ML20141E734
| ML20141E734 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/15/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20141E712 | List: |
| References | |
| 70-7002-97-202, NUDOCS 9705210098 | |
| Download: ML20141E734 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION.
L Inspection Report No.
70-7002/97-202.
l Docket No. 7002 Facility Operator:
United States Enrichment Corporation Facility Name:
Portsmouth Gaseous Diffusion Plant Observations' At:
Piketon, OH
. Inspection Conducted:
April.14-18,1997 Inspectors:
Yen-Ju Chen, FCOB i
Rex Wescott, FSPB i
Approved By:
Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS
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970521009g 970515 4 PDR ADOCK 07007002 I
C PDRe
EXECUTIVE
SUMMARY
PORTSMOUTH GASEOUS DIFFUSION PLANT NRC INSPECTION REPORT 70-7002/97-202 Introduction NRC performed an announced fire safety inspection of the U.S. Enrichment Corporation (USCC; 'ertsmouth Gaseous Diffusion Plant (PORTS) at Piketon, OH, on April 14-18, 1997. The h.soection was performed by staff from NRC Headquarters. The focus of this inspection was on the adequacy of the facility's fire safety program and systems.
Major fire safety performance elements reviewed at PORTS included:
e Fire suppression systems e
Fire alarm systems e
Lube oil system o
Fire station e
Internal tests and surveillance e
Building surveys and inspections e
Hot work permit Einnificant Findinas and Conclusions e
The inspectors concluded that the design and installation of the sprinkler systems appeared to be adequate for the hazards protected against as determined from the process building walk-throughs and the review of selected calculations (Detail 1.0).
e The inspectors concluded that the alarm system appeared to be of adequate design in regard to the type of supervision on the signaling and initiating device circuits (Detail 1.0).
The inspectors found no apparent defects in the lube oil system design or the operating procedures which could adversely affect fire safety in the process buildings (Detail 2.0).
e The inspectors concluded that the material condition of fire protection related items appeared to be generally satisfactory. However, some National Fire Protection Association (NFPA) code departures and facility modifications were observed. The facility personnel committed to perform evaluations to justify and appropriately resolve these departures and modifications (Detail 3.0).
The inspectors concluded that the fire station appeared to be adequate in terms of e
equipment, apparatus, and clothing to effectively augment the automatic fire suppression system in the process buildings (Detail 4.0).
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- . The inspectors noted weaknesses in the procedure for the identification of failed Technical Safety Requirements (TSR) surveillances. The Fire Services (FS) has taken actions to promptly implement the revised procedure to correct this problem (Detail 5.0).
The inspectors reviewed a Problem Report and its associated technical evaluations, and concluded that they were appropriate (Detail 6.0).
The facility's building survey and inspection procedures describe the process of conducting building surveys and report preparation, and provide survey schedules.
The building survey reports reviewed were comprehensive and provided adequate fire protection evaluation. The inspectors concluded that the building survey program appeared adequate (Detail 7.0).
The inspectors found weaknesses in the Hot Work Permit (HWP) program apparently due to procedure deficiencies and inadequate coordination between FS and Maintenance for the preparation and implementation of HWPs. The FS ' committed to appropriately resolve the matter (Detail 8.0).
DETAILS 1.0 Fire Protection System Desians a.
Scope The inspectors conducted discussions with the fire protection engineering staff, reviewed the Safety Analysis Report (SAR) and sprinkler system calculations, and performed a walk-through of portions of the process buildings to ascertain that the installed fire protection systems provide an adequate level of protection for potential t
fire (s).
- b. Qbgrvations Ei e Suporession System if SAR Section 5.4.1.1 states that the process buildings meet the definition for Ordinary Hazard Occupancy (Group 2) as per NFPA 13, " Standard for the Installation of Sprinkler Systems (1989)." Ordinary Hazard (Group 2)is defined as " occupancies or portions of other occupancies where quantity and combustibility of contents is moderate to high, stockpiles do not exceed 12 feet (3.7 m), and fires with moderate rates of heat release are expected." The inspectors performed a walk-through of process buildings X-330 and X-326, and concluded that the SAR classification
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appeared to be proper, given the amount and types of combustibles present. Although the amount of lubricating oilin the building is substantial, the oil is pumped under i
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relatively low pressure or supplied under gravity feed and is stored in large closed steel tanks.,
The process buildings are of noncombustible unprotected steel frame, and the fire suppression system is necessary te maintain structural integrity of the buildings during a fire. The inspectors reviewed the sprinkler system design and the original hydraulic.
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i calculations,' and concluded that the system performance appeared to meet the requirements for Ordinary Hazard Occupancy classification (Group 2). The process building sprinkler systems are designed to fight the worst case fire resulting from a j
large lube oil spill. This design basis is supported by a Professional Loss Control study, dated May 27,1981, which concluded that a lube oil spill followed by a fire would cause the worst case accident. The risk of a lube oil fire has since been j>
reduced by changing to a synthetic oil with a higher flash point.
a Fire Detection and Alarm Systems
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In the process buildings, the fire alarm system is designed to provide indication of fire and system operability in the fire station (building X-1007) due to the opening of sprinkler alarm valves, activation of manual pull switches, or the closing of electrically supervised valves in the high-pressure fire water system. Alarms from manual pull stations and sprinkler alarm valves are also annunciated in the plant control facility
! building X-300) along with other parameters from the high-pressure fire water system. There are no electronic smoke detectors or heat detectors for the principle purpose of fire detection in the process buildings; the sprinkler system is both the fire 4
detection and suppression system. Alarm signals are announced at the fire station by a shunt type alarm system. A McCulloh circuit provides Class A operation, which will send an alarm during a simple trouble condition. Valve supervisory circuits are Class B, which will annunciate a trouble condition but will not send an alarm during a trouble condition. The plant control facility annunciation panel provides quick identification of -
I all operating sprinkler systems as well as the first transmitter to send an alarm.
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Conclusions 1
The inspectors concluded that the design and installation of the sprinkler systems appear to provide an adequate level of protection for potential fire (s) in the process 1-buildings.
The alarm system appeared to be of adequate design with regard to the type of i
supervision on the signaling and initiating device circuits, i'
2.0 Lube Oil System a.
ScODe The inspectors reviewed the lube oil system design and conducted a walk-through of the process buildings to ascertain the fire protection is provided for potential lube oil fires.
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- b.
Observations :
The inspectors' review of the lobe and hydraulic oil systems consisted of an overview -
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presentation by the certificate holder, a' walk through inspection of typical lube oil
'i systems in buildings X-330 and X 326, and a review of the following lube oil -
procedures:
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CA 7.0,' Rev.1, Operation of the Lube Oil and Hydraulic Oil Systems, effective October 5,1988.
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e. XP4-CO-CA2635, Rev.0, Lube Oil Pit Sump Pump - Routine Inspection, effective 4
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e 'XP4-CO-CA3947, Rev. O, Controlling A Hydraulic Oil Failure, effective
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February. 10,1997.
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XP4-CO-CES975, Rev. O, Emergency Actions During A Process Building Fire, i
effective April 5,1997.
e XP4-CO-CA2632, Rev. O, Remote Control of Unit Lube Oil Systems, effective
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January 22,1997.
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e CE 10.3.1, Rev.0, Lube Oil Pit Sump Pump System - Emergency Operations, effective July 30,1980.
e CE 13.1-3, Add.2, Controlling A Lube Oil Failure,. revised September 3,1987.
j-The inspectors found that: (1) the instrumentation and controls appeared to be adequate to identify and control anticipated credible leakage events, and (2) backup controls appeared to be located sufficiently remote from the oil storage areas to be I
accessible during a fir's event.
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- c. ' Conclusions
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The inspectors concluded that the lube oil system design and the comporting operating procedures appeared to be adequate for fire safety in the process buildings.
3.0 Facility Walk-Throuah
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Scope The inspectors conducted a walk through of pump house buildings X-640-1 and X-6644 and process buildings X-330 and X-326. The purpose of the walk-throughs j.
. was to ascertain the nature of potential fire hazards in the process buildings relative to the design of the sprinkler system and to observe the general condition of the high.
pressure fire water system, including the wet pipe suppression system.
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Observations In process buildings X-330 and X 326, the inspectors made the following observations (1) As a result of construction modifications, an upright sprinkler was found to be less than'4 inches from the wall in the room containing ~ lube oil tank X-31-3 in building X-330. This is a departure from NFPA 13(1989) Section 4-2.1.5.2, which states:
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" Sprinklers shall be located a minimum of 4 inches (102 mm) from a wall" '
'(Problem Report PR-PTS-97-3817).
(2) Sprinklers were also found to be too close to the wall in stairwell 17 in building X 326 (Problem Report PR-PTS-97-3722).
(3) Upright sprinkler heads were found to be misaligned (not vertical) near a canopy on the operating floor in building X-330. This is a departure from NFPA 13(1989)
Section 4 2.4.7, which states: " Deflectors of sprinklers shall be parallel to ceilings, roofs, or the incline of stairs....." (Problem Report PR-PTS-97-3908).
(4) A welder's glove was found over an operable, sprinkler head on the cell floor near l
column EE61 in building X 330. This observation will be discussed in greater detail in Detail 8.0 of this report (Problem Report PR-PTS-97-3839).
l The facility personnel prepared Problem Reports for all of the above listed code departures or impairments of the sprinkler systems, and committed to evaluate and appropriately resolve the problems. The inspectors subsequently reviewed the evaluations and found that the evaluations for items 2,3, and 4 appeared adequate.
The inspectors concluded that a more comprehensive evaluation should be conducted i
for item 1 considering the type of potential fire hazards in the room. The inspectors will review the facility's further evaluation of item 1 to determine its adequacy. This will be tracked as inspector Follow-up Item (IFI) 97-202-01.
The inspectors also noted that several sprinkler systems on *e operating floor of j
building X-326 were modified in the 1989-1990 timeframe. ac.:ording to the FS staff.
The modification was made to provide coverage under a canopied area where potential I
combustible materials were stored. The inspectors requested a copy of the hydraulic calculations and/or design basis of the modification to assess the possible deg edation of the existing system. The FS staff could not locate the information by the end of the inspection. The FS staff committed to provide this information for future inspection. This matter will be tracked as IFI 97 202-02.
The inspectors randomly sample checked the operability surveillance date for portable fire extinguishers throughout the facility. Allinspected portable fire extinguishers showed a March or April 1997 surveillance date on the inspection tags, which j
appeared to be' appropriate.
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The inspectors also observed the placement and storage of various combustibles within process buildings X-330 and X-326 and found that an " ordinary hazard (group
. 2)" classification, as defined in NFPA 13, appeared to be appropriate.
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Conclusions 2
The inspectors concluded that the material condition of fire protection related features appeared to be generally satisfactory. However, there appeared to be some NFPA code departures and facility modifications. The facility committed to perform evaluations to justify that these departures and modifications are appropriate.
t 4.0 Fire Department a.
Scope The inspectors toured the fire station (building X-1007) to evaluate the capability of.
the onsite fire department and fire alarm system. Fire fighting equipment, apparatus, and protective clothing were considered. Fire department organization and training were not evaluated.
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Observations The inspectors conducted discussions with fire safety personnel with regard to pumper
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capacities, equipment and apparatus testing, protective clothing, and self contained breathing apparatus. The inspectors noted that the total pumper capacity appeared sufficient to provide manual suppression capability during anticipated potential fire emergencies. The inspectors also noted that equipment, clothing, and apparatus appeared to be well maintained and readily available for use, c.
Conclusions The inspectors concluded that the fire station appeared to be adequate in terms of-equipment, apparatus, and clothing to effectively augment the automatic fire suppression system in the process buildings.
5.0 Internal Tests and Surveillance a.
Sgppg The inspectors reviewed surveillance records to evaluate the recording of unsatisfactory surveillances and how compensatory and corrective measures were implemented.
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Observations The inspectors reviewed the following surveillance records:
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Test and inspection of wet pipe sprinkler systems (Procedure XP4-SS-FS6022) for-buildings X-330 ar.d X-326 for March 1997.
Quarterly tank water level drop tests performed on March 18,1997.
Annual fire pump performance tests performed on October 18,1996 (building X 6644), and June 24,1996 (building X-640).
High-pressure fire water system checklist completed between March 2 to April 6, l
1997.
t In the review of the wet pipe sprinkler system surveillances, the inspectors noted the l
surveillance failure of sprinkler system position indicating valve (PlV) #292 in process building X-330 on March 13,1997. A Maintenance Service Report (MSR) was submitted on March 13,1997, but no Problem Report was submitted at the time. The pre-printed record page indicated with an asterisk that this particular surveillance j
was a TSR requirement. A Problem Report (PR-PTS-97-3344) was submitted by FS on April 19,1997, when the fire protection engineering staff found the problem during a review of the surveillance records. The inspectors reviewed the MSR documentation i
and noted that PlV #292 was repaired, and FS tested and verified the completion of the work on April 10,1997. The inspectors also noted that FS had taken actions to j
revise Procedure XP4-SS-FS6022 and the pre-printed record sheets to make TSR L
related surveillances more prominent, in order to minimize the likelihood of missed or improperly documented TSR surveillance failures. However, the inspectors were uncertain as to whether the TSR surveillance failure was handled appropriately in this L
case. This matter will be followed up by the NRC resident inspectors as part of a generic issue and will be documented in Inspection Report 97-003.
1 The inspectors did not find failed surveillances in the record of the quarterly tank drop tests and the annual fire pump tests. This appeared to be appropriate.
l In the high-pressure fire water system checklist, an unsatisfactory remote pump operation for pumps 1 & 2 in building X-640 was recorded on April 6,1997, and a Problem Report was submitted accordingly. The inspectors reviewed the Problem Report and discussed with FS staff and the plant shift superintendent to ascertain whether this Problem Report was appropriately handled. The inspectors concluded l
that the plant operating procedures appeared to be followed, and the staff's technical evaluation and judgment appeared to be adequate.
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_Q.onclusions The inspectors noted weaknesses in the procedure for the identification of failed TSR surveillances. The FS has taken actions to promptly implement the revised procedure to correct this problem. This issue will be followed up by the resident inspectors.
6.0 Heview of X-330 Buildino Canoov Area -
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Scope The inspectors reviewed Problem Report PTS-97-3344 vsith regard to a canopy area on the operating floor of building X-330 to ascertain its adequacy.
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Observation On the operating floor of building X-330, a canopy was erected below sprinkler heads, effectively separating a significant section of floor area from sprinkler suppression of potential fires. A Problem Report (PR-PTS-97-3344, dated April 1,1997) was prepared to address this matter. The inspectors observed the subject area and reviewed the supporting technical evaluations to assess the adequacy of the report.
The inspectors reviewed the brief operability justification attached to the Problem Report and the 10 CFR 76.68 Plant Change Review Report PCR-X-97-0737, dated Avil 11,1997. : The evaluation considered the design basis of the sprinkler system (to prott,ct the structural steel and roof from a potential lube oil fire), the location of the canopy (operating floor), and the potential hazards in the area around the canopy.
While observing the area, the inspectors noted a switch gear panel and a 13.5 KV transformer in the area where sprinkler coverage is blocked or impaired. However, according to the FS staff, the transformer does not contain oil, and the switch gear panel (inside closed metal cabinets) pose little, if any, fire loading. The inspectors also noted the area is rather clean due to good housekeeping and the nearest combustibles (other than the switch gear cabinets and transformer) are safely distanced away from the canopied area and are under other sprinkler protection. Signs were posted around the canopied area prohibiting the storage of combustibles. The certificate holder j
presented in the Plant Change Review (PCR) documentation the argument that the i
major potential fire hazard is lobe oil leaking through the openings in the cell floor.
Such lube oil would drip onto the top of the canopies, and the resulting potential fire would be controlled by sprinkler protection. The PCR documentation included a recommendation that the canopies should either be removed or sprinklers should be installed underneath them.
Although a preliminary operability justification was prepared along with the Problem Report, the inspectors were concerned that the more comprehensive evaluation (PCR-X 97-0737) was not performed in a timely manner, i.e., within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This issue will be followed up by the NRC resident inspectors as part of a generic issue and will be documented iri Inspection Report 97-003.
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Conclusions The inspectors concluded that the certificate holder's evaluations appeared appropriate to resolve the sprinkler system operability issue. The inspectors will review the corrective action plan and its implementation, as recommended in the PCR documentation. This will be tracked as IFl 97-202-03. However, the timeliness of the operability evaluation will be followed up by the NRC resident inspectors as a generic issue.
-7.0 Buildino Surveys and insoections a.
Scope The inspectors reviewed building fire surveys and procedures to ascertain whether the surveys adequately evaluated process building potential fire hazards.
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Observations The FS engineers briefed the inspectors on the building inspection and survey process.
The facility's inspection requirement and responsibilities are documented in Procedure XP4-SS FS6240, Rev. O, effective March 1,1996. The monthly building fire protection inspections are conducted by FS Shift Commanders on a rotating basis for self assessment and facility familiarization. Areas of inspection include housekeeping, potential fire hazards inspection, and review of the facility emergency packet.
Cunditions, findings, and comments are recorded on Form A-2304, " Building Fire Protection Inspection." The Fire Training / Relief Commanders review the completed form and prepare reports and recommendations for disposition by facility custodians.
The procedure for the monthly building inspections appears to be adequate.
FS engineers perform the annual building surveys and inspections. The level of effort for building survey and building inspection is the same, except that a comyehensive i
report is required for building survey, while only an inspection sheet (Form A-3650,
" Fire Protection Engineering inspection") is required to document the building inspection. Procedure XP4-SS FS1910 (Rev. O, effective December 16,1996) describes the process for conducting building surveys and inspections and for formatting the survey report and inspection sheet. The procedure also specifies j
schedules for conducting building surveys and inspections for process buildings. The inspectors found that the building survey and inspection process appeared to be l
- adequate, The inspectors reviewed building surveys for building X-326, and noted that the reports have been prepared in a consistent way in the past few years. The reports identify discrepancies, make recommendations, and provide adequate evaluations of fire safety of the building.
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Conclusions The facility's building survey and inspection procedures describe the process of conducting building surveys and report preparation, and provide survey schedules.
The building survey reports reviewed appeared to be comprehensive and provide adequate fire protection evaluation. In this regard, the inspectors found that the building survey and inspection program appear adequate.
8.0 Hot Work Permit Proaram a.
Scope The inspectors reviewed the f acility's Hot Work Permit program to ascertain its adequacy.
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Observations While walking through building X-330, the inspectors noted a sprinkler head covered by a welder's glove. The glove was immediately removed, and a Problem Report was submitted to remind maintenance workers to remove shielding after hot work is completed. After further evaluation, the inspectors learned that the glove was left an the sprinkler head to protect the sprinkler during hot work performed in July 1996.
The inspectors noted the importance to protect sprinklers during hot work; however, any shielding for sprinklers should be removed after completion of the hot work. The inspectors reviewed the facility's HWP procedure a1d noted the following: (1) The procedure is silent on the protection of sprinklers during hot work, (2) the procedure does not emphasize post hot-work inspection, including bringing equipment or systems back to service if it was placed out of service during the hot work. The inspectors noted that NFPA 518 (1994), " Standard for Fire Prevention in Use of Cutting and Welding Processes," provides guidance concerning (1) and (2) above.
The inspectors discussed HWP implementation practices w!G maintenance managers and workers. The inspectors learned that protecting sprinkiers with a glove had been an acceptable past practice. However, this practice has not been formally discussed or coordinated with FS. The inspectors noted the weaknesses in the implementation of HWP and the coordination between FS and Maintenance.
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Conclusions The inspectors noted weaknesses in the HWP program, apparently due to procedure deficiencies and inadequate coordination between FS and Maintenance for the preparation and implementation of HWPs. The FS committed to appropriately resolve this matter. This will be tracked as IFl 97-202-04.
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MANAGEMENT MEETINGS Exit Meetina Summarv inspectors met with PORTS management representatives throughout the inspection. The exit meeting was held on April 18,1997. No classified or proprietary information was involved. At the exit meeting, PORTS acknowledged the deficiencies identified, and committed to take appropriate actions. The following is a list of exit meeting attendees:
O. Allen, LMUS T. Boss, LMUS J. Uovees, LMUS R. Armstrong, LMUS S. Casio, LMUS D. Mullens, LMUS D. Rockhold, LMUS
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L. Fink, USEC l
J. Blackmon, LMUS K. Tomko, LMUS -
J. Johnson, LMUS J. Henricks, LMUS C. Sheward, LMUS J. Parker, LMUS S. Martin, USEC M. Hasty, LMUS K. Zimmermann, LMUS D. Hartland, NRC Y. Chen, NRC/NMSS R. Wescott, NRC/NMSS LIST OF ACRONYMS USED FS Fire Services SAR Safety Analysis Report
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NFPA National Fire Protection Association IFl Inspector Follow-up Items TSR Technical Safety Requirements HWP Hot Work Permit PlV Position Indicating Valve MSR Maintenance Service Report 12
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