ML20079A591
| ML20079A591 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/01/1994 |
| From: | Bertz S, Frick G, Pardee C CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20078T056 | List: |
| References | |
| 94-0182, 94-0182-R00, 94-182, 94-182-R, NUDOCS 9501030152 | |
| Download: ML20079A591 (15) | |
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'&f EER Number 94-0182 Rev.O Q-list System File Number 1005 Reference Non-O Document (s) EWR 13557 i
Title:
Unit 2 Feedwater Sparger Evaluation Following IVVI Exammations i
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EER No. 94-0182.
Revision No.
O ENGINEERING EVALtIkTION Page No.
2 l
. List of Effective Pages
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.PAGE INITIAL REV REV REV REV REV NO.
ISSUE NO.
NO.
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NO.
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EER No. 94-0182-
.. ENGINEERING EVALtIATION Revision No." 0 TABLE OF CONTENTS Page No.-
3 Sections Page s
Traveler (Form 2) 1*
List of Effective Pages.
2 Table of Contents.
3 Section 1 - History.
4 1.1 Introduction......................
4 1.2 Inspection Scope 5
Section 2 - Evaluation of NDE Results.
5 2.1 Inspection Results 5
2.2 Circumferential Welds.
6 2.3 Flow Holes 7
Section 3 - Disposition of Unit 1 Spargers 9
References 10 Safety Review.
11 BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34
EERINo. 94-0182~
ENGINEERING EVAI.UATION Revision No.
O Page No.
4 This EER documents the NDE examinations performed on the Unit 2 feedwater spargers during Refuel Outage B211R1; summarizes the results; and provides the justification -
to use the spargers for another operating cycle. This EER is identified as Quality, Classification Non-Q on Form 2 The spargers are not safety related components as evaluated by EER 85-0182 (Ref 6).
1.0 HISTORY OF FEEDWATER SPARGER NON-DESTRUCTIVE EXAMINATIONS 1.1 Introduction 1.1.1 Each feedwater sparger has thirty-six (36) side drilled flow holes and three (3) circumferential butt welds. The feedwater spa.rger tee has a horizontal welded seam which has four flow holes located in it. The other flow holes are located in each sparger arm section which is made of seamless bent pipe. Each sparger arm and the thermal sleeve is welded to the tee with a circumferential butt weld.
The feedwater spargers in Unit 2 continue to experience flow hole cracking. The cracks are basically of two types:
A.
Radial cracks in random directions which appear as a " sunburst" pattern centered around the flow hole.
B.
Cracks in the welded tee and in the circumferential welds attaching the sparger arms to the tee which follow alon welded seam on the flow hole side of the sparger,g the edge of the i.e., next to flow holes 17 and 20.
General Electric reports these cracks to be likely the result of weld residual stresses not fully relieved by solution heat treatment and cold working. These cracks have linked together in the horizontal weld at the 315' sparger tee section in BSEP Unit 2.
The root cause of the cracks around the flow holes is believed to be high-cycle thermal fatigue with IGSCC contributing to crack growth in the cracks following the heat affected zone of the welds.
The cracks in the flow holes were observed in 1982 (Unit 2) and 1979 (Unit 1) by visual inspection. In 1988 (B208R1) detailed mapping and measurements were accomplished in Unit 2 by liquid penetrant examination of selected flow holes to create a reliable baseline for future reference.
LP was performed again during the 1989/1990 (B209R1) Unit 2 outage.
The Unit 1 spargers were initially examined by liquid penetrant during Refueling Outage B108R1. Indicatiers were also found in the circumferential tee to sparger arm welds.
Normally, feedwater spargers are examined in conjunction with the periodic NUREG 0619 (Ref.1) examinations, however, the spargers at BSEP are the original spargers (since commercial start-up) and due to the extent of the flow hole and circumferential cracking, the sparger flow holes have been liquid penetrant examined during previous outages to monitor the crack growth.
BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34
-~
l
+
- t EER No. 94-01821 ENGINEERING EVALUETION..
Revision No.-
0 Page No.-
5-Prior to Refuel Outage B109R1', the. twelve 3 (12)' Unit l' circumfar&ntial welds had not been LP examined for their" entire. length.
In' refuel. '
Outage B108R1, only a portion of each. circumferential weld adjacent to' the respective flow holes had been examined by LP.=In Refuel Outage.
B109R1, the complete outside diameter of each circumferential weld was.
3 LP examined and weld joints with relevant indications were also UT" examined to determine the length of the cracks. All of the flow holes were visually exantined and fifty six: (56) - were selected for a liquid penetrant examination (Ref. 8).
In June of 1992 CP&L submitted the-results from the nondestructive examination of the Unit 2 feedwater spargers, performed during refueling outage B210R1, to the NRC for review.
Also, with the results, CP&L requested the NRC staff to concur on a change to the NRC requirement for continued monitoring of crack growth at future outages using a LP' technique.
CP&L proposed to monitor the crack growth during refueling e
outage B211R1 by visual examination using a high resolution remote The NRC concurred to the underwater visual inspection in a camera.
letter dated June 24, 1993 (Ref. 7).
1.2 Inanection Scone - Unit 2 Refuel Outace B21121
.All four feedwater spargers were visually ~ examined using a high I
resolution remote underwater camera.
The spargers were examined for gross defects and missing fragments.
All of the flow holes were inspected for cracking and the results recorded for each hole.
i circumferential welds were inspected to the extent possible with the
' I The remote camera.
i 2.0 EVALUATION OF REFUEL OUTAGE (B211R1) wn -ih TION Remus.TS 2.1 Insnection Results 2.1.1 The video tapes of the B211R1 visual inspection was compared with the photographs of the LP examination taken during B210R1.
shown in Tables 1 and 2.
The results are i
P i
l SSEP/Vol. XX/ENP-12 Equivalent to Rev. 34
,y
.y 4-
-p
EER No. 94-0182.
Revision No.
O ENGINEERING EVALUATION Page No.
6 2.2 Circumferential Welds Insoection Results 2.2.1 Table 1 summarizes the non-destructive examination results of the eight, welds connecting the sparger arms to the tees.
l
-Nossle.
Tee-to-Arm' Deecription.of Change:
Azimuth-.
Weld 45' Left No cracks in HAZ of cire, weld. Radial cracks from flow hole 17 into weld.
Right No cracks in HAZ of circ. weld. Radial cracks from flow hole 20 into weld.
135' Left No cracks in HAZ of cire, weld. Radial cracks from flow hole 17 into weld.
Right No change to crack in HAZ of circ. weld.
Radial cracks from flow hole 20 into weld.
225' Left No change to crack in HAZ of cire, weld.
Radial cracks from flow hole 17 into weld.
Right No change to crack in dAZ of circ. weld.
Radial cracks from flow hole 20 into weld.
315' Left No change to crack in HAZ of cire. weld.
Radial cracks from flow hole 17 into weld.
Right No change to crack in HAZ of circ. weld.
Radial cracks from flow hole 20 into weld.
Table 1. Summary of Circumferentially Oriented Indications:
The circumferential weld cracks are in the same condition as in the previous Unit 2 examination, i.e., all of the cracks are on the flow hole side of the sparger. The cracks grow downward following the heat affected zone of the circumferential weld.
There is no appreciable change in crack length or number of cracks since the last inspection.
i BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34
e i
1 EER No. 94-0182 Revision No.: t
. ENGINEERING EVALITATION Page No.-
7 l
2.3 Flow Holes Inanection Results 2.3.1 Table 2 ~ for azimuths 45*
and 135' summarizes the non-destructive '
examination results of flow holes with apparent changes as compared tof
?
-the results of the B210P.1-liquid penetrant examination.
Nossle; Flow Hole-Description of Change-
'Asinuth Number...
45*
1 No Change 2
No Change 8-No Change 12 No Change 15
~No Change-16 No Change 17-20 No new cracks or growth along longitudinal seam welds.
21 No Change 22 Cracks appear to be growin: in length with a new crack at the 12:00 position 23 Cracks appear to be growing in length 30 No Change 35 No Change 36 No Change 135*
1 Cracks appear to be growing in length and
-[
appears to be some new radial cracks.
2 New crack at 12:00 location.
6 Cracks appear to be growing in length and a new crack at 1:00 location.
15 Three new radial cracks.
17-20 No new cracks or growth along longitudinal seam welds.
19 New cracks at 12:00 location 21 New crack at 10:00. Starts at edge of flow hole and runs vertical.
22 No change.
l 31 New crack at 3:30 location.
35 No change 36 New cracks at 11:00, 11:30, 12:00, 2:00 t
I and 4:00 locations.
Table 2. Summary of changes at selected flow nole locations:
i r
I l
BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34
l l
1 EER Nor.94-0182:
Revision-No.. O ENGINEERING EVALUATION' Page No.
8 2.3.2 Table 2 for azimuths 225* and 315* summarizes the non-deatructive examination results of flow holes with apparent changes as compared to the results of the B210R1 liquid penetrant examination.
s Nossleu Flow Mole ~
Description of.. Change-
" Azimuth-msaber-225*
1 Cracks appear to be growing in length and new cracks have developed.
i 2
Cracks appear to be growing in length and new cracks have developed.
15 Cracks appear to be growing in length and new cracks have developed.
16 Cracks appear to be growing in length.
{
17-20 No new cracks or growth along longitudinal seam welds.
19 Cracks appear to be growing in length.
20 Cracks appear to be growing in length.
21 Cracks appear to be growing in length.
22 No cracks
)
29 Cracks appear to be growing in length and new cracks have developed.
33 Cracks appear to be growing in length and new cracks have developed.
35 No change 36 Cracks appear to be growing in length and new cracks have developed.
315*
1 Cracks appear to be growing in length.
2 No Change 8
No Change 15 No Change 16 No Change 17-20 No new cracks or growth along longitudinal seam welds.
21 No Change 22 No Change 28 No Change 36 Cracks appear to be growing in length.
Table 2.
Summary of changes at selected flow nole locations:
ISI has measured the following crack lengths and recorded them in PT 90.1:
Sparger at 45* - Hole No. 4 - 5:30 location Sparger at 1358 - Hole No. 6 - 6:00 location Sparger at 225* - Hole No. 26 - 1:00 location Sparger at 315* - Hole No. 27 - 8:00 location BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34
EER No. 94-0182; ENGINEERING EVALUATION Revision No..
O Page No.
9 A comparison of the LP examination results (OPT 90.1) from the previous outage show no significant changes during the operating cycle following Refueling Outage 2B11R1.
The photographs from the previous LP examination (B210R1) 4 were compared to the video.
of this examination (B211R1).
The flow holes continue to show slow crack growth.
Some new cracking was seen around the flow holes.
However, the new cracks are not.
as long as existing cracks and do not increase the probability of loose pieces in the vessel.
No segments of the spargers have separated from around the flow holes and the present configuration of the cracks should not result in any loose pieces.
3.0 DISPOSITION OF UNIT 2 SPARGERS 3.1 Circumferential Welds 3.1.1 An analysis (Ref. 3) of the circumferential weld cracking was previously prepared by General Electric Company.
This analysis was performed to identify allowable conditions for continued operation for another cycle.
The analysis concluded that the maximum allowable length of an existing circumferentially oriented crack to permit operation for one additional cycle was 10.9 inches, i.e., this is the longest allowable crack which would reach critical flaw size in one cycle of operation when additional IGSCC crack growth is considered for the cycle. (The IGSCC crack growth rate predicted by GE in Ref. 3 is 3.16" per operating cycle for a similar indication. The maximum predicted length of a crack before structural failure would occur was 14.1". ) The longest existing crack found in Unit 2 was on the 135* sparger and measured 2.0 inches at the sparger outside diameter (OD).
There is no apparent change in any of the circumferential welds.
Thus, there is a total margin of 12.1" of additional crack growth (14.1" minus 2.0") before structural failure of the joint is predicted.
It is assumed that the maximum intergranular stress corrosion crack (IGSCC) growth for one opersting cycle is 3.16 inches. The longest flaw at the end of the next operating cycle would be approximately 5.16" (2.0" plus 3.16").
It is therefore acceptable to operate for an additional cycle with the existing feedwater spargers.
The longest existing crack will not reach critical flaw size in the next operating cycle.
3.2 Flow Holes i
3.2.1 There are no significant changes from the previous examinations, therefore, it is acceptable to operate for an additional cycle with the existing flow hole cracking found in Refuel Outage B211R1.
Any potential loose fragments of the spargers would be very small and the consequences of this has been previously analyzed for Unit 2 in Ref. 9.
BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34 i
i
i 9
EER No.~94-0182..
Revision Noe O'
ENGINEERING EVALtmTION Page No.-
10 REFERENCES 1.
NUREG 0619, "BWR_Feedwater Nozzle and Control Rod Drive Return Line Nozzle
' Cracking".
2.
General Electric Company Report No. R-052, Dated 1-17-91.
t 3.
General Electric Company Report No. GE-NE-523-112-1191; DRF 137-0010, dated November, 1991, "Feedwater Sparger Circumferential Cracking Evaluation for l
Brunswick Units 1 and 2".
4.
General Electric Company Report No. BNP1-RFO-B109, IVV Inspection Report and Video Review 5.
General Electric Company Evaluation No. RDE-46-1290, "BSEP Unit 1 Feedwater Sparger Crack Growth Assessment", December, 1990.
6.
CP&L Engineering Evaluation EER 85-0182.
7 NRC Letter Dated June 24, 1993, Docket No. 50-324.
8 CP&L Engineering Evaluation EER 93-0462.
9.
Brunswick Steam Electric Plant Feedwater Sparger Crack Growth Analysis Update For Unit 2, February 12, 1990, ADK-90-14.
10.
OPT-90.1 for Unit 2,
Refuel Outage B211R1, " Core Spray /Feedwater Visual Examination".
11.
OPT-90.1 for Unit 2,
Refuel Outage B210R1, " Core Spray /Feedwater Visual Examination".
BSEP/Vol. XX/ENP-12 Equivalent to Rev. 34 l
KER No. 94-0182-ENGINEERING EVALUATION Revision No.1 ~0 Page No.
11 SAFETY REVIEW COVER SHEET DOCUMENT NO.
EER 94-0182 REV. NO.
0 DESCRIPTION OF TITLE:
Evaluation of Unit 2 Feedwater Searcers 1 Assigned Responsibilities:
Safety Analysis Preparer:
Georae L.
Frick Lead 1st Safety Reviewer Georce L.
Frick 2nd Safety Reviewer:
Steve Bertz 2 Safety Analysis Preparer: Co ete P I,
AFETY ANALYSIS Safety Analysis Prepare Date
- 2I~O O
3 Lead 1st Safety Reviewer: Complete Part II, Item Classification.
4 Lead 1st Safety Reviewer: III may be completed.
If either question 1 or 2 is "yes," then Part IV is not required.
5 Lead 1st Safety Reviewer: Determine which DISCIPLINES are required for review of this item (including own) and mark the appropriate blocks below.
DISCIPLINES Recuired-(Print Name)
Sir.rnature/Date (Steo 7)
{] Nuclear Plant Operations
[ ] Nuclear Engineering
(/] Mechanical Georoe L.
Frick f
Y 7 "!
GV
[] Electrical
( 1 Instrumentation & Control
( l Structural
() Metallurgy
[] Chemistry / Radiochemistry
[ ] Health Physics
[] Administrative Controla 6
A QUALIFIED SAFETY REVIEWER will be assigned for each DISCIPLINE marked in step 5 and his/her name printed in the space provided. Each person shall perform a SAFETY REVIEW and provide input into the Safety Review Package.
The Lead 1st Safety Reviewer will assure that a Part III or Part IV is completed 7
(see step 4 above) and a Part VI if required (see 9.b of Part II).
Each person listed in step 5 shall sign and date next to his/her name in step 5, indicating completion of a SAFETY REVIEW.
8 2nd Safety Reviewer: Per a a SAFETY REVIEW in a cordance with Section 8.0 2nd Safety Reviewer
/
Date
'/
DISCIPLINE:
Afem4s#4_
9 PNSC review required? If "yes" attach Part V and mark reason 122.
EQ 1
below:
[]
(x)
() Potential UNREVIEWED SAFETY QUESTION
[ ] Question 9 of Part IV answered "Yes"
[] Other (specify) ;
O AI-109 Rev. 002
H i
G i
'EER N3. 94-0182
' ENGINEERING EVALIZATION Revision No.
O
'i Page No.
12-PART Is. SAFETY ANALYSIS i
(See instructions in Section 8.4.1)
(Attach additional sheets as necessary)
I 1
DOCUMENT NO.
FRD 94-0182 REV. NO.
O i
DESCRIPTION OF CONDITION / CHANGE: The currently installed feedwater spargers in BSEP
- {
Unit 2 have a single row of side drilled flow holes which been developing radial cracks -
l around the flow holes since 1982. The cracks which started growing radially from the-l sparger flow holes have apparently served as initiation points for circumferential1y
~ ;.
oriented cracks traveling along the heat affected zone of the circumferential sparger _
arm-to-tee butt welds. The spargers were non-destructively examined by LP and UT during
'i refuel outage. B210R1 to document the extent of the cracking in the circe.mferential'
.i welds and to monitor the continued flow hole crack growth.
The sparg: 1 are not scheduled to be replaced until the next refueling outage, therefore the EER was written to evaluate the existing condition and provide the justification to use the existing f
spargers for an additional operating cycle.
ANALYSIS: The spargers are not safety related equipment. The spargers do not perform any safety related function. They are not part of. the reactor coolant pressure boundary. The worst case scenarios involving the flow hole cracks and the circumferential weld joint cracks are discussed in the following paragraphs and the conclusion reached by previous analyses bound the Unit 2 spargers as examined in this refuel outage, i.e., the existing spargers as examined in Refuel Outage B211R1 will be acceptable for one more operating cycle, i
Failure of one of the circumferential welds would not affect safe operation of the i
plant. The sparger end brackets are designed to provide complete support of a sparger
{
arm in the event that an arm separates from the rparger tee. Although RPV t
instrumentation would not specifically detect a broken sparger, the power distribution
{
of the core would be imbalanced by the uneven ' feedwater distribution, and the recirculation loop temperatures would change. According to GE, all of these changes would provide indicators to the operator that a problem existed that would likely result in the shutting down the unit. A sparger with a completely separated arm would
{
have no impact on a safe and orderly shutdown and since the sparger is wholly contained inside the RPV, there would be no impact on the reactor coolant pressure boundary integrity.
Therefore, the significant effect would be purely economical, since i
commercial operation would have to be suspended until the spargers were replaced.
l Circumferential weld joint failure is the worst case scenario considered for the existing spargers and has been evaluated by General Electric Company for CP&L in Ref
{
- 1. The existing circumferencial cracks are well within the allowable length evaluated i
for an additional cycle of operation. The longest existing crack found was 2.0 inches
{
long. Per Ref.
1, the maximum calculated allowable length is 10.9 inches to permit an l
additional cycle of operation. Therefore, the longest existing crack has a margin of
- B.9 inches until it reaches the allowable maximum length for continued operation for i
another cycle and has a margin of 12.1 inches until failure of the joint is predicted.
f i
2 General Electric says this is one of the design criteria for i
the sparger pinned end bracket design.
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EER N3. 94-0182 Revision No.
O ENGINEERING EVAIXATION Page No.
13 PART I SAFETY ANALYSIS CONT'D (See instructions in Section 8.4.1)
DOCUMENT NO.
EER 94-0182 REV. No.
0 These values are based upon crack growth rates for IGSCC. Irradiation assisted stress corrosion cracking (IASCC) is not considered a factor in the sparger crack growth because the fluence at the feedwater sparger locations is not sufficient to cause IASCC to dominate IGSCC growth rate.
The estimated flux at +353.88" above vessel zero is less than 1.5 E 19 n/cm. The industry accepted IASCC initiation threshold value is 2
5.0 E 20 n/cm2 for low stress. Even though Unit 2 fluence is expected to be 25% higher (1.875 E 19 n/cm ) than Unit 1, the Unit 2 value is well below the threshold value 2
required for IASCC initiation.
The sparger flow hole cracking is a known industry condition that has occurred at almost all other BWR's. The potential for small fragments of the sparger to break loose has been previously analyzed in Ref 2. The size of any likely pieces that could break free is not significant and presents no hazards to safe plant operation. The worst scenario predicted was that a piece could get lodged in a jet pump inlet mixer nozzle and cause flow erosion and or partially interrupt the reactor coolant flow passing through the jet pump.
Since the size of any potential loose parts is so small, any i
changes to the feedwater distribution would not be significant enough to be detected.
The lengths of the flow cracks are not long enough to jeopardize the structural integrity of the spargers, however, the results of a circumferential failure of the spargers are predicted be the same as previously discussed. Impingement of the cooler temperature feedwater on the RPV through a circumferential crack is a long term scenario that would impact the integrity of the RPV.
This is not a concern at this time since the circumferential indications are en the side of the sparger opposite from the RP shell,
i.e., the cracks are on the flow hole side of the spargers.
REFERENCES (1)
Feedwater Sparger Circumferential Cracking Evaluation for Rrunswick Units 1 and 2., General Electric Co. Report DRF-137-0010, November 1991.
(2)
BSEP Unit 2 Fecdwater Sparger Crack Growth Analysis Update for Unit 2, ADK 014, February 12, 1990 0 AI-109 Rev. 002
EER N3. 94-0182 ENGINEERING EVALUATION Revision No.
O Page No.
14 PART II: ITEM CLASSIFICATION DOCUMENT NO.
EER 94-0182 REV. NO.
0 1 Does this item represent:
111 H2 A change to the facility as described in the SAFETY a.
ANALYSIS REPORT?
b.
A change to the procedures as described in the SAFETY
[}
[/]
Ju1ALYSIS REPORT 7 A test or experiment not described in the SAFETY
[}
[/]
c.
ANALYSIS REPORT 7
[}
[/]
2 Does this item involve a change to the individual plant Operating License or to its Technical Specifications?
[]
[/]
3 Does this item require a revision to the FSAR?
[]
[/]
Does this item involve a change to the Offsite Dose 4
Calculation Manual?
[]
[/]
5 Does this item constitute a change to the Process Control Program?
[]
[/]
6 Does this item involve a major change to a Radwaste Treatment System?
[]
[/]
7 Does this item involve a change to the Technical Specification Equipment List?
[]
[/]
8 Does this item impact the NPDES Permit (all 3 sites) or constitute an "unreviewed environmental question" (SENPP Environmental Plan Section 3.1) or a "significant environmental impact" (BSEP) ?
[]
[/)
9 Does this item involve a change to a previously accepted:
Quality Assurance Program a.
(3
[/}
b.
Security Plan (including Training, Qualification, and Contingency Plans)?
c.
[}
l/l
[}
[/]
d.
Independent Spent Fuel Storage Installation license?
[]
I/]
(If yes, refer to Section 8.4.2,
" Question 9,"
for special considerations.
Complete Part VI in accordance with Section 8.4.6)
SEE SECTION 8.4.2 FOR INSTRUCTIONS FOR EACH "YES" ANSWER.
I REFERENCES. List FSAR and Technical Specification references used to answer questions 1-9 above.
Identify specific reference sections used for any "Yes" answer.
UFSAR Sections 3.0.
4.0.
5.0.
6.0.
7.0.
10.0.
and 15.0 and Technical Snecif.ications Sections 3/4.3. 3 /4. 4. 3/4.5 and associated desien bases.
]
O AI-109 Rev. 002
,.. ~ -
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.EER N3.'94-0182-4 a9 ENGINEERING EVAI,UATION Revision No.
'O -
Page No -
15 PART III:- UNREVIENED SAFETY QUESTION DETERMINATION SCREEN DOCUMENT NO.
m 94-0182 REV.'NO.
0 1 Is this change fylbc addressed by another completed UNREVIEWED
~
SAFETY QUESTION determination? - (See Section 7.2.1,
.7.2.2.5,_and 7.9.1.1)
~
-(/]: :( ) -
REFERENCE DOCUMENT:
m No. 93-0462
-REV.
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R 2 For procedures, is the change a non-intent change which~
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gabc (check all that. apply) : (See Section 7.2.2.3)
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Correct typographical errors which do not alter the meaning or intent of the'.
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Add or revise steps for clarification (provided they are consistent with the original purpose or applicability of the procedure); or,
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Change the title of an organizational positions or.
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Change names, addresses,'or tebphor.e numbers of persons; or,.
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Change the designation of an item of equipment where the equipment is the same as the original equipment or is an authorized replacements or,.
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Change a specified tool or instrument to an equivalent substitute; or, j
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Change the format of a procedure without altering the meaning, intent, or
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content; or
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Deletes a part or all of a procedure, the deleted portions of which are wholly covered by approved plant procedures?
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If.the answer to either Question 1 or Question 2 in.PART III is "Yes," then PART IV'
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need not be completed.
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