughout the facility were observed to determine whether safety and/or fire hazards existed.

(4)

Radiological Protection Program - Radiation protection control activities were observed routinely to verify that these activities were in conformance with the facility policies and procedures, and in compliance with regulatory requirements.

The

inspectors also reviewed selected radiation work permits to verify that controls were adequate.

(5)

Security Control -

The performance of various shifts of the security force was observed in the conduct of daily activities which included:

protected and vital area access controls; searching of personnel, packages, and vehicles; badge issuance and retrieval; escorting of visitors; patrols; and compensatory posts.

In addition, the inspector observed the operational status of Closed Circuit Television (CCTV) monitors, the Intrusion Detection system in the central and secondary alarm stations, protected area lighting, protected and vital'rea barrier integrity, and the security organization interface with operations and maintenance.

(6)

Fire Protection

- Fire protection activities, staffing and equipment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency equipment, and fire barriers were operable.

The inspectors found plant housekeeping and component material condition to be good.

The licensee's adherence to radiological controls, security controls, fire protection requirements, and TS requirements in these areas were satisfactory.

c.

Review of Nonconformance Reports Adverse Condition Reports (ACRs)

were reviewed to verify the following:

TS were complied with, corrective actions as identified in the reports were accomplished or being pursued for completion, generic items were identified and reported, and items were reported as required by the TS.

No violations or deviations were identified.

3.

Surveillance Observation (61726)

Surveillance tests were observed to verify that approved procedures were being used; qualified personnel were conducting the tes'ts; tests were adequate to verify equipment operabil*ity; calibrated equipment was utilized; and TS requirements were followed.

The following tests were observed and/or data reviewed:

- OST-1014

- OST-1070

- OST-1077 Turbine Valve Test Monthly Interval Axial Flux Difference Monitoring and Logging Auxiliary Feedwater Valves Operability Test quarterly Interval

- OST-1118

- OST-121'4 Containment Spray Operability Train A quarterly Interval Emergency Service Water System Operability, Tr'ain A quarterly Interval

- NST-I0067 Turbine First Stage Pressure Loop (P-0447)

Reactor Calibration

- NST-I0068 Turbine First Stage Pressure Loop Calibration

- NST-I0164 Nuclear Instrumentation System Power Range N42 Operational Test

- NST-I0319 Main Turbine Electrical Overspeed Protection System

~

Channel Calibration

- NPT-I0002 Ralph A. Hiller Model 12SA-A029 Valve Actuator

- EPT-113 Determination of Feedwater Flow Split Ratio

- EPT-393 Preheater Bypass Valve Accumulator Drop Test In general, the performance of these procedures was found to be satisfactory with proper use of test equipment, necessary communications established, notification/authorization of control room personnel, and knowledgeable personnel performed the tasks.

However, problems associated with the performance of procedures OST-1118 and OST-1214 were observed and are discussed below:

a.

Several problems were noted by the inspector during the performance of procedure OST-1118.

On January 29, 1992, licensee personnel performed a containment spray operability test which required the installation of a differential pressure gauge to measure eductor flow.

Following performance of the flow test, it was discovered by the test crew that the gauge was reading a differential pressure with the spray pump secured (with no actual differential pressure across the gauge).

A check of the gauge showed it was still within calibration and improper gauge venting was suspected as the cause of the erroneous readings during initial installation.

The gauge was reinstalled in the system for a second test.

This time, however, the test hoses connecting the high and low side gauge inputs were switched at the flow orifice connections.

This resulted in erroneously low readings during'he second pump run.

In Nay 1989, licensee personnel identified a discrepancy with the noun identifiers (high and low side)

being switched for these two test connections.

Although a trouble tag and work request were initiated at that time to correctly tag the valves, no actions were taken to correct this deficiency prior to January 29, 199 b.

While the mislabeling at the orifice connections could have been a

contributor to switching the hoses, the presence of both the deficiency tag and the test procedure, which properly referenced the two connections should have alerted the crew to the tag problem and the potential for improperly connecting the gauge.

The inspectors considered the technician's attention to detail during the connecting and venting processes to be weak.

In addition, the inspectors considered the licensee's correcti.ve'ctions to correct the mislabeling of the test connections to be weak.

On February 3,

1992, while observing activities associated with the performance of OST-1214, the inspector noted that the valve isolating NSW from the ESW header, 1SW-275, failed to stroke full open when operated by the control board operators.

On the following day, the inspectors reviewed control room logs and the test procedure and found that the problem with 1SW-275 was not documented.

When questioned, operating personnel investigated the previous day's valve fai lure and retested the valve.

Although the valve was stroked successfully, on-shift operating personnel agreed that the problems with 1SW-275 should have been recorded in accordance with procedure PLP-002, Corrective Action Program.

The licensee determined that the most likely cause of the problem was associated with the valve torque switch.

These torque switches are by-passed during ESF actuation signals, therefore the valve would not have been affected during an ESF actuation.

Since the valve was tested successfully following the problem on February 3, the inspectors view the safety significance of this finding to be minor.

In addition, licensee management have included discussion of this issue in an operations night order which was read by each control room shift.

This NRC identified violation is not being cited because criteria specified in Section V.A of the NRC Enforcement Policy were satisfied.

NCV (400/92-02-01):

Failure to document identified deficiencies in accordance with procedure PLP-002.

4.

Maintenance Observation (62703)

The inspector observed/reviewed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits, as required, were issued and being followed; quality control personnel were available for inspection activities as required; and, TS requirements were being followed.

Maintenance was observed and work packages were reviewed for the following maintenance (WR/JO) activities:

Replacement of power supply card for a containment pressure channel in accordance with procedure MST-I0006, Containment Pressure (P-0953)

Calibratio Troubleshooting failure to open problem with motor operated valve 1SW-270 in accordance with procedures CH-I0002, AC Limitorque Calibration Check and Stroking, and PH-I0020, Limitorque Operator Inspection.

Troubleshooting the Cape Fear line breaker failure to close on demand.

Efforts by the utility's traveling line crew were observed.

Calibration of main feedwater flow transmitters in accordance with procedures LP-F-20038, Hain Nozzle Flow -

Steam Generator B

Calibration, LP-F-2003C, Hain Nozzle Flow -

Steam Generator C

Calibration, 'nd LP-F-2003A, Main Nozzle Flow - Steam Generator A

Calibration.

Troubleshooting failure of the anticipated transient without scram panel in accordance with procedure MPT-I0119, Instructions for Reprogramming AMSAC Set Point Constants.

In general, the maintenance observed was performed satisfactory.

Appropriate procedures were utilized and proper return to service of affected components independently verified by the craft.

The review of the main feedwater flow transmitter calibration included the licensee's process for obtaining test data, per procedure EPT-113, calculation of appropriate scaling factors, and incorporation of this data into the calibration procedures.

The inspector found the licensee's method to be

= satisfactory.

a

~

During the replacement of the power supply card for the containment pressure channel, the inspector noted that the work request'ticket (WR 92-ABTJ1)

was classified as non-safety work.

Since this channel performed several safety-related functions, the inspector considered the non-safety classification incorrect.

This matter was discussed with licensee instrumentation and controls personnel.

The replacement card was procured as a safety-related component and the work was performed in accordance with approved procedures.

The inspector concluded that quality work had been performed even though the work ticket was classified as non-safety.

Licensee personnel informed the inspector that the computer data base (EDBS)

used to obtain this classification has many process instrument components listed twice dependent on function and in many cases under separate system numbers, and that many of these dual listings did not contain the same safety classification.

In this case the system function had been classified as non-safety yet the card tag number was classified as safety-related.

This issue was further discussed with licensee engineering, personnel.

The data base errors had previously been identified in January 1991, and a plant change request, PCR-5666, g-Class Discrepancies in Various PIC Cards, had been initiated to correct the discrepancies.

The PCR was scheduled to be completed in March 199 Inspector Follow-up Item (400/92-02-02):

Follow the licensee's activi ties to correct safety classifications in.the equipment data base.

b.

Following the failure of service water valve 1SW-270 to stroke, it was noted that the licensee had reduced the torque switch setting following the initial stroke failure.

Several service water valves were identified with torque switch settings higher than the manufacturer's original recommendations.

It was noted that during construction field change request FCR-N-1994 had been initiated to increase the torque switch settings.

Per correspondence from the manufacturer, dated August 27, 1986, the maximum allowable torque switch settings were reevaluated and changed.

The torque switch for service water valve 1SW-270 was reset at the higher value and was retested satisfactory.

5.

Design Changes and Nodifications (37828)

Installation of new or modified systems were reviewed to verify that the changes were reviewed and approved in accordance with 10 CFR 50.59, that the chan'ges were performed in accordance with technically adequate and approved procedures, that subsequent testing and test results met acceptance criteria or deviations were resolved in an acceptable manner,

'nd that appropriate drawings and facility procedures were revised as necessary.

This review included selected observations of modifications and/or testing in progress.

The following modifications/design changes were reviewed:

PCR-1006 Freeze Protection Nodification for the Diesel Generator Building Fire Suppression System.

'CR-5138 Essential Chiller Expansion Tank Sightglass and Level Transmitter Reference Leg.

PCR-5495 Heater Drain Pump Seal Water Flow Orifice and Seal Water Flow Switch Nodification.

PCR-5748 CCW Thermal Relief Valve Deletion PCR-6158 Steam Generator Preheater Bypass Control Valves Pneumatic Control Circuit Pressures (Air Amplifier Failure).

Field revision number 5 for PCR-6158 added new air pressure regulators into the system.

Field revision number 1 for PCR-5748 replaced additional relief valves on the component cooling water lines to the spent fuel heat.

exchangers.

Proper tagging of the clearance boundaries was verified.

The performance of work was satisfactory with proper post-modification testing performed prior to returning the systems to operable status.

Good contingency planning was observed for the, CCW thermal relief valve modification.

Pre-evolution briefings for craft personnel and operating personnel covered the potentially serious consequences which could arise

s if CCW system.inventory was lost through the freeze seals utilized to isolate the portions of the system being modified.

Abnormal operating procedures were referenced and access was staged to remote valves to enable quick manual operation if necessary.

A licensed senior reactor.

operator was utilized to monitor work in the field and report status to the control room.

Control room personnel monitored and trended important CCW system parameters during the work.

The modification was installed without mishap.

No violations or Deviations were identified.

Cold Weather Preparations (71714)

The inspectors reviewed the licensee's preparations and administrative controls established to protect plant equipment during cold weather.

The licensee implemented procedure AP-301, Adverse Weather Operations, section 5. 1, when ambient temperature reached 35 degrees F.

In addition, generic rounds guidance required Auxiliary Operators (AO) to ensure temperature conditions were normal in areas they inspect.

Specific guidance documents required the AO to check'reeze protection panels and space heaters for operability, as well as thermostat settings for installed space heaters in critical instrumentation cabinets.=

The inspector also noted that operator'raining was relied upon to trigger entry into the procedure.

The inspector toured the turbine building and outdoor areas of the plant to ascertain the condition and operability of freeze protection equipment.

Open work requests were also reviewed with licensee personnel.

Alarm response procedures for the heat trace panels were also reviewed.

All freeze protection equipment inspected was found to be in good condition, and appropriate measures had been taken to protect plant equipment from freezing.

Personnel contacted by the inspector were aware of freeze pr'otection measures and required actions.

In addition, the licensee indicated that there were no significant system failures or problems associated with cold weather or failures of freeze protection equipment.

The inspector noted that the licensee employed temporary "tents erected over the instrument air compressors, with portable space heaters inside, to help.prevent freezing of these components.

In the radwaste control room approximately half of the 36 heat trace panel annunciators were in alarm.

The licensee's alarm response procedure APP-ill, Freeze Protection and Temperature Maintenance, directed the operator to log alarms and notify the main control room.

This procedure was observed to be properly followed for several of the existing alarms.

A typical response for the operator would then be to check the associated heat trace panel for circuit failure lights to identify the faulted circuits so a work request could be generated to fix the identified problem.

k The licensee's preventive maintenance for these circuits consisted of annual calibration checks which included a check of the electrical current through the circuit to verify adequate heater operation.

The inspector

noted that a significant backlog existed in outstanding open work tickets associated with various.freeze protection components.

A review of outstanding work orders, in the planned but not scheduled category, indicated that approximately 20 work orders involved problems with freeze protection circuits that were not in proper working order.

Approximately half of these work orders were over six months old.

Procedure AP-301 lacked a specific checklist for the AO to perform his cold 'weather round, Only general statements requiring the operator to check that heat trace panels were energized was included.

Considering the numerous heat trace panels in the plant, a lot of reliance was placed on the operator's memory.

The procedure was also inconsistent in referencing other operating procedures and the precautions contained therein.

Some of the procedures referenced contained specific precautions for cold weather operation, yet others did not.

These comments were discussed with licensee management personnel who stated that appropriate procedure clarifications would be considered.

\\

The inspector considered the material condition of the installed freeze protection equipment to be adequate and associated administrative controls should prevent critical plant equipment from freezing.

However, the licensee was encouraged to decrease the work order backlog and make enhancements to administrative procedures to clarify expected operator acti on.

7.

Review of Licensee Event Reports (92700)

The following LERs were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriate.

Events that were reported immediately were reviewed as they occurred to determine if the TS were satisfied.

LERs were reviewed in accordance with the current NRC Enforcement Policy.

a.

(Open)

LER 90-03:

This LER reported that a train of essential services chilled water was inoperable due to air intrusion into the system.

This matter was previously discussed in NRC Inspection Report 50-400/90-06.

The licensee has completed procedure revisions to allow system venting, developed logs for monitoring chiller performance, granted system engineer access to chemical addition records, completed a plant modification to allow chiller expansion tank sight-glasses to remain in-service, and has, performed a root cause investigation into the event.

The root cause investigation revealed further measures which needed to be taken which included additional plant modifications.

. These modifications will include a

reduction in the number of continuous alarms on the chiller expansion tanks (PCR-3961),

change the normal makeup water supply from fire water to demineralized water to improve system cleanliness (PCR-5534),

and provide reliable expansion tank pressure control (PCR-2512).

The licensee plans to install these modifications during the next refueling outage scheduled for September 1992.

The LER will remain open pending completion of this actio b.

c ~

d.

e.

9 ~

(Closed)

LER 90-06:

This LER reported the operation of the plant in an unanalyzed condition with waste gas decay, tanks cross connected.

This event was previously discussed in NRC Inspection Report.

50-400/90-06.

The licensee has completed appropri'ate procedure changes and conducted training for operators to preclude recurrence of this event.

An engineering evaluation was performed to allow cross connecting of the tanks to support system operation.

The licensee plans to revise the FSAR for this method of operation during the next routine FSAR update.

(Closed)

LER 91-11:

This LER reported that the concentration of boron in the refueling water storage tank was in excess of TS limits.

This event was previously discussed in NRC Inspection Report 50-400/91-16.

The licensee has reviewed this event with chemistry and operating personnel and has revised applicable procedures to specify acceptance ranges for test data.

(Closed)

LER 91-13:

This LER reported a reactor trip which occurred during plant cooldown.

This event was previously discussed in NRC Inspection Report 50-400/91-16.

The licensee has revised the surveillance test procedure to clarify restoration requirements and has re-emphasized. effective communications and adherence to written procedures.

The licensee is investigating a possible alternative for connection of the reactivity computer which would not require an NI channel to be placed in the tripped condition.

(Closed)

LER 91-15:

This LER reported an unplanned actuation of the auxiliary feedwater system due to an improperly adjusted feed flow transmitter dampening device.

This item was previously discussed in NRC Inspection Report 50-400/91-16.

Although a

review of the modification process was performed by licensee personnel, this review failed to identify any needed improvements.

The inspector therefore concluded that the root cause of this event should have been

~identified as personnel error.

(Closed)

LER 91-17:

This LER reported that a composite sample for a secondary waste tank continuous release was not taken as required by the TS.

"This item was previously discussed in NRC Inspection Report 50-400/91-21.

The licensee has reviewed this event with chemistry and radwaste personnel and has revised the operating procedure to include administrative controls to verify that the composite sampler has been properly placed in service.

(Closed)

LER 91-21:

This LER reported a deficiency'in the computer program used to calculate containment sump leakrates, This matter was identified by licensee personnel during a routine RCS chemistry sample for which sump inleakage was anticipated but corresponding change in leakrate was not observed.

The licensee has corrected the computer program deficiency and has reviewed this event with applicable plant personne '

h.

(Open)

LER 92-01:

This LER reported that the swing charging/safety injection pump was not provided with adequate ventilation when aligned to the

"A" safety bus.

The licensee has revised appropriate plant procedures and locked the applicable ventilation dampers in the open positi,on.

A plant modification (PCR-6192)

was implemented to add blank flanges to the ventilation ducts in the spare room.

This LER will remain open pending a review of design drawings to ensure manual dampers are included in plant procedures and that required blank flanges are installed.

8.

Licensee Action on Previously Identified Inspection Findings (92702

92701)

a.

(Closed)

Violation 400/91-15-01:

Failure to maintain two operable automatic reactor tri'p channels.

The inspector reviewed and verified completion of the corrective actions listed in the licensee's response letter, dated August 16, 1991.

The temporary jumper and wire removal procedure (AP-024)

has been revised, to provide guidance for use of-jumpers while troubleshooting.

The modified UV card circuit boards have been installed and operations manager review and concurrence of voided post-maintenance testing for SSPS is now required.

b.

(Closed) Violation 400/91-15-02:

Failure to properly implement plant procedures.

The inspector reviewed and verified completion of the corrective actions listed in the licensee's response letter, dated August 16, 1991.

Personnel involved in maintenance and modification work have been caution'ed to ensure that post-maintenance testing is extensive enough to ensure that no additional problems were created.

The jumper.

and wire removal procedure was. revised to provide additional guidance for use of jumpers while troubleshooting.

9.

Exit Interview (30703)

'I The inspectors met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on February 14, 1992.

During this meeting, the inspectors summarized the scope and findings of the inspection as they are detailed in this report, with particular emphasis on the Violation and Inspector Follow-up item addressed below.

The licensee representatives acknowledged the inspector's comments and did not

,identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.

Item Number Descri tion and Reference 400/92-02-01 NCV - Failure to document identified deficiencies in accordance with procedure PLP-002, paragraph Item Number cont d

Descri tion and Reference I[

400/92-02-02 IFI - Follow the licensee's activities to correct=

safety classifications in the equipment data base, paragraph 4.a.

s and Initialisms Acronym ACR AFW.

AMSAC AO ATWS CCTV CCW CFR EDBS EPT ESF ESW FCR FSAR IFI LER MPT MST NCV NRC NSlJ OST PCR PIC RCS/RC SSPS TS UV WR/JO Adverse Condition Report Auxiliary Feedwater ATWS Mitigating System Actuation Circuitry Auxiliary Operator Anticipated Transient Without Scram Closed Circuit Television Component Cooling Water Code of Federal Regulations Equipment Data Base System Engineering Performance Test Engineered Safety Feature Emergency Service Water Field Change Request Final Safety Analysis Report

'Inspector Follow-up Item Licensee Event Report Maintenance Performance Test Maintenance Surveillance Test Non-Cited Violation Nuclear Regulatory Commission Normal Service Water Operations Surveillance Test Plant Change Request Primary Instrument Control Reactor Coolant System Solid State Protection System Technical Specification Under Voltage Work Request/Job Order

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