IR 05000352/2016008

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Limerick Generating Station - Problem Identification and Resolution Inspection Report 05000352/2016008 and 05000353/2016008
ML17018A231
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 01/17/2017
From: Schroeder D L
Reactor Projects Region 1 Branch 4
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Schroeder D
References
IR 2016008
Download: ML17018A231 (15)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BLVD., SUITE 100 KING OF PRUSSIA, PA 19406

-2713 January 17, 2017 Mr. Bryan Hanson Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road

Warrenville, IL 60555

SUBJECT:

LIMERICK GENERATING STATION

- PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000352/2016008 AND 05000353/2016008

Dear Mr. Hanson:

On December 1 5, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at the Limerick Generating Station, Units 1 and 2. The NRC inspection team discussed the results of this inspection with Mr. M. Herr, Assistant Plant Manager, and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the station's corrective action program and the station's implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety.

The team also evaluated the station's processes for use of industry and NRC operating experience information and the effectiveness of the station's audits and self

-assessments.

Based on the samples reviewed, the team determined that your staff's performance in each of these areas adequately supported nuclear safety

.

Finally, the team reviewed the station's programs to establish and maintain a safety

-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the team's observations and the results of these interviews, the team found no evidence of challenges to your organization's safety

-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

In all of the areas reviewed, the NRC inspectors did not identify any findings or violations of more than minor significance. 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 the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."

Sincerely,/RA/ Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects

Docket Nos.

50-352 and 50-353 License Nos.

NPF-39 and NPF-85

Enclosure:

Inspection Report 05000352/2016008 and 05000353/2016008

w/Attachment:

Supplementary Information cc w/encl:

Distribution via ListServ

ML17018A231 SUNSI Review Non-Sensitive Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME TSetzer/TS MFerdas/MF DSchroeder/DS DATE 01/05/17 01/10/17 01/17/17 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.:

50-352 and 50-353 License Nos.:

NPF-39 and NPF

-85 Report Nos.:

05000352/2016008 and 05000353/2016008 Licensee:

Exelon Generation Company, LLC Facility:

Limerick Generating Station, Units 1 and 2 Location:

Sanatoga, PA 19464 Dates: November 28

- December 2, 2016 December 1 2 -15, 2016 Team Leader:

Thomas Setzer, PE, Senior Project Engineer Inspectors:

Peter Boguszewski, Project Engineer Matthew Fannon, Resident Inspector Mark Henrion, Project Engineer

Approved by:

Daniel L. Schroeder, Chief Reactor Projects Branch 4 Division of Reactor Projects

2

SUMMARY

IR 05000352/2016008 and 05000353/2016008; 11/28/2016

- 12/15/2016

Limerick Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution.

This NRC team inspection was performed by three regional inspectors and one resident inspector. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 6

. Problem Identification and Resolution The inspectors concluded that Exelon was effective in identifying, evaluating, and resolving problems.

Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon implemented corrective actions to address the problems identified in the corrective action program in a timely manner.

The inspectors concluded that Exelon adequately identified, reviewed, and applied relevant industry operating experience to Limerick operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.

No findings were identifie d.

3

REPORT DETAILS

OTHER ACTIVITIES (OA)

4OA2 Problem Identification and Resolution

(71152B) This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Exelon's corrective action program at Limerick. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," and Exelon procedure PI

-AA-125, "Corrective Action Program (CAP) Procedure." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed CAP issue reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple Station Ownership Committee meetings. The inspectors selected items from the following functional areas for review: engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, Maintenance Rule, and oversight programs.

(1) Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems in both Units 1 and 2

, which included the high pressure coolant injection (HPCI), reactor core isolation cooling (RCIC), core spray (CS), and residual heat removal (RHR)systems. Additionally, the inspectors reviewed a sample of CAP issue reports written to document issues identified through internal self

-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program as appropriate.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of CAP issue reports issued since the last NRC biennial problem identification and resolution inspection completed in October 2014. The inspectors also reviewed CAP issue reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution.

The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments

, Licensee Event Reports, and extent

-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

(3) Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed CAP issue reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of CAP issue reports associated with selected non

-cited violations and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon's actions related to the reactor enclosure recirculation system for both Units 1 and 2.

b. Assessment (1) Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon, in general, identified problems and entered them into the corrective action program at a low threshold. Exelon staff at Limerick initiated approximately 24,000 CAP issue reports between October 2014 and November 2016. The inspectors observed supervisors at the Station Ownership Committee meetings appropriately questioning and challenging CAP issue reports to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in CAP issue reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels.

During a plant walkdown of safety significant areas in Units 1 and 2

, the inspectors identified two minor issues that had not been entered into the corrective action program. Specifically, the inspectors identified an oil leak on the Unit 1 HPCI suction valve from the condensate storage tank. Additionally, the inspectors identified an uncapped pipe that penetrated the floor in the Unit 1 RCIC room. Both of these issues were considered performance deficiencies because Exelon failed to identify the conditions adverse to quality and enter them into the CAP. Exelon promptly entered the issues into the corrective action program (IRs 3948230 and 3948821) and evaluated the issues to determine if there were any adverse effects upon the availability or operability of the HPCI or RCIC systems. Exelon determined that neither issue affected operability, and took corrective action to address the issues. The inspectors determined that the issue s did not affect the availability, reliability, or capability of the HPCI and RCIC systems. Therefore, the performance deficiencies were determined to be minor and not subject to enforcement action in accordance with the NRC's Enforcement Policy.

(2) Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon screened CAP issue reports for operability and reportability, categorized the CAP issue reports by significance, and assigned actions to the appropriate department for evaluation and resolution. The issue report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of CAP issue reports reviewed, the inspectors noted that the guidance provided by Exelon CAP implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue.

The inspectors noted one observation concerning the station's management of the oldest Action Items (ACIT s). The inspectors requested a list of all corrective action program CAP issue reports initiated before the last PI&R inspection (October 2014) and that remain open. Exelon provided a list of approximately 600 items ranging from two to ten-years old. The inspectors reviewed this list of items and determined that there were no issues of safety significance; however, the due dates were not assigned in accordance with the intent of the corrective action procedure

, and had in some cases been extended numerous times. Specifically, many items were extended due to lack of resources or higher priority work, and these items were then extended multiple times for the exact same reason. The inspectors noted that Exelon recently began monitoring this list but had not ensured that the due dates for the items were set according to priorities

and resources. This was not considered a performance deficiency since Exelon procedures allow ACIT due dates to be extended multiple times; however, the inspectors noted that this practice would not ensure that the items get completed.

(3) Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC non

-cited violations and findings since the last problem identification and resolution inspection were timely and effective.

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of CAP issue reports associated with review of industry operating experience to determine whether Exelon appropriately evaluated the operating experience information for applicability to Limerick and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon adequately considered the underlying problems associated with the issues for resolution via their corrective action program.

In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

Assessment The inspectors determined that Exelon appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable.

b. Findings

No findings were identified.

.3 Assessment of Self

-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self

-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies.

Assessment The inspectors concluded that self

-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self

-assessments in a methodical manner. Exelon completed these audits and self

-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

b. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Limerick. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management

and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns. The inspectors reviewed the Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate.

Assessment During interviews, Limerick staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On December 15, 2016, the inspectors presented the inspection results to Mr. M. Herr, Assistant Plant Manager

, and other members of the Limerick staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

R. Libra, Site Vice President
D. Lewis, Plant General Manager
M. Herr, Assistant Plant Manager
I. Chaudry, ECP Coordinator
S. Desimone, Security Manager
T. Fritz, System Manager
N. Lampe, Engineer
W. Levis, Branch Manager
C. Mattson, System Manager
B. McCall, CAP Program Manager
J. Mills, System Manager
T. Ray, Security CAPCO
E. Rosa, System Manager
J. Somers, System Manager
J. Thoryk, System Manager
B. Tracy, IST Engineer
M. Trexler, Site Maintenance Rule Coordinator
B. Weingard, Engineering Supervisor

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

None

LIST OF DOCUMENTS REVIEWED

Section 4OA2: Problem Identification and Resolution

Audits and Self

-Assessments

ACAD 12-001, Limerick Operations Training Objective 3 Focused Area Self

-Assessment Radiological Gaseous and Liquid Effluents Control Program Check In Self-Assessment

IR 2413683, Security 95001 Inspection Self

-Assessment

IR 2436679, Emergency Preparedness Check

-In Self-Assessment

IR 2628038, Maintenance Rule Self

-Assessment

IR 2398621, FASA: Preparation for the 2015 NRC Component Design Basis Inspecti on
IR 2624177, FASA: EQ Program
IR 2631529, CHECK

-IN Self-Assessment: 50.59 Process

CHECK-IN Self-Assessment of Corrective Action Program, dated 12/15/15
CAP Program Audit dated April 1, 2015
PI&R FASA, dated 10/6/16
ECP CHECK

-IN Self-Assessment dated 1/15/16

CAP Issue Reports (* indicates that issue report was generated as a result of this inspection)
2388098
2391087
2391388
2434705
2434544
2437674
2447137
2451717
2470878
2485343
2502888
2510510
2523623
2581137
2602641
20374
2719790
2703066
2674478
2656504
2391035
2391372
2400170
2425829
2435722
2441885
2457984
2471714
2481579
2483118
2490882
2500806
2523403
2557605
2573006
2721792
2711526
2699977
2655914
2440393
2587076
2563872
20306
1271456
1320455
1353502
1366130
1386000
1388299
1408405
1475954
1426111
1484029
1600991
1609113
2409258
1691686
1684293
1650706
1624066
1577935
2458005
2430692
2563872
2601176
2466892
2607883
2722233
2497686
2458432
1558559
3948230*
1653696
1687907
2472778
2417570
1440246
1440254
2542598
2686844
1656697
1695702
1697821
2398492
2402576
2408483
2413683
2429779
2434529
2436679
2436878
2439637
2442697
2445264
2445519
2446419
2458286
2459678
2462439
2471505
2478644
2480263
2494273
2510180
2513554
2514772
2516721
23766
2523907
2529147
2529503
2535664
2543916
2545600
2546805
2547594
2551157
2553230
2553273
2571809
2571968
2586986
2587076
2601215
2602637
2605441
2607821
2611406
2612217
2612228
2622237
2628038
2655286
2655823
2662331
2663248
2666087
2667045
2667382
2667682
2679688
2696498
2707958
2709120
2711609
2724995
25350
2725379
2726027
2726138
3947291
2653296
2523108
2606000
2483972
2646407
2581426
2545199
2437079
2700512
2520906
2551930
2524303
2532093
2548650
2664644
2679609
2681596
2700501
2390846
2461965
2511146
2511297
2605828
2711443
2425030
2477449
2477513
2478467
2484626
2672406
2675189
2539426
2653298
2674023
2675759
2676685
2591861
2448149
2485871
2680421
2446756
2575739
2480166
2463216
2464416
2624349
2624349
2458005
2602637
2711263
2664553
2697253
2699806
3952320*
3948821*
2509699
2584452
2584456
2584458
2671958
2671965
2671968
2671980
2671992
2671996
2672004
2621786
2621784
2447137
1418917
2520732
2480166
2525512
2490592
2556568
2624266
2563872
2602637
2624349
2644005
2592543
2545199
2116233
2426547
2521700
2566856
2566861
2566863
2577704
2577705
2622047
2625171
2652313
2461166
2740480
3943194
3946803
2740598
3949624
2726060
2673104
2619459
2673333
3953024*
1468974*
2444385
2555360
2669948
2661084
2574532
0566953
1050522
1196633
1219466
1250199
0618182
2634231
2640779
2619459
2642077
2671663
2673104

Drawings

8031-M-20, Fuel and Diesel Oil Storage Transfer (Starting Air System Unit 1), Sheet 6, Revision 52 M-563, Plumbing and Drainage Reactor Building No. 1&2 Dirty Radwaste System Isom, Diag.
M-513, Plumbing and Drainage Reactor Building No. 1 Floor Plan EL. 177'

- 0" M-500, Plumbing and Drainage Symbols, Abbreviations, and General Notes

M-61, P&ID Liquid Radwaste Collection (Unit 1)

Operating Experience

IN 2016-13, Uranium Accumulation in Fuel Cycle Facility Ventilation and Scrubber Systems
CFR Part 21 Notification of Defective Moore 535 Controllers Event Notification 51923, Part 21 Initial Notification of Masterpact Breaker Failure to Close
RIS 2015-003, Reporting Security Incidents
RIS 2015-006, Tornado Missile Protection
IN 2006-05, Operating Experience Regarding Complications from a Loss of Instrument Air Non-Cited Violations and Findings
05000352/2015004-02, Condition Prohibited by Technical Specifications Due to Standby Gas Treatment System Subsystem Inoperable
05000352/2015005

-01, Unplanned Manual Power Reduction to 90%

05000352/2016001

-01, Reactor Enclosure Recirculation System Design Change Was Not Evaluated

05000352,353

/2014004-01

05000352,353/2015201-01 05000352,353

/2015201-02 NCV 05000352/2016001

-02, Seismic Qualification of Safety Related Battery not Maintained

NCV 05000352; 05000353/2015001

-01, Fire Safe Shutdown Diesel Generator Maintenance Program Did Not Account for Cold Temperatures due to Inadequate Specification for Fuel Oil Cloud Point

NCV 05000352; 05000353/2015001

-02, Startup Procedure Considered High Pressure Coolant Injection Operable with High Reactor Water Level Trip Actuated Preventing High Drywel

l Pressure Automatic Actuation

Procedures

ER-AA-302-1006, Motor

-Operated Valve Maintenance and Testing Guidelines, Revision 13

PI-AA-120, Issue Identification Screening Process, Revision 6
PI-AA-125, Corrective Action Program Procedure (CAP), Revision 4
ST-2-026-603-0, Radioactive Gaseous Effluent Monitoring North Stack Effluent Monitor Channel 'A' Functional Test (RIX

-26-075A,

RY-26-075A)
ST-2-026-640-0, Radioactive Gaseous Effluent Monitoring

- North Stack Effluent

- Flow Rate Monitor Functional Test (FT

-26-074)

TQ-LG-121-1000, Limerick Station Supervisory Development Program Site Specific Training, Revision 2
ER-AA-310, Implementation of the Maintenance Rule, Revision 9
ER-AA-310-1003, Maintenance Rule

- Performance Criteria Selection, Revision 5

ER-AA-310-1004, Maintenance Rule

- Performance Monitoring, Revision 13

ER-AA-310-1007, Maintenance Rule

- Periodic (a)(3) Assessment, Revision 4

LS-AA-104-1000, Exelon 50.59 Resource Manual, Revision 10
MA-AA-716-025, Scaffold Installation, Modification, and Removal Request Process
LS-AA-104-1002, 50.59 Applicability Review Form
MA-AA-716-026, Station Housekeeping/ Material Condition Program
ST-6-022-252-0, Diesel Driven Fire Pump Flow Test
M-C-700-335, Rev. 8
Alarm Response Card (ARC)-MCR-002 B-4, Revision 1
ON-122, Loss of Main Control Room Annunciators, Revision 20

Work Orders

A1968726 A1970158
A1986287 A1992876 A2050067

Miscellaneous

ECR
LG-15-00291 Limerick Generating Station Plant Health Committee Significant Work List for Work Week 1651
CFR 50.65(a)(3) Periodic Assessment 2/29/2016
LG-11-0183, H2O2 Analyzer Project Authorization Request Maintenance Rule Basis Documents Security PI Data Security PIIM 2015

-0466 System Health Reports

50.59 review of procedure
MA-AA-716-025, Scaffold Installation, Modification, and Removal Request Process
LGS UFSAR Section 9.3.3, Plant Drainage Systems Operator Logs

- November 20, 2016

Email dated 11/3/2016 from Robert McCall; Re:
Passport Assignments with Excessive Reschedules
ECP Investigative Cases 2014 thru 2016
Safety Culture Monitoring Panel Meeting Minutes dated 5/19/15, 8/24/15, 12/2/15, 1/29/16, 6/3/16 3Q-4Q 2015 Senior Leadership Team Safety Culture Review dated 4/25/16
Attachment

LIST OF ACRONYMS

ACIT Action Item
ARC Alarm Response Card
ADAMS Agency-wide Documents Access and Management System
CAP Corrective Action Program
CAPCO Corrective Action Program Coordinator
CFR Code of Federal Regulations
CS Core Spray

ECP Employee Concerns

Program FASA Focused Area Self

-Assessment

HPCI High Pressure Coolant Injection
IMC Inspection Manual Chapter
IR Issue Report
NRC Nuclear Regulatory Commission
OA Other Activities
PARS Publicly Available Records System
PI&R Problem Identification and Resolution

RCIC Reactor Core Isolation Cooling

RHR Residual Heat Removal