Text

Draft IR 05000327-02-003 and IR 05000328-02-003 on 03/25-29/02, Sequoyah Nuclear Plant. Non-Cited Violations Noted
	ML040090225
Person / Time
Site:	Sequoyah
Issue date:	04/30/2002
From:	Ogle C; NRC/RGN-II/DRS/EB
To:	Scalice J; Tennessee Valley Authority
References
	FOIA/PA-2003-0358 IR-02-003
	Download: ML040090225 (24)
	v • d • e

V

April XX, 2002

Tennessee Valley Authority

ATTN: Mr. J. A. Scalice

Chief Nuclear Officer and

Executive Vice President

6A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC INSPECTION REPORT 50-327/02-03,

50-328/02-03

Dear Mr. Scalice:

On March 29, 2002, the Nuclear Regulatory Commission (NRC) completed a triennial fire

protection inspection at the Sequoyah Nuclear Plant. The enclosed report documents the

results of this inspection which were discussed on March 28A 29, with Mr. Dennis Cole and other

members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, the inspectors identified two issues of very low safety

significance (,iven). These issues were determined to involve violations of NRC

requirement [however, because of their very low safety significance and because they have

been entered into your corrective action program, the NRC is treating these issues as Non-cited

violations, in accordance with Section VI.A.1 of the NRC's Enforcement Policy. The first

violation involved a failure to ensure that one of the redundant trains for isolation of normal

letdown would be maintained free of fire damage. The second violation involved the failure to

properly establish the plant fire procedure such that actions necessary to mitigate the

consequences of a severe fire could be effectively performed.

If you deny these Non-cited violations, you should provide a response with the basis for your

denial, within 30 days of the date of this inspection report, to the Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the

Regional Administrator, Region II; the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the

Sequoyah Nuclear Plant.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and Its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's Document

-

ill

system (ADAMS). ADAMS is accessible from the NRC web site at http:/Iwww.nrc. ov readin'-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

Charles R. Ogle, Chief

Engineering Branch 1

Division of Reactor Safety

Enclosure: NRC Inspection Report 50-327/02-03,

50-328/02-03

SUMMARY OF FINDINGS

Sequoyah Nuclear Plant, Units land 2

IR 05000327-02-03 and IR 05000328-02-03 on 03/25-29/2002,Tennesee Valley Authority,

Sequoyah Nuclear Plant Units I and 2, triennial baseline inspection of the fire protection

program.

The inspection was conducted by a Brunswick resident inspector, and three regional reactor

inspectors. The inspection identified two Non-cited violations which were determined to be of

very low safety significance (Green). The significance of most findings is indicated by their

color (Green, White, Yellow, Red) using IMC 0609 "Significance Determination Process."

Findings for which the SDP does not apply are indicated by "No Color" or by the severity level

of the applicable violation.

Inspector Identified Findings

Cornerstone: Mitigating Systems

Green. A Non-cited violation (Green) of Title 10 to the Code of Federal Regulations

CFR Part 50 (10 CFR 50) Appendix R, III.G.2, was identified for failure to ensure, in the

event of a severe fire, that one of the redundant trains of a system necessary to achieve

and maintain hot shutdown condition would be free of fire damage. Electrical cables for

redundant charging flow isolation valves 1-FCV-62-90 and 1-FCV-62-91 were located in

fire area FAA-029 without adequate spatial separation or fire barriers.

The finding had a credible impact on safety in that fire damage to the unprotected

cables could prevent closure of the valves from the main control room (MCR) and

challenge the operators' ability to establish adequate injection flow to the reactor coolant

pump (RCP) seals. This finding was determined to be of very low safety significance

because the ignition frequency was relatively low, fire detection and suppression

systems were not degraded, and there were no components in this area whose failure

would result in an accident initiator (i.e., loss of offsite power, loss of main feedwater) so

the finding only affected the mitigating systems cornerstone. (Section 1R05.02)

Green. A Non-cited violation of Technical Specification 6.8.1.a. was identified for

inadequate procedure guidance related to the transition from abnormal operating

procedure (AOP)-N.01, Plant Fires, to AOP-C.04, Shutdown From Auxiliary Control

Room, in the event of a severe fire in the control building. AOP-N.01 did not clearly

delineate what conditions would require entry into the severe fire shutdown procedure for

shutdown from the main control room (MCR) in accordance with 10 CFR 50 Appendix R,

III.G.2 nor did it provide adequate criteria for a shutdown from outside the MCR in

accordance with 10 CFR 50 Appendix R, III.G.3.

This finding had a credible impact on safety, in that, the inadequate guidance in

procedure AOP-N.01 could delay entry into AOP-C.04 and could challenge the operators'

ability to perform certain critical safe shutdown functions (e.g., isolate normal charging,

establish adequate seal injection flow to the RCPs) within the times specified in the

licensee's safe shutdown calculation for Appendix R. This finding was determined to be

of very low safety significance because it did not affect fire detection, fire. suppression, or

fire barriers. (Section 1R05.05)

.:'I - :11

Licensee identified Findings

.- Two-violations of very low safety significance which were identified by the licensee were

reviewed by the inspection team. Corrective actions taken or planned by the licensee

appear reasonable. (Section 40A7)

. . . . .~~~~~~~~~~~~~~~~~~C

Report Details

2. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems

I R05 FIRE PROTECTION

.01 Systems Required To Achieve and Maintain Post-Fire Safe Shutdown (SSD)

a. Inspection Scooe

The team evaluated the licensee's fire protection program against applicable

requirements, including the Sequoyah Nuclear (SQN) Units 1 and 2 fire protection

License Conditions 2.C(16) and 2.C(13) respectively; Title 10 of the Code of Federal

Regulations Part 50 (10 CFR 50) Appendix R, lIl.G, Il.J, 111.0, and Il.L; Appendix A of

Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch

(APCSB) 9.5-1; 10 CFR 50.48; related NRC Safety Evaluation Reports (SERs);

NUREGS and the Technical Specifications (TS).

The team used the licensee's Individual Plant Examination for External Events (IPEEE)

and in-plant walkdowns to select four risk significant fire areas for inspection. The four

selectedore areas were:

Fire Area FAA-029, Auxiliary Building, Elevation 690: Auxiliary Building Corridor

Thi~'e area includes rooms 690.0-Al, A9, A10, A13, A14, A17, A18, A22, A23, A23a,

A2 7, A30 and A31. This area is classified as a 10 CFR Part 50 Appendix R

(Appendix R), III.G.2 area and contains both trains of motor-driven auxiliary feedwater

(MDAFW) pumps, as well as the cables for both trains of essential raw cooling water

(ERCW). In addition all five component cooling water pumps (CCWP) are within the Fire

area. A significant fire in this area would require shutdown of either unit from the main

control room (MCR).

Fire Area FAA-067, Auxiliary Building, Elevation 734: 6.9 kilovolt (kV) Shutdown Board

Rooms

Thisbre area includes rooms 734.0-A2 and A9. This fire area includes both units train

'A' auxiliary electric power switchgear. This area is classified as a Appendix R, III.G.2.

A significant fire in this fire area would require shutdown of either or both unit(s) from the

MCR.

Fire Area FAC-009, Control Building, Elevation 685: Unit 1 Auxiliary Instrument Room

This(re area includes controls to important safe shutdown (SSD) equipment from

outside the MCR. This area is classified as a Appendix R, II.G.3 area. A significant fire

in this area would require evacuation of the MCR and alternative shutdown (ASD) from

the Auxiliary Control Room (ACR) using the remote shutdown panel.

Fire Area FAC-20, Control Building, Elevation 732: Relay Room

Thisfre area includes high voltage electrical relay.equipment for offsite power and is

- located adjacent to the MCR complex. A significant fire in this area may result in a fire

Induced loss of offsite power'(LOOP). .This area is classified as a Appendix R, III.G.3

-e7a.AbbireIn tfisar6a Woiuld'irequire evacuatian ofhe hMCR'and ASD from the remote

-shutdown panel-using the ____ -

The team reviewed the IPEEEFire Hazards Analysis (FHA), the Sequoyah Fire

-- Protection Report (FPR), associated procedures, and plant drawings to identify those

systems credited for SSD of the facility in the event of a fire in the four selected fire

areas. The inspection included review of the post-fire SSD capability and of the fire

protection features to ensure that at least one post-fire SSD success path was

maintained free of fire damage. .--.

For a selected sample of SSD systems, components, and plant monitoring instruments,

the team reviewed the FPR, the FHA, applicable fire protection SERs and NUREGS, and

. system flow diagrams to evaluate the completeness and adequacy of the FPR and the

-systems relied upon to mitigate fires in the four selected fire areas..

The team inspected the capability to shutdown for the-scenario where a fire in fire area

FAC-20 could initiate a LOOP. The team inspected the control circuits and associated

circuit analysis for the diesel ,nerators to determine whether any devices in the control

circuit were located irre ar ta9C-20.. In a similar manner, the control =ruits for the 6.9

kV shutdown board were reteived to determine whether a fire. YaraC-20 could

interfere with opening of the offsite breaker or closing the emergency diesel generator

(EDG) breaker.

b. Findings

No findings of significance were identified.

.02 Fire Protection of Safe Shutdown Cagabilitv

a..- Inspection Scope

The team reyi6wed the licensee's the FPR foire areas FAA-029 and FAA-067 to

determin hether redundant trains of components or circuits required for SSD were

- located' the same fire area. -From those components, the team selected the power

cables entrifugal charging pumps (CCP) 1A and IB, and the power and control cables

to the charging flow isolation valves I-FCV-62-90 and 1-FCV-62-9. The team verified

that adequate spatial separation or proper fire barrier protection features were installed in

accordance with the design requirements of Appendix R. The team examined cable

routing rjceway drawings, the actual configuration of the circuits, fire barriers, fire

* detection,-and fire suppression equipment as applicable for conformance to applicable

- NRC requirements and National Fire Protection Association (NFPA) standards. In

- * addition the team walked down these fire areas to verify that the licensee documentation

reflected the as-built configuration.

Team members also walked down the four selected fire areas and compared the

associated fire fighting pre-plans and drawings with as-built plant conditions. This was

done to verify that fire fighting pre-plans and drawings were consistent with the fire

protection features and potential fire conditions described in the FPR. Additionally, the

team reviewed engineering evaluations associated with the Auxiliary Building floor and

equipment drain sump capacity to verify that those actions required for ASD wo not be

inhibited by fire suppression activities or leakage from' fire suppression systems DIhe

'tearif rev1Wed fire brigade responsbe, training, and d'rill program procedures. Fire brigade

drill critiques and training drill records for the operating shifts from 1999 through 2001

were reviewed. The team evaluated whether drills had been conducted in high fire risk

plant areas and that fire brigade personnel qualifications, drill response, and performance

met the requirements of the licensee's approved fire protection program.

The team reviewed selected portions of the FHA and fire prevention/combustible hazards

procedures to determine if the conditions established in the fire protection licensing basis

documents were satisfied. The team performed walkdowns of the four selected fire

areas to observe whether the licensee limited fire hazards in a manner consistent with

these procedures. 'Fire brigade response and emergency/incident reports from 1999

through 2001; as well'as Problem Evaluation Reports (PERs) resulting from fire, smoke,

sparks, arcing, and equipment overheating incidents were reviewed. This review was

conducted to assess the effectiveness.of the fire prevention program and to identify any

maintenance or material condition problems related to fire incidents. Additionally, design

control procedures were reviewed to verify that plant changes were adequately reviewed

for the potential impact on the fire protection program, SSD equipment, and procedures

as required by SQN License Conditions 2.C(16) and 2.C(13).

The team walked down the primary fire brigade staging and dress-out areas to assess

the condition of fire fighting and smoke control equipment. Fire brigade personal

protective equipment located in the fire brigade house, dress-out area and lockers in the

fire brigade staging area were reviewed to evaluate equipment accessibility and

functionality. The team observed whether emergency exit lighting was provided for

personnel evacuation pathways to the outside exits as identified in the NFPA 101, Life

Safety Code. This review also included examination of whether backup emergency

lighting was provided for access pathways to and within the fire brigade staging and

dress-out areas in support of fire brigade operations should power fail during a fire

emergency. The adequacy of the fire brigade self-contained breathing apparatus

(SCBAs) was reviewed as well as the availability of supplemental breathing air tanks.

The team reviewed the RCP oil collection system enclosure drawings to verify

compliance with Appendix R, 111.0. The team evaluated operator response procedures to

determine ifsufficient procedural guidance was provided to identify an oil leak from the

RCP lubrication system and take appropriate action.

b. Findings

A Non-cited violation (Green) of 10 CFR Part 50 Appendix R. III.G.2, was identified for

failure to ensure, in the event of a severe fire, that one of the redundant trains of a

system necessary to achieve and maintain hot shutdown condition would be free of fire

damage. Electrical cables for redundant charging flow isolation valves 1-FCV-62-90 and

1-FCV-62-91 were located in'fire area- FAA029 without adequate spatial separation or

'fire barriers.

For fire area FAA-029, the FHA' indicated that reactor 'coolant system (RCS) inventory

control was achieved through isolatioh of normal charging and letdown while maintaining

RCP seal flow cooling. Through review of associated system prints and SSD procedures

AOP-N.01 and AOP-N.08, the team noted that the step to.achieve charging flow isolation

while continuing RCP seal flow cooling was to close 'either valve 1-FCV-62-90 or 1-FCV-

62-91 from the MCR. These valves were installed in series and powered from redundant

power sources. Tbe FHA indicated that powver and control cables for both valves were

routed closer than42tfeet specified in Appendix R, IlI.G.2.b,, onduit drawings lo-

45N824-7 and 1a45N824-16 'depicted the routing for these cables. 'During a walkdown

of the cable routing, the team verified that there was a location where the cables for 1-

FCV-62-90rand 1-FCV-62-91 were unprotected and separated by approximately 16 feet.

The team noted that, in lieu of protectin'g'the 1-FCV-62-90 and 1-FCV-62-91 cables in

accordance with Appendix R, to'permit operation from the MCR, the licensee

incorporated steps in the shutdown procedure'AOP-N.08 to manually manipulate local

valves 1-62-537 or 1-62-539.'

This finding h'ad more' than minorTsFgfific hcd'be~c'ausd' both charging flow isolation

valves could be'damaged by a credible-fire in fire area FAA-029,which in turn could

could affect the RCP seal Injection flow arid seal integrity. The finding was found to have

credible impact on safety in'that fire damage tothe unprotected cables could prevent

closure of the valves'from the'MCR and challenge thb'o'peirtors' ability to establish

adequate flow to the' RCP seals.' The ignition frequency forthe sub-area in'question was

taken from the SQN IPEEE as 1.85E-3 pIyear. y ie team observed that fire detection

and suppression was installed througho e arlF -029. Manual suppression

I

capability and the automatic suppression system ere deemed to be' in the normal

operating state by the team. The fire mitigation frequency was conservatively calculated

-to be once-per 105 years. The missing barrier,'condition existed for greater than 30 days.

Based on these factors, the finding was processed using the Phase 2 transient sheet and

subsequently characterized by the Significance Determination' Process as having very

low risk significance (Green). This was because the ignition frequency was relatively low,

fire detection and suppression systems were not degraded, and there were no

components in this area whose failure would result in an accident initiator (i.e. loss of

offsite power (LOOP) or loss of main feedwater, etc.). -The finding'only affects the

mitigating systems'cornerstone. '"

The failure'to protect cables with'in adequate fire barrier or to' provide 20 foot separation

between redundant charging flow isolation valves is a'violationr of 10 CFR 50 Appendix R,

Il.G.2.b.' This violation is being treated a's a No6-cited violation and is identified as NCV

50-327/02-003-01. The licensee documented the violation in PER 02-03645.

.03 Post-Fire SSD Circuit Analysis

I a. Inspection Scope I.

The team verified that selected cables of equipment required to achieve and maintain hot

shutdown conditions in the event of fire in the,four selected fire areas' had been properly

identified and either adequately protected from the potentially adverse effects of fire

damage or analyzed to show that fire-induced faults would not prevent safe shutdown.

The team selected power, control and instrumentation circuits indicated to be credited for

SSD in the licensee's FHA and walked down the routing of the circuits. The circuits

selected for review were:

Fire Area FAA-067: 1-L068-335, Pressurizer level indication

Fire Area FAC-009: FI-3-1 63C, Auxiliary feedwater flow to steam generator 1.

Fire Area FAC-20: Diesel generator start button

Additionally, the team reviewed selected electrical coordination studies to verify that fire

induced faults on energized non-shutdown circuits would not prevent the success of the

SSD functions. Specifically, the team reviewed overcurrent prote~ction,,devices related to

the control circuit for CCP IA from power source at 125 volt (V) iital iattery ~oard 1 to

the circuit breaker close and trip circuits. The manufacturer's time-current chiaracteristics

were checked; and installed devices were examined and compared to design

information. The team reviewed the coordination of overcurrent devices on the

alternating current (AC) system. From the licensee's FHA, the team reviewed those

buses identified in the FPR for a fire located in fire area FAA-029. Phase faults and

ground faults on the 6.9kV system were considered, and a review of the 6.9kV system

coordination was performed for a phase fault on a cable emanating from 480V shutdown

board1A1-A, reactor MOV board 1A1-A and ERCW MCC IA-A. To the extent possible

installed devices were examined and compared to design documents.

b. Findings

No findings of significance were identified.

.04 ASD Cagability

a. Inspection Scoge

The team reviewed the licensee's procedures for fire response and ASD capability for the

four selected fire areas to verify conformance with applicable requirements (see Section

1R05.01 above). This review included the licensee's ASD methodology to determine the

adequacy of the identified components and systems to achieve and maintain safe

shutdown. The review also evaluated that the methodology addressed achieving and

maintaining hot and cold shutdown from outside the MCR, with and without off-site power

available. The team also reviewed the licensee's procedures for consistency with the

calculations and assumptions supporting the operator actions identified in the ASD

methodology.

The team selected several ci~ui1's where the control or instrumentation devices were

determined to be located at Sh9 P or other local panels. The team reviewed relevant

drawings to determine whether isolation devices were appropriately designed into the

following circuits: '

Control circuit for the centrifugal charging pump

AFW flow to the steam generator FI-3-163C

Volume control tank outlet isolation valve LCV-62-132 (MOV)

- CCP flow to RCS-coolant-loop-1FCV-62-85-(AOV)

Source range flux monitor XI-92-5

The team evaluated if hot and cold shutdown could be maintained from outside the MCR

without offsite power through a review of selected EDG electrical components.

b. Finding

No findings of significance were identified.

.05 Operational Imblemerntation of ASD Capability

a. Inspection Scope

The team reviewed the operational implementation of post-fire safe shutdown capability

for a fire in the four selected fire areas to determine if: (1)the training program for

licensed and non-licensed personnel included alternative or dedicated SSD capability; (2)

personnel required to achieve and maintain the plant in hot standby from outside the

MCR could be provided from normal onsite staff, exclusive of the fire brigade; (3)

adequate procedures existed for use during ASD; and (4)the licensee periodically

performed operability'testing of the ACP instrumentation aslwell astransfer and control

functions. The team'observed the contents of selected SSD lockers that'materials

needed to support implementation' of operator actions specified in the ASD procedures

for hot standby were available and properly maintained. Fire' brigade staffing was

-reviewed to verify that it met the requirements of the licensee's fire protection program.

Training requirements were reviewed for the fire brigade members and related support

personnel 'such as incident commander,_ reactor operator, senior reactor operator, and

auxiliary operators to verify compliance with theflicensee's fire protection program.

Lesson plans and job performance mea sures (JPMs) were reviewed to'determine

whether ASD activities were included in the training program.'

.. - - S7S6-- .. A -. :- o :r.

Post-fire saf-htdewn procedures for thekselected areas were reviewed to determine if

adequate staffing ahd appropriate guidance was provided for'the operators to identify

protected equipment-and instrumentationand those recovery actions s pit-

7 4dshs~deyw-procedurecJ~onsidered manpower needs for performing restorations and Beth

C - * aea accessibility. Specific procedures reviewed included Abnormal Operating

Procedure (AOP)-N.01, Plant Fires, Revision (Rev)14; AOP-N.08,'Appendix R Fire Safe

Shutdown, Rev 0; AOP-C.04, Shutdown From Auxirary Control Room, Rev 4. Selected

/\

procedure sections were walked down to verify that the procedures could be performed

within the times specified in the supporting calculations, given the minimum required

staffing level of operators, concurrent with a LOOP. Additionally, the team walked down

the designated pathways and reviewed the licensee's smoke control procedures,

ventilation systems, and the availability of SCBAs to verify that environmental conditions,

-- such-as smoke and heat-,-would-not-prevent operators from performing the procedures.

b. Findings

A Non-cited violation {Green) of c n ca a, was identified for

inadequate procedu guidance relate o the transi oAOP-N.01, Plant Fires, Rev

14, to AOP-C.04, Shutdown From Auxiliary Control Room, Rev 4, 92-AGP44:6&,

Appendix-Re-Si 1 6Se utdown, Rlv, in the event of a severe fire. L

OnA~.4arch 7, he team identified thatthe guidance contained in AOP-N.01 was not

adequate to transition'operators to AOP-C.04, in that,'A2P-2[.01 did not clearly delineate

what conditions would require entry into AOP-C.04 andfi'cuation of the MCR. Also,

AOP-N.01 failed to direct operators to enter AOP-C.04 in the event of a severe fire in the

Control Building. The lack of clear guidance in AOP-N.01 washb during a

walkthrough by the team of procedures AOP-N.01 and AOP-C.04 with operations

.-- personnel. The team observed that the lack of adequate guidance in AOP-N.01

appeared to contribute to the operators' confusion regarding the entry conditions for

AOP-C.04 and the transition from AOP-N.01 to AOP-C.04. The team determined that

the confusion could cause the operator to delay entry into AOP-C.04 and the

performance of time critical ASD actions.

This finding had a credible impact on safety, in that the inadequate guidance in

procedure AOP-N.01 could delay entry into AOP-C.04 and could challenge the operators'

ability to perform certain critical safe shutdown functions (e.g., isolate normal charging,

establish adequate seal injection flow to the RCPs) within the times specified in licensee

calculation SQN'SQS4-0127, Equipment Required for Safe Shutdown Per 10 CFR 50

Appei'dix R,.Rev 21. This'fihding affect6d the mitigating systems cornerstone and was

determined to be of very low safety significance (Green) using Attachment F to the

Significance Determination Process (SDP), because it did not adversely affect fire

detection, fire suppression, or fire barriers.

TS 6.8.1.a, requires that written procedures shall be established, implemented, and

maintained covering the activities in Appendix "A" of Regulatory Guide (RG) 1.33, Rev 2.

RG 1.33, Section 6.v, requires procedures for plant fires. The failure to adequately

establish guidance in AOP-N.01, Plant Fires, for transition into SSD procedures AOP-

C.04 and AOP-N.08 in the event of a severe fire is'a violation. This violation is being

treated as a Non-cited violation and is identified as NCV 50-327, 328/02-03-02,

Inadequate Procedure Guidance for Implementing Abnormal Operating Procedures for

Plant Fires. The licensee documented the violation in PER 02-03550.

The team noted other observations during the procedure reviews and walkthroughs

which could challenge operator performance of safe shutdown activities. The following

are examples of the types of observations identified:

The validation method for the latest revisions to AOP-N.01, AOP-N.08 and AOP-C.04

lacked thoroughness in that, a "tabletop review" was performed instead of a field

validation despite significant procedural changes. These changes included the addition

of new locations for some procedural steps.

Time requirements specified in calculation SQN-SQS4-0127 for performing certain

critical safe shutdown functions were not incorporated into AOP-N.08. '

AOP-C.04, Checklist 5 required an excessive amount of time (more than 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) to

complete. The checklist appeared to contain various unnecessary items and was not

developed to assure timely performance of critical SSD actions. The team noted that

an additional field validation of AOP-C.04, Checklists 5 and 6 was performed the week

of March 11, 2002. However, this validation verified accuracy of component identifiers

and tags, but did not evaluate timeliness of critical SSD actions.

AOP-C.04 and AOP-N.08 were inconsistent in specifying the time required to re-

establish time critical actions such as seal injection flow to the RCPs. The team rioted

that AOP-C.04 specified as soon as possible and AOP-N.08 specified 15 minutes;

Weaknesses were identified in the operators' understanding and familiarity with AOP-

N.01, AOP-N.08, and AOP-C.04 during a comprehensive walkdown of the procedures

by the inspection team. -

.06 Communications for Performance of Alternative SSD Capability

a. InsDection ScoDe

The team reviewed the licensee's communications systems separation analysis to verify

the availability of the communication system to support plant personnel in the

performance of alternative safe shutdown functions and fire brigade duties. Walkdowns

were performed of sections of the alternative SSD procedure AOP-C.04 to evaluate the

adequacy of the plant communication systems to support plant personnel in the

performance of alternative SSD functions. The team reviewed the adequacy of credited

redundant communications systems and verified the licensee's portable radio channel

features would operate should the radio repeaters for the primary communications

.system be unavailable. The team also examined whether sound-powered phone jacks

--were present at the locations identified in the alternative shutdown' procedure as

designated by the SQN Updated Final Safety Analysis Report (UFSAR).. This review

included examination of the sound powered phone periodic test record and inventory

surveillance records of post-fire SSD operator equipment to assess whether the

surveillance test program was sufficient to verify proper operation of the system.

b. Findings

No findings of significance were identified.

.07 Emeraency Lighting for Performance of ASD CaDability

a. Inspection Scope

The team walked down selected areas where equipment would be controlled or

monitored during post-fire shutdown to observe whether battery pack emergency lighting

units (ELUs) were installed to allow operation of the equipment if normal lighting was lost.

In some cases the installed ELUs were tested to demonstrate functionality, and the

locations and identification numbers on the ELUs were compared to design documents to

assure the as-built configuration was consistent with the design. The team also reviewed

licensee periodic test documentation to verify that the ELUs were being maintained in an

operable manner.

b. Findings

No findings of significance were identified.

.08 Cold Shutdcown Repairs'

a. Insgection Scope

The team randomly selected a component, from the section of the FHA th t

repairs that may be needed to achieve cold shutdown, and evaluated th a

success of the repair. The component -chosen was the RHR syste

FCV-074-001 specified f,6 e arEFA-029. The review consider~dhtyevel of difficulty

of the repair as comparecfo expecfed skills of the person assigne lperform the task,

adequacy o6f relevant procedures, and the availability of necessary materials.

b. Findings

No findings of significance were identified.

.09 Fire Barriers and Fire ArealZone/Room Penetration Seals

a. Inspection Scope

The team walked down the selectecire areas to evaluate the adequacy of the fire

resistance offire areabarrier enclosure walls, ceilings, floors, structural steel support

protection, fire barrier penetration seals, fire doors, fire dampers, and electrical raceway

fire barrier systems (ERFBS) to eris that at least one train of SSD equipment would

be maintained free of fire damage ET9e team observed the material condition and

configuration of the installed fire b&Freir features, as well as, reviewed construction details

and supporting fire endurance tests for,the installed fire barrier features. The team

compared the observed fire barrier penetration seal configurations to the design drawings

and tested configurations. The team also compared the penetration seal ratings with the

ratings of the barriers in which they were installed.

The team reviewed ASD procedures, selected fire fighting pre-plan procedures, and

heating ventilation and air conditioning (HVAC) systems to verify that access to remote

shutdown equipment and operator manual actions would not be inhibited by smoke

migration from one area to adjacent plant areas used to accomplish SSD. y

In addition, the team reviewed the licensing documentation, Generic Letter86-10

engineering evaluations of fire barrier features, and engineering evaluations for NFPA

co6dedeeviatin6is to veifVhUtatieafrrierin'isfa'llatio imiet design requiements and

license commitments.

b. Findings

No findings of significance were identified.'

.10 Fire Protection Systems. Features. and EcuiDment

a. Inspection' Scope

The team reviewed flow diagrams, cable routing information, periodic test procedures,

engineering evaluations for NFPA code deviations, and operational valve lineup

procedures associated with the electric driven high pres u e ervi ater fire pumps

and fire protection water supply system. The review whether the

common fire protection water delivery and supply components could be damaged or

inhibited by fire-induced failures of electrical power supplies or control circuits.

Additionally, team members walked down portions of the fire protection water supply

system in Be selected areas to assess the material condition, operational effectiveness,

and whethl hinsteled configurations were within the parameters of the engineering

evaluations..

The team verified that adequate fire protection features were installed in accordance with

the separation and design requirements in Appendix R III.G.2. Tie team waled down

._

accessible portions of the fire detection and alarm sysfems in thele Tected OF areas to

_ . ,-- .,.....,..............................A

evaluate the engineering design and operation of the installed configurations. The team

also reviewed engineering drawings for fire detector spacing and locations in the selected

plant areas to verify H i'sof the systems and compliance with the licensee's FPR

and associated NFPA code of record. Team members walked down the selected areas

with sprinklers to assure proper placement and spacing of the sprinkler heads and the

lack of sprinkler head obstructions. The team reviewed design calculations to verify that

the required fire hose water flow and sprinkler system density for each protected area

were a6vailable. The team reviewed a sample of manual fire hose lengths to vs o4hat-

they could reach the SSD equipment. Additionally, the team verified whether the

placement of the manual fire fighting-fire hose equipment and fire extinguishers were

properly reflected in the fire brigad pre-fre plans. -

The team reviewed the adequacy of e des' and installation of the carbon dioxide

(CO2) fire suppression system for tpefi# ar&,AC-009. This review included CO2 fire

suppression system controls to asse acc sibility and fun ctionality ofhe system-ed-Qs

- I rN~~~~~~~~~~~~~~~~

associated ventilation system fire dampers ~he team also Ma

calculations, vendor certifications, and pre-'perational test data to verify that the' required

iensee design

quantity of C02 for the area was available. Additionally, the team reviewed several

I!

raeirs

i

drawings, schem fc 3 flow diagrams, and evaluations associated with the area floor

drain system to that systems and operator actions required for aftemotlve SSD AA

would ft be inhibited thfetuh potential leakage from CO2 fire suppression activities.

b. Findings T

No findings of significance were identified.

.11 ComDensatory Measures

a. Inspection Scope

The team reviewed several licensee e W iesvhich dealt with maintaining

one redundant train of SSCs free from fire damage accprdance with

Appendix R, lll.G.2. The review was performed to

= =Pe9FR-5

the risk associated with the

adverse conditions were properly assessed and adste compensatory measures

adequately considered IPEEE risk insights an ai

appl .cdrn-poteam.

b. Findings

No findings of significance were identified.

.12 Identification and Resolution of Problems

a. Inspection ScoDe

The team reviewed a sample of PERs related to fire protection and protection of SSCs

for SSD in accordance with 1Ff4-Appendix R, Il.G, Il.J. and 111.0 to verifythktklp f

items were captured in the licensee's corrective action program in accordance with SPI!7

3.1, Corrective Action Program, Rev 4. The items selected were reviewed for

classification and for the appropriateness of the corrective actions taken to resolve the

issues.¢he team reviewed self-assessments and audits related to the fire protection and

safe-swn programs to assess whether the licensee was performing comprehensive

audits of these programs in accordance with the requirements set forth in Appendix A of

BTP APCSB 9.5-1.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

40A6 Meetings

Exit Meeting Summary

The team presented the inspection results to Dennis Cole, and other members of

licensee management and staff at the conclusion of the inspection on March 28-29, 2002

and on April 24, 2002. The licensee acknowledged the findings presented. No

proprietary information is included in this report.

4oA7 Lic6hsee Identified Violations'

The following findings of very low significance were identified by the licensee and are

violations of NRC requirements which met the criteria of Section VI of the NRC

Enforcement Policy, NUREG-1600 for being dispositioned as NCVs.

NC Trackin.. i N Rn. tI F t Mee

NCV Tracking Number *'. Reqiuirement Licensee Failed to Meet

50-327,#28/02-03-03 . 10 .CFR 50 Appendix II.J states that emergency lighting

units with at least an 8-hour battery power supply shall be

provided in all areas needed for operation of safe

shutdown equipment and in access and egress routes

thereto. The licensee identified during a self-as5Bssmeqt

'hN the need for emergency lighting for the 2FCV:32,.

(~I-had not been provided. Manual operation o these

valves is required in the event of a severe fire in.

accordance with licenseefishutdown procedures. The

failure to provide adequate illumination of manual actions

required for safe shutdown is identified as a Non-cited/

violation of 10 CFR 50, Appendix R. Il!.J.Pe issue is in

tfle licensee's corrective action program as PER 02-

00550.G'(Green).

50-327,7328/02-03-04 . 10 CFR 50 Appendix R, lIl.G. 2. states that except as

provided for in paragraph G.3 of this secti6n, where cables

or equipment, including associated non-safety circuits that

could prevent operation or cause maloperation due to hot

shorts, open circuits, or shorts to ground, of reduiindnt

trains of-systems necessary to achieve and maintain hot

shutdown conditions are located within the sa'iy

ar~~tside of primary containment, one of thMUowing

mens of ensuring'that bne of the redundant trains is free

of fire damage shall be provided: (4epaPration of cables

and equipment and associated non-safety circuits of

redundant trains by a fire barrier having a 3-hour rating.

Structural steel forming a,part of or supporting such fire

barriers shall be protected to provide fire 'resistance:

equivalent to that required of the barrier; (b eparation of

cables and equipment and assboiated norn-safety circuits

of redundant trains by a horizontal distance of more than

20 feet with no intervening combustible or fire hazards. In

addition, fire detectors and an automatic fire suppression

system shall be installed in the fire area; or (ckLclosure

of cable and equipment' and associated non-safety circuits

of one~edundant train in a fire barrier having a 1-hour

ratin gIn addition, fire detectors and an automatic fire

supprS'ssion system shall be installed in the fire area. The

licensee identified during a self-assessment that as a p.,

result of inadequate protection to the contrq~2 r oQnftl

cables a spurious closure signal to the VCT level control

valves was credible. Atihe power cables for the RW

suctions valves in the sam6re pa

,thme.was an interaction which existed such that suction Bra

-both the VCT an RST could be lost. The licensee's '

failure to provide adequate protection to prevent the

operation or the maloperation of cables or equipment

necessary to achieve and maintain hot shutdown is

identified a Non-cited violation of 10 CFR 50 Appendix

R, Ill.G.2 1 he issue is in the licensee's corrective action

program E PER 02-0B576-G (Green).

PARTIAL LIST OF PERSONS CONTACTED

Licensee

J. Bajraszewski, Licensing Engineer

J. Bible, Maintenance and Modifications Manager, SQN

J. Beasley, Site Quality Manager, SQN

P. Boulden, Engineer, SQN

D. Craven, TPS-TOM Service Manager, SQN

T. Davis, Fire Protection Supervisor, WBN

B. Dukes, Engineer, SQN

R. Egli, Fire Protection Systems Engineer, SQN

K. Frazier, Systems Engineer, SQN

E. Freeman, Operations Manager, SQN

R. Gladney, Electrical Design Manager, SQN

J. Gomez, Lead Electrical Engineer, WBN

R. Goodman, Training Manager, SQN

0. Hayes, Operations Support Superintendent, SQN

P. Johnson, Fire Operations, SQN

D. Koehl, Plant Manager, SQN

D. Lundy, Engineering Manager, SQN

J. Patrick, Senior Specialist, SQN

J. Pierce, Engineer, SQN

D. Porter, Operations, SQN

R. Proffitt, Nuclear Engineer, SQN

J. Reynolds, Nuclear Assurance, SQN

R. Rogers, Engineering Design Manager, SQN

P. Salas, Licensing and Industrial Affairs Manager, SQN

B. Simril, Fire Protection Specialist, SQN

J. Smith, Licensing Manager, SQN

J. Thomas, Mechanical/Nuclear Engineering Supervisor, SQN

E. Turner, Electrical Engineering Design, SQN

J. Wilkes, Operations Superintendent, SQN

NRC C-

C. Payne, Senior Reactor ,nspector,

1 R1I

R. Tellson, Resident Inspector

ITEMS OPENED, CLOSED, and DISCUSSED

ODened and Closed

50-327/02-03-01 NCV Failure to Provide Adequate Protection for Cables to

Redundant SSD Components (Section 1R05.03)

50-327, 328/02-03-02 NCV Inadequate Procedure Guidance for Implementing

Abnormal Operating Procedures for Plant Fires (Section

1R05.05)

50-327,K28/02-03-03 NCV Inadequate Emergency Lighting for the RWST Suction

Valve (Section 40A7)

50-327,*328/02-03-04 NCV Failure to Provide Adequate Protection for Cables to the

VCT Suction Valves (Section'OA7)

Closed

None

Discussed

None

LIST OF ACRONYMS

ACR - Auxiliary Control Room

AOP - Abnormal Operating Procedure

APCSB - Auxiliary and Power Conversion ' Systems Branch

ASD - Alternative Shutdown

BTP - Branch Technical Position

CFR - Code of Federal Regulations

DC - Directd Cufrrcnt

FflP m~gcc~,' peraing Procede

ELU - Emergency Lighting Unit

cflt A lfl AD - N. L_

A,

, uv

.\,t,,

- 1-eeew:nrer

ERA Z F An

HVAC - Heating, Ventilation, and Air Conditioning

IPEEE - Individual Plant Examination for Extemal Events

JPM - Job Performance Measure

LP11LFI - LOW k-ressuri: lIjecuii

MCR Main Control Room

NCV - Non-cited Violation

NRC - Nuclear Regulatory Commission

PER - Problem Evaluation Report

Pe

rPRA - Pi-u-bilistic PisRk Asseesrseit

RCP - Reactor Coolant Pump

RCS>O - Reactor Coolant System

SCBA - Self-Contained Breathing Apparatus

SDP - Significance Determination Process

SER - Safety Evaluation Report

SLC- - Selected Licens'ee Csommitment

SSA - Safe Shutdown Analysis

SSD - - Safe Shutdown ' .. .....

TS - - Techliical Spiecifidations '

UFSAR - Updated Final Safety Analysis Report

URI~~ - Unroolved Item_

kV

LIST OF DOCUMENTS REVIEWED

Procedures:

0-AR-M-29, Annunciator Response Fire Detection System,' Rev 8

0-PI-OPS-000-708.0, 1OCFR50 Appendix R Compliance'Verification, Rev 3

1-AR-M5-B, Annunciator Response CVCS Seal Water and RCP, Rev 28

1-SO-77-4, System Operating Instruction for Auxiliary Reactor Building Floor and Equipment

1-PI-OPS-000-010.A, Verification of Remote Shutdown Transfer Switches, Rev 0, Completed

11/13/2001

AOP-C.04, Shutdown From Auxiliary Control Room, Rev 4

AOP-N.01, Plant Fires, Rev 14 '

AOP-N.08, Appendix R Fire Safe Shutdown, Rev 0 '

SPP-9.3, Plant Modifications and Engineering Change Con rol, TRev 6

SPP-10.7,-Housekeeping/Temporary Equipment Control, )~ev 0S2

SSP-10.10, Control of Transient Combustibles, Rev I

SSP-10.11, Control of Ignition Sources, Rev 1

SMI-0-317-18, Special Maintenance Instruction - Appendix R - Casualty Procedures, Rev 6

0-SI-FPU-031-001.R, Visual Inspection Fire Dampers, Rev 2

O-PI-FPU-317-299.W, Attachment 4, Operations Fire Protection Weekly Inspection, Rev 10

0-SI-FPU-410-703.0, Inspection of FPR Required Fire Doors, Rev 0.

0-SI-234.6, Functional Test of Fire Protection Report Required Detectors, Rev 32

FPI-0102, Appendix C Active Permits (Impairments), dated March'26, 2002

Pre-Fire Plan No. AUX-0-690-00, Auxiliary Building, Elevation 690'- 0, Rev 1

Pre-Fire Plan No. AUX-0-690-01, Auxiliary Building, Elevation 690'- 0, Rev 1

Pre-Fire Plan No. AUX-0-690-02, Auxiliary Building, Elevation 690'- 0, Rev 5

Pre-Fire Plan No. AUX-0-734-00, Auxiliary Building, Elevation 734'- 0, Rev 2

Pre-Fire Plan No. AUX-0-734-01, Auxiliary Building, Elevation 734'- 0, Rev 4

Pre-Fire Plan No. AUX-0-734-02, Auxiliary Building, Elevation 734'- 0, Rev 3

Pre-Fire Plan No. AUX-0-734-03,-Auxiliary Building,- Elevation 734'- 0, Rev 4

Pre-Fire Plan No. CON-0-685-00, Control Building, Elevation 685'- 0, Rev 3

Pre-Fire Plan No. CON-0-732-00, Control Building, Elevation 732'- 0, Rev 4

Job Performance Measures (JPMs) and Lesson Plans:

Lesson Plan OPL273C0202, Appendix R Fires (AOP-N.01, AOP-N.08, AOP-C.04), Rev 0

JPM CRO-005, Evacuate the Control Room, Rev 13 --

JPM CRO-052, Perform Required Actions in Preparation for Manning the SSF, Rev 4

PERS. Audits.-and Self-Assessments::,:

Fire Protection and Loss Prevention Program Audit (Biennial\Triennial) No. SSA0101-'-

Fire Protection and Loss Prevention Program Audit (Annual) No. SSAOOOI' -' .

Fire Protection and Loss Prevention Program Audit (Triennial) No. SSA9802,

Self Assessment Report, SQN-OPS-09-001 Rev 1 -

Self Assessment Report ,SQN-OPS-01-007

Attachment

2

PER 00-011423, Sequoyah Does not Perform Periodic Functional Testing on Alternate

Shutdown Transfer Switches and Controls, dated 12/15/2000

PER 01-009956, Handswitches Had to be Cycled to Pass Continuity Checks During

Performance of Procedure O-Pl-OPS-000-010.A. dated 11/2/2001

PER 01-010214, Discrepancies During Performance of Procedure 1-PI-OPS-000-010.A,

dated 11/8/2001

Calculations

SQN-26-D054/EPM-ABB-IMPFHA, Sequoyah Fire Hazards Analysis Calculation, Rev 31

SQN-SQS4-0127, Equipment Required for Safe Shutdown Per 10 CFR 50 Appendix R,

Rev 1

SQN-APPR-1, Analysis of AC/DC Instrument and Control (I&C) Power Systems to Identify

Associated Circuits - 10 CFR 50, Appendix R, Sheets 16A, 16B, 16C, 17, 37, 46, 54, 76 & 79C

of 131, Appendix R Common Power Supply Analysis, Rev 7 [Coordination 125 VDC Vital

Battery Board I, Il, lIl & IV]

SQN-APS-003, 480 V APS Class 1E Load Coordination Study, Time-Current Curve # 2, Sheet

C-6, Rev 15 (480 V shutdown boards]

SQN-APS-003, 480 V APS Class 1E Load Coordination Study, Time-Current Curve # 3, Sheet

C-7, Rev 12 [480 V reactor mov boards]

SQN-APS-003, 480 V APS Class 1E Load Coordination Study, Time-Current Curve # 8, Sheet

C-13, Rev 28 [480 V ERCW PMP STA MCCs]

Drawing Numbers

1-47W809-1, Unit I Chemical and Volume Control System Flow Diagram, Rev 64

1, 2-47W810-1, Units I and 2 Residual Heat Removal System Flow Diagram, Rev 39

1-47W81 1-1, Unit I Safety Injection System Flow Diagram, Rev 57

1, 2-47W813-1,-Units 1 and 2 Reactor Coolant System Flow Diagram, Rev 49

2-47W809-1, Unit 2 Chemical and Volume Control System Flow Diagram, Rev 64

2-47W81 1-1, Unit 2 Safety Injection System Flow Diagram, Rev 48

1,2-45N767-1, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-1 Rev 26

1,2-45N767-2, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-2 Rev 31

1,2-45N767-3,-Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-3 Rev 23

1,2-45N767-4, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-4 Rev 20

1,245N767-5, Wiring Diagrams 6900 V Diesel Generators Schematic Diagrams Sht-5 Rev 15

1,2-45N765-1, Wiring Diagrams 6900 V Shutdown Aux Power Schematic Diagram Sht-1, Rev

14 (6900 V Shutdown board 1A-A normal feeder breaker 1718]

1,2-45N765-2, Wiring Diagrams 6900 V Shutdown Aux Power Schematic Diagram Sht-2, Rev

16 [6900 V Shutdown board 1A-A emergency feeder breaker 1912]

1-45E890-104-1, 10 CFR 50 Appendix R RCS Pressure Control Operational & Spurious CA

Keys 1,2,4,5,6&9, Rev 4 [conduit and tray plan for charging pump cables in FAA-029]

1,2-45N824-7, Conduit & Grounding Floor Elevation 690.0 Ceiling Plan, Rev 2 [conduit plan for

62-90 & 91 valve cables]

Attachment

3

1,2-45N824-16, Conduit & Grounding Floor Elevation 690.0 Details - Sht-4, Rev 0 [conduit plan

for 62-90 valve cables] -

1,2-45N826-8, Conduit & Grounding Floor Elevations 706.0 & 714.0 Ceiling Plan, Rev 2,

[Routing of pressuriZ2fler l -circtLitsl-

1-45E890-103-1, 10 CFR 50 Appendix R RCS Inventory Control Operational & Spurious CA

Keys 1,2,4,5,6 & 9, Rev 3, [Routing of pressurizer level circuits]

1-45E890-103-2, 10 CFR 50 Appendix R RCS Inventory Control Operational & Spurious CA

Keys 1,2,4,5,6 & 9, Rev 1, [Routing .of pressurizer level circuits]

1-45E890-102-2,10 CFR 50 Appendix R RCS Inventory Control Operational & Spurious CA

Keys 1,2,4,5,6 & 9, Rev 1,- [Routing of pressurizer level circuits]

1-47W610-3-3, Mechanical Control Diagram Auxiliary Feedwater System, Rev 17

1,2-45N812-5, Conduit & Grounding Floor 685.0 Details - Sht 3, Rev 1 [Routing of cables for

diesel generator start button] , - -- : -

1,2-45N765-16, Wiring Diagrams 6900 V Shutdown Aux Power Schematic Diagram Sht-16,

Rev 17 [Centrifugal charging pumps]

1,2-15E500-1, Key Diagram Station Aux Power System, Rev 22

1,2-45N779-1 1, Wiring Diagrams 480 V Shutdown Aux Power Schematic Diagram Sht-1 1, Rev

24, [MOV LCV-62-132] :

1,2-45N662-1, Wiring Diagrams Chemical & Volume Cont Sys Schematic Diagram Sht-1, Rev

10, [AOV LCV-62-85] -

1-47W610-92-1, Mechanical Control Diagram Neutron Monitoring System, Rev 3

1,2-47A381-111, Mechanical Heating & V6ntilation & Air Conditioning Dampers, Rev 3

1,2-47A381 -113, Mechanical Heating & Ventilation & Air Conditioning Dampers, Rev 2

1,2-47W494 series, Fire Protection Fire Cells, Rev 6

1,2-47W600-250, Mechanical Instruments and Controls Fire Detectors, Rev 5

1,2-47W600-254, Mechanical Instruments and Controls Fire Detectors, Rev 2

1,2-47W610 series, Control Diagram High Pressure Fire Protection System, Rev 21

1,2-47W611 series, Logic Diagram Fire Detection System, Rev 12

1,2-47W849-1, Flow Diagrahm Hydrogen System for Generator Cooling, Rev 31

'1,2-47W850-2, Flow Diagram Fire Protection, Rev 25

1,2-47W850-6A, Connectivity Diagram Fire Protection System, Rev 0

1,2-47W866-2, Flow Diagram Heating & Ventilation Air Flow, Rev 11

1,2-47W866-4, FlowDiagrarm Heating & Ventilation Air Flow, Rev 32

1,247W880-26,'Conduit and Grounding Cable Tray.Fire Stop, Rev 2

1,2-48W990-1,' Miscellaneous'Steel Fire Protection Reactor Coolant'Pump Hood, Rev 3

1,2-48W991-1 , Miscellaneous Steel Fire Protection Reactor Coolant Pump, Rev 6

1,2-47W920-8, Mechanical Heating'&Ventilation & Air Conditioning, Rev'3

ML040090225

Text

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