IR 05000277/2022011: Difference between revisions

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{{Adams
{{Adams
| number = ML21348A164
| number = ML22138A376
| issue date = 12/14/2021
| issue date = 05/18/2022
| title = Information Request to Support Triennial Baseline Design-Basis Capability of Power-Operated Valves Inspection; Inspection Report 05000277/2022011 and 05000278/2022011
| title = Design Basis Assurance Inspection (Programs) Inspection Report 05000277/2022011 and 05000278/2022011
| author name = Gray M
| author name = Gray M
| author affiliation = NRC/RGN-I/DORS
| author affiliation = NRC/RGN-I/DORS
| addressee name = Rhoades D
| addressee name = Rhoades D
| addressee affiliation = Exelon Generation Co LLC, Exelon Nuclear
| addressee affiliation = Constellation Energy Generation, LLC, Constellation Nuclear
| docket = 05000277, 05000278
| docket = 05000277, 05000278
| license number = DPR-044, DPR-056
| license number = DPR-044, DPR-056
| contact person = Gray M
| contact person = Gray M
| document report number = IR 2022-011
| document report number = IR 2022-011
| document type = Letter
| document type = Inspection Report, Letter
| page count = 8
| page count = 11
}}
}}


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=Text=
=Text=
{{#Wiki_filter:December 14, 2021
{{#Wiki_filter:May 18, 2022


==SUBJECT:==
==SUBJECT:==
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 -
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000277/2022011 AND 05000278/2022011
INFORMATION REQUEST TO SUPPORT TRIENNIAL BASELINE DESIGN-BASIS CAPABILITY OF POWER-OPERATED VALVES INSPECTION; INSPECTION REPORT 05000277/2022011 AND 05000278/2022011


==Dear Mr. Rhoades:==
==Dear Mr. Rhoades:==
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
On April 8, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Peach Bottom Atomic Power Station, Units 2 and 3 and discussed the results of this inspection with Mr. David Henry, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.
Region I staff will conduct a team inspection at Peach Bottom Atomic Power Station, Units 2 and 3. David Kern, a Senior Reactor Inspector from the NRCs Region I Office, will lead the inspection team. The inspection will be conducted in accordance with Inspection Procedure 71111.21N.02, Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements, dated October 9, 2020 (ADAMS Accession No. ML20220A667).


The inspection will assess the reliability, functional capability, and design bases of risk-important power-operated valves (POVs) as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a, and Appendix A and B requirements. The inspectors will select a sample of POVs based on risk insights, safety significance, and operating margin.
No findings or violations of more than minor significance were identified during this inspection.


During a telephone conversation on December 7, 2021, with Ms. Amy Huber, Senior Regulatory Engineer, we confirmed arrangements for an information gathering visit and the two-week onsite inspection. Depending on site access conditions, the information gathering visit may be onsite or may be performed remotely. The schedule is as follows:
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
* Information gathering visit: Week of January 3, 2022
* Onsite weeks: Weeks of March 21 and April 4, 2022 The purpose of the information gathering visit is to meet with members of your staff and to become familiar with your programs and procedures intended to ensure compliance with 10 CFR 50.55a for POVs. The lead inspector will discuss aspects of the programs including any specific applicable regulatory commitments made by your facility and your use of NRC regulatory guides or industry standards. Experience with previous design basis team inspections of similar depth and length has shown this type of inspection is resource intensive, both for NRC inspectors and licensee staff. In order to minimize the inspection impact on the site and to ensure a productive inspection for both parties, we have enclosed a request for information needed for the inspection.


It is important that all of these documents are up-to-date and complete in order to minimize the number of additional documents requested during the preparation and onsite portions of the inspection. Insofar as possible, this information should be provided electronically to the lead inspector at the NRC Region I Office by January 3, 2022. Recognizing the timeframe, my staff will work with your staff to prioritize our document requests so these activities can be accomplished, as much as possible, in the normal course of your activities. Particularly considering the end of year timeframe, please do not hesitate to contact Mr. Dave Kern if there are challenges in document retrieval. We will work with your staff. Additional documents may be requested during the information gathering visit and/or during team preparation week (the week prior to the first onsite inspection week). The inspectors will minimize your administrative burden by specifically identifying only those documents required for the inspection.
Sincerely, Digitally signed by Melvin K.


If there are any questions about the inspection or the material requested in the enclosure, please contact the lead inspector at 610-337-6931 or via e-mail at David.Kern@nrc.gov.
Melvin K. Gray Gray Date: 2022.05.18 15:26:28-04'00'
Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56


This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget Control Number.
===Enclosure:===
As stated


This letter and its enclosure will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
==Inspection Report==
 
Docket Numbers: 05000277 and 05000278 License Numbers: DPR-44 and DPR-56 Report Numbers: 05000277/2022011 and 05000278/2022011 Enterprise Identifier: I-2022-011-0021 Licensee: Constellation Energy Generation, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, PA Inspection Dates: March 21, 2022 to April 8, 2022 Inspectors: E. Dipaolo, Senior Reactor Inspector D. Kern, Senior Reactor Inspector N. Mentzer, Reactor Inspector Approved By: Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure
Sincerely, Digitally signed by Melvin K.


Gray Melvin K. Gray Date: 2021.12.14 12:55:34-05'00'
=SUMMARY=
Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56 Enclosure:
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at Peach Bottom Atomic Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
Document Request for Design Bases Assurance Inspection cc: Distribution via ListServ


ML21348A164 X Non-Sensitive  X Publicly Available X SUNSI Review Sensitive  Non-Publicly Available OFFICE RI/DORS RI/DORS NAME DKern  MGray DATE 12/13/21 12/14/21
===List of Findings and Violations===


DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION Inspection Report: 05000277/2022011 and 05000278/2022011 Onsite Inspection Dates: March 21 through March 25, 2022; and April 4 through 8, 2022 Inspection Procedure: Inspection Procedure 71111.21N.02, Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements Lead Inspector:  David Kern, Senior Reactor Inspector 610-337-6931 David.Kern@nrc.gov I. Information Gathering Visit During this visit, we plan to obtain sufficient insights to finalize power-operated valve (POV)
No findings or violations of more than minor significance were identified.
samples for this inspection. We would like to meet with POV specialists to discuss the upcoming inspection and our sample selection process. The primary valve types to be reviewed for this inspection include motor-operated valves (MOVs) and air-operated valves (AOVs); and additional valve types include hydraulic-operated valves (HOVs), solenoid-operated valves (SOVs), and pyrotechnic-actuated (squib) valves. During this visit, the lead inspector will: (a) discuss the scope of the planned inspection; (b) identify additional information needed to review in preparation for the inspection; (c) ensure that the information to be reviewed is available at the beginning of the inspection; and (d) verify that logistical issues will be identified and addressed prior to the teams arrival. Depending on the local COVID environment and potential travel restrictions, this visit may be either onsite or performed remotely through a series of skype video calls. If performed onsite, please reserve a room during the site visit with a telephone, wireless internet access, and a licensee computer with access to procedures, corrective action program documents, and a printer.


II. Information Requested for Selection of Power-Operated Valves The following information is requested by January 3, 2022, to facilitate inspection preparation. Feel free to contact the lead inspector if you have any questions regarding this information request. Please provide the information electronically in pdf files, Excel, or other searchable formats. The files should contain descriptive names, and be indexed and hyperlinked to facilitate ease of use. Information in lists should contain enough information to be easily understood by someone who has knowledge of light water reactor technology and POVs.
===Additional Tracking Items===
None.


1. A word-searchable Updated Final Safety Analysis Report. If not available in a single file for each unit, please ensure a collective table of contents is provided.
=INSPECTION SCOPES=


2. Site (and corporate if applicable) procedures associated with implementation of the MOV program required by 10 CFR 50.55a(b)(3)(ii) and/or ASME OM Code Mandatory Appendix III; and site (corporate) procedure for AOV program.
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.


Enclosure
==REACTOR SAFETY==


DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION 3. Site response(s) to NRC Generic Letter (GL) 95-07, Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves.
===71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03) ===
{{IP sample|IP=IP 71111.21|count=12}}
The inspectors:
a. Determined whether the sampled power-operated valves (POVs) are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.


4. Site response(s) to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves.
b. Determined whether the sampled POVs are capable of performing their design-basis functions.


5. Site evaluation of NRC Information Notice 2012-14, MOV Inoperable due to Stem-Disc Separation.
c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.


6. List of corrective action documents related to the MOV and AOV programs since January 1, 2017 (include document No., title/short description, date).
d. Evaluated maintenance activities including a walkdown of the sampled POVs (if accessible).
: (1) MO-0-33-0498, Emergency Service Water (ESW) Return to Discharge Pond
: (2) MO-3-02-053B, Recirculation Pump Discharge Isolation Valve
: (3) MO-3-10-013A, Residual Heat Removal Pump 3AP035 Torus Suction Isolation Valve
: (4) MO-3-10-025A, Residual Heat Removal Loop A, Inboard Discharge Valve
: (5) MO-3-13-021, Reactor Core Isolation Cooling Pump Discharge to B Feedwater Line
: (6) MO-3-14-005D, D Core Spray Pump Minimum Flow Valve
: (7) MO-3-23-014, High Pressure Coolant Injection Turbine Steam Supply Valve
: (8) AO-0-33-0241B, ESW Outlet Block Valve from E2 Diesel Generator Coolers
: (9) AO-2-01A-080D, Inboard D Main Steam Isolation Valve
: (10) AO-2-03-35B, Scram Discharge Volume Outboard Isolation Vent Valve
: (11) AO-2-07B-2511, Torus 18 Vent Inboard Isolation Valve to SBGT/ATMOS
: (12) AO-3-01A-080A, Inboard A Main Steam Isolation Valve


7. List of corrective action documents related to each of the 30 POVs listed below since January 1, 2017 (include document No., title/short description, date).
==INSPECTION RESULTS==
Very Low Safety Significance Issue Resolution Process: Emergency Heat Sink            71111.21 (including ESW-0498, ESW Return to Pond) Safety Classification and Inservice          N.02 Test (IST) Requirements This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.


8. List of significant modifications, repairs, or replacement of safety-related POVs completed since January 1, 2017, including date completed (include document No., title, date completed).
=====Description:=====
The Peach Bottom 5th 10-Year Test Interval Inservice Test (IST) Program Plan, Revision 16 identified that valve MO-0-33-0498, ESW Return to Pond, had a passive safety function to remain open. This open safety function supported cooling for the emergency diesel generators and the emergency core cooling system rooms during normal plant operation. The Plan specified that the associated IST requirement was a biennial position indication verification (PI) test.


9. List of POVs removed from the In-Service Test program since January 1, 1990.
The inspectors determined MO-0-33-0498 also had an active safety function to close, which was not documented in the 10-Year IST Program Plan. The Peach Bottom Updated Final Safety Analysis Report (UFSAR) credited this active function to provide closed-loop emergency heat sink (EHS) operation to support safe shutdown of Units 2 and 3 in the event of a loss of normal heat sink (Conowingo Pond) or a design basis flood. The inspectors further determined the EHS system, including MO-0-33-0498 was safety-related. The basis for this conclusion included the following:
: (1) 10 CFR 50.2 defines safety-related components as those relied upon to remain functional during and following design basis events (DBE) to assure . the capability to maintain the reactor in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents leading to offsite exposures comparable to 10 CFR Part 100 exposure guidelines.
: (2) Peach Bottom UFSAR Section 2.4.3.5 identified EHS as a safe shutdown system, required to mitigate two design basis events; the design flood condition (Run-up of the Maximum Wave Superimposed on the Probable Maximum Flood Water Level) and a loss of normal heat sink (e.g., seismic DBE damages the Conowingo dam).
: (3) UFSAR Section 10.9.3 credited EHS to mitigate both the design flood condition and a loss of normal heat sink (loss of Conowingo pond).
: (4) Section ISTA-1100(a) of the ASME OM 2012 Code defines IST scope to include pumps and valves required to shut down a reactor, maintain safe shutdown, or mitigate consequences of an accident.
: (5) The inspectors determined that if the EHS was unavailable, a design basis seismic event which caused a loss of normal heat sink event and loss of offsite power could lead to offsite exposures comparable to 10 CFR Part 100 exposure guidelines.


10. Any self-assessments or quality assurance type assessments of the MOV/AOV programs (performed since January 1, 2017).
Notwithstanding these conclusions, the inspectors noted the design did not provide for redundancy in the MO-0-33-0498 closure function as would be typical for a safety-related system. The inspectors further noted the closed-loop EHS function was added late in the original licensing of Peach Bottom Units 2 and 3 as a result of additional oversight reviews.


11. Most recent POV (e.g., MOV, AOV, SOV) program health report(s).
Section III-3600 of the ASME OM 2012 Code required active motor operated valves (MOVs)to be exercised (e.g., stroked open and closed) at least once per refueling cycle. Section ISTA-3110 of the ASME OM 2012 Code required the 10-year IST Program Plan to include the code requirements for each component and the test(s) to be performed. The inspectors reviewed station operating procedures and identified 19 EHS components (pumps and valves), including MO-0-33-0498, which were operated or verified by operators when placing EHS in closed-loop operation. Accordingly, the inspectors determined all 19 components were required to be tested in accordance with the ASME OM Code.


12. List and electronic copy of all Emergency Operating Procedures.
The inspectors verified that, with the exception of the MO-0-33-0498 active closure function, the ASME OM Code IST test requirements for the EHC system were properly identified in the 10-year IST Plan. Even EHS pumps and valves with no safety function identified in the Plan, had appropriate tests specified as though the components were credited for active safety functions. The inspectors also determined that MO-0-33-0498 was exercised and PI verified in accordance with annual surveillance test ST-O-033-310-2 (last performed 1/14/22).


13. List of Abnormal Operating Procedures.
Although Constellation staff considered the MO-0-33-0498 active closure function to be non-safety-related and outside of the ASME OM Code scope, they have been performing the testing required by the ASME OM Code for an active MOV. The inspectors reviewed maintenance and test records for the last 5 years and found no problems identified for MO-0-33-0498.


14. Identify the edition of the ASME Operation and Maintenance of Nuclear Power Plants (OM Code) that is the Code of Record for the current 10-year Inservice Test Program interval, as well as any standards to which the station has committed with respect to POV capability and testing.
Licensing Basis: Constellation staff classified MO-0-33-0498 as safety-related and therefore within the scope of ASME OM Code IST requirements, for its passive safety function to remain open to return ESW cooling water from the emergency diesel generators and emergency core cooling system loads to the Conowingo Pond (e.g., river). The active function of MO-0-33-0498 to close isolates the return flow path to the Conowingo Pond and supports closed-loop operation of the EHS in the case of the Loss of Conowingo Pond Special Event. Constellation engineers acknowledged that the loss of Conowingo Pond was part of Peach Bottoms design and licensing basis. However, Constellation staff determined the EHS and the MO-0-33-0498 active closure function were augmented quality (non-safety-related), because they were not credited to mitigate any analyzed design basis accident or transient described in Chapter 14 of the UFSAR. Therefore, Constellation staff concluded EHS and the MO-0-33-0498 active closure function did not fall within the scoping criteria specified in ASME OM Code, ISTA-1100 because they were non-safety-related.


15. Identify which of the valves listed in items #16 and #17 are located in harsh environment areas and subject to Environmental Qualification (EQ) requirements.
Constellation staff also stated that two previous NRC-approved licensing actions (Peach Bottom conversion to Improved Standard Technical Specifications (ISTS) and Peach Bottom IST Program Third 10-year Interval Update) accepted the licensee determination that EHS and the MO-0-33-0498 active closure function were augmented quality (non-safety-related). The NRC safety evaluation report (SER) for the ISTS conversion (dated 8/30/95)documented the licensee statement that the emergency cooling water pump (part of EHS)was not credited for mitigation of design bases accidents or transients, and accepted the licensees proposed alternative testing. The NRC SER for the IST Program Update (dated 5/11/98) stated the licensee should evaluate the applicability of MO-0-33-0498 and EHS components to the IST program. The licensee responded (dated 1/29/99) that the classification of EHS and the MO-0-33-0498 closure function was augmented quality (non-safety-related) because the components did not support mitigation of any design basis transient or accident. The NRC response (dated 3/15/00) to this letter repeated the licensee position that the components were augmented quality and found the alternative testing proposed by the licensee to be acceptable.


16. For each of the following MOVs, provide the information listed in the table below.
The inspectors noted the purpose of the two licensing actions was for the licensee to request NRC approval for alternative test requirements, in lieu of the existing IST Code and Peach Bottom technical specification test requirements. The associated NRC SERs stated that the specified components were subject to the testing requirements of the IST program and approved the proposed alternative test requirements. However, after stating the components were subject to requirements of the IST program, the SER documented the licensee position that the components were not credited with mitigation of design basis accidents and were augmented quality. These statements appear to conflict. The inspectors concluded the SERs and associated documentation did not make a clear determination of whether MO-0-33-0498 and the EHS were safety-related quality or were non-safety-related quality.


MO-0-33-0498 ESW Return to Discharge Pond MO-2-12-15 RWCU Inlet Inboard Isolation Valve MO-2-10-017 RHR Shutdown Cooling Suction Outboard Isolation Valve MO-2-10-026B RHR Loop B, Drywell Spray Outboard Isolation Valve MO-2-13-015 RCIC Steam Line Inboard Isolation Valve MO-2-14-012B Core Spray Loop B, Inboard Discharge Isolation Valve MO-2-23-016 HPCI Turbine Steam Line Outboard Isolation Valve MO-2-23-020 HPCI Pump Discharge Valve MO-3-02-053B Recirculation Pump Discharge Isolation Valve MO-3-10-013A RHR Pump 3AP035 Torus Suction Isolation Valve
Significance: For the purpose of the VLSSIR process, the inspectors screened the issue of concern through IMC 0612, Issue Screening, and determined the issue of concern would likely be of minor significance had a performance deficiency been identified. Additionally, the issue of concern was similar to IMC 0612, Appendix E, Examples of Minor Issues, example 3.b, because the documentation error in the 10-year IST Plan did not result in any missed IST tests or adversely impact MO-0-33-0498 reliability.


DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION MO-3-10-018 RHR Pump Shutdown Cooling Suction Inboard Isolation Valve MO-3-10-025A RHR Loop A, Inboard Discharge Valve MO-3-10-039A RHR Loop A, Outer Block for Torus Cooling Spray MO-3-10-089A RHR HX 3AE024 HPSW Outlet Valve MO-3-13-016 RCIC Steam Line Outboard Isolation Valve MO-3-13-021 RCIC Pump Discharge to B Feedwater Line MO-3-14-005D D Core Spray Pump Minimum Flow Valve MO-3-23-014 HPCI Turbine Steam Supply Valve MO-3-23-015 HPCI Turbine Steam Line Inboard Isolation Valve Item Parameter/Information*
The inspectors also verified the following information which provides reasonable assurance that EHS and MO-0-33-0498 will continue to meet the regulatory requirements of 10 CFR 50.55a(B)(3)(ii):
1 MOV Identification 2 Safety Function 3 Valve manufacturer, type, and size 4 Actuator manufacturer, type, and size 5 Motor manufacturer, type (AC/DC), and size 6 Valve ASME Class 7 Risk Significance 8 Control Switch Trip (CST) Application (Close/Open)
: (1) Constellation is currently testing the required EHS components iaw ASME OM 2012 Code;
9 Design-Basis Differential Pressure (DBDP) and Flow (Close/Open)
: (2) Regulatory commitments by Constellation and procedures are in place regarding this periodic IST testing;
10 Rising-Stem Valve: Assumed Valve Factor (VF)
: (3) Constellation staff informed the inspectors that there are no current plans to revise this testing; and
11 Quarter-Turn Valve: Assumed bearing torque coefficient 12 Assumed Stem Friction Coefficient (SFC)
: (4) The inspectors noted that changes to the associated IST test procedures would require review through the 10 CFR 50.59 safety evaluation process.
13 Assumed Load Sensitive Behavior (LSB) (%)
14 % Uncertainties (e.g., diagnostic equipment, CST repeatability, etc.)


15 Calculated Required Thrust/Torque (Close/Open)
Technical Assistance Request: No Technical Assistance Request was processed in support of this issue.
16 Least Available Output (e.g., actuator, CST, rating, spring pack, weak link)
17 Test Conditions (e.g., fluid differential pressure (DP), system pressure, flow, and temperature; ambient temperature; and motor voltage) (Close/Open)
18 Thrust and torque required to overcome dynamic conditions (Close/Open)
19 Rising-Stem Valve: Measured VF (Close/Open)
20 Rising-Stem Valve: Available VF (Close/Open)
21 Measured SFC (Close/Open)
22 Measured LSB (%)
23 Quarter-Turn Valve: Measured bearing torque coefficient (Close/Open)
24 Determined % Margin (Close/Open)
25 Basis for Design-Basis Capability:
25.a Dynamic test performed at design-basis DP/flow conditions 25.b Extrapolation of dynamic test data 25.c Justification from normal operation at or above design-basis conditions 25.d Industry dynamic test methodology (such as EPRI MOV PPM)
25.e Grouped with similar valves dynamically tested at plant 25.f Grouped with similar valves dynamically tested at other plants 25.g Valve qualification testing (such as ASME QME-1-2007)
25.h Other (such as large calculated margin)
  *Specify Not Applicable (NA) as appropriate


DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION 16. For each of the following AOVs/SOVs/HOVs, provide the information listed in the table below.
Corrective Action Reference: Constellation entered the issue into the corrective action program as Issue Report


AO-0-33-0241B ESW Outlet Block Valve from E2 DG Coolers AO-2-01A-080D Inboard D MSIV AO-2-01A-086D Outboard D MSIV AO-2-03-35B Scram Discharge Volume Outboard Isolation Vent Valve AO-2-03-36 Scram Discharge Volume Outboard Isolation Drain Valve AO-2-07B-2511 Torus 18 Vent Inboard Isolation Valve to SBGT/ATMOS AO-2-20-83 Drywell Floor Drain Sump Outboard Isolation Valve HO-2-13C-4495 Steam Supply to RCIC Turbine Governor Valve AO-3-01A-080A Inboard A MSIV AO-3-16-5235 Instrument Nitrogen System Suction Isolation Valve HO-3-23C-5513 HPCI Turbine Stop Valve Item Parameter/Information*
==EXIT MEETINGS AND DEBRIEFS==
1 AOV Identification 2 Safety Function 3 Fail safe position (open/close)
The inspectors verified no proprietary information was retained or documented in this report.
4 Valve manufacturer, type, and size 5 Actuator manufacturer, type, and size 6 Valve ASME Class 7 Risk Significance 8 Design-Basis Differential Pressure (DBDP) and Flow (Close/Open)
* On April 8, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. David Henry, Site Vice President and other members of the licensee staff.
9 Rising-Stem Valve: Assumed Valve Factor (VF)
10 Quarter-Turn Valve: Assumed bearing torque coefficient 11 % Uncertainties (e.g., diagnostic equipment, CST repeatability, etc.)


12 Calculated Required Thrust/Torque (Close/Open)
=DOCUMENTS REVIEWED=
13 Minimum allowable air pressure (Beginning/End Stroke)
14 Maximum allowable air pressure (Beginning/End Stroke)
15 Minimum allowable spring preload (Beginning/End Stroke)
16 Maximum allowable spring preload (Beginning/End Stroke)
17 Least Available Actuator Output (e.g., actuator capability, actuator limit, valve weak link limitation)
18 Test Conditions (e.g., fluid differential pressure (DP), system pressure, flow, and temperature; and ambient temperature) (Close/Open)
19 Thrust and torque required to overcome dynamic conditions (Close/Open)
20 Rising-Stem Valve: Measured VF (Close/Open)
21 Quarter-Turn Valve: Measured bearing torque coefficient (Close/Open)
22 Determined Margin (%) (Least margin for air stroke operation, spring stroke operation, maximum spring load, and structural capability)
23 Basis for Design-Basis Capability:
24.a Dynamic test performed at design-basis DP/flow conditions 24.b Extrapolation of dynamic test data 24.c Justification from normal operation at or above design-basis conditions 24.d Industry dynamic test methodology 24.e Grouped with similar valves dynamically tested at plant 24.f Grouped with similar valves dynamically tested at other plants


DOCUMENT REQUEST FOR DESIGN BASES ASSURANCE INSPECTION 24.g Valve qualification testing (such as ASME QME-1-2007)
Inspection  Type              Designation      Description or Title                                  Revision or
24.h Other (such as large calculated margin)
Procedure                                                                                            Date
   *Specify Not Applicable (NA) as appropriate 5
71111.21N.02 Corrective Action 01335599
Documents        01420676
01537143
04013582
04378793
Corrective Action 04486879
Documents        04486979
Resulting from    04486991
Inspection        04487131
04487138
04487271
04490276
04490281
04490910
04491096
04491472
04492216
04494831
Drawings          6280-M-315, Sht. Emergency Service Water and High Pressure Service    Revision 92
Water
280-M-315, Sht. Emergency Service Water and High Pressure Service    Revision 95
Water
280-M-330      Emergency Cooling System                              Revision 39
Sht.1
Engineering      EC 07-00344      Differing Detail of Tech Spec Basis & PIMS CRL Safety Revision 0
Changes                            Function
EC 556030        MO-3-23-014 Actuator Upgrade SMB1 to SB1              Revision 0
EC 626985        Approve MPR Anti-Rotation Device for Recirculation    Revision 0
Valves
EC 630174        Evaluate BWROG Document TP16-1-112, Revision 5 for    Revision 0
Applicability to Peach Bottom Recirculation Valves
Inspection Type          Designation    Description or Title                                  Revision or
Procedure                                                                                      Date
Engineering  JOG MOV        AC Motor Operated GL 96-05 Gate Valve                Revision 11
Evaluations  Evaluation
Report MO-3-02-
053B
PMC-21-128124  Peach Bottom, System 14 Core Spray MOV/IST Alternate  02/23/2021
Treatment Plan
Miscellaneous                BWR Main Steam Isolation Valve (MSIV) PM Template    Revision 2
280-M-1-JJ-80  MSIV Vendor Technical Manual                          Revision 1
910328 NRC      Peach Bottom Response to NCR P-91152                  03/28/1991
GNL 88-14
A-391-VC-8      Vendor Technical Manual                              Revision 1
Commitment                                                            02/24/2020
Change
Evaluation
290603,
Assignment 02-
DBD P-S-09      Residual Heat Removal System                          Revision 19
F-130-VC-273    Vendor Technical Manual                              Revision 0
NRC Information Potential Design Deficiency in Motor-Operated Valve  08/23/2013
Notice 2013-14  Control Circuitry
P-S-19          Recirculation System                                  Revision 19
P-S-25B        Primary Containment Auxiliary Systems                Revision 10
PB-5069-14-14A- 10 CFR 50.69 System Categorization Document - Core    Revision 1
003            Spray System
ST-O-003-450-2  Scram Discharge Vent and Drain Valve Functional Test  01/08/2022
ST-O-007-410-3  PCIS Valves Colder Shutdown Inservice Test            11/05/2021
ST-O-010-302-3  "A" RHR Loop Pump, Valve, Flow and Unit Cooler        03/01/2021
Functional and Inservice Comprehensive Test
ST-O-023-300-3  HPCI Pump, Valve, Flow and Unit Cooler Functional and 02/28/2022
In-service Test without Vibration Data Collected
ST-O-02A-400-3  Recirculation Pump Discharge Valve Operability Test   11/01/2021
ST-O-033-410-2  IST Exercise of ESW Air Operated Valves              02/26/2022
ST-O-07G-470-3  Main Steam Isolation Valve Closure Timing            11/03/2021
Inspection Type        Designation    Description or Title                              Revision or
Procedure                                                                                Date
Procedures  ER-AA-200      Preventive Maintenance Program                    Revision 5
ER-AA-200-1004 PCM Templates                                      Revision 1
ER-AA-569-1004 10 CFR 50.69 Alternative Treatment Implementation  Revision 5
Process
MA-AA-723-300  Diagnostic Testing of Motor Operated Valves        Revision 14
MA-AA-723-301  Periodic Inspection of Limitorque Model SMB/SB/SBD Revision 15
SBD-000 through 5 Motor Operated Valves
MA-AA-796-024  Scaffold Installation, Inspection, and Removal    Revision 12
MA-MA-796-024- Scaffolding Criteria for the Mid Atlantic Stations Revision 9
1001
OP-AA-201-009  Control of Transient Combustible Material          Revision 26
SO 48.1.B      Emergency Cooling Water System Startup            Revision 20
ST-O-032-301-2 HPSW Pump, Valve and Flow Functional and Inservice Revision 42
Test
Work Orders 04246550
247914
250943
252128
264168
04306865
04869070
04880360
05133013
R1155387
R1196156
9
}}
}}

Revision as of 11:44, 23 May 2022

Design Basis Assurance Inspection (Programs) Inspection Report 05000277/2022011 and 05000278/2022011
ML22138A376
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 05/18/2022
From: Mel Gray
Division of Operating Reactors
To: Rhoades D
Constellation Energy Generation, Constellation Nuclear
Gray M
References
IR 2022-011
Download: ML22138A376 (11)
v • d • e


Text

May 18, 2022

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - DESIGN BASIS ASSURANCE INSPECTION (PROGRAMS) INSPECTION REPORT 05000277/2022011 AND 05000278/2022011

Dear Mr. Rhoades:

On April 8, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Peach Bottom Atomic Power Station, Units 2 and 3 and discussed the results of this inspection with Mr. David Henry, Site Vice President and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Digitally signed by Melvin K.

Melvin K. Gray Gray Date: 2022.05.18 15:26:28-04'00'

Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket Nos. 05000277 and 05000278 License Nos. DPR-44 and DPR-56

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000277 and 05000278 License Numbers: DPR-44 and DPR-56 Report Numbers: 05000277/2022011 and 05000278/2022011 Enterprise Identifier: I-2022-011-0021 Licensee: Constellation Energy Generation, LLC Facility: Peach Bottom Atomic Power Station, Units 2 and 3 Location: Delta, PA Inspection Dates: March 21, 2022 to April 8, 2022 Inspectors: E. Dipaolo, Senior Reactor Inspector D. Kern, Senior Reactor Inspector N. Mentzer, Reactor Inspector Approved By: Mel Gray, Chief Engineering Branch 1 Division of Operating Reactor Safety Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (programs) inspection at Peach Bottom Atomic Power Station, Units 2 and 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.21N.02 - Design-Basis Capability of Power-Operated Valves Under 10 CFR 50.55a Requirements POV Review (IP Section 03)

Main article: IP 71111.21

The inspectors:

a. Determined whether the sampled power-operated valves (POVs) are being tested and maintained in accordance with NRC regulations along with the licensees commitments and/or licensing bases.

b. Determined whether the sampled POVs are capable of performing their design-basis functions.

c. Determined whether testing of the sampled POVs is adequate to demonstrate the capability of the POVs to perform their safety functions under design-basis conditions.

d. Evaluated maintenance activities including a walkdown of the sampled POVs (if accessible).

(1) MO-0-33-0498, Emergency Service Water (ESW) Return to Discharge Pond
(2) MO-3-02-053B, Recirculation Pump Discharge Isolation Valve
(3) MO-3-10-013A, Residual Heat Removal Pump 3AP035 Torus Suction Isolation Valve
(4) MO-3-10-025A, Residual Heat Removal Loop A, Inboard Discharge Valve
(5) MO-3-13-021, Reactor Core Isolation Cooling Pump Discharge to B Feedwater Line
(6) MO-3-14-005D, D Core Spray Pump Minimum Flow Valve
(7) MO-3-23-014, High Pressure Coolant Injection Turbine Steam Supply Valve
(8) AO-0-33-0241B, ESW Outlet Block Valve from E2 Diesel Generator Coolers
(9) AO-2-01A-080D, Inboard D Main Steam Isolation Valve
(10) AO-2-03-35B, Scram Discharge Volume Outboard Isolation Vent Valve
(11) AO-2-07B-2511, Torus 18 Vent Inboard Isolation Valve to SBGT/ATMOS
(12) AO-3-01A-080A, Inboard A Main Steam Isolation Valve

INSPECTION RESULTS

Very Low Safety Significance Issue Resolution Process: Emergency Heat Sink 71111.21 (including ESW-0498, ESW Return to Pond) Safety Classification and Inservice N.02 Test (IST) Requirements This issue is a current licensing basis question and inspection effort is being discontinued in accordance with the Very Low Safety Significance Issue Resolution (VLSSIR) process. No further evaluation is required.

Description:

The Peach Bottom 5th 10-Year Test Interval Inservice Test (IST) Program Plan, Revision 16 identified that valve MO-0-33-0498, ESW Return to Pond, had a passive safety function to remain open. This open safety function supported cooling for the emergency diesel generators and the emergency core cooling system rooms during normal plant operation. The Plan specified that the associated IST requirement was a biennial position indication verification (PI) test.

The inspectors determined MO-0-33-0498 also had an active safety function to close, which was not documented in the 10-Year IST Program Plan. The Peach Bottom Updated Final Safety Analysis Report (UFSAR) credited this active function to provide closed-loop emergency heat sink (EHS) operation to support safe shutdown of Units 2 and 3 in the event of a loss of normal heat sink (Conowingo Pond) or a design basis flood. The inspectors further determined the EHS system, including MO-0-33-0498 was safety-related. The basis for this conclusion included the following:

(1) 10 CFR 50.2 defines safety-related components as those relied upon to remain functional during and following design basis events (DBE) to assure . the capability to maintain the reactor in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents leading to offsite exposures comparable to 10 CFR Part 100 exposure guidelines.
(2) Peach Bottom UFSAR Section 2.4.3.5 identified EHS as a safe shutdown system, required to mitigate two design basis events; the design flood condition (Run-up of the Maximum Wave Superimposed on the Probable Maximum Flood Water Level) and a loss of normal heat sink (e.g., seismic DBE damages the Conowingo dam).
(3) UFSAR Section 10.9.3 credited EHS to mitigate both the design flood condition and a loss of normal heat sink (loss of Conowingo pond).
(4) Section ISTA-1100(a) of the ASME OM 2012 Code defines IST scope to include pumps and valves required to shut down a reactor, maintain safe shutdown, or mitigate consequences of an accident.
(5) The inspectors determined that if the EHS was unavailable, a design basis seismic event which caused a loss of normal heat sink event and loss of offsite power could lead to offsite exposures comparable to 10 CFR Part 100 exposure guidelines.

Notwithstanding these conclusions, the inspectors noted the design did not provide for redundancy in the MO-0-33-0498 closure function as would be typical for a safety-related system. The inspectors further noted the closed-loop EHS function was added late in the original licensing of Peach Bottom Units 2 and 3 as a result of additional oversight reviews.

Section III-3600 of the ASME OM 2012 Code required active motor operated valves (MOVs)to be exercised (e.g., stroked open and closed) at least once per refueling cycle. Section ISTA-3110 of the ASME OM 2012 Code required the 10-year IST Program Plan to include the code requirements for each component and the test(s) to be performed. The inspectors reviewed station operating procedures and identified 19 EHS components (pumps and valves), including MO-0-33-0498, which were operated or verified by operators when placing EHS in closed-loop operation. Accordingly, the inspectors determined all 19 components were required to be tested in accordance with the ASME OM Code.

The inspectors verified that, with the exception of the MO-0-33-0498 active closure function, the ASME OM Code IST test requirements for the EHC system were properly identified in the 10-year IST Plan. Even EHS pumps and valves with no safety function identified in the Plan, had appropriate tests specified as though the components were credited for active safety functions. The inspectors also determined that MO-0-33-0498 was exercised and PI verified in accordance with annual surveillance test ST-O-033-310-2 (last performed 1/14/22).

Although Constellation staff considered the MO-0-33-0498 active closure function to be non-safety-related and outside of the ASME OM Code scope, they have been performing the testing required by the ASME OM Code for an active MOV. The inspectors reviewed maintenance and test records for the last 5 years and found no problems identified for MO-0-33-0498.

Licensing Basis: Constellation staff classified MO-0-33-0498 as safety-related and therefore within the scope of ASME OM Code IST requirements, for its passive safety function to remain open to return ESW cooling water from the emergency diesel generators and emergency core cooling system loads to the Conowingo Pond (e.g., river). The active function of MO-0-33-0498 to close isolates the return flow path to the Conowingo Pond and supports closed-loop operation of the EHS in the case of the Loss of Conowingo Pond Special Event. Constellation engineers acknowledged that the loss of Conowingo Pond was part of Peach Bottoms design and licensing basis. However, Constellation staff determined the EHS and the MO-0-33-0498 active closure function were augmented quality (non-safety-related), because they were not credited to mitigate any analyzed design basis accident or transient described in Chapter 14 of the UFSAR. Therefore, Constellation staff concluded EHS and the MO-0-33-0498 active closure function did not fall within the scoping criteria specified in ASME OM Code, ISTA-1100 because they were non-safety-related.

Constellation staff also stated that two previous NRC-approved licensing actions (Peach Bottom conversion to Improved Standard Technical Specifications (ISTS) and Peach Bottom IST Program Third 10-year Interval Update) accepted the licensee determination that EHS and the MO-0-33-0498 active closure function were augmented quality (non-safety-related). The NRC safety evaluation report (SER) for the ISTS conversion (dated 8/30/95)documented the licensee statement that the emergency cooling water pump (part of EHS)was not credited for mitigation of design bases accidents or transients, and accepted the licensees proposed alternative testing. The NRC SER for the IST Program Update (dated 5/11/98) stated the licensee should evaluate the applicability of MO-0-33-0498 and EHS components to the IST program. The licensee responded (dated 1/29/99) that the classification of EHS and the MO-0-33-0498 closure function was augmented quality (non-safety-related) because the components did not support mitigation of any design basis transient or accident. The NRC response (dated 3/15/00) to this letter repeated the licensee position that the components were augmented quality and found the alternative testing proposed by the licensee to be acceptable.

The inspectors noted the purpose of the two licensing actions was for the licensee to request NRC approval for alternative test requirements, in lieu of the existing IST Code and Peach Bottom technical specification test requirements. The associated NRC SERs stated that the specified components were subject to the testing requirements of the IST program and approved the proposed alternative test requirements. However, after stating the components were subject to requirements of the IST program, the SER documented the licensee position that the components were not credited with mitigation of design basis accidents and were augmented quality. These statements appear to conflict. The inspectors concluded the SERs and associated documentation did not make a clear determination of whether MO-0-33-0498 and the EHS were safety-related quality or were non-safety-related quality.

Significance: For the purpose of the VLSSIR process, the inspectors screened the issue of concern through IMC 0612, Issue Screening, and determined the issue of concern would likely be of minor significance had a performance deficiency been identified. Additionally, the issue of concern was similar to IMC 0612, Appendix E, Examples of Minor Issues, example 3.b, because the documentation error in the 10-year IST Plan did not result in any missed IST tests or adversely impact MO-0-33-0498 reliability.

The inspectors also verified the following information which provides reasonable assurance that EHS and MO-0-33-0498 will continue to meet the regulatory requirements of 10 CFR 50.55a(B)(3)(ii):

(1) Constellation is currently testing the required EHS components iaw ASME OM 2012 Code;
(2) Regulatory commitments by Constellation and procedures are in place regarding this periodic IST testing;
(3) Constellation staff informed the inspectors that there are no current plans to revise this testing; and
(4) The inspectors noted that changes to the associated IST test procedures would require review through the 10 CFR 50.59 safety evaluation process.

Technical Assistance Request: No Technical Assistance Request was processed in support of this issue.

Corrective Action Reference: Constellation entered the issue into the corrective action program as Issue Report

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

  • On April 8, 2022, the inspectors presented the design basis assurance inspection (programs) inspection results to Mr. David Henry, Site Vice President and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.21N.02 Corrective Action 01335599

Documents 01420676

01537143

04013582

04378793

Corrective Action 04486879

Documents 04486979

Resulting from 04486991

Inspection 04487131

04487138

04487271

04490276

04490281

04490910

04491096

04491472

04492216

04494831

Drawings 6280-M-315, Sht. Emergency Service Water and High Pressure Service Revision 92

Water

280-M-315, Sht. Emergency Service Water and High Pressure Service Revision 95

Water

280-M-330 Emergency Cooling System Revision 39

Sht.1

Engineering EC 07-00344 Differing Detail of Tech Spec Basis & PIMS CRL Safety Revision 0

Changes Function

EC 556030 MO-3-23-014 Actuator Upgrade SMB1 to SB1 Revision 0

EC 626985 Approve MPR Anti-Rotation Device for Recirculation Revision 0

Valves

EC 630174 Evaluate BWROG Document TP16-1-112, Revision 5 for Revision 0

Applicability to Peach Bottom Recirculation Valves

Inspection Type Designation Description or Title Revision or

Procedure Date

Engineering JOG MOV AC Motor Operated GL 96-05 Gate Valve Revision 11

Evaluations Evaluation

Report MO-3-02-

053B

PMC-21-128124 Peach Bottom, System 14 Core Spray MOV/IST Alternate 02/23/2021

Treatment Plan

Miscellaneous BWR Main Steam Isolation Valve (MSIV) PM Template Revision 2

280-M-1-JJ-80 MSIV Vendor Technical Manual Revision 1

910328 NRC Peach Bottom Response to NCR P-91152 03/28/1991

GNL 88-14

A-391-VC-8 Vendor Technical Manual Revision 1

Commitment 02/24/2020

Change

Evaluation

290603,

Assignment 02-

DBD P-S-09 Residual Heat Removal System Revision 19

F-130-VC-273 Vendor Technical Manual Revision 0

NRC Information Potential Design Deficiency in Motor-Operated Valve 08/23/2013

Notice 2013-14 Control Circuitry

P-S-19 Recirculation System Revision 19

P-S-25B Primary Containment Auxiliary Systems Revision 10

PB-5069-14-14A- 10 CFR 50.69 System Categorization Document - Core Revision 1

003 Spray System

ST-O-003-450-2 Scram Discharge Vent and Drain Valve Functional Test 01/08/2022

ST-O-007-410-3 PCIS Valves Colder Shutdown Inservice Test 11/05/2021

ST-O-010-302-3 "A" RHR Loop Pump, Valve, Flow and Unit Cooler 03/01/2021

Functional and Inservice Comprehensive Test

ST-O-023-300-3 HPCI Pump, Valve, Flow and Unit Cooler Functional and 02/28/2022

In-service Test without Vibration Data Collected

ST-O-02A-400-3 Recirculation Pump Discharge Valve Operability Test 11/01/2021

ST-O-033-410-2 IST Exercise of ESW Air Operated Valves 02/26/2022

ST-O-07G-470-3 Main Steam Isolation Valve Closure Timing 11/03/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Procedures ER-AA-200 Preventive Maintenance Program Revision 5

ER-AA-200-1004 PCM Templates Revision 1

ER-AA-569-1004 10 CFR 50.69 Alternative Treatment Implementation Revision 5

Process

MA-AA-723-300 Diagnostic Testing of Motor Operated Valves Revision 14

MA-AA-723-301 Periodic Inspection of Limitorque Model SMB/SB/SBD Revision 15

SBD-000 through 5 Motor Operated Valves

MA-AA-796-024 Scaffold Installation, Inspection, and Removal Revision 12

MA-MA-796-024- Scaffolding Criteria for the Mid Atlantic Stations Revision 9

1001

OP-AA-201-009 Control of Transient Combustible Material Revision 26

SO 48.1.B Emergency Cooling Water System Startup Revision 20

ST-O-032-301-2 HPSW Pump, Valve and Flow Functional and Inservice Revision 42

Test

Work Orders 04246550

247914

250943

252128

264168

04306865

04869070

04880360

05133013

R1155387

R1196156

9

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