IR 05000277/1986008: Difference between revisions

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{{Adams
{{Adams
| number = ML20198E570
| number = ML20214D258
| issue date = 05/09/1986
| issue date = 11/13/1986
| title = Insp Repts 50-277/86-08 & 50-278/86-08 on 860317-21.No Violation Noted.Major Areas Inspected:Fire Protection Features to Ensure Ability to Achieve & Maintain Safe Shutdown in Event of Fire
| title = Mgt Meeting Repts 50-277/86-08 & 50-278/86-08 on 861016. Major Areas Discussed:Licensee Identified Noncompliances of 10CFR50,App R Requirements & Plans to Achieve Compliance, Including Timetable for Completing Mods
| author name = Anderson C, Krosopoulos A
| author name = Anderson C, Krasopoulos A
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| addressee name =  
| addressee name =  
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-277-86-08, 50-277-86-8, 50-278-86-08, 50-278-86-8, NUDOCS 8605280063
| document report number = 50-277-86-08-MM, 50-277-86-8-1, 50-277-86-8-MM, 50-278-86-08, 50-278-86-8, NUDOCS 8611210440
| package number = ML20198E563
| package number = ML20214D232
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 10
| page count = 9
}}
}}


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U.S. NUCLEAR REGULATORY COMMISSION
U.S. NUCLEAR REGULATORY COMMISSION


==REGION I==
==REGION I==
Report N /86-08 and 50-278/86-08 Docket N /50-278 License No. DPR-44 and DPR-56  Priority -
50-277/86-08 Report Nos. 50-278/86-08 50-277 Docket Nos. 50-278 DPR-44 License Nos. DPR-56   Priority --
Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: March 17-21, 1986 Inspector: ie Nf   Nac4- Y _ /9/6 A. Krasopoul'os, Re%ctor Engineer, DRS
Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Units 2 & 3 Meeting at: U.S. NRC, Region I, King of Prussia
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Meeting conducted: October 16, 1986 NRC Personnel~-
Also participating in the inspection and contributing to the report were:
_g[/ 3 !88 A: 'G.V Kra sopou10:. , Reactor Engineer, DRS   ' date Approved by:  b      //
J. Stang, Fire Protection Specialist, NRR K. Parkinson, Electrical System Specialist, BNL A. Coppola, Mechanical Systems Specialist, BNL
C. #nderson, Chief, Plant Systems Section    date Meeting Summary: Management Meeting at the NRC Region I office on October 16, 1986 to discuss licensee identified non-compliances of the 10CFR50, Appendix R requirement The licensee described the non-compliances and the interim compensatory actions taken pendina full compliance with the requirement The licensee also described their plans to achieve full compliance and they presented a timetable for completing the modifications required for compliance.
, Approved by: ~ St2A,A >>44/ //9 f/o 3 3''d*DRS ElSection, "' " '"T* ' "' * "'V It''** ' ''''
 
Inspection Summary: Inspection on March 17-21, 1986 (Combined Report N /86-08 and 50-278/86-08)
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Areas Inspected: Special, announced team inspection of the licensee's efforts to comply with the requirements of 10 CFR 50, Appendix R, Sections III. G, J and L, concerning fire protection features to ensure the ability to achieve and maintain safe shutdown in the event of a fir Results: No violations were identifie Five items remained unresolved at the end of the inspectio , PDR ADOCK.0500 e -
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8611210440 DR 861114 ADOCK 05000277 PDR i
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DETAILS 1.0 Persons Contacted 1.1 Philadelphia Electric Company (PECO)
DETAILS 1.0 Participants
  * H. Abendroth, Co-owner Site Representative
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  * W. Birely, St. Licensing Engineer
1.1 Philadelphia Electric Company (PECO)
  * W. Boyer, Electrical Supervising Engineer
W. Alden, Engineer in Charge, Licensing W. Birely, Senior Engineer, Licensing W. Boyer, Supervising Engineer W. Brady, Engineer R. Lees, Assistant Chief Electrical Engineer W. Mindick, Senior Engineer
  * G. Brecht, Jr., Chief Electrical Engineer
 
  * G. Cambell, Senior Designer
G. Morely, Supervising Engineer G. Reid, Senior Engineer C. Swenson, Compliance D. Spaner, Engineer G. Termino, Engineer U.S. Nuclear Regulatory Commission (USNRC)
  * R. Dellangelo, Designer
C. Anderson, Chief, Plant Systems Section J. Durr, Chief, Engineering Programs Branch
  * R. Fleischmann, Plant Manager
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  * C. Gerdes, Mechanical Engineer
P. Eselgroth, Chief, Projects Section 2A G. Gears, NRR Project Manager T. Johnson, Senior Resident Inspector
  * M. Lohr, Electrical Engineer R. Lonabaugh, Fire Marshal
, A. Krasopoulos, Reactor Engineer S. Pullani, Lead Reactor Engineer 2.0 Background The inspection of Peach Bottom Units 2 and 3 during March 17-21, 1986 for compliance with the 10CFR50, Appendix R requirements resulted in the issuance of a Conformatory Action Letter (CAL) by the Region on April 11, 1986.
  * J. McCawley, Electrical Engineer
 
  * W. Mindick, Sr. Electrical Engineer
r The CAL specified the licensee's schedule to complete the Appendix R Safe Shutdown confirmatory program and stated that they would inform the Region
  * G. Morley, Supervising Engineer J. Pizzolo, QA Engineer
; if any violations from the Appendix R requirements are identified.
  * G. Reid, Sr. Mechanical Engineer
 
  * M. Ryan, Compliance Engineer
l The purpose of this Management Meeting was to discuss: the Appendix R violations identified by the licensee as requested by the CAL; the interim compensatory actions taken and the long term corrective actions planned by the license .0 Presentation and Discussion Following the initial introductions, Mr. Jacque Durr, Chief of the l
  * 0. Spaner, Engineer
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  * S. Spitko, Administrative Engineer
Engineering Programs Branch opened the meeting by asking the licensee to describe the violations as identified by their safe shutdown re-evaluation.
  * C. Swenson, Compliance Engineer
 
  * G. Termine, Engineer
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  * W. Ullrich, Superintendent Nuclear Generation Division T. Wilson, Site QA Supervisor 1.2 Licensee Contractors
_ _ . . _ . _ _ _ . _ _ , _ _ . _ _ . _ _ _ _ = _ _ _ . , . . . _ _ _ _ _ . _ . . . , - . . , , . _ . . _ _ - _ _ _ . . . _ , _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ .
  * A. Melikian, Project Engineer (EPM)
  * D. Brecken, Project Manager-(EPM)
1.3 Nuclear Regulatory Commission (NRC)
  * T. Johnson, SRI
  * G. Gears, Project Manager J. Williams, RI
* Denotes those present at exit intervie .0 Purpose This team inspection was conducted to ascertain licensee compliance with 10 CFR 50, Appendix R, Sections III. G, J, and O. Because full compliance with the above regulations is not required until the end of the next i Unit 2 refueling outage, the team reviewed the licensee's approach to compliance, along with the plans and schedules for completing all other modifications required in this are I i


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The licensee distributed a document titled " Appendix R Task Force Deficiency Summary" which is included as Attachment 1 to this repor The licensee proceeded to explain that their re-evaluation of the safe shutdown capability identified about 50 deficiencies in about 20 fire area The deficiencies were classified as falling into three categories:
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Changes in initial assumptions
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Spurious Operation
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Other items The licensee stated that they have established, as an interim compensatory '
measure, fire watches to patrol the affected areas pending their achieving full complianc The adequacy of the fire watches established by the licensee was questioned by Regional Management. The licensee indicated that they would consider enhancing their program of interim fire watche The licensee stated _that Unit 2 compliance would be given highest priorit Full compliance with Appendix R for Unit 2 is scheduled for the end of the spring 1987 refueling outag However, for Unit 3 full compliance is scheduled for the next Unit 3 refueling outage in late 1987. Regional Management stated that a I
justification for continued operation should be prepared for NRC review.


3.0 Background 10 CFR 50.48 and 10 CFR 50, Appendix R, became effective on February 17, 198 For Peach Bottom Units 2 and 3, the applicable portions of this regulation are Sections III.G, " Fire Protection of Safe Shutdown Capa-bility," III.J, " Emergency Lighting," and III.L, " Alternative and  <
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Dedicated Shutdown Capability."


10 CFR 50.48 sets forth the schedule for the completion of modifications required for compliance with the above regulations. Section III.G of Appendix R requires that fire protection features are provided to ensure ~ ~ ~~~ ~
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that one train of equipment necessary to achieve and maintain safe shut-down remains available in the event of a fire at any location within a licensed operating facility. For hot shutdown conditions, one train of the systems necessary must be free of fire damage (III.G.I.a). For cold shutdown conditions, repair is allowed using in place procedures and materials available onsite with the provision that cold shutdown be achievable within 72 hours of the initiating event (III.G.1.b). Section III.G.2 lists specific options to provide adequate protection for redun-dant trains of equipment located outside of the primary containmen These options are:
 
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Separation by a fire barrier having a three hour rating (III.G.2.a).
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Attachment 1 PHILADELPHIA ELECTRIC COMPANY APPENDIX R SAFE SHUTDOWN ANALYSIS AGENDA i
Introduction  W. M. Alden R. J. Lees Overview of Task Force Review  W. J. Boyer Deficiencies and Causes  W. J. Mindick Compensatory Actions  W. C. Birely Corrective Actions W. J. Boyer Implementation of Corrective Actions W. J. Boyer l
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Separation by a horizontal distance of at least 20 feet with no in-tervening combustibles and with fire detection and automatic fire suppression installed in the fire area (III.G.2.b).
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APPENDIX R TASK FORCE DEFICIENCY SUMMARY I. Changes in initial assumptions:
l Associated DC loads were not included in the battery calcula-tions. Calculations now include the largest credible high im-pedance fault. The effect is that batteries are depleted at a faster rat Area  Parameter 13N-I Instrument power * (MOD 2085)
2-III DG exciter control (MOD 2078)
2-IV Reactor press, torus temp, drywe11 tem (MOD 2085, 1029E)
*These items also resulted from the censolidation of fire areas without proper review of instrumention concern Hot shorts and grounds on the ungrounded DC system were originally assumed to not cause undesired effect Un-grounded DC systems are new assumed to become grounded as a result of the fire and the potential for blown control fuses and spurious operation are now included in the analysi Area  Effect 43II, 44I, 45I, 46I Blown control power fuse for ESW (MOD 1351D)
37-II, 38-I, 39-I, 48-I, 50-II  Blown control power fuse for ESW (MOD 1351D)
351, 36II, 37III Tripping of RHR pump breaker  (MOD 2078)
6S-I  Tripping of HPCI (MOD 1457)
turbine Previous analyses did not address putting excess inventory into the reactor vessel. The analysis now reflects the need to shut down systems which are not required for safe shutdown but which could cause the loss of the safe shutdown capabil-ity by overfilling the reacto . . ,__ . _ - - --  . -
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Appandix R Task Force    -2-
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Enclosure of one train in a fire barrier having a one hour rating in addition to having fire detection and automatic suppression installed in the fire area (III.G.2.c).
Deficiency Summary


If the protection required by Section III.G.2 is not provided or the systems of concern are subject to damage from fire suppression .
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activities, Section III.G.3 of the rule requires that an alternate or dedicated shutdown capability be provided which is independent of the area of concern. Any alternate or dedicated system requires NRC review and approval prior to implementation.


For situations in which fire protection does not meet the requirements of--
Area    Effect 6S-I, 13N-III, 13S-II    Inability to isolate
Section III.G, however, such protection is deemed to be adequate by the licensee for the specific situation, the rule allows the licensee to request an exemption on a case-by-case basi Such exemption requests are submitted to the NRC for review and approval and must be justified by the licensee on a technical basi l Presently the licensee must comply with all of the requirements iterated
.      HPCI    (MOD 2080)
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25-IV    Inability to isolate RCIC    (MOD 1352A,
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above. One exemption from full compliance is the modification work associated with the alternative shutdown capability for Unit 2. Since some of the alternative shutdown systems are common to both units, alter- !
1353A)
i Previous analyses did not include consideration of separation between manholes for imbedded conduit The analysis now examines the separation between redundant cables within the various compartments of the manhole Area    Effect
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50-II    Less than 3 hr. sep-Yard    aration between re-dundant HPSW/ESW
:      pumps    (MOD 2078)
Yard    Less than 3 hr. sep-aration between re-dundant DG cable (MCD 2091) Previous analyses assumed that instrument air could be es-tablished for a fire in Fire Area 13S by cross-connecting the
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Unit 2 and Unit 3 headers. It has been determined that this solution is not feasible due to timing constraints and the possibility that parallel air headers may be damaged by the fire such that pressure could not be maintained. (FA-13SIII MOD 1950)
; Previous Hi/Lo pressure boundary analyses did not factor the environmental effects of a Hi/Lo pressure boundary failure into the safe shutdown analysis. Fire damage to the control cables of the RPV head vent valves could result in the in-crease of drywell temperature, which has potential adverse effects on equipment operabilit I Spurious operations
! Spurious operations that occur at inopportune times could re-sult in equipment damage.


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! Fire damage to logic cables in the RHR system could
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cause the RHR pump-breakers to close prior to power being available from the emergency bu If this oc-curs, the breaker logic will trip and lock up and must be cleared at the switchgear prior to restarting the pum (FA-34-III MOD 2078)
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native shutdown capability is not required for either unit until the end of the next Unit 2 refueling outage. Also, because the licensee is developing a more detailed fire hazards analysis, compliance with section III.G and J. could not be fully ascertained. The analysis will be completed by September 30, 198 .0 Post-Fire Safe Shutdown Capability 4.1 Systems Required for Safe Shutdown In the event of a fire concurrent with the loss of offsite power, the~ ~~ ~
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following systems are used to provide the safe shutdown capability of the plant:
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High Pressure Coolant Injection (HPCI) System
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Reactor Core Isolation (RCIC) System
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Automatic Depressurization (ADS) and non-ADS Safety Relief Valves (SRVs)
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Residual Heat Removal (RHR) System-shutdown cooling mode, suppression pool cooling mode, and low pressure coolant injection (LPCI) mode
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Core Spray (CS) System
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High Pressure Service Water (HPSW) System
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Emergency Service Water (ESW) System
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Onsite AC Power Generation and Distribution System
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Onsite DC Power Generation and Distribution System
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Essantial Ventilation Systems Safe shutdown is initiated from the control room by a manual scram of the control rods or automatically by the reactor protection syste The support systems required for safe shutdown include the emergency service water system (ESW) for diesel generator cooling, high pressure service water system (HPSW) for RHR heat exchanger cooling, onsite AC emergency power system, onsite DC Emergency power system and essential ventilation system The precise methodology used for safe shutdown has not been finalized by the licensee. Currently, the following shutdown methods are under review:
Method-A l
For Method A, RCIC is used to maintain reactor vessel coolant inven-tor RHR and HPSW are used for suppression pool cooling which is required for decay heat remova Heat is transferred from the vessel to the suppression pool via the ADS system and/or the RCIC steam turbine discharg _ _ _ _ - _ .
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, Appendix R Task Force    -3-Deficiency Summary 4 Fire damage to logic cables could start the RHR pumps with no minimum flow protection on the pump. The avail-able time before damage occurs to the RHR pump is con-
Method B For Method B, HPCI is used to maintain reactor vessel coolant inven-tory, RHR and HPSW are required as in method A for suppression pool cooling. Heat is transferred from the vessel to the suppression via the ADS system and/or the HPCI steam turbine discharg Method C For Method C, the reactor is depressurized using the ADS system to a point where either the Core Spray or the LPCI mode of the RHR' - ~ ~ -
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systems can be used to maintain core inventor Method D Method D, is the alternative shutdown method for a catastrophic fire in either the Control Room, Cable Spreading Room or the Emergency Shutdown Panel Are This method is described in the following sectio .2 Alternate Safe Shutdown Areas The licensee committed to and is in the process of_ establishing alternate safe shutdown capability independent of the main control room, cable spreading room and the emergency shutdown panel are The alternative shutdcwn stations are provided with circuit isolation capability using manual control switches, relays, breakers or fuse-disconnect switches, to ensure that no electrical connection exists between the alternative shutdown circuits and those affected by a fire in any one of the above-mentioned area In the event of an unmitigated fire in these areas, the operators will proceed to the alternative shutdown stations to initiate shut-down operation Communications will be established between the operators who are at the alternative shutdown stations and the coordinating operator. The alternative control stations for Peach Bottom are or will be in the following locations:
sidered to be too short for the operator to recognize the situation and to take manual action to secure the
4. HPCI Alternative Control Station - This panel will be located in each unit in the MG set room at elevation 135' - 0". The-HPCI alternative control station will be equipped with pump diagnostic instrumentation and transfer switches and alternative power supplies for the HPCI turbine. This panel will be equipped -
!    RHR pum (FA-6S-II, 13N-II MOD 2084) Spurious operations of equipment or components that could de-feat system function that were overlooked or not included in previous analyse . Fire damage to the fire protection system cables in the diesel generator building could initiate CO, injection in individual diesel bays. Since the dieser takes com-bustion air from its room, the diesel would stop on loss of ai (FA-44II, 45II, 46II, 54II MOD 2078) Fire damage to control cables for the ESW sluice gates could cause these gates to close and block ESW flow path. (FA-25II, 39II, 50I lock open sluice gates) Fire damage to control cables for the ESW discharge valve could cause the valve to close and block the ESW flow pat This item was identified, but not installed for Alternative Shutdown and overlooked for Safe Shutdow (2-I, 25-III, 34-II, 36-III, 43-I, 54-I MOD 2079) Fire damage to logic cables for HPCI could isolate the system. (13S-I MOD 2078) Fire damage to bus current transformer cables could trip the bus and lockout the diesel generator breaker (34-I, 35-II, 36-I, 37-I MOD 2078) Fire damage to control cables for a HPCI AC valve could cause the valve to close and disable the HPCI syste (FA-25I Mod 1352A, 1353A)
with the alternative process monitoring instrumentation which indicates reactor vessel pressure and level, suppression pool temperature, and condensate storage tank leve . Diesel Generators Alternative Control Station - These panels will be located in Unit 2 4KV emergency switchgear rooms B/D and are common to both Units 2.and 3. The panels will be equipped with transfer switches to isolate all main control room control circuits, and also diesel generator diagnostic instrumentatio _ _
:  II Other items 1 The field walkdown of safe shutdown conduits identified that some safe shutdown conduits were inaccurately shown on de-sign drawings. (2-II MOD 2085) Fire damage in FA-30 results in the loss of both the primary and backup power sources to the RHR and HPSW flow instrument (MOD 1029E, 2085)
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. Appendix R Task Force  -4-Deficiency Summary Emergency lighting was installed for analyses submitted 9/16/83, 7/11/83, and 7/22/83. During subsequent analysis, further installations of emergency lighting was de ferred pending final design of Alternative Shutdown and completion of the Safe Shutdown reverification program. The locations have now been identified (Table A-4 of FPP) and design for installation is in progress. (MOD 2081) Fire damage results in the loss of power to a diesel genera-tor auxiliary motor control center. The diesel is used for safe shutdown in the area. (6N-II, 40-I MOD 2078) The associated circuit analysis identified one molded case circuit breaker which requires a trip setpoint change to pro-vide proper coordinatio (Associated circuit by common power source) (MCD 2083) The associated circuit analysis identified a motor control center section 20DllA separated from its main motor control center 20Dll that had no overcurrent protection. (Associated circuit by common enclosure) (MOD 13S2A, 1353A) Fire damage in Unit 3 results in the loss of a Unit 3 torus temperature loop fed from a common unit power supply. (13N-I)
(MOD 2085)
I Previously identified items Unit 2 Process and Diagnostic Instrumentatio Previous commitment was for end of upcoming Unit 2 re-fueling outag (Mod 1029E) Frovide thermal magnetic trip devices to MCC Previous Associated Circuit Analyses identified need for thermal magnetic breaker Modification was on hold pending equipment qualification of device (Mod 1029J, K, L) Spurious closure of HPCI and RCIC steam valves The potential for these valves to defeat system operation was identified during the 3/86 audit and reported en 5/22/86. This report identified the condition on one RCIC valve and one HPCI valve. The reverification iden-tified the concern on one additional RCIC valv (Mod 2079) Unit 2 relief valve capability Previous commitment was for end of upcoming Unit 2 refueling outage (Mcd 1950)


4. KV Emergency Switchgear Alternative Controls - These controls are located in the 4KV emergency switchgear rooms in each unit. Transfer switches will provide alternative local control and status indication for the motor control centers and for the ESW, RHR and HPSW pump . ADS Transfer / Isolation Station - Alternative control capabilities for 3 ADS valves and the associated nitrogen supply isolation valves will be located on the HPCI Alternative Control Stations in the M-G Set Rooms. The transfer / isolation switches for these controls are located in the 4KV switchgear rooms. The remote locations for the transfer / isolation switches are necessary to preserve safe shutdown capability for the M-G Set Room . RHR/HPSW Suppression Pool Alternative Control Stations -
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Alternative control capabilities and transfer / isolation switches for one loop of RHR/HPSW Motor Operated Valves (MOV's), needed to support Suppression Pool Cooling, will be located at the HPCI Alternative Control Stations in the M-G Set Room .3 Remaining Plant Areas The licensee indicated that all other areas of the plant not required to have an alternate safe shutdown system, comply with the requirements of Section III.G.2 of Appendix R, unless an exemption request has been approved by the staf .0 Inspection Methodology The inspection team examined the licensee's provisions for separating and protecting equipment, cabling and associated circuits necessary to achieve and maintain hot and cold shutdown conditions. This inspection sampled selected fire areas which the licensee had identified as being in compli-ance with Section II The following functional requirements were reviewed for achieving and maintaining hot and cold shutdown:
* Reactivity control
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Pressure control
* Reactor coolant makeup
* Decay heat removal
* Support systems
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Process monitoring
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The inspection team examined the licensee's capability to achieve and maintain hot shutdown and the capability to bring the plant to cold shut-down conditions in the event of a fire in various areas of the plant. The examination included a review of drawings, safe shutdown procedures and other documents. Drawings were reviewed to verify electrical independence from the fire areas of concern. Procedures were reviewed for general content and feasibilit Also inspected were fire detection and suppression systems and the degree of physical separation between redundant trains of Safe Shutdown Systems (SSSs). The team review included an evaluation of the susceptibility of' -
the SSSs to damage from fire suppression activities or from the rupture or inadvertent operation of fire suppression system The inspection team examined the licensee's fire protection features provided to maintain one train of equipment needed for safe shutdown free of fire damage. Included in the scope of this effort were fire area boundaries, including walls, floors and ceilings, and fire protection.of
openings such as fire doors, fire dampers, and penetration seal The inspection team also examined the licensee's compliance with Section III.J, Emergency Lighting. Section III.0, Oil Collection System for Reactor Coolant Pump is not applicable to the licensee since the contain-ment is inerted during normal operations.
) 6.0 Inspection of Protection Provided for Safe Shutdown Systems 6.1 Protection in Various Fire Areas The team reviewed the protection prov'ided to SSSs in selected fire areas for compliance with Appendix R, Sections III.G.1, 2 and The following fire areas were inspected:
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The Control Room
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The Cable Spreading Room
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  'The Switch Gear Room
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The Battery Room
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The Intake Structure (Fire Areas 47 and 48)
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The Turbine Building
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The Reactor Building, Fire Areas 5, 6, 12 and 13
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;- . Appendix R Task Force    -5-Deficiency Summary
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h I Con't.
i i Testable check equalizer valves on RHR and CS.


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;    Previous Hi/Lo pressure boundary analysis identified
The Radwaste Building, Fire Areas 2 and 25
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Yard Area Manholes 25, 89 and 90 No unacceptable conditions were identified except as follows:
Inspection effort incomplete because of unfinished analysi The inspection team could not ascertain the licensee's compliance with Section III.G of Appendix R because the analysis identifying the shutdown methodology had not been finalized at the time of the inspection. This is an unresolved item pending completion of the analysi (50-277/86-08-01 and 50-278/86-08-01)
6.2 Safe Shutdown Procedures The team requested to review safe shutdown and alternative shutdown procedures to ascertain that shutdown can be achieved in a safe and orderly manne The licensee stated that these procedures have not been developed as yet but will be in effect by the end of the next Unit 2 refueling outage. This is in agreement with previous commitments made to the NR This is an unresolved item pending licensee completion of the procedure (50-277/86-08-02 and 50-278/86-08-02)
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6.3 Protection for Associated Circuits Appendix R, Section III.G requires that protection be provided for associated circuits that could prevent operation or cause malopera-tion of redundant trains of systems necessary for safe shutdow The circuits of concern are generally associated with safe shutdown circuits in one of three ways:
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Common bus concern
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need to address valves. Mechanical analysis now demon-
Spurious signals concern
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Common enclosure concern
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The associated circuits were evaluated by the team for common bus, spurious signal, and common enclosure concerns. . Power, control, and instrumentation circuits were examined on a sampling basis for potential problem . Common Bus Concern-The common bus concern may be found in circuits, either safety related or non-safety related, where there is a common power source with shutdown equipment and the power source is not electrically protected from the circuit of concer .
. 9 The team examined, on a sampling basis, protective relay coordination for 4160V and 480V buses and protection for specific instrumentation, control and power circuits. The coordination of fuses and circuit breakers was checked by examination of the licensee's fuse and breaker coordination curves. The licensee performs relay calibration during refueling outages on approximately 18 month interval No unacceptable conditions were identifie .3.2 Spurious Signals Concern  ~ ~~ -
The spurious signal concern is made up of 2 items:
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False motor control and instrument indications can occur such as those encountered during the 1975 Browns Ferry fire. These could be caused by fire initiated grounds, short or open circuit *
Spurious operation of safety related or non-safety related components can occur that would adversely affect shutdown capability (e.g., RHR/RCS isolation valves).


The team requested to review documents, on a sampling basis, in the following areas to ascertain that no spurious signal concern exists:
1 Unit 2 and Common Alternative Shutdown ~
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i    Previous commitment was for end of upcoming Unit 2 re-j    fueling outage (Mod 1351,1352)        -
Current transformer secondaries
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General fire instigated spurious signals The licensee explained that an associated circuit analysis for spurious signals is currently being developed but is not yet finishe This is an unresolved item pending the licensee's comple-tion of an associated circuits analysis for spurious signal (50-277/86-08-03 and 50-278/86-08-03).
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6.3.3 Common Enclosure Concern The common enclosure concern may be found when redundant circuits are routed together in a raceway or enclosure and they are not electrically protected or when a ~ fire can destroy both circuits due to inadequate fire barriers. The team could not inspect this area since the licensee's analysis was incomplete. The licensee stated that this analysis is currently in proces ..
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,  10 This is an unresolved item pending licensee completion of the analysis and reinspection in this are (50-277/86-08-04 and 50-278/86-08-04)
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7.0 Emergency Lighting 10 CFR 50, Appendix R, Section III.J, requires 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 theret ~. - _ . - -.
Due to lack of safe shutdown procedures, the team was not able to inspect this area. This item remains unresolved. (50-277/86-08-05 and 50-278/86-08-05)
8.0 Oil Collection System for Reactor Coolant Pumps 10 CFR 50, Appendix R, Section III.0, requires that the reactor coolant pumps shall be equipped with an oil collection system if the containment is not inerted during normal operation. As the containment for either unit is inerted during normal operation, the above requirement does not apply to Units 2 or .0 _ Unresolved Items Unresolved items are matters for which more information is required in order to ascertain whether they are acceptable, violations, or deviation Unresolved items are discussed in Sections 6.1, 6.2, 6.3 and .0 Exit Interview The inspection team met with the licensee representatives, denoted in Section 1.0, at the conclusion of the inspection on March 21, 1986, and the team leader summarized the scope and findings of the inspection at that time.
 
, The team leader also confirmed with the licensee that the report will not contain any proprietary information. The licensee agreed that the inspection report may be placed in the Public Document Room without prior licensee review for proprietary information (10 CFR 2.790).


At no time during this inspection was written material provided to the licensee by the team.
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Revision as of 19:25, 19 January 2021

Mgt Meeting Repts 50-277/86-08 & 50-278/86-08 on 861016. Major Areas Discussed:Licensee Identified Noncompliances of 10CFR50,App R Requirements & Plans to Achieve Compliance, Including Timetable for Completing Mods
ML20214D258
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 11/13/1986
From: Anderson C, Krasopoulos A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214D232 List:
References
50-277-86-08-MM, 50-277-86-8-1, 50-277-86-8-MM, 50-278-86-08, 50-278-86-8, NUDOCS 8611210440
Download: ML20214D258 (9)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-277/86-08 Report Nos. 50-278/86-08 50-277 Docket Nos. 50-278 DPR-44 License Nos. DPR-56 Priority --

Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Units 2 & 3 Meeting at: U.S. NRC, Region I, King of Prussia

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Meeting conducted: October 16, 1986 NRC Personnel: ~-

_g[/ 3 !88 A: 'G.V Kra sopou10:. , Reactor Engineer, DRS ' date Approved by: b //

C. #nderson, Chief, Plant Systems Section date Meeting Summary: Management Meeting at the NRC Region I office on October 16, 1986 to discuss licensee identified non-compliances of the 10CFR50, Appendix R requirement The licensee described the non-compliances and the interim compensatory actions taken pendina full compliance with the requirement The licensee also described their plans to achieve full compliance and they presented a timetable for completing the modifications required for compliance.

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8611210440 DR 861114 ADOCK 05000277 PDR i

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DETAILS 1.0 Participants

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1.1 Philadelphia Electric Company (PECO)

W. Alden, Engineer in Charge, Licensing W. Birely, Senior Engineer, Licensing W. Boyer, Supervising Engineer W. Brady, Engineer R. Lees, Assistant Chief Electrical Engineer W. Mindick, Senior Engineer

G. Morely, Supervising Engineer G. Reid, Senior Engineer C. Swenson, Compliance D. Spaner, Engineer G. Termino, Engineer U.S. Nuclear Regulatory Commission (USNRC)

C. Anderson, Chief, Plant Systems Section J. Durr, Chief, Engineering Programs Branch

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P. Eselgroth, Chief, Projects Section 2A G. Gears, NRR Project Manager T. Johnson, Senior Resident Inspector

, A. Krasopoulos, Reactor Engineer S. Pullani, Lead Reactor Engineer 2.0 Background The inspection of Peach Bottom Units 2 and 3 during March 17-21, 1986 for compliance with the 10CFR50, Appendix R requirements resulted in the issuance of a Conformatory Action Letter (CAL) by the Region on April 11, 1986.

r The CAL specified the licensee's schedule to complete the Appendix R Safe Shutdown confirmatory program and stated that they would inform the Region

if any violations from the Appendix R requirements are identified.

l The purpose of this Management Meeting was to discuss: the Appendix R violations identified by the licensee as requested by the CAL; the interim compensatory actions taken and the long term corrective actions planned by the license .0 Presentation and Discussion Following the initial introductions, Mr. Jacque Durr, Chief of the l

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Engineering Programs Branch opened the meeting by asking the licensee to describe the violations as identified by their safe shutdown re-evaluation.

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The licensee distributed a document titled " Appendix R Task Force Deficiency Summary" which is included as Attachment 1 to this repor The licensee proceeded to explain that their re-evaluation of the safe shutdown capability identified about 50 deficiencies in about 20 fire area The deficiencies were classified as falling into three categories:

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Changes in initial assumptions

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Spurious Operation

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Other items The licensee stated that they have established, as an interim compensatory '

measure, fire watches to patrol the affected areas pending their achieving full complianc The adequacy of the fire watches established by the licensee was questioned by Regional Management. The licensee indicated that they would consider enhancing their program of interim fire watche The licensee stated _that Unit 2 compliance would be given highest priorit Full compliance with Appendix R for Unit 2 is scheduled for the end of the spring 1987 refueling outag However, for Unit 3 full compliance is scheduled for the next Unit 3 refueling outage in late 1987. Regional Management stated that a I

justification for continued operation should be prepared for NRC review.

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Attachment 1 PHILADELPHIA ELECTRIC COMPANY APPENDIX R SAFE SHUTDOWN ANALYSIS AGENDA i

Introduction W. M. Alden R. J. Lees Overview of Task Force Review W. J. Boyer Deficiencies and Causes W. J. Mindick Compensatory Actions W. C. Birely Corrective Actions W. J. Boyer Implementation of Corrective Actions W. J. Boyer l

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APPENDIX R TASK FORCE DEFICIENCY SUMMARY I. Changes in initial assumptions:

l Associated DC loads were not included in the battery calcula-tions. Calculations now include the largest credible high im-pedance fault. The effect is that batteries are depleted at a faster rat Area Parameter 13N-I Instrument power * (MOD 2085)

2-III DG exciter control (MOD 2078)

2-IV Reactor press, torus temp, drywe11 tem (MOD 2085, 1029E)

  • These items also resulted from the censolidation of fire areas without proper review of instrumention concern Hot shorts and grounds on the ungrounded DC system were originally assumed to not cause undesired effect Un-grounded DC systems are new assumed to become grounded as a result of the fire and the potential for blown control fuses and spurious operation are now included in the analysi Area Effect 43II, 44I, 45I, 46I Blown control power fuse for ESW (MOD 1351D)

37-II, 38-I, 39-I, 48-I, 50-II Blown control power fuse for ESW (MOD 1351D)

351, 36II, 37III Tripping of RHR pump breaker (MOD 2078)

6S-I Tripping of HPCI (MOD 1457)

turbine Previous analyses did not address putting excess inventory into the reactor vessel. The analysis now reflects the need to shut down systems which are not required for safe shutdown but which could cause the loss of the safe shutdown capabil-ity by overfilling the reacto . . ,__ . _ - - -- . -

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Appandix R Task Force -2-

Deficiency Summary

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Area Effect 6S-I, 13N-III, 13S-II Inability to isolate

. HPCI (MOD 2080)

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25-IV Inability to isolate RCIC (MOD 1352A,

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1353A)

i Previous analyses did not include consideration of separation between manholes for imbedded conduit The analysis now examines the separation between redundant cables within the various compartments of the manhole Area Effect

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50-II Less than 3 hr. sep-Yard aration between re-dundant HPSW/ESW

pumps (MOD 2078)

Yard Less than 3 hr. sep-aration between re-dundant DG cable (MCD 2091) Previous analyses assumed that instrument air could be es-tablished for a fire in Fire Area 13S by cross-connecting the

! Unit 2 and Unit 3 headers. It has been determined that this solution is not feasible due to timing constraints and the possibility that parallel air headers may be damaged by the fire such that pressure could not be maintained. (FA-13SIII MOD 1950)

Previous Hi/Lo pressure boundary analyses did not factor the environmental effects of a Hi/Lo pressure boundary failure into the safe shutdown analysis. Fire damage to the control cables of the RPV head vent valves could result in the in-crease of drywell temperature, which has potential adverse effects on equipment operabilit I Spurious operations

! Spurious operations that occur at inopportune times could re-sult in equipment damage.

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! Fire damage to logic cables in the RHR system could

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cause the RHR pump-breakers to close prior to power being available from the emergency bu If this oc-curs, the breaker logic will trip and lock up and must be cleared at the switchgear prior to restarting the pum (FA-34-III MOD 2078)

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, Appendix R Task Force -3-Deficiency Summary 4 Fire damage to logic cables could start the RHR pumps with no minimum flow protection on the pump. The avail-able time before damage occurs to the RHR pump is con-

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sidered to be too short for the operator to recognize the situation and to take manual action to secure the

! RHR pum (FA-6S-II, 13N-II MOD 2084) Spurious operations of equipment or components that could de-feat system function that were overlooked or not included in previous analyse . Fire damage to the fire protection system cables in the diesel generator building could initiate CO, injection in individual diesel bays. Since the dieser takes com-bustion air from its room, the diesel would stop on loss of ai (FA-44II, 45II, 46II, 54II MOD 2078) Fire damage to control cables for the ESW sluice gates could cause these gates to close and block ESW flow path. (FA-25II, 39II, 50I lock open sluice gates) Fire damage to control cables for the ESW discharge valve could cause the valve to close and block the ESW flow pat This item was identified, but not installed for Alternative Shutdown and overlooked for Safe Shutdow (2-I, 25-III, 34-II, 36-III, 43-I, 54-I MOD 2079) Fire damage to logic cables for HPCI could isolate the system. (13S-I MOD 2078) Fire damage to bus current transformer cables could trip the bus and lockout the diesel generator breaker (34-I, 35-II, 36-I, 37-I MOD 2078) Fire damage to control cables for a HPCI AC valve could cause the valve to close and disable the HPCI syste (FA-25I Mod 1352A, 1353A)

II Other items 1 The field walkdown of safe shutdown conduits identified that some safe shutdown conduits were inaccurately shown on de-sign drawings. (2-II MOD 2085) Fire damage in FA-30 results in the loss of both the primary and backup power sources to the RHR and HPSW flow instrument (MOD 1029E, 2085)

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. Appendix R Task Force -4-Deficiency Summary Emergency lighting was installed for analyses submitted 9/16/83, 7/11/83, and 7/22/83. During subsequent analysis, further installations of emergency lighting was de ferred pending final design of Alternative Shutdown and completion of the Safe Shutdown reverification program. The locations have now been identified (Table A-4 of FPP) and design for installation is in progress. (MOD 2081) Fire damage results in the loss of power to a diesel genera-tor auxiliary motor control center. The diesel is used for safe shutdown in the area. (6N-II, 40-I MOD 2078) The associated circuit analysis identified one molded case circuit breaker which requires a trip setpoint change to pro-vide proper coordinatio (Associated circuit by common power source) (MCD 2083) The associated circuit analysis identified a motor control center section 20DllA separated from its main motor control center 20Dll that had no overcurrent protection. (Associated circuit by common enclosure) (MOD 13S2A, 1353A) Fire damage in Unit 3 results in the loss of a Unit 3 torus temperature loop fed from a common unit power supply. (13N-I)

(MOD 2085)

I Previously identified items Unit 2 Process and Diagnostic Instrumentatio Previous commitment was for end of upcoming Unit 2 re-fueling outag (Mod 1029E) Frovide thermal magnetic trip devices to MCC Previous Associated Circuit Analyses identified need for thermal magnetic breaker Modification was on hold pending equipment qualification of device (Mod 1029J, K, L) Spurious closure of HPCI and RCIC steam valves The potential for these valves to defeat system operation was identified during the 3/86 audit and reported en 5/22/86. This report identified the condition on one RCIC valve and one HPCI valve. The reverification iden-tified the concern on one additional RCIC valv (Mod 2079) Unit 2 relief valve capability Previous commitment was for end of upcoming Unit 2 refueling outage (Mcd 1950)

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- . Appendix R Task Force -5-Deficiency Summary

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i i Testable check equalizer valves on RHR and CS.

Previous Hi/Lo pressure boundary analysis identified

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need to address valves. Mechanical analysis now demon-

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1 Unit 2 and Common Alternative Shutdown ~

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