Letter Sequence Approval |
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MONTHYEARML0314903522003-05-29029 May 2003
Letter Risk Informed Testing Program
Project stage: Other
ML0324613332003-09-0202 September 2003
Meeting with South Texas Project, Units 1 & 2 Staff Review Issues with STP Proposed Risk-Informed Inservice Testing Program
Project stage: Approval
ML0324613482003-09-0202 September 2003
Summary of Meeting with South Texas Project Nuclear Operating Company, Regarding Staff Review Issues with the Proposed Risk-Informed Inservice Testing Program
Project stage: Approval
ML0327700042003-10-0101 October 2003
Letter, Summary of Telephone Conference Call on September 12, 2003, Regarding Proposed Risk-Informed Inservice Testing Program
Project stage: Request
ML0329302842003-10-17017 October 2003
Acknowledgment of Withdrawal of November 12, 2002, Risk-Informed Inservice Testing Program Submittal
Project stage: Withdrawal
2003-10-17
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Category:Meeting Summary
MONTHYEARML22252A0432022-09-12012 September 2022
Summary of August 31, 2022, Webinar with STP Nuclear Operating Company to Discuss a Proposed LAR to Revise the Dose Consequence Analysis for Main Steam Line Break and Locked Rotor Analysis Events for STP, Units 1 & 2
ML22147A0932022-06-0606 June 2022
2021 Annual Assessment Public Meeting Summary
ML21236A3082021-09-10010 September 2021
Regulatory Audit Summary Regarding License Amendment Request to Revise Moderator Temperature Coefficient Surveillance Requirements
ML21222A1192021-08-12012 August 2021
Summary of Meeting with STP Nuclear Operating Company Regarding the License Amendment Request to Revise the Moderator Temperature Coefficient Surveillance Requirements for South Texas Project, Units 1 and 2
ML21140A3892021-05-24024 May 2021
Riv Column 1 EOC 2020 Public Meeting Summary
ML20279A8152020-10-20020 October 2020
Summary of September 14, 2020, Presubmittal Teleconference with STP Nuclear Operating Company Regarding the Proposed LAR to Revise the Moderator Temperature Coefficient Surveillance Requirement for South Texas Project, Units 1 and 2 (EPID L
ML20189A2832020-07-0707 July 2020
Summary of Region IV Annual Assessment Public Meeting
ML20163A5522020-06-12012 June 2020
Summary of April 21, 2020, Teleconference with STP Nuclear Operating Company to Discuss the License Amendment Request to Revise the Emergency Plan for South Texas Project, Units 1 and 2
ML20140A2612020-05-27027 May 2020
May 5, 2020, Summary of Teleconference with STP Nuclear Operating Company to Discuss a Proposed Exigent License Amendment Request to Revise the Pressure of the Safety Injection Accumulators for South Texas Project, Unit 1
ML20107J5482020-04-15015 April 2020
Teleconference Regarding NRC Observations on the March 30, 2020, License Amendment Request to Revise the Emergency Plan STP Nuclear Operation Company South Texas Project, Units 1 and 2, Dockets 50-498 and 50-499
ML20049A0572020-02-26026 February 2020
Summary of February 6, 2020, Meeting with STP Nuclear Operating Company to Discuss a Proposed License Amendment Request to Revise the Emergency Plan for South Texas Project, Units 1 and 2 (EPID L- 2020-LRM-0004)
ML19350C5902019-12-17017 December 2019
12/3/19, Summary of Teleconference with STP Nuclear Operating Company to Discuss a Proposed License Amendment Request to Revise the Emergency Plan for South Texas Project, Units 1 and 2,
ML19102A0162019-04-16016 April 2019
4/10/2019 Summary of Public Teleconference Regarding Potential Submission of a Relief Request to Allow Use of Carbon Fiber Reinforced Polymer for Selected Piping Repairs at South Texas, Units 1 and 2
ML17005A1002017-01-18018 January 2017
January 4, 2017, Summary of Meeting to Discussion Stp'S Response to Request for Additional Information the Revised Aluminum Bronze Selective Leaching Aging Management Program for All Potentially Susceptible Welds Throughout the Facility
ML16279A3312016-10-27027 October 2016
Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409)
ML16272A4362016-10-14014 October 2016
Summary of Public Preapplication Meeting with STP Nuclear Operating Company to Discuss Possible License Amendment Request to Modify Emergency Response Organization for South Texas Project, Units 1 and 2
ML16246A0222016-10-0505 October 2016
Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items Related to Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400 - MF2409)
ML16238A5272016-09-0101 September 2016
Summary of 7/28/16, Public Meeting with STP Nuclear Operating Company to Discuss the License Amendment and Exemption Requests to Use a Risk-Informed Approach to the Resolution of GSI-191 (CAC Nos. MF2400 - MF2409)
ML16218A3672016-08-30030 August 2016
07/21/2016 Summary of Public Teleconference Meeting with STP Nuclear Operating Company Discussing Revisions to License Renewal Application Aluminum Bronze Selective Leaching Aging Management Program and Background Document
ML16236A0322016-08-23023 August 2016
08/18/2016 Summary of Conference Call With STP Nuclear Operating Company Concerning the Aluminum Bronze Selective Leaching Aging Management Program in the South Texas Project, License Renewal Application
ML16236A3042016-08-23023 August 2016
08/11/2016 Summary of Conference Call Between NRC and STP Nuclear Operating Company Concerning the 2016 Annual Update to the South Texas Project License Renewal Application
ML16180A0142016-07-25025 July 2016
Summary of Meeting Discussion Between South Texas Project, Units 1 and 2, and NRC Staff Regarding the Revised Aluminum Bronze Selective Leaching Aging Management Program for All Potentially Susceptible Welds Throughout the Facility
ML16190A0082016-07-13013 July 2016
Summary of 6/22/2016 Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409)
ML16188A0072016-07-0707 July 2016
Summary of Telecon Held on July 5, 2016 With STP Nuclear Operating Company, Concerning Additional Information Pertaining to the STP, License Renewal Application (TAC. Nos. ME4936, ME4937)
ML16188A0112016-07-0707 July 2016
Summary of Telecon Held on July 5, 2016 With STP Nuclear Operating Company, Concerning Additional Information Pertaining to the STP, License Renewal Application (TAC Nos. ME4936, ME4937)
ML16188A0092016-07-0707 July 2016
Summary of Telecon Held on July 5, 2016 with STP Nuclear Operating Company, Concerning Additional Information Pertaining to the STP, License Renewal Application (Tac. Nos. ME4936, ME4937) - Enclosure 1
ML16175A1082016-06-24024 June 2016
Summary of 4/21/2016 Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2
ML16166A0272016-06-14014 June 2016
Summary of Telephone Conference Call Held on 06/08/2016, Between the USNRC and STP Nuclear Operating Company Response to Request for Additional Information B2.1.18-6 Pertaining to the South Texas Project License Renewal Application
ML16092A0852016-04-13013 April 2016
3/17/2016 Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2401-MF2409)
ML16092A0442016-04-11011 April 2016
Summary of 3/3/2016 Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409)
ML16088A2432016-04-0101 April 2016
2/18/2016, Summary of Public Meeting with STP Nuclear Operating Company Regarding Open Items, Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2 (CAC Nos. MF2400-MF2409)
ML16081A2052016-03-24024 March 2016
Summary of Meeting with STP Nuclear Operating Company to Discuss Potential License Amendment Request for South Texas Project, Unit 1 Regarding Permanent Operation with 56 Control Rods
ML16074A0412016-03-14014 March 2016
Summary of a Call Held on March 10, 2016, between USNRC and STPNOC, Concerning the Staff's Upcoming Audit Regarding the Amp for the Loss Of Material Due to Selective of Al-Br Welds in the ECW System for the STP LRA (TAC Nos. ME4936 And ME4937)
ML16060A1272016-03-0707 March 2016
February 23, 2016, Summary of Conference Calls Held between NRC and STP Concerning Staff's Review of Submerged Closure Bolting Portion of 2014 Annual Update for STP License Renewal Application (TAC ME4936 And ME4937)
ML16028A1522016-02-18018 February 2016
1/14/2016 Summary of Public Meeting with STP Nuclear Operating Company Regarding Modifications to the Licensee'S Risk-Informed Generic Safety Issue (GSI) 191 Application and Supplements for South Texas Project, Units 1 and 2
ML16035A4802016-02-12012 February 2016
Jsc Meeting Summary Attachment
ML16011A0612016-02-0202 February 2016
Summary of 10/1/15 Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas Project, Units 1 and 2 (CAC MF
ML16011A0702016-01-28028 January 2016
Summary of Preapplication Meeting with STP Nuclear Operating Company to Discuss Exigent License Amendment Request to Operate Following Removal of a D6 Control Rod at South Texas Project, Unit 1
ML16033A0072016-01-19019 January 2016
January 19, 2016, Summary of Public Meeting with STP to Discuss the Plant-Specific Aging Management Program, Selective Leaching of Aluminum Bronze, Associated with STP's License Renewal Application
ML16013A0662016-01-14014 January 2016
Summary of 11/9 and 12/30/15 Conference Calls with STP Nuclear Operating Company to Discuss the Fall 2015 Steam Generator Tube Inspection Activities (CAC No. A11018)
ML15308A0112015-11-30030 November 2015
Record of Conference Call on STP Request for Additional Information Set 34
ML15201A0032015-07-30030 July 2015
7/2/15 Summary of Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Units 1 and 2
ML15177A1042015-07-21021 July 2015
4/22/2015 Summary of Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Units 1 and 2 (TAC MF2400 t
ML15177A2742015-07-21021 July 2015
5/6/2015 Summary of Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Units 1 and 2 (TAC Nos. MF24
ML15180A2732015-07-15015 July 2015
6/3/2015 Summary of Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Units 1 and 2 (TAC MF2400 to
ML15139A3442015-06-11011 June 2015
Summary of Telephone Conference Call Held on May 12, 2015 Between the U.S. Nuclear Regulatory Commission and STP Nuclear Operating Company, Concerning Request for Additional Information, Set 31, Pertaining to the South Texas Project, Licens
ML15103A0022015-05-13013 May 2015
Summary of 4/8/15 Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Units 1 and 2
ML15084A0032015-04-0606 April 2015
2/4/15 Summary of Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Units 1 and 2 (TAC MF2400-MF24
ML15084A0042015-04-0101 April 2015
2/5/2015 Summary of Presubmittal Meeting with STP Nuclear Operating Company to Discuss Integrated Leak Rate Testing Program License Amendment Request for South Texas, Units 1 and 2
ML15020A1062015-02-19019 February 2015
12/1-3/2014 Summary of Meeting with STP Nuclear Operating Company to Discuss Revised Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 at South Texas, Unit 1 and 2 (TAC MF2400-
2022-09-12
[Table view] |
Text
September 2, 2003 LICENSEE: STP Nuclear Operating Company FACILITY: South Texas Project, Unit 1and Unit 2
SUBJECT:
SUMMARY
OF HEADQUARTERS AND SOUTH TEXAS PROJECT NUCLEAR OPERATING COMPANY TELEPHONE CONFERENCE CALL OF JULY 2, 2003, REGARDING STAFF REVIEW ISSUES WITH THE SOUTH TEXAS PROJECT PROPOSED RISK-INFORMED INSERVICE TESTING PROGRAM (TAC NOS. MB8948 AND MB8949)
On July 2, 2003, the U. S. Nuclear Regulatory Commission (NRC) Headquarters staff held a telephone conference call with STP Nuclear Operating Company (STPNOC), the licensee for South Texas Project (STP), Units 1 and 2. The purpose of the telephone conference call was to discuss the proposed Risk-Informed Inservice Testing (RI-IST) program submittal. The staff had previously transmitted 6 technical issues concerning the RI-IST submittal to STP on May 29, 2003 (ADAMS ML031490352). To support the July 2, 2003, discussions STP had provided the staff with some brief responses to the NRCs technical issues along with a matrix depicting the relationship of the proposed RI-IST change with respect to the previously approved special treatment exemption (Enclosure 1). A list of participants is enclosed as Enclosure 2.
During the call, STP provided clarifying and amplifying information about their proposed RI-IST program in response to the staffs concerns.
STP agreed that they could have done a better job documenting why their proposed RI-IST ranking for components differed from the special treatment exemption ranking. STP said they felt they could document the basis for these differences to the staffs satisfaction. The staff suggested that STP not start this substantive effort until after the staff makes a decision on the proposed RI-IST categorization approach.
The telephone conference call ended with STP and NRC staff indicating that they understood each others positions on the issues and that the NRC staff would discuss the viability of the STP proposed categorization approach with NRR management. The staff agreed to get back to STP on their proposed categorization approach as soon as practical. The STP personnel
also indicated they would further consider the NRC comments with respect to their proposed RI-IST methodology. Both parties agreed to have a follow-up discussion after the requisite internal interactions have been held.
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499
Enclosures:
- 1. STP bullet responses to fundamental review issues with matrix
- 2. List of Participants cc w/encls: See next page
ML032461348 NRC-001 OFFICE PDIV-1/SECY PDIV-1/SC PDIV NAME DBaxley RGramm HBerkow DATE 9 / 02 /2003 9 / 02 /2003 9 / 02 /2003 South Texas Project, Unit 1 and Unit 2 cc:
Mr. Cornelius F. OKeefe Senior Resident Inspector A. H. Gutterman, Esq.
U.S. Nuclear Regulatory Commission Morgan, Lewis & Bockius P. O. Box 910 1111 Pennsylvania Avenue, NW Bay City, TX 77414 Washington, DC 20004 A. Ramirez/C. M. Canady Mr. T. J. Jordan, Vice President City of Austin Engineering & Technical Services Electric Utility Department STP Nuclear Operating Company 721 Barton Springs Road P. O. Box 289 Austin, TX 78704 Wadsworth, TX 77483 Mr. L. K. Blaylock S. M. Head, Manager, Licensing Mr. W. C. Gunst Nuclear Quality & Licensing Department City Public Service Board STP Nuclear Operating Company P. O. Box 1771 P. O. Box 289, Mail Code: N5014 San Antonio, TX 78296 Wadsworth, TX 77483 Mr. C. A. Johnson/A. C. Bakken Environmental and Natural Resources AEP Texas Central Company Policy Director P. O. Box 289 P. O. Box 12428 Mail Code: N5022 Austin, TX 78711-3189 Wadsworth, TX 77483 Jon C. Wood INPO Matthews & Branscomb Records Center 112 East Pecan, Suite 1100 700 Galleria Parkway San Antonio, TX 78205 Atlanta, GA 30339-3064 Arthur C. Tate, Director Regional Administrator, Region IV Division of Compliance & Inspection U. S. Nuclear Regulatory Commission Bureau of Radiation Control 611 Ryan Plaza Drive, Suite 400 Texas Department of Health Arlington, TX 76011 1100 West 49th Street Austin, TX 78756 D. G. Tees/R. L. Balcom Texas Genco, LP Brian Almon P. O. Box 1700 Public Utility Commission Houston, TX 77251 William B. Travis Building P. O. Box 13326 Judge, Matagorda County 1701 North Congress Avenue Matagorda County Courthouse Austin, TX 78701-3326 1700 Seventh Street Bay City, TX 77414 May 2003
South Texas Project, Unit 1 and Unit 2 cc:
Susan M. Jablonski Office of Permitting, Remediation and Registration Texas Commission on Environmental Quality MC-122 P.O. Box 13087 Austin, TX 78711-3087 Mr. Terry Parks, Chief Inspector Texas Department of Licensing and Regulation Boiler Division P. O. Box 12157 Austin, TX 78711 Mr. Ted Enos 4200 South Hulen Suite 630 Ft. Worth, Texas 76109 Mr. James J. Sheppard President and Chief Executive Officer STP Nuclear Operating Company South Texas Project Electric Generating Station P. O. Box 289 Wadsworth, TX 77483 May 2003
NRC Staffs Issues with STPNOCs Proposed RI-IST Program STP has reviewed the NRC staff feedback on the subject submittal, and believes that additional clarification is needed on each of the identified issues as stated below:
Issue 1 - RI-IST will recategorize SSCs
RI-IST does not recategorize SSCs - SSCs remain categorized as per the STP Exemption
RI-IST does not affect program scope - RI-IST merely identifies appropriate treatment strategies for scoped SSCs
Reg Guides 1.174 and 1.175, as well as OMN-3 guidance, were followed to determine the appropriate treatment strategies Issue 2 - Proposed RI-IST and the STP Exemption impacts must be considered together
The STP Exemption and the proposed RI-IST are separate issues - the Exemption determined the scope of SSCs in the IST Program, while RI-IST determines the treatment strategy for those SSCs remaining in the IST scope
The sensitivity studies used to demonstrate the acceptability of the STP Exemption approach remain bounding for the proposed RI-IST Issue 3 - Proposed RI-IST does not properly address passive functions
Certain SSCs are categorized as HIGH/MEDIUM due to pressure boundary considerations only - these SSCs do not require pressure boundary testing under either IST or proposed RI-IST
In the PRA, passive refers to an SSC performing its function without changing state
SSC repositioning after an event is an active function - the PRA specifically models off-normal states and the recovery actions as applicable
RI-IST will test all safety functions as required by the Code Issue 4 - RI-IST will not properly test scoped components
Per the approved STP Exemption, SSCs categorized as LOW/NRS are removed from the scope of IST - LOW/NRS SSCs are not within the scope of the RI-IST request
RI-IST merely applies treatment strategies for scoped SSCs consistent with RG1.175
Per RG1.175, staggered testing of valve groups is permitted - test interval is no greater than the number of valves in a group x 18 months - we will not exceed a test interval of 6 years
The STP proposal is consistent with RI-IST programs already approved for Comanche Peak and San Onofre ENCLOSURE 1
Issue 5 - HSS/MSS SSCs must be evaluated for enhanced treatment
Per the STP Exemption, Box 2 SSCs must be evaluated for enhanced treatment
- there are no Box 2 SSCs in the existing IST Program or in the proposed RI-IST Program
During the categorization process (which is not part of this RI-IST request), Box 1 SSCs are evaluated for enhanced treatment only if beyond design basis functions are identified
STP has chosen to add certain safety significant SSCs into the RI-IST program which are not scoped in the existing IST Program - these new SSCs will be trended as part of their treatment Issue 6 - Common cause is not properly addressed in the proposed RI-IST
STPs approach to common cause is extremely conservative - if we were to apply a common cause approach similar to already-approved RI-IST programs, a significant number of STPs SSCs would migrate from a more robust treatment approach to a more relaxed treatment approach
ASME PRA standard (DG-1122) does not require modeling of inter-system common cause
STPs cultural approach to potential common cause issues is both a strength and is conservative, as highlighted by the recent MOV issue - following 100%
inspection by STP, only the initial identified deficiency could have affected component functionality
Risk-Informed Inservice Testing Program Matrix RISC-1 RISC-2 Safety Related Non-Safety Related High Safety Significant High Safety Significant RISC-3 RISC-4 Safety Related Non-Safety Related Low Safety Significant Low Safety Significant IST TREATMENT HIGH MEDIUM LOW SSC Not Exempt SSC Not Exempt SSC Not Exempt IST Code Test IST Extended Interval IST Extended Interval Enhanced Testing with Compensatory Measure with Performance Monitoring HIGH 13 Valve Groups - 40 Valves 8 Valves Groups - 31 Valves 4 Valve Groups - 13 Valves 4 Pump Groups - 10 Pumps 4 Pump Groups - 12 Pumps 0 Pumps - 0 Pumps
- 1 Valve Group - 3 Valves *1 Valve Group - 3 Valves
- 2 Valve Groups - 6 Valves SSC Not Exempt SSC Not Exempt SSC Not Exempt IST Code Test IST Extended Interval IST Extended Interval Enhanced Testing with Compensatory Measure with Performance Monitoring MEDIUM 0 Valve Groups - 0 Valves 11 Valve Groups - 39 Valves 39 Valve Groups - 131 Valves 0 Pump Groups - 0 Pumps 1 Pump Group - 2 Pumps 1 Pump Group - 2 Pumps EXEMPTION CATEGORIZATION SSC Exempt SSC Exempt SSC Exempt IST Code Test IST Extended Interval IST Extended Interval Enhanced Testing with Compensatory Measure with Performance Monitoring LOW 0 Valve Groups - 0 Valves 0 Valve Groups - 0 Valves 92 Valve Groups - 186 Valves 0 Pump Groups - 0 Pumps 0 Pump Groups - 0 Pumps 3 Pump Groups - 8 Pumps SSC Exempt SSC Exempt SSC Exempt IST Code Test IST Extended Interval IST Extended Interval Enhanced Testing with Compensatory Measure with Performance Monitoring NRS 0 Valve Groups - 0 Valves 0 Valve Groups - 0 Valves 20 Valve Groups - 57 Valves 0 Pump Groups - 0 Pumps 0 Pump Groups - 0 Pumps 0 Pump Groups - 0 Pumps
- Valve group has different ranks for the open and close functions
TREATMENT COMPARISONS Commache Peak IST SONGS IST STP IST HIGH 138 SSCs - 20.7% 114 SSCs - 15.8% 53 SSCs - 9.9%
MEDIUM N/A 64 SSCs - 7% 87 SSCs - 16.2%
LOW 529 SSCs - 79.3% 693 SSCs - 76.1% 397 SSCs - 73.9%
STP EXEMPTION RANKS STP IST w/Code Thresholds HIGH 112 SSCs - 20.9% 17 SSCs - 3.2%
MEDIUM 174 SSCs - 32.4% 35 SSCs - 6.5%
LOW 194 SSCs - 36.1% 485 SSCs - 90.3%
NRS 57 SSCs - 10.6%
LIST OF PARTICIPANTS STP/NRC TELEPHONE CONFERENCE CALL JULY 2, 2003 Licensees Participants S. Head G. Schinzel W. Stilwell P. Walker B. Scott NRC Participants D. Harrison D. Fischer M. Thadani D. Terao H. Berkow M. Tschiltz ENCLOSURE 2
