Text

NRC Integrated Inspection Report 05000445/2016001 and 05000446/2016001
	ML16120A616
Person / Time
Site:	Comanche Peak
Issue date:	04/29/2016
From:	Sean Hedger; NRC/RGN-IV/DRP/RPB-A
To:	Peters K; Luminant Generation Co
	Groom J
References
	IR 2016001
	Download: ML16120A616 (55)
	v • d • e

UNITED STATES ril 29, 2016

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT - NRC INTEGRATED INSPECTION REPORT 05000445/2016001 AND 05000446/2016001

Dear Mr. Peters:

On March 31, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Comanche Peak Nuclear Power Plant, Units 1 and 2. On March 24, 2016, the NRC inspectors discussed the results of this inspection with Tom McCool, Site Vice President, and other members of your staff. Inspectors documented the results of this inspection in the enclosed inspection report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

The finding involved a violation of NRC requirements. Further, inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy.

If you contest the violations or significance of these NCVs, 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 IV; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Comanche Peak Nuclear Power Plant, Units 1 and 2. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Jeremy R. Groom, Chief Project Branch A Division of Reactor Projects Docket Nos. 50-445 and 50-446 License Nos. NPF-87 and NPF-89

Enclosure:

Inspection Report 05000445/2016001 and 050446/2016001 w/ Attachment: Supplemental Information

REGION IV==

Docket: 05000445, 05000446 License: NPF-87, NPF-89 Report: 05000445/2016001 and 05000446/2016001 Licensee: Luminant Generation Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: 6322 N. FM-56, Glen Rose, Texas Dates: January 1 through March 31, 2016 Inspectors: J. Josey, Senior Resident Inspector S. Hedger, Acting Senior Resident Inspector R. Kumana, Resident Inspector M. Bloodgood, Operations Engineer J. Watkins, Reactor Inspector L. Carson II, Senior Health Physicist B. Dionne, CHP, Health Physicist P. Hernandez, Health Physicist J. ODonnell, CHP, Health Physicist G. Guerra, CHP, Emergency Preparedness Inspector Approved Jeremy R. Groom By: Chief, Project Branch A Division of Reactor Projects-1- Enclosure

SUMMARY

IR 05000445/2016001 and 05000446/2016001; 01/01/2016 - 03/31/2016; Comanche Peak

NPP, Units 1 and 2; Problem Identification and Resolution.

The inspection activities described in this report were performed between January 1, 2016, through March 31, 2016, by the resident inspectors at the Comanche Peak Nuclear Power Plant and inspectors from the NRCs Region IV office. One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements.

Additionally, NRC inspectors documented in this report one licensee-identified violation of very low safety significance. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609,

Significance Determination Process. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process.

Cornerstone: Mitigating Systems

Green.

The inspectors identified seven examples of a non-cited violation of 10 CFR 50,

Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to perform adequate operability assessments for a degraded or nonconforming condition. Specifically, when vacuum breakers installed in the service water system failed to actuate during surveillance testing, the licensee completed an operability evaluation that relied on judgement, and was contrary to the station design analysis. In particular, the licensee concluded that the vacuum breakers were not required to support operability of the service water system. Following questions from inspectors, the licensee determined that this judgement was not correct and performed a new evaluation to establish operational parameters necessary to ensure operability of the service water system with a failed vacuum breaker. The licensee entered this issue into corrective action program as Condition Report CR-2015-008334.

The failure to properly assess and document the basis for operability for a degraded or nonconforming condition was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, service water vacuum breakers failing to open resulted in a condition where structures, systems, and components necessary to mitigate the effects of a column separation event may not have functioned as required. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding (1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality, (2) did not represent a loss of system and/or function, (3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and (4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with the licensees maintenance rule program. The inspectors determined that this finding does not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago, and is not indicative of current licensee performance.

(Section 4OA2)

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 associated corrective action tracking numbers are listed in Section 4OA7 of this report.

PLANT STATUS

Unit 1 began the inspection period at approximately 100 percent power. On January 8, 2016, the licensee reduced power to approximately 65 percent power for turbine and feedwater pump testing. The unit returned to approximately 100 percent power the next day, and operated at that power level for the remainder of the inspection period.

Unit 2 began the inspection period at approximately 100 percent power. On March 11, 2016, the licensee reduced power to approximately 60 percent power for feedwater pump testing. The unit returned to approximately 100 percent power the next day, and operated at that power level for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness to Cope with External Flooding

a. Inspection Scope

On March 9, 2016, the inspectors completed an inspection of the stations readiness to cope with external flooding. After reviewing the licensees flooding analysis, the inspectors selected three plant areas that were susceptible to flooding:

Circulating water intake and discharge structures

Station service water intake structure

Electrical and control building and turbine building, 778 elevation The inspectors reviewed plant design features and licensee procedures for coping with flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether credited operator actions could be successfully accomplished.

These activities constituted one sample of readiness to cope with external flooding, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walk-Down

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems:

February 22, 2016, spent fuel pool cooling pump X-02 while pump X-01 was out of service for maintenance

February 23-24, 2016, Unit 1, train A component cooling water system

March 3, 2016, Unit 1, emergency diesel generators 1-01 and 1-02 during work on turbine driven auxiliary feedwater pump

March 10, 2016, Unit 1, emergency diesel generators 1-01 and 1-02 while emergency diesel generator 2-01 was scheduled for an engine analysis run The inspectors reviewed the licensees procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

No findings were identified.

1R05 Fire Protection

Main article: IP 71111.05

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety:

March 8, 2016, Unit 1, fire zone SB4, safeguards 790 corridor

March 8, 2016, Unit 2, fire zone 2SB4, safeguards 790 corridor

March 10, 2016, Unit 1, fire zone EC50, train B inverter room X-118

March 10, 2016, Unit 1, fire zone SB8, safeguards 810 corridor For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensees fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

a. Inspection Scope

On February 25, 2016, the inspectors completed an inspection of the stations ability to mitigate flooding due to internal causes. After reviewing the licensees flooding analysis, the inspectors chose one plant area containing risk-significant structures, systems, and components that were susceptible to flooding:

Unit 2 emergency diesel generator rooms The inspectors reviewed plant design features and licensee procedures for coping with internal flooding. The inspectors walked down the selected areas to inspect the design features, including the material condition of seals, drains, and flood barriers. The inspectors evaluated whether operator actions credited for flood mitigation could be successfully accomplished.

These activities constituted completion of one flood protection measures sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On February 11, 2016, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators critique of their performance. The inspectors also assessed and the modeling and performance of the simulator during the requalification activities.

These activities constituted completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

The inspectors observed the performance of on-shift licensed operators in the plants main control room. At the time of the observations, the plant was in a period of heightened risk due to testing being performed on reactor protection and engineered safety features systems. The inspectors observed the operators performance of the following activities:

January 25, 2016, Unit 2, reactor trip breaker testing

February 22, 2016, Unit 2, solid state protection system testing

March 8, 2016, Unit 2, repair of valve 2RC-8054A on the Unit 2 pressurizer and restoration of level transmitters LT-459 and LT-459F to service In addition, the inspectors assessed the operators adherence to plant procedures, including conduct of operations procedure and other operations department policies.

These activities constituted completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.3 Annual Review of Requalification Examination Results

The licensed operator requalification program involves two training cycles that are conducted over a two-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination. For this annual inspection requirement, the licensee was in the first part of the training cycle.

a. Inspection Scope

The inspector conducted an in-office review of the annual requalification training program to determine the results of this program.

On January 4, 2016, the licensee informed the inspector of the following results:

13 of 14 crews passed the simulator portion of the operating test

72 of 78 licensed operators passed the simulator portion of the operating test

77 of 78 licensed operators passed the job performance measure portion of the operating test The individuals that failed the Simulator Scenario and Job Performance Measure portions of the operating test were remediated, retested, and passed their retake tests.

The inspector completed one inspection sample of the annual licensed operator requalification program.

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed one instance of degraded performance or condition of safety-related structures, systems, and components (SSCs):

February 19, 2016, Unit 2, feed water check valves 2FW-191, 2FW-192, 2FW-193, and 2FW-194 in-service testing failures The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensees corrective actions. The inspectors reviewed the licensees work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensees characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of one maintenance effectiveness sample, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed five risk assessments performed by the licensee prior to changes in plant configuration and the risk management actions taken by the licensee in response to elevated risk:

January 11, 2016, Unit 2,125 V DC Battery discharge test

January 27, 2016, Unit 2, Maintenance on steam generator blowdown isolation valve 2-HV-2400A

February 12, 2016, Unit 2, Maintenance on turbine driven auxiliary feedwater pump flow control valve

February 16, 2016, both units, Maintenance on the 138 kV Decordova offsite power line

March 1, 2016, Unit 2, Maintenance on offsite power supply breaker for bus 2EA2 The inspectors verified that these risk assessment were performed timely and in accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant procedures. The inspectors reviewed the accuracy and completeness of the licensees risk assessments and verified that the licensee implemented appropriate risk management actions based on the result of the assessments.

These activities constituted completion of five maintenance risk assessments and emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed five operability determinations and functionality assessments that the licensee performed for SSCs:

January 19, 2016, CR-2016-000477, operability determination of Unit 1 emergency diesel generator 1-02 due to a starting air leak

February 4, 2016, CR-2016-000898, operability determination for Units 1 and 2 emergency diesel generator fuel oil transfer pumps due to potential for internal flooding from fire water piping

March 7, 2016, CR-2016-001706, operability determination for Unit 2 valve 2RC-8054A due to a packing leak

March 10, 2016, CR-2016-002006, operability determination for Unit 2 emergency diesel generator 2-01 due to loose magnetic speed sensor cable

March 17, 2016, CR-2016-002507, functionality assessment for the technical support center due to degraded air handling unit The inspectors reviewed the timeliness and technical adequacy of the licensees evaluations. Where the licensee determined the degraded SSC to be operable or functional, the inspectors verified that the licensees compensatory measures were appropriate to provide reasonable assurance of operability or functionality. The inspectors verified that the licensee had considered the effect of other degraded conditions on the operability or functionality of the degraded SSC.

These activities constituted completion of five operability and functionality review samples as defined in Inspection Procedure 71111.15.

b. Findings

No findings were identified.

1R18 Plant Modifications

Main article: IP 71111.18

.1 Temporary Modifications

a. Inspection Scope

On March 7, 2016, the inspectors reviewed a temporary modification to perform leak sealant injection to pressurizer instrument isolation valve 2RC-8054A.

The inspectors verified that the licensee had installed this temporary modification in accordance with technically adequate design documents. The inspectors verified that this modification did not adversely impact the operability or availability of affected SSCs.

The inspectors reviewed design documentation and plant procedures affected by the modification to verify the licensee maintained configuration control.

These activities constituted completion of one sample of a temporary modification, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

.2 Permanent Modifications

a. Inspection Scope

On February 23, 2016, the inspectors reviewed one permanent modification to the station service water system. This modification removed the vacuum breakers on the suction side piping, relocated the vacuum breakers on the discharge piping and added isolation valves to the vacuum breakers on the discharge piping.

The inspectors reviewed the design and implementation of the modification. The inspectors verified that work activities involved in implementing the modification did not adversely impact operator actions that may be required in response to an emergency or other unplanned event. The inspectors verified that post-modification testing was adequate to establish the operability of the SSC as modified.

These activities also included a follow up of Unresolved Item 05000445/2015008-05; 05000446/2015008-05, Failure to Perform Adequate Operability Assessments associated with Failures of Service Water System Vacuum Breaker during Surveillance Tests, as documented in Section 4OA2.

These activities constituted completion of one sample of a permanent modification, as defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed five post-maintenance testing activities that affected risk-significant SSCs:

January 5, 2016, Unit 1, VT-2 visual examination of welds following vacuum breaker modification

February 17, 2016, Unit 2, turbine driven auxiliary feedwater pump

February 23, 2016, Unit 1, steam generator atmospheric relief valve

March 8, 2016, Unit 2, pressurizer level instruments LT-459 and LT-459F

March 21, 2016, Unit 2, safety injection pump 2-01 following preventative maintenance The inspectors reviewed licensing- and design-basis documents for the SSCs and the maintenance and post-maintenance test procedures. The inspectors observed the performance of the post-maintenance tests to verify that the licensee performed the tests in accordance with approved procedures, satisfied the established acceptance criteria, and restored the operability of the affected SSCs.

These activities constituted completion of five post-maintenance testing inspection samples, as defined in Inspection Procedure 71111.19.

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed four risk-significant surveillance tests and reviewed test results to verify that these tests adequately demonstrated that the SSCs were capable of performing their safety functions:

In-service tests:

January 27, 2016, Unit 1, train A emergency diesel generator fuel oil system transfer pump test in accordance with procedure OPT-513A, SI Pump Performance and Flow Balancing, Revision 1

February 23, 2016, Unit 2, steam generator 2-04 check valve 2FW-191 test in accordance with procedure OPT-506B, FW Valve Testing, Revision 9 Reactor coolant system leak detection tests:

February 19, 2016, Unit 1, manual reactor coolant leak rate determination test in accordance with procedure OPT-303A, Reactor Coolant System Water Inventory, Revision 14 Other surveillance tests:

February 12, 2016, Unit 2, steam generator flow control valve 2-HV-2459-AO test in accordance with procedure IST-305, Air Operated Valve Program Document, Revision 6 The inspectors verified that these tests met technical specification requirements, that the licensee performed the tests in accordance with their procedures, and that the results of the test satisfied appropriate acceptance criteria. The inspectors verified that the licensee restored the operability of the affected SSCs following testing.

These activities constituted completion of four surveillance testing inspection samples, as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert and Notification System Evaluation

Main article: IP 71114.02

a. Inspection Scope

The inspector verified the adequacy of the licensees methods for testing the primary and backup alert and notification system (ANS). The inspector interviewed licensee personnel responsible for the maintenance of the primary and backup ANS and reviewed a sample of corrective action system reports written for ANS problems. The inspector compared the licensees alert and notification system testing program with criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; FEMA Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants; and the licensees current FEMA-approved alert and notification system design report, Comanche Peak Nuclear Power Plant Alert and Notification System Design Report, Revision 2.

These activities constituted completion of one alert and notification system evaluation sample as defined in Inspection Procedure 71114.02.

b. Findings

No findings were identified.

1EP3 Emergency Response Organization Staffing and Augmentation System

Main article: IP 71114.03

a. Inspection Scope

The inspector verified the licensees emergency response organization on-shift and augmentation staffing levels were in accordance with the licensees emergency plan commitments. The inspector reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to verify the adequacy of the licensees methods for staffing emergency response facilities, including the licensees ability to staff pre-planned alternate facilities.

The inspector also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments.

These activities constitute completion of one emergency response organization staffing and augmentation testing sample as defined in Inspection Procedure 71114.03.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness

Main article: IP 71114.05

a. Inspection Scope

The inspector reviewed the following for the period May 2014 to January 2016:

After-Action reports for emergency classifications and events

After-Action evaluation reports for licensee drills and exercises

Independent audits and surveillances of the licensees emergency preparedness program

Self-Assessments of the emergency preparedness program conducted by the licensee

Licensee evaluations of changes made to the emergency plan and emergency plan implementing procedures

Drill and Exercise performance issues entered into the licensees Corrective Action Program

Emergency preparedness program issues entered into the licensees Corrective Action Program

Emergency response organization training records The inspector reviewed summaries of corrective action program reports associated with emergency preparedness and selected 29 to review against program requirements, to determine the licensees ability to identify, evaluate, and correct problems in accordance with planning standard 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, IV.F. The inspector verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments.

These activities constitute completion of one sample of the maintenance of the licensees emergency preparedness program as defined in Inspection Procedure 71114.05.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on February 24, 2016, to verify the adequacy and capability of the licensees assessment of drill performance.

The inspectors reviewed the drill scenario, observed the drill from the simulator and technical support center, and attended the post-drill critique. The inspectors verified that the licensees emergency classifications, off-site notifications, and protective action recommendations were appropriate and timely. The inspectors verified that any emergency preparedness weaknesses were appropriately identified by the licensee in the post-drill critique and entered into the corrective action program for resolution.

These activities constituted completion of one emergency preparedness drill observation sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

RADIATION SAFETY

Cornerstones: Public Radiation Safety and Occupational Radiation Safety

2RS5 Radiation Monitoring Instrumentation

Main article: IP 71124.05

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring equipment used by the licensee

(1) to monitor areas, materials, and workers to ensure a radiologically safe work environment, and

(2) to detect and quantify radioactive process streams and effluent releases. The inspectors interviewed licensee personnel, walked down various portions of the plant, and reviewed licensee performance in the following areas:

Selected plant configurations and alignments of process, post-accident, and effluent monitors with descriptions in the Final Safety Analysis Report and the offsite dose calculation manual

Selected instrumentation, including effluent monitoring instrument, portable survey instruments, area radiation monitors, continuous air monitors, personnel contamination monitors, portal monitors, and small article monitors to examine their configurations and source checks

Calibration and testing of process and effluent monitors, laboratory instrumentation, whole body counters, post-accident monitoring instrumentation, portal monitors, personnel contamination monitors, small article monitors, portable survey instruments, area radiation monitors, electronic dosimetry, air samplers, and continuous air monitors

Audits, self-assessments, and corrective action documents related to radiation monitoring instrumentation since the last inspection These activities constituted completion of Inspection Procedure 71124.05.

b. Findings

No findings were identified.

2RS6 Radioactive Gaseous and Liquid Effluent Treatment

Main article: IP 71124.06

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent processing systems and properly mitigated, monitored, and evaluated radiological discharges with respect to public exposure. The inspectors verified that abnormal radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors were out-of-service, were controlled in accordance with the applicable regulatory requirements and licensee procedures. The inspectors verified that the licensees quality control program ensured radioactive effluent sampling and analysis adequately quantified and evaluated discharges of radioactive materials. The inspectors verified the adequacy of public dose projections resulting from radioactive effluent discharges. The inspectors interviewed licensee personnel and reviewed or observed the following items:

Radiological effluent release reports since the previous inspection and reports related to the effluent program issued since the previous inspection

Effluent program implementing procedures, including sampling, monitor setpoint determinations and dose calculations

Equipment configuration and flow paths of selected gaseous and liquid discharge system components, filtered ventilation system material condition, and significant changes to their effluent release points, if any, and associated 10 CFR 50.59 reviews

Selected portions of the routine processing and discharge of radioactive gaseous and liquid effluents (including sample collection and analysis)

Controls used to ensure representative sampling and appropriate compensatory sampling

Results of the inter-laboratory comparison program

Effluent stack flow rates

Surveillance test results of technical specification-required ventilation effluent discharge systems since the previous inspection

Significant changes in reported dose values

A selection of radioactive liquid and gaseous waste discharge permits

Part 61 analyses and methods used to determine which isotopes are included in the source term

Offsite dose calculation manual changes

Meteorological dispersion and deposition factors

Latest land use census

Records of abnormal gaseous or liquid tank discharges

Groundwater monitoring results

Changes to the licensees written program for identifying and controlling contaminated spills/leaks to groundwater

Identified leakage or spill events and entries made into 10 CFR 50.75(g) records, if any, and associated evaluations of the extent of the contamination and the radiological source term

Offsite notifications and reports of events associated with spills, leaks, and groundwater monitoring results

Audits, self-assessments, reports, and corrective action documents related to radioactive gaseous and liquid effluent treatment since the last inspection These activities constituted completion of Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

Main article: IP 71124.07

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensees technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items:

Annual environmental monitoring reports and offsite dose calculation manual

Selected air sampling and dosimeter monitoring stations

Collection and preparation of environmental samples

Operability, calibration, and maintenance of meteorological instruments

Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement

Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water

Records required by 10 CFR 50.75(g)

Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection

Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation

Inter-laboratory comparison program results

Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constituted completion of Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items:

The solid radioactive waste system description, process control program, and the scope of the licensees audit program

Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition

Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place

Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides

Processes for waste classification including use of scaling factors and 10 CFR Part 61 analyses

Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest

Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection These activities constitute completion of Inspection Procedure 71124.08.

b. Findings

No findings were identified.

The inspector reviewed the licensees records of Alert and Notification System tests conducted between April 2015 and December 2015 to verify the accuracy of the licensees data for siren system testing opportunities. The inspector reviewed procedural guidance on assessing Alert and Notification System opportunities and the results of periodic alert and notification system operability tests. The inspector used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this report.

These activities constituted verification of the alert and notification system reliability performance indicator as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items entered into the licensees corrective action program and periodically attended the licensees condition report screening meetings. The inspectors verified that licensee personnel were identifying problems at an appropriate threshold and entering these problems into the corrective action program for resolution. The inspectors verified that the licensee developed and implemented corrective actions commensurate with the significance of the problems identified. The inspectors also reviewed the licensees problem identification and resolution activities during the performance of the other inspection activities documented in this report.

b. Findings

No findings were identified.

.2 Annual Follow-up of Selected Issues

a. Inspection Scope

The inspectors selected one issue for an in-depth follow-up:

On March 30, 2014, relay 27-59/2EG2 (K-300 relay), an under voltage relay associated with breaker 2EG2, was found to be out of set point tolerances while performing work order 4500655 and procedure MSE-GO-0020, Relay Calibration, Attachment BE01. Condition Reports 2014-003431 and 2015-008148 were written to evaluate the issue, including a past operability review.

Initially, a potential for the K-300 relay revised settings to allow EDG operation outside the Technical Specifications limits, without isolation of a faulty Automatic Voltage Regulator (AVR), was not recognized. After further evaluation, it was determined that the K-300 relay would cause the AVR to be disconnected prior to the Class 1E bus degrading outside its Technical Specification limits.

The inspectors assessed the licensees problem identification threshold, cause analyses, extent of condition reviews and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

These activities constituted completion of one annual follow-up sample as defined in Inspection Procedure 71152.

b. Findings

No findings were identified.

.3 (Closed) Unresolved Item 05000445/2015008-05; 05000446/2015008-05, Failure to

Perform Adequate Operability Assessments associated with Failures of Service Water System Vacuum Breaker during Surveillance Tests

a. Inspection Scope

The inspectors reviewed an unresolved item associated with the failure of service water vacuum breakers. When these failures occurred, the licensee evaluated the operability of the service water system and determined that the system was degraded but operable because the vacuum breakers were not required for system operability.

Inspectors identified that the vacuum breakers in the discharge piping were required, and that the licensee had insufficient information documented associated with the vacuum breaker failures in order to determine if a non-compliance existed. Specifically, the NRC required information associated with the specific valves that failed, the length of time that the failed valves remained in service prior to replacement, and whether the opposite train diesel generator was inoperable during the periods the failed valves remained in service.

b. Findings

Introduction.

The inspectors identified seven examples of a Green non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to perform adequate operability assessments for a degraded or nonconforming condition. Specifically, the licensee failed to follow station procedures when evaluating the operability of the service water system following identification of degraded system vacuum breaker valves.

Description.

Inspection report 2015-008 documented URI 05000445/2015008-05; 05000446/2015008-05, Failure to Perform Adequate Operability Assessments associated with Failures of Service Water System Vacuum Breaker during Surveillance Tests. This URI involved licensee operability assessments performed for surveillance tests where at least one of the service water systems vacuum breakers failed to meet surveillance acceptance criteria to actuate at the required set point. Following these failed surveillances, operations used a previously generated engineering evaluation and determined that the service water system was degraded but operable because the vacuum breakers were not required for system operability. To address this degraded condition, maintenance personnel mechanically agitated the vacuum breakers but did not replace the vacuum breakers until a later date.

Inspectors noted the station service water system contains a 1-inch vacuum breaker on the supply header and a 2-inch vacuum breaker on the return header. Design basis calculations identified that the return header vacuum breakers are required to protect the diesel generator jacket water coolers from water hammer events caused by column separation. Because the design relied on the return header vacuum breakers, the inspectors determined that the licensee did not have appropriate justification to conclude that the service water system remained operable with a failed discharge side vacuum breaker. The inspectors noted that Station Procedure STI-422.01, Operability Determination and Functionality Assessment Program, Revision 3 Step 6.1, requires, in part, that when a potential degraded or nonconforming condition is identified, the shift manager should ensure the operability determination process is initiated to determine the operability of the structure, system or component. The inspectors determined the licensee had failed to follow this procedure when evaluating operability of the service water system with failed vacuum breakers, in that operators utilized incorrect information in the operability evaluations.

During subsequent reviews of 26 vacuum breaker failures that occurred in the service water system between September 2010 and November 2015, the licensee identified 7 associated with the 2-inch return header vacuum breakers. The licensee performed an evaluation for the seven failures of 2-inch return header vacuum breakers to determine if the service water system remained functional. The licensees evaluation concluded that a new temperature limit of 93.8 degrees Fahrenheit for the safe shutdown impoundment was required to prevent water column separation and potential water hammer. The licensees evaluation identified an approximately 20-day period in summer of 2013 and a 15-day period in summer of 2014 where the temperature of the service water impoundment exceeded 93.8 degrees Fahrenheit by 3.0 and 0.6 degrees Fahrenheit, respectively. The licensee evaluated this temperature rise and concluded that the small change in vapor pressure corresponding to the increased temperature would result in a small water hammer but that the service water system remained functional. The licensee informed their conclusions from operational experience involving a water hammer event in 1986 that bounded the column separation that could have been experienced due to the inadequate operability evaluations.

As corrective actions, the licensee incorporated the new temperature limits for the service water system impoundment into system operating procedures. The licensee entered this issue into the corrective action program as Condition Report CR-2015-008334.

Analysis.

The failure to properly assess and document the basis for operability when a degraded or nonconforming condition was identified was a performance deficiency. The performance deficiency was more than minor, and therefore a finding, because it was associated with the equipment performance attribute of the Mitigating Systems Cornerstone and affected the cornerstone objective to ensure availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, service water vacuum breakers failing to open resulted in a condition where structures, systems, and components necessary to mitigate the effects of a column separation event may not have functioned as required. Using Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, dated June 19, 2012, inspectors determined that this finding was of very low safety significance (Green) because the finding

(1) was not a deficiency affecting the design and qualification of a mitigating structure, system, or component, and did not result in a loss of operability or functionality,

(2) did not represent a loss of system and/or function,

(3) did not represent an actual loss of function of at least a single train for longer than its allowed outage time, or two separate safety systems out-of-service for longer than their technical specification allowed outage time, and

(4) does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with the licensees maintenance rule program. The inspectors determined that this finding does not have a cross-cutting aspect because the most significant contributor of this finding occurred more than three years ago, and is not indicative of current licensee performance.

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be accomplished in accordance with documented instructions, procedures, or drawings, of a type appropriate to the circumstances. Licensee Procedure STI-422.01, Operability Determination and Functionality Assessment Program, Revisions 3, an Appendix B quality related procedure, provides instructions for evaluating the operability of safety-related components. Procedure STI-422.01 step 6.1, requires, in part, that when a potential degraded or nonconforming condition is identified, the shift manager should ensure the operability determination process is initiated to determine the operability of the structure, system or component. Contrary to the above, on seven occasions between September 2010 and November 2015, the shift manager failed to determine the operability of the structure, system or component. Specifically, the licensee failed to determine the operability of the service water system following identification of a degraded condition involving failed surveillances of return header vacuum breakers.

This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. The violation was entered into the licensees corrective action program as Condition Report CR-2015-008334. (NCV 05000445/2016001-01; 05000446/2016001-01, Failure to Adequately Evaluate Operability for a Degraded Condition)

4OA3 Follow-up of Events and Notices of Enforcement Discretion

Main article: IP 71153

These activities constituted completion of two event and notice of enforcement discretion samples, as defined in Inspection Procedure 71153.

.1 (Closed) Licensee Event Report 05000446/2015-001-00, Unit 2 Train B Safety Injection

System Inoperable For Longer Than Allowed By TS

a. Inspection Scope

On July 10, 2015, Comanche Peak Nuclear Power Plant, Unit 2, exceeded a 72-hour limiting condition for operation (LCO), after being granted a period of enforcement discretion. The need for enforcement discretion was due to a through-wall leak found on the "B" train of the Safety Injection (SI) system piping at the 3/4" socket weld coupling to valve 2SI-0055. After discovering the flaw on July 7, 2015, the licensee declared the "B" train of SI inoperable and entered Technical Specification 3.5.2, ECCS - Operating Condition B, which required restoration of the train within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The licensee repaired the socket weld and restored the system to service within the time allowed by the enforcement discretion. This event was reportable under 10 CFR 50.73(a)(2)(i)(B)as an operation or condition which was prohibited by the plant's Technical Specifications. The licensee concluded that the most probable cause of the through-wall leak was an original weld defect, which resulted in a stress concentration that allowed otherwise acceptable tensile loads to cause propagation of a through-wall crack.

The inspectors reviewed the licensees evaluation and corrective actions. The inspectors determined that the failure of the socket weld was not within the licensees ability to foresee and correct, and therefore was not a performance deficiency. As a result, the inspectors concluded there was no violation associated with the condition.

The inspectors also determined that the licensee took appropriate corrective actions to correct the defect.

b. Findings

No findings were identified.

.2 (Closed) Unresolved Item 05000446/2015003-03, Notice of Enforcement Discretion 15-

4-02 for One Inoperable Train of Emergency Core Cooling Systems

a. Inspection Scope

The inspectors performed a review of the circumstances associated with the granting of Notice of Enforcement Discretion 15-4-02 for Luminant Generation Company, LLC by the NRC staff at 9:20 a.m. on July 10, 2015. The notice of enforcement discretion granted an additional 25 hours2.893519e-4 days 0.00694 hours 4.133598e-5 weeks 9.5125e-6 months to restore compliance with Technical Specification 3.5.2, ECCS - Operating. The inspectors verified the licensees oral assertions, including the likely cause and compensatory measures, and verified the notice of enforcement discretion request was consistent with the staffs policy and guidance. The licensee documented the issue in Licensee Event Report 05000446/2015-001-00, which the inspectors closed in Section 4OA3.1 of this report.

The inspectors reviewed the sequence of events and the licensees cause evaluation.

Upon discovery of the leak, the licensee attempted to repair the leak using an approved methodology for weld repair, ASME Code Case N-666. The repair failed when the licensee created a hole in the pipe while welding. The licensee then drained the pipe, and performed a replacement of the pipe section and socket weld. The licensee requested enforcement discretion due to their inability to perform the replacement within the time remaining. The inspectors reviewed the cause of the failure of the licensees attempt to repair the leak using ASME Code Case N-666. The inspectors determined that the failure to successfully perform the weld repair was due to the difficulty of the weld and not within the licensees ability to foresee and correct.

However, the inspectors did identify two minor NRC violations associated with the closure of the unresolved item.

The inspectors identified a minor violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to follow work instructions for the weld repair on July 7, 2015. Specifically, licensee staff did not complete Step 12 of Work Order 5086991, which required a VT-1 visual inspection of the weld. The inspectors determined this violation was minor because this did not cause the failure or adversely affect a cornerstone objective.

The licensee entered this violation into the corrective action program as condition reports CR-2016-002247 and CR-2016-002427.

The inspectors also identified a minor violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, for the licensees failure to follow procedure NQA 3.09, Inspection Examination Program, Step 6.1.2.

Specifically, the licensee quality control inspector provided instruction to the welder on how to complete the work, thus losing his independence. The inspectors determined this violation was minor because this did not cause the failure or adversely affect a cornerstone objective. The licensee entered this violation into the corrective action program as CR-2016-002412.

These failures to comply with 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, constitute minor violations that are not subject to enforcement action in accordance with the NRCs Enforcement Policy.

b. Findings

No findings were identified.

4OA5 Other Activities

a. Inspection Scope

The inspectors evaluated the impact of financial conditions on continued safe performance at Comanche Peak. In that the licensees parent company, Energy Future Holdings, was under bankruptcy protection/reorganization during the inspection period, NRC Region IV conducted special reviews of processes at Comanche Peak. The inspectors evaluated several aspects of the licensees operations to determine whether the financial condition of the station impacted plant safety. The factors reviewed included:

(1) impact on staffing,

(2) corrective maintenance backlog,

(3) changes to the planned maintenance schedule,

(4) corrective action program implementation, and

(5) reduction in outage scope, including risk-significant modifications. In particular, the inspectors verified that licensee personnel continued to identify problems at an appropriate threshold and enter these problems into the corrective action program for resolution. The inspectors also verified that the licensee continued to develop and implement corrective actions commensurate with the significance of the problems identified.

The special review of processes at Comanche Peak included continuous reviews by the Resident Inspectors, as well as the specialist-led baseline inspections completed during the inspection period which are documented previously in this report.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 25, 2016, the inspectors telephonically exited with Mr. G. Struble, Operations/Simulator Training Manager, regarding the review of the licensed operator annual operating test results. The inspectors did not review any proprietary information during this inspection.

On February 11, 2016, the inspectors presented the radiation safety inspection results to Mr. T. Hope, Manager, Regulatory Affairs, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On February 25, 2016, the inspectors presented the results of the onsite inspection of the emergency preparedness program to Mr. K. Peters, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

On March 24, 2016, the resident inspectors presented the inspection results to Mr. T. McCool, Site Vice President, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

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 a non-cited violation.

Title 10 CFR 50.54(q)(2) requires, in part, that licensees shall follow and maintain the effectiveness of an emergency plan that meets the planning standards of 10 CFR 50.47(b). Title 10 CFR 50.47(b)(4) requires, in part, that a standard emergency classification and action level scheme is in use by the licensee. The licensees emergency plan provides for the ability to classify an unusual event due to failed fuel indications based on an alarm from the failed fuel radiation monitor. Contrary to the above, on February 4, 2016, the licensee took the Unit 1 Failed Fuel Monitor (FFM) out of service for planned maintenance without a viable compensatory measure in place.

Sampling and local surveys were referenced, but they were not adequate to provide the ability to provide for timely EAL classifications that normally rely on use of the Unit 1 FFM (Emergency Action Level [EAL] SU 7.2). Section 7.0 of the Comanche Peak Emergency Plan says that if core damage is suspected, appropriate procedures may be used to estimate the extent of damage. This situation did not allow for implementation of core damage assessment in a manner to effectively use the EAL scheme as required by 10 CFR 50.47(b)(4). The violation is more than minor because it affected the facilities and equipment attribute of the Emergency Preparedness cornerstone and impacted the cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Using Inspection Manual Chapter 0609, Appendix B, Emergency Preparedness Significance Determination Process, the inspector determined that the violation is of very low safety significance (Green) because the finding represented a failure to comply with planning standard (b)(4), and, using table 5.4-1, was screened as a Green finding because an emergency action level initiating condition was rendered ineffective such that an Unusual Event would not be declared for failed fuel, but no Site Area Emergency or General Emergency initiating conditions were affected. The violation was entered into the licensees corrective action program as CR-2016-001082.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

G. Struble, Operations/Simulator Training Manager

J. Alldredge, Technician, Radiation Protection

T. Curtis, Lead Environmental Technician

S. Darter, Coordinator, Radiation Protection

S. Dixon, Consulting Licensing Analyst/Regulatory Affairs

T. Emery, REMP Environmental Technician

T. Hope, Manager, Regulatory Affairs

B. Knapp, Acting Manager, Radiation Protection

M. Macho, Supervisor, Radiation Protection

S. Peterson, Senior Calibration Laboratory Technician, Radiation Protection

K. Powell, Supervisor, Radiation Protection

M. Syed, Engineer, Systems Engineer

M. Watkins, Lead Technician, Instruments and Controls Maintenance

J. Barnette, Consultant, Licensing Technologist

S. Bartholomew, Emergency Preparedness Analyst

G. Bryan, Emergency Preparedness Operations Specialist

K. Faver, Emergency Preparedness Planner

R. Fishencord, Emergency Preparedness Planner

J. Hull, Manager, Emergency Preparedness

R. Marquez, Emergency Preparedness Planner

S. Sewell, Director, Organization Effectiveness

D. Volkening, Manager, Nuclear Oversight

T. McCool, Site Vice President

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000445, Failure to Adequately Evaluate Operability for a Degraded

05000446/2016001- NCV Condition (Section 4OA2)

Closed

05000445, Failure to Perform Adequate Operability Assessments associated

05000446/2015008- URI with Failures of Service Water System Vacuum Breaker during Surveillance Tests (Section 4OA2)

Licensee Event Report

05000446/2015-001-00, Unit 2 Train B

05000446/2015-

LER Safety Injection System Inoperable for Longer Than Allowed by TS 001-00 (Section 4OA3)

05000446/2015003- Notice of Enforcement Discretion 15-4-02 for One Inoperable Train URI of Emergency Core Cooling Systems (Section 4OA3)

Attachment

LIST OF DOCUMENTS REVIEWED