12-02-2016 | On July 23, 2015, plant operators became aware of indications of an increase in the Reactor Coolant System ( RCS) unidentified leak rate. The indications included containment radiation alarms as well as increasing containment humidity and sump levels. An RCS inventory balance indicated an unidentified leak rate of 1.2 gpm leak which is greater than the Technical Specification limit of 1 gpm for unidentified leakage. Actions were taken to determine the source of the leak. A containment entry was made, and a steam cloud was identified to be coming from the Pressurizer Spray Valve cubicle. The plant was shut down in order to comply with requirements of the Technical Specifications.
It was determined that the leak was due to seat leakage through the RCS Pressurizer CVCS Auxiliary Spray Supply Drain valve BBV0400 and then through the non-safety related pipe flange immediately downstream of the valve.
The valve was tightened which reduced the leakage to 60 drops per minute. The flange gasket was replaced. The root cause of the leak was determined to be that valve BBV0400 was not fully closed at normal closing force in RF20. The valve was replaced in April 2016 during Refueling Outage RF21. Additionally, a plant procedure was revised to require that selected valves (including BBV0400) are closed in MODE 3 using normal force or additional force if leakage is identified. |
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Category:Letter
MONTHYEARIR 05000483/20240032024-10-23023 October 2024 Integrated Inspection Report 05000483/2024003 IR 05000483/20240132024-10-21021 October 2024 Design Basis Assurance Inspection (Programs) Inspection Report 05000483/2024013 IR 05000483/20244012024-10-0909 October 2024 Material Control and Accounting Program Inspection Report 05000483/2024401 Public ULNRC-06901, Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter)2024-10-0101 October 2024 Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting (Letter) ML24247A3042024-09-11011 September 2024 Regulatory Audit Questions for License Renewal Commitments 34 and 35 (EPID L-2024-LRO-0009) - Non-Proprietary IR 05000483/20244032024-08-28028 August 2024 Security Baseline Inspection 05000483-2024-403 IR 05000483/20240052024-08-14014 August 2024 Updated Inspection Plan for Callaway Plant (Report 05000483/2024005) IR 05000483/20253012024-08-0505 August 2024 Notification of NRC Initial Operator Licensing Examination 05000483/2025301 ML24212A2822024-08-0202 August 2024 Regulatory Audit Summary Concerning Review of Request No. C3R-01 for Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections IR 05000483/20240022024-07-18018 July 2024 And Independent Spent Fuel Storage Installation Integrated Inspection Report 05000483/2024002 and 07201045/2024001 ML24185A1032024-07-16016 July 2024 2024 Biennial Problem Identification and Resolution Inspection Report ULNRC-06892, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00062024-06-26026 June 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0006 ULNRC-06891, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00052024-06-26026 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0005 ULNRC-06884, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00022024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0002 ULNRC-06886, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00042024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0004 ULNRC-06885, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00032024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0003 ML24144A0492024-06-11011 June 2024 Requests for Relief from ASME OM Code Pump and Valve Testing Requirements for Fifth 120-Month Inservice Testing Interval ML24178A1132024-06-0606 June 2024 Ameren Missouris Intent to Adopt Revision 1 to Amendment 0 of Certificate of Compliance No. 1040 as Applicable to the ISFSI at the Callaway Plant Site ML24158A5222024-06-0606 June 2024 Application to Revise Technical Specifications to Adopt Tstf-569, Rev. 2, Revise Response Time Testing Definition (LDCN 24-0008) ML24143A1632024-05-23023 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Storage Canister HGMPC0001 ULNRC-06882, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00122024-05-16016 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0012 ML24137A2342024-05-16016 May 2024 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Storage Canister HGMPC0011 ML24122A1502024-05-0707 May 2024 Audit Plan to Support Review of Steam Generator License Renewal Response to Commitment Nos 34 and 35 IR 05000483/20244022024-05-0606 May 2024 Security Baseline Inspection Report 05000483/2024402 (Full Report) ULNRC-06877, Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 252024-05-0606 May 2024 Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 25 IR 05000483/20240112024-05-0101 May 2024 NRC Post-Approval Site Inspection for License Renewal (Phase 2) Report 05000483/2024011 ULNRC-06856, CFR 50.59 and 10 CFR 72.48 Summary Report2024-05-0101 May 2024 CFR 50.59 and 10 CFR 72.48 Summary Report ML24122A1132024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radioactive Effluent Release Report ULNRC-06869, Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report2024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report ULNRC-06876, Registration of Dry Spent Fuel Storage Canister HGMPC00102024-04-25025 April 2024 Registration of Dry Spent Fuel Storage Canister HGMPC0010 ULNRC-06872, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00082024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0008 ULNRC-06866, Submittal of Cycle 26 Commitment Change Summary Report2024-04-17017 April 2024 Submittal of Cycle 26 Commitment Change Summary Report ML24108A1082024-04-17017 April 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0009 ULNRC-06871, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00072024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0007 IR 05000483/20240012024-04-16016 April 2024 Integrated Inspection Report 05000483/2024001 IR 05000483/20244042024-04-0909 April 2024 Cyber Security Inspection Report 05000483/2024404 ML24088A3212024-04-0101 April 2024 Notification of Commercial Grade Dedication Inspection (05000483/2024013) and Request for Information ML24086A5132024-03-26026 March 2024 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06863, Submittal of Annual Exposure Report for 20232024-03-20020 March 2024 Submittal of Annual Exposure Report for 2023 ML24079A1622024-03-19019 March 2024 Re Nuclear Property Insurance Reporting ML24066A1932024-03-0707 March 2024 2024 Callaway Plant Notification of Biennial Problem Identification and Resolution Inspection and Request for Information ULNRC-06852, Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 262024-03-0505 March 2024 Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 26 IR 05000483/20230062024-02-28028 February 2024 Annual Assessment Letter for Callaway Plant Report 05000483/2023006 ML24052A3662024-02-26026 February 2024 Regulatory Audit Plan in Support of Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ULNRC-06858, Completion of License Renewal Activities Prior to Entering the Period of Extended Operation2024-02-21021 February 2024 Completion of License Renewal Activities Prior to Entering the Period of Extended Operation ML24036A1712024-02-20020 February 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0079 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 ML24008A0552024-01-19019 January 2024 Acceptance of Requested Licensing Action - Proposed Alternative to the Requirements of the ASME Code (EPID L-2023-LLR- 0061) IR 05000483/20230042024-01-19019 January 2024 – Integrated Inspection Report 05000483/2023004 ML23353A1712024-01-18018 January 2024 Issuance of Amendment No. 237 to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 2024-09-11
[Table view] Category:Licensee Event Report (LER)
MONTHYEAR05000483/LER-2024-002, Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting2024-10-0101 October 2024 Concurrent Inoperability of Control Room Air Conditioning System Train and Opposite Train Emergency Diesel Generator Results in Condition Prohibited by Technical Specifications Limiting . 05000483/LER-2024-001, Reactor Trip Due to Turbine Trip2024-04-0404 April 2024 Reactor Trip Due to Turbine Trip 05000483/LER-2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023 Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications ULNRC-06398, Special Report 2017-02: Non-Functional Seismic Instrument for Greater than 30 Days2017-11-0808 November 2017 Special Report 2017-02: Non-Functional Seismic Instrument for Greater than 30 Days 05000483/LER-2017-0022017-10-13013 October 2017 Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design, LER 17-002-00 for Callaway Plant, Unit 1, Regarding Inadequate Protection from Tornado Missiles Identified Due to Nonconforming Design 05000483/LER-2017-0012017-08-15015 August 2017 Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train Inoperability, LER 17-001-00 for Callaway, Unit 1, Regarding Violation of Technical Specification 3.7.9 Due to Ultimate Heat Sink (UHS) Cooling Tower Train Inoperability 05000483/LER-2015-0012016-12-0202 December 2016 Completion of a Shutdown Required by the Technical Specifications - TS 3.4.13, LER 15-001-01 for Callaway Plant, Unit 1, Regarding Completion of a Shutdown Required by the Technical Specifications - TS 3.4.13 05000483/LER-2015-0022016-09-0707 September 2016 Manual Auxiliary Feedwater System Actuation, LER 15-002-00 for Callaway, Unit 1, Regarding Manual Auxiliary Feedwater System Actuation 05000483/LER-2016-0012016-06-20020 June 2016 Control Room Air Conditioning Inoperability Due To Essential Service Water Pressure Transient, LER 16-001-00 for Callaway, Unit 1, Regarding Control Room Air Conditioning Inoperability Due to Essential Service Water Pressure Transient 05000483/LER-2015-0032016-01-21021 January 2016 Reactor Trip Caused by Transmission Line Fault, LER 15-003-01 for Callaway, Unit 1, Regarding Reactor Trip Caused by Transmission Line Fault ULNRC-06162, Special Report 2014-05 Inoperability of Loose Parts Monitoring Instrument for Greater than 30 Day2014-12-11011 December 2014 Special Report 2014-05 Inoperability of Loose Parts Monitoring Instrument for Greater than 30 Day ULNRC-06142, SR-14-002 Callaway, Unit 1 - Special Report 2014-02-PAM Report Inoperability of Post Accident Monitoring (PAM) Instrument2014-09-16016 September 2014 SR-14-002 Callaway, Unit 1 - Special Report 2014-02-PAM Report Inoperability of Post Accident Monitoring (PAM) Instrument ULNRC-05991, Special Report 13-001-00 for Callaway, Unit 1, Inoperability of a Seismic Instrument for Greater than 30 Days2013-05-13013 May 2013 Special Report 13-001-00 for Callaway, Unit 1, Inoperability of a Seismic Instrument for Greater than 30 Days ULNRC-05932, Special Report 2012-02 - Pam Report: Inoperability of a Post Accident Monitoring (PAM) Instrument for Greater than 30 Days2012-11-14014 November 2012 Special Report 2012-02 - Pam Report: Inoperability of a Post Accident Monitoring (PAM) Instrument for Greater than 30 Days ULNRC-05824, Special Report 2011-01 for Callway, Unit 1 Regarding Inoperability of a Seismic Instrument for Greater than 30 Days2011-11-10010 November 2011 Special Report 2011-01 for Callway, Unit 1 Regarding Inoperability of a Seismic Instrument for Greater than 30 Days ULNRC-05721, Special Report, Inoperable Channel 8 of the Loose Parts Monitoring System (Lpms)2010-07-22022 July 2010 Special Report, Inoperable Channel 8 of the Loose Parts Monitoring System (Lpms) ULNRC-05374, Special Report 07-001 Re Historical Inoperability of Seismic Instrument SGAR00082007-03-0808 March 2007 Special Report 07-001 Re Historical Inoperability of Seismic Instrument SGAR0008 ML0413203792004-05-0303 May 2004 Special Report for Callaway Plant Unit 1 Regarding Inoperability of 60 Meter Meteorological Monitoring Instrumentation on the Primary Meteorological Tower 2024-04-04
[Table view] |
1. DESCRIPTION OF STRUCTURE(S), SYSTEM(S) AND COMPONENT(S):
BBV0400 [EIIS code V] is a drain valve in the Auxiliary Spray line from the Chemical Volume and Control System (CVCS) [EIIS system code CB] to the pressurizer in the Reactor Coolant System [EIIS system code AB]. The valve is an American Society of Mechanical Engineers (ASME) Code Section III Class 2, 3/4-inch welded globe valve. The BBV0400 drain line connection to the Auxiliary Spray header contains a 3/8-inch orifice [EIIS code OR] (upstream of the BBV0400 valve) that serves as the designed Safety Class break between the ASME Class 1 and Class 2 portions of this piping. A non-ASME Class 1, 2, or 3 blind flange is located downstream of valve BBV0400.
The 3/8-inch orifice is a design feature for mitigation of a line break that may be postulated to occur in the Class 2 piping upstream of the drain valve. Specifically, the orifice enables the normal makeup system to the Reactor Coolant System (i.e., the CVCS) to be capable of providing makeup flow while maintaining pressurizer level by limiting the maximum break flow to less than the available charging flow.
2. INITIAL PLANT CONDITIONS:
The plant was in MODE 1 at approximately 100 percent power on July 22, 2015.
3. EVENT DESCRIPTION:
On July 22, 2015, Callaway Plant was operating normally in Mode 1, at approximately 100% reactor power. At 2109, the particulate channel on a containment radiation monitor alarmed in Alert status. This was followed shortly with an alarm on another containment radiation monitor.
A ten-minute water inventory balance of the Reactor Coolant System (RCS) was performed and it identified a 1.2 gallon per minute (gpm) leak. Technical Specification (TS) 3.4.13 Condition A was entered due to unidentified RCS leakage greater than 1.0 gpm.
Shortly after midnight on July 23, 2015, a containment entry was made. A steam cloud was identified to be coming from the Pressurizer Spray Valve cubicle. Technical Specification (TS) 3.4.13 Condition B was entered at 0053 based on the inability to rule out pressure boundary leakage. Per TS 3.4.13 Condition B, shut down of the plant due to the inability to rule out pressure boundary leakage was commenced.
A plant load reduction was started at 0115. This was the initiation of a shutdown required by the TS. The NRC was notified of the shutdown initiation via Event Notification 51253. MODE 2 was entered at 0513. MODE 3 was entered at 0600. This was completion of a shutdown required by the TS.
Cooldown of the RCS was initiated at 1210. During the cooldown, the B Main Feedwater Pump was tripped. This led to a manual Auxiliary Feedwater initiation which is discussed in LER 2015- 002-00.
At an RCS pressure of approximately 950 psig, a containment entry was made. The leak location was determined to be at the flange downstream of valve BBV0400, CVCS Aux Spray Drain Valve. At this time it was determined that the leakage was unidentified leakage, not RCS pressure boundary leakage. BBV0400 was closed one quarter turn and leakage reduced to approximately 60 drops per minute which is less than the 1 gpm TS limit for unidentified leakage. TS 3.4.13 Conditions B and A were exited at 1725.
The flange downstream of valve BBV0400 was removed, and its Gore-Tex gasket was removed.
As noted above, the leakage past BBV0400 valve seat was observed to be 60 drops per minute. A Flexitallic gasket was placed in the flange, and the flange was bolted and tightened to approximately 150 ft-lbs. Later, a RCS heat-up was commenced. At normal operating temperature and pressure, no leakage was observed at BBV0400 valve and flange. The reactor and secondary plant startup was continued.
4. ASSESSMENT OF SAFETY CONSEQUENCES:
As mentioned above, the BBV0400 drain line connection to the Auxiliary Spray header contains a 3/8" orifice that serves as the designed Safety Class break between the ASME Class 1 and Class 2 portions of the piping. This 3/8" orifice is a design feature that enables the normal makeup system to be capable of providing makeup flow while maintaining pressurizer level by limiting the maximum break flow to less than the available charging flow. Although the leak was determined to exceed the TS limit for unidentified leakage, the leak was well within the capacity of a charging pump, as it was much less than the flow that would result from a postulated break in the Class 2 drain line. Thus, there was no significant safety impact on the plant.
In terms of a Probabilistic Risk Assessment (PRA), the leak was classified as a Very Small LOCA. The associated success criteria included charging and secondary or alternate core cooling with RHR in the injection mode, but it did not require RHR recirculation.
The incremental change in core damage frequency was determined to be less than 1E-6; therefore, this event was of very low risk significance.
Use of the PRA model to evaluate the event provides for a comprehensive, quantitative assessment of the potential safety consequences and implications of the event, including consideration of alternative conditions beyond those analyzed in the FSAR.
5. REPORTING REQUIREMENTS:
This LER is submitted pursuant to 10 CFR 50.73(a)(2)(i)(A) to report a completion of a shutdown required by the Technical Specifications. The event, i.e., initiation of a shutdown required by the Technical Specifications due to the leak from the piping around valve BBV0400, was reported to the NRC via Event Notification51253 on July 23, 2015.
The manual actuation of the auxiliary feedwater system was reported in Callaway Plant LER 2015-002-00.
6. CAUSE OF THE EVENT:
The cause of the plant shutdown was an RCS leak in excess of the limit specified in the Technical Specifications. It was determined that the leak was due to seat leakage through the RCS Pressurizer CVCS Auxiliary Spray Supply Drain valve BBV0400 and then through the non-safety related pipe flange immediately downstream of the valve. This leakage ultimately placed the plant in Condition B of TS 3.4.13, requiring the plant to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per Required Action B.1.
The valve at location BBV0400 was removed during Refuel Outage 21 (RF21) and replaced with a new valve. The removed valve was subjected to forensic analyses. The root cause of the leak was determined to be that valve BBV0400 was not fully closed at normal closing force in RF20. Contributing to this cause was a manufacturing defect that prevented the valve from being fully closed at hand-tight torque when it was closed in RF20. The defect was in the bevel machining on the valve disc and seat.
Additionally, the gasket in the flange downstream of valve BBV0400 failed.
7. CORRECTIVE ACTIONS:
After identification of the leakage, the leakage past the seat of valve BBV0400 was reduced to approximately 60 drops/minute which is below the TS limit for unidentified leakage of 1 gallon per minute. The valve was subsequently replaced in April 2016 during Refueling Outage RF21.
Additionally, a plant procedure was revised to add valve BBV00400 to the list of selected that valves are closed in MODE 3 using normal force or additional force if leakage is identified.
The Gore-Tex gasket in the flange downstream of valve BBV0400 was replaced with a flexitallic gasket.
8. PREVIOUS SIMILAR EVENTS:
A review of Callaway LERs for the past three years did not find any in which Callaway reported completion of a shutdown required by the Technical Specifications.
In July 2013, Callaway submitted LER 2013-006-00 for RCS leakage from a crack in a socket weld located where a 3/4-inch vent valve is connected to B train injection piping which in turn is connected to a cold leg of the RCS. The estimated leakage rate through the crack was 6 drops per minute.
The plant's corrective action system also documents an event from November 2014 where a sample from a containment radiation monitor showed indication of a possible RCS leak. A socket weld downstream of the CVCS Letdown Orifice B Outlet Throttle Valve developed a leak which required isolation of normal letdown and placing excess letdown in service.
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05000483/LER-2015-001, Completion of a Shutdown Required by the Technical Specifications - TS 3.4.13 | Completion of a Shutdown Required by the Technical Specifications - TS 3.4.13 | 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | 05000483/LER-2015-001 | Completion of a Shutdown Required by the Technical Specifications - TS 3.4.13 LER 15-001-01 for Callaway Plant, Unit 1, Regarding Completion of a Shutdown Required by the Technical Specifications - TS 3.4.13 | 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown | 05000483/LER-2015-002, Manual Auxiliary Feedwater System Actuation | Manual Auxiliary Feedwater System Actuation | 10 CFR 50.73(a)(2)(iv)(A), System Actuation | 05000483/LER-2015-002 | Manual Auxiliary Feedwater System Actuation LER 15-002-00 for Callaway, Unit 1, Regarding Manual Auxiliary Feedwater System Actuation | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(iv), System Actuation | 05000483/LER-2015-003, Reactor Trip Caused by Transmission Line Fault | Reactor Trip Caused by Transmission Line Fault | 10 CFR 50.73(a)(2)(iv)(A), System Actuation | 05000483/LER-2015-003 | Reactor Trip Caused by Transmission Line Fault LER 15-003-01 for Callaway, Unit 1, Regarding Reactor Trip Caused by Transmission Line Fault | 10 CFR 50.73(a)(2)(iv)(A), System Actuation 10 CFR 50.73(a)(2)(iv), System Actuation | 05000483/LER-2015-004, Auxiliary Feedwater Control Valve Inoperable Due To Faulty Electronic Positioner Card | Auxiliary Feedwater Control Valve Inoperable Due To Faulty Electronic Positioner Card | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(v)(D), Loss of Safety Function - Mitigate the Consequences of an Accident 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications | 05000483/LER-2015-004 | Auxiliary Feedwater Control Valve Inoperable Due To Faulty Electronic Positioner Card | 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition 10 CFR 50.73(a)(2)(v)(D), Loss of Safety Function - Mitigate the Consequences of an Accident 10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications |
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