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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K9681999-10-19019 October 1999 Ack Receipt of Transmitting Rev 40 to Physical Security Plan for Washington Nuclear Plant 2.Based on Determination That Changes Do Not Decrease Effectiveness of Plan,No NRC Approval Required ML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML20206U4501999-05-19019 May 1999 Ack Receipt of Which Transmitted Rev 39 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required,Since Changes Do Not Decrease Effectiveness of Security Plan ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule ML20196K6961999-03-30030 March 1999 Ack Receipt of ,Transmitting Rev 38 to Physical Security Plan for Plant.No NRC Approval Is Required,In Accordance with 10CFR50.54(p) GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML20204F0261999-03-19019 March 1999 Forwards Insp Rept 50-397/99-01 on 990201-04 & 0303-05.No Violations Noted.Areas of Physical Security Plan Effectively Implemented with Listed Exceptions ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17284A8981999-10-14014 October 1999 Forwards Rev 0 to WNP-2 Cycle 15,COLR 99-15, IAW Requirements of TS 5.6.5 ML17284A9061999-09-24024 September 1999 Forwards Final Rept for 990812 out-of-sequence Drills for Energy Northwest Washington Nuclear Power Project 2 (Lab, Food Control Point & Milk Sampling).No Deficiences & No Areas Requiring C/A Identified in Three Drills ML17292B7591999-09-24024 September 1999 Forwards Rev 24 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b), 50.54(q) & 10CFR50 App E.Detailed Synopsis of Changes,Encl ML17284A8881999-09-24024 September 1999 Informs NRC of Change in Schedule Pertaining to Final Implementation of Reactor Stability long-term Solution for WNP-2 ML17292B7581999-09-22022 September 1999 Forwards NRC Forms 396 & 398 for Nl Hancock,License SOP-50027-3,AR Herrington,License OP-50013-3,WH Sawyer, License SOP-50023-3 & Dl Strote,License SOP-50031-3,for Renewal of Licenses.Without NRC Forms 396 & 398 ML17284A8811999-09-0909 September 1999 Forwards Response to NRC 990623 RAI to Support Review of Pending Request for Amend to Reactor pressure-temp Limit Curve TS GO2-99-168, Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3)1999-09-0808 September 1999 Forwards Rev 40 to Physical Security Plan.Rev Withheld,Per 10CFR2.790(a)(3) ML17284A8751999-08-30030 August 1999 Provides Correct Page from License NPF-21 Marked to Show Rev Addressed in 990729 Application for Amend,Which Included Page That Was Inadvertently Included as Attachment 4.Replace Attachment 4 with Attached Page & Disregard Attachment 5 ML17284A8721999-08-30030 August 1999 Forwards Proprietary Info to Support Review of Request for Amend to License NPF-21,re Min Critical Power Ratio Safety Limits Tss,As Requested During 990816 Conversation. Proprietary Encl Withheld ML17284A8711999-08-30030 August 1999 Informs Staff of Errors in world-wide-web Database Related to WNP-2 Reactor Vessel Structural integrity.Marked-up Pages Containing Errors or Omissions Will Be Forwarded by 991201 ML17292B7531999-08-24024 August 1999 Requests That Eleven Individuals Listed Below Take BWR Generic Fundamentals Examination to Be Administered on 991006 ML17292B7511999-08-24024 August 1999 Forwards Fitness for Duty (FFD) Semiannual Performance Data Rept for Jan-June 1999,per 10CFR26.71(d) ML17284A8701999-08-19019 August 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee & NRC Form 398, Personal Qualification Statement - Licensee, for Jd Prescott (License SOP-50262-1).Without Encls ML17292B7501999-08-19019 August 1999 Informs Staff That Licensee Has Completed Review of NRC SER for B&Wog Util Resolution Guidance Document Addressing ECCS Suction Strainer Blockage ML17284A8681999-08-12012 August 1999 Submits Two ISI Program Plan Relief Requests for NRC Review & Approval,Per 10CFR50.55a(a)(3)(i).Proposed Alternatives Provide Acceptable Level of Quality & Safety ML17284A8541999-08-0202 August 1999 Forwards Proprietary Addl Info to Support Review of Pending Request for Amend to MCPR Safety Limit Ts.Info Consists of Proprietary Ltr from Abb Combustion Engineering,Inc.Encl Withheld ML17284A8531999-07-30030 July 1999 Forwards Estimate of Number of Licensing Action Requests Planned for Submittal in Future,As Requested in Administrative Ltr 99-02.Twenty-nine Submittals Scheduled for Fy 2000 & Four for Fy 2001 ML17284A8301999-07-22022 July 1999 Clarifies Change of Licensee Name from Wpps to Energy Northwest & Change of Facility Name from Wppss Nuclear Project Number 2 to WNP-2,as Requested in 990719 Telcon with Js Cushing of NRC.Marked-up OL Pages,Encl ML17292B7451999-07-20020 July 1999 Forwards Rev 23 to WNP-2 Emergency Plan,Iaw 10CFR50.4(b) & 50.54(q) & 10CFR50 App E.Rev 23 Provides Updated Description Re Establishment of Separate Emergency Operation Centers for Benton & Franklin Counties ML17292B7391999-07-16016 July 1999 Submits Withdrawal of Request for Amend to Secondary Containment & Standby Gas Treatment Sys Ts.Util Currently Plan to re-submit Amend Request in Entirety by 991112 ML17292B7381999-07-12012 July 1999 Forwards NRC Form 396 & NRC Form 398,for If Sumsion,License OP-50487 & Ga Westergard,License SOP-50415 for Renewal of Operator Licenses.Without Encls ML17292B7171999-07-0606 July 1999 Provides Notification of Early Completion on 990630 of Exception Noted in 990629 Ltr.Equipment within Scope of GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants, Evaluated & Y2K Ready ML17292B7181999-07-0202 July 1999 Responds to 990623 RAI to Support Review of Evaluation of Planar Indication Found on Weld Number 24RRC(2)A-1 During 1998 RO ML17292B7161999-06-30030 June 1999 Forwards Addl Info Requested in 990513 Ltr to Support Review of Pending Response to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power Operated Gate Valves. ML17292B7131999-06-29029 June 1999 Forwards Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. ML17292B7091999-06-21021 June 1999 Forwards Proprietary Response to NRC 990603 RAI Re Licensee Request for Amend to MCPR Safety Limit Tss.Proprietary Info Withheld IAW Requirements of 10CFR2.790 ML17292B7041999-06-17017 June 1999 Forwards NRC Forms 396 & 398 for Three Individuals Listed Below for Renewal of Operator Licenses.Without Encls ML17292B7031999-06-10010 June 1999 Forwards Response to NRC 990511 RAI Re License Request for Amend to Secondary Containment & SGTS Tss.Results of Addl Benchmark of Gothic Computer Code Performed to Demonstrate Modeling Capability of Drawdown Response,Encl ML17292B6841999-06-0404 June 1999 Forwards Response to NRC 990326 RAI Re WNP-2 GL 96-05 Program for Periodic Verification of design-basis Capability of MOVs ML17292B6851999-06-0101 June 1999 Forwards 1999 Quality Audit of WNP-2 Emergency Preparedness Program, Per NUREG-0654,Section Ii,Criteria P.9.Seven Problem Evaluation Requests & Nine Recommendations for Improvement Were Issued as Result of Audit Activities ML17292B6751999-05-25025 May 1999 Forwards Proprietary ABB-CE Ltr Re WNP-2 Cycle 15 SLMCPR & Core Reload Design Rept,Per Util Request for Amend Re MCPR Safety Limits.Proprietary Info Withheld,Per 10CFR2.790 ML17292B6831999-05-25025 May 1999 Informs That Request for NRC Approval of Changes to Emergency Plan Requesting Reduction in on-shift HP Staffing, Is Retracted.Util Will Resubmit Request with Required Addl Info at Later Date ML17292B6661999-05-0707 May 1999 Requests Exemption to Requirement in 10CFR55.59(a)(2) Re Annual Operating Test requirements.One-time Exemption from Requirement to Period Not to Exceed 15-months from Last Date of Passing Operating Exam for Licensee at Facility ML17292B6531999-05-0303 May 1999 Forwards Response to NRC 990402 RAI Re Licensed Operator Positive Drug Test.Encl Withheld,Per 10CFR2.790 ML17292B6561999-04-29029 April 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Safe End & Calculation Mod Record CMR-98-0243, Fracture Mechanics Evaluation of N1A Nozzle Safe End, as Suppl Info to ISI Exam ML17292B6421999-04-19019 April 1999 Responds to NRC 990319 Ltr Re Violations Noted in Insp Rept 50-397/99-01.Corrective Actions:Provisions Are Presently in Place to Maintain Adequate Level of Security GO2-99-073, Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.7901999-04-19019 April 1999 Forwards Rev 39 to WNP-2 Physical Security Plan,Per 10CFR50.54(p).Changes Do Not Decrease Effectiveness of Approved Plan.Encl Withheld IAW 10CFR73.21 & 10CFR2.790 ML17292B6401999-04-13013 April 1999 Requests That WNP-2 Operator Requalification Program Be Granted one-time Extension Beyond Requirement in 10CFR55.59(a)(2) for Annual Operating Tests ML17292B6371999-04-12012 April 1999 Forwards Response to NRC 990211 RAI Re Util Request for Amend to Secondary Containment & SBGTS TS ML17292B6281999-04-0606 April 1999 Informs NRC That Insp Interval Ending Date for ISI Program Plan Has Been Extended by One Year to Dec 12,2005 Due to Changes in Plant Refueling Outage Schedule GO2-99-060, Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1)1999-03-26026 March 1999 Submits Rept of Status of WNP-2 Decommissioning Fund as of 981231,IAW 10CFR50.75(f)(1) ML17292B6131999-03-24024 March 1999 Forwards Rev 0 to Calculation ME-02-98-04, Fracture Mechanics Evaluation of N1 Nozzle Safe End. Info Will Be Used to Assist NRC in Review of WNP-2 ISI Activities Associated with Evaluation of Planar Indication ML17292B5991999-03-16016 March 1999 Informs That Listed Property & Liability Insurance Coverage for WNP-2 Is in Force,In Compliance with Licensing Responsibilities Delineated in 10CFR50.54(w)(3) ML17292B5911999-03-16016 March 1999 Forwards 1998 Environ Operating Rept, Per Reporting Requirements of Section 5.4.1 of WNP-2 Epp.No Design or Operational Changes or Tests in 1998 Involved Unreviewed Environ Question ML17292B5941999-03-16016 March 1999 Forwards NRC Form 396, Certification of Medical Exam by Facility Licensee, & NRC Form 398, Personal Qualification Statement - Licensee, for MD Comstock,Mc Naulty & RR Nelson.Without Encls ML17292B6001999-03-16016 March 1999 Responds to Weakness Noted in Insp Rept 50-397/98-24. Corrective Actions:Developed Document to Identify Areas Needing Improvement,Assigned Responsibility for Actions & Provided Milestones for Achievement ML17292B5901999-03-11011 March 1999 Forwards Hard Copy of Addl Occupational Exposure Data Requested in GL 94-04,per 990303 e-mail.Original Electronic Version Was Corrupted ML17292B5681999-03-0101 March 1999 Forwards Radioactive Effluent Release Rept for 1998, IAW 10CFR50.36a(a)(2) & TS 5.6.3 & Complete Copy of WNP-2 ODCM Per TS 5.5.1 ML17292B5651999-02-22022 February 1999 Forwards Relief Request 2ISI-20,proposing Alternate Exam Expected to Reduce Dose Significantly & Still Provide Adequate Safety & Quality.Attached Relief Request Will Be Used to Support ALARA Dose Reduction Efforts During Maint ML17292B5581999-02-0404 February 1999 Requests Change to Co Which Modified WNP-2 OL to Reflect Schedule for Implementing Thermo-Lag 330-1 Fire Barrier C/As.Change Requested to Reflect That Final Implementation of C/As Will Be Completed During Fall 1999 Not Spring 1999 1999-09-09
[Table view] Category:UTILITY TO NRC
MONTHYEARML17286A2801990-08-27027 August 1990 Forwards fitness-for-duty Program Performance Data for 900103-0630,per 10CFR26.71(d) ML17286A2671990-08-23023 August 1990 Provides Info on Steps Taken to Minimize Potential Effects of NRC Maint Insp Interface Record, Form on Candor of Supply Sys Personnel When Talking W/Nrc Inspectors ML17286A2641990-08-20020 August 1990 Advises That Tech Spec Rev Re ATWS Recirculation Pump Trip Will Be Submitted by 900928,per Discussions W/ P Eng & H Lee ML17285B4341990-08-20020 August 1990 Withdraws 900302 Request for Amend to Tech Spec 3.8.1.1, AC Sources Reducing Excessive Testing of Diesel Generators. IR 05000397/19900141990-08-10010 August 1990 Provides Info Re Final Assessment of Causes & Corrective Actions Associated W/Recent 25 Kv iso-phase Bus Electrical Fault Incident,Per Request in Cover Ltr to Insp Rept 50-397/90-14.Plant Procedure 10.25.141 Will Be Revised ML17285B4171990-08-10010 August 1990 Provides Info Re Final Assessment of Causes & Corrective Actions Associated W/Recent 25 Kv iso-phase Bus Electrical Fault Incident,Per Request in Cover Ltr to Insp Rept 50-397/90-14.Plant Procedure 10.25.141 Will Be Revised ML17285B4041990-08-0202 August 1990 Submits Justification for Continued Operation W/Emergency Diesel Generator 2 Shorted Turns ML17285B3981990-07-30030 July 1990 Advises That Installation of Detector Check Valve in Fire Protection Underground Piping Sys Complete,Per 890911 Ltr. Sys Monitors for Underground Sys Leakage Over Entire Fire Protection Sys ML17285B3991990-07-27027 July 1990 Forwards Justification for Continued Operation Re Emergency Diesel Generator 2 Shorted Turns.Justification Concludes That Diesel Generator Capable of Supporting Present Operability Requirements of Tech Specs ML17285B3711990-07-12012 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. Confirms That Items 1,2,3,4 & 5 of Requested Actions of Operating Reactors Completed ML17285B3761990-07-12012 July 1990 Discusses Potential for Surface Entry & Mining Near Plant Sites.Concludes That NRC Need Not Consider Issue as One Requiring Continued Monitoring ML17285B3781990-07-11011 July 1990 Requests Waiver of Compliance from Tech Spec 3.8.1.2 Re Ac Sources - Shutdown.Waiver Will Allow Performance of Rotor Pole Ac Voltage Drop Test to Provide Confirmation That for Extended Run Degradation Condition Will Not Occur ML17285B3841990-07-10010 July 1990 Forwards Util 1990 Emergency Exercise Scenario.W/O Encl ML17285B3661990-07-0505 July 1990 Advises of Listed Organizational & Personnel Changes, Effective 900707.J Burn Will Be New Director of Projects, C Powers Promoted to Director of Engineering & J Baker Promoted to Plant Manager ML17285B3641990-06-29029 June 1990 Advises That All Equipment Identified W/Atws Safety Function Acceptable from Environ Qualification Standpoint. ATWS Equipment Has Been Determined to Be Qualified to Normal Design Environ Conditions Followed by ATWS Accident Environ ML17285B3571990-06-28028 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. ML20055D2391990-06-28028 June 1990 Forwards Response to Re Violations Noted in Insp Rept 50-397/90-12.Response Withheld (Ref 10CFR73.21) ML17285B3501990-06-22022 June 1990 Advises That Mods to Recirculation Pump Trip Sys Implemented During 1990 Spring Refueling Outage.Remaining ATWS Items to Be Resolved as Listed ML17285B3511990-06-20020 June 1990 Forwards WPPSS-FTS-129, BWR Transient Analysis Model, for Review & Approval ML17285B3441990-06-20020 June 1990 Advises That Util Intends to Utilize R-value of 0.13% Delta K/K in Cycle 6 Implementing Procedures.Should R-value Change in Final Startup & Operations Rept,Changed Value Shall Be Used Instead ML17285B3451990-06-19019 June 1990 Forwards Rev 10 to EPIP 13.1.1, Classifying Emergency. Rev Includes New Format of Matrix Charts Intended to Improve Identification of Symptomatic & situation-based Emergency Conditions ML17285B3431990-06-18018 June 1990 Advises of Appointment of AL Oxsen to Position of Deputy Managing Director,Effective 900601 ML17285B3461990-06-15015 June 1990 Responds to NRC Evaluation Findings of Licensed Operator Requalification Program.Quality of Written Exam & Job Performance Measure Question Bank Testing Matls Will Be Improved to Meet Std Prior to Next Program Evaluation Cycle ML17285B3301990-06-12012 June 1990 Forwards Warrant for $50,000 in Response to Order Imposing Civil Monetary Penalty Dtd 900521 ML17285B3251990-06-0707 June 1990 Advises That Calculated Max Control Room Temp Re Station Blackout Will Be Provided by 900701 ML17285B2931990-05-29029 May 1990 Responds to NRC 900426 Ltr Re Violations Noted in Insp Rept 50-397/90-09.Validity of Violation Challenged.Opposes Issuance of Severity Level IV Violation Based on Listed Reasons ML17285B2861990-05-22022 May 1990 Advises That Submittal of Improved Tech Spec Scheduled for Mar 1991 & Implementation Tenatively Scheduled for Oct 1991 ML17285B2881990-05-11011 May 1990 Forwards Engineering Std EES-4,Rev 0, Setpoint Methodology, as Committed in Util 900329 Ltr.W/O Encl ML17285B2471990-05-0101 May 1990 Advises That No Changes to Tech Specs Required as Stated in 891130 Ltr in Response to Generic Ltr 89-21 Requesting Plant Status on Implementation of USI Re ATWS ML17285B2741990-04-26026 April 1990 Advises That Util Has No Comments on Licensed Operator Annual Requalification Exam During Wks of 900226 & 0305.All Comments Resolved When Exams Administered ML17285B2321990-04-25025 April 1990 Submits Revised Scheduled Completion Dates for Commitments Made in Response to Violations Noted in Insp Repts 50-397/89-06 & 50-397/89-17 ML17285B2121990-04-19019 April 1990 Responds to Fire Protection Issues Identified in 900201 Notice of Violation.Corrective Actions:Major Hardware Changes Implemented & Independent Consultant Will Be Employed to Review Fire Protection Program ML17285B2221990-04-16016 April 1990 Forwards Status Rept for Commitments Made in 891130 Ltr Re commercial-grade Dedication Process.Resolution of 10 Samples Identified by NRC & 50 Samples Identified by Cynga Completed ML17285B1881990-04-11011 April 1990 Responds to NRC 900312 Ltr Re Violations Noted in Insp Rept 50-397/90-01.Corrective Actions:Complete Job & Task Analysis Completed for Health Physics Technician Training Program & New Program Will Include Training on Fundamentals ML17285B1821990-04-0505 April 1990 Requests Exemption from Filing Requirements of 10CFR55.45(b)(2)(iii) & (IV) to Allow Delayed Submittal of NRC Form-474, Simulation Facility Certification & to Administer Simulation Test as Upgraded,Respectively ML17285B1741990-04-0505 April 1990 Advises That NRC Approved Use of Final Feedwater Temp Reduction in Amend 77 to License NPF-21 ML20012F6141990-04-0404 April 1990 Forwards Rev 17 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML17285B2041990-03-29029 March 1990 Requests Review of Encl Topical Rept WPPSS-FTS-127,Rev 0, Qualification of Core Physics Methods for BWR Design & Analysis. Upon Rept Approval,Tech Spec Changes (Per Generic Ltr 88-16) Scheduled for Jan 1992 ML17285B1421990-03-29029 March 1990 Forwards Revised Schedule for Plant Equipment Setpoint Methodology Program Plan.Methodology Revised to Incorporate Latest ISA Std Draft.Setpoint Program Design Team for FY90 Onsite,Trained & Began Work on 900312 ML17285B1381990-03-29029 March 1990 Forwards Concluding Rept of Results Requested by Generic Ltr 88-14, Instrument Air Supply Sys Problems Affecting Safety- Related Equipment. Air Quality Testing Performed to Date Reveals Steadily Improving Results ML17285B1131990-03-28028 March 1990 Advises of Release of Subchannel Thermal Hydraulic Computer Code & Requests Review of VIPRE-01 Mod-02 & Issuance of SER for PWR & BWR Applications.Bwr Qualification Analyses Completed & Rept on BWR Applications Encl ML17285B1331990-03-23023 March 1990 Responds to NRC 900221 Ltr Re Violations Noted in Insp Rept 50-397/89-40.Corrective Actions:Plant Procedure 10.25.63, Emergency Lighting Insp in Process of Being Expanded to Provide Instructions & Check Sheets to Ensure Uniform Insps ML17285B1311990-03-21021 March 1990 Forwards Proposed Bases Change Re 891129 Request for Amend to Tech Spec Table 4.3.6.1, Srm/Irm Detector Not-Full-In Functional Test. Bases Change Describes Special Circumstances Re Test Exception ML17285B1291990-03-19019 March 1990 Responds to Generic Ltr 89-19 Re Resolution of USI A-47 on Safety Implications of Control Sys in LWRs & Generic Ltr 89-21 Re Status of Implementation of Usis.Tech Specs Adequate to Verify Operability of Overfill Protection Sys ML17285B1171990-03-19019 March 1990 Suppls 900102 Response Re Implementation of fitness-for-duty Program at Facility.All Items Identified as Incomplete as of 900103 Completed at End of Jan 1990 ML17285B1121990-03-15015 March 1990 Provides Level of Property & Liability Insurance Coverage for Facility,Per 10CFR50.54(w)(2) Annual Requirement ML17285B0931990-03-0202 March 1990 Forwards Supplementary Info Re 900214 Application for Amend to License NPF-21,revising Tech Spec 3.3.7.5 to Address Failed Safety/Relief Valve Position Indicators ML17285B0741990-03-0202 March 1990 Responds to NRC 900201 Ltr Re Violations Noted in Insp Rept 50-397/89-30.Corrective Action:Plant Personnel Currently in Process of Making Improvements to Plant Operations Procedure Writers Guide ML17285B0861990-03-0101 March 1990 Forwards Compilation of Responses to Regulatory Impact Survey Questionnaire,Per Generic Ltr 90-01 ML17285B0581990-02-26026 February 1990 Forwards Washington Nuclear Plant-2 Semiannual Radioactive Effluent Release Rept,Jul-Dec 1989 & Amend 7 to Odcm. 1990-08-27
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ACCESSION NBR:8811030365 DOC.DATE: 88/10/13 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME - AUTHOR AFFILIATION SORENSEN,G.C. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION JOHNSON,A.D. Region 5, Ofc of the Director
SUBJECT:
Provides addi info necessary to close equipment qualification issues.
DISTRIBUTION CODE: A048D COPIES RECEIVED:LTR ~ ENCL / SIZE:
TITLE: OR/Licensing Submittal: Equipment Qualification NOTES:
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 0 PD5 PD 1 . 0 SAMWORTHiR 1 1 INTERNAL: ACRS 6 6 ARM/OAF/LFMB 1 0 NRR/DEST/ADE 8H 1 0 NRR/DEST/MEB 9H 1 1 NRR/DEST/SGB 8D 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 RES/DSIR/EIB 1
1 1
1 E 4 1 1 EXTERNAL: LPDR NRC PDR 1 1 NSIC TOTAL NUMBER OF COPIES REQUIRED: LTTR 20 ENCL 16
ti WASHINGTON PUBLIC POWER SUPPLY SYSTEM " .-',,
P.o. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 October 13, 1988 G02-88"215 Docket No. 50-397 Mr . A.D. Johnson, Enforcement Officer U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596
Dear Mr. Johnson:
Subject:
NUCLEAR PLANT NO. 2 ADDITIONAL INFORMATION EQUIPMENT QUALIFICATION The attached provides a written summary of our position on the issues which were discussed during your site inspection. Because of the complexity of the issues, this written summary should help to clarify our position and prevent misunderstanding.
We trust that this will provide the information necessary to close these equip-ment qualification issues.
Should you have any further questions, please contact Mr. J.E. Rhoads at (509) 377-8548.
Very truly yours, G. C. Sorensen, Manager Regulatory Programs GCS/bk cc: NRC Document Control Desk RB Samworth - NRC DL Williams - BPA, 399 NS Reynolds - BCP8R o<<
881i030365 88iOi305000397 PDR ADOCK
ATTACHMENT 1 Page 1 of 7 Potential Enforcement/Unresolved Item 1.
Cont ary to paragraphs (f) and (k) of 10 CFR 50.49 and section 5.0 of NUREG-0588 Category II, at the time of the inspection, Washington Public Power Supply System's installation of three Rosemount 1151 transmitters was not qualified because spare cable entrance hubs were not sealed.
Su 1 S stem Res onse To Unresolved Item 1.
The above unresolved item was directed at three transmitters, MS-PT-518, CMS-LT-1 and CIA-PT-21A. All three transmitters perform only a Regulatory Guide 1.97 post accident monitoring safety function. The WNP-2 Operating License, at Attachment 2, Item 3 (a) requires:
The licensee shall implement (installation or upgrade) requirements of R.G.
1.97 Rev. 2 with the exception of flux monitoring prior to startup following the first refueling outage.
In March of 1985, the Supply System identified the list of equipment affected by the above license condition in our correspondence G02-85-152, dated March 21, 1985, G.C. Sor ensen to A. Schwencer. The above equipment is listed in attachment 1 to that letter.
At the time of the inspection, the Supply System was performing its first refueling outage. The particular transmitters cited by the inspectors are Reg. Guide 1.97 instruments whose only safety function is to follow the course of an accident and thus were required to be qualified after the outage. The equipment was not required to be qualified at the time of the inspection.
Therefor e the November 30, 1985 deadline date is not applicable to the cited instruments. The date that qualification was required for the above instruments was prior to restart following the first refueling outage (July 1986). We stated to the. auditors that they had 'selected a Reg. Guide 1.97 (CMS-LT-1) instrument for their audit and suggested that an alternate Rosemount transmitter candidate be chosen. These instruments could have been removed from the Master Equipment gualification list prior to the 1986 audit and then placed back on prior to restart from the refueling outage. This information was previously provided to the NRC at the 1986 audit.
In addition, we provided information at the time of the audit and later in correspondence that clearly showed that the insertion of silicone foam into the entry hub of the transmitters sealed the transmitters and negated the need for any type of plug. Thus at the time of the inspection in 1986 the installed units were in a qualified configuration even though our license requirement did not call for qualification completion until restart following the first refuel-ing outage (July 1986). We also attempted to show that the need for the steel plug, as called out in the vendor instructions and in the NRC's 1983 inspection findings, was primarily intended for applications that would experience the direct effects of a LOCA inside primary containment. The WNP-2 plant has no Rosemount transmitters inside primary containment. There are transmitters located in the secondary containment where the only steam break accidents stem from RCIC, RWCU, and Auxiliary Steam lines which have quick acting isolation features and thus produce only short term, moderate steam temperature and low pressure accident conditions.
Page 2 of 7 Because the issue had not been resolved at the audit and was cited as a potential enforcement issue at the exit interview the Supply System elected to install steel plugs in the above instruments. Maintenance Work Request No. AU 535 documents completion of the installation of steel plugs including gC veri-fication by May 19, 1986.
For all of the above reasons, the escalated enforcement provisions are not applicable. Please note that the Supply System has consistently disagreed with the NRC's findings on this issue and such disagreement is documented in our September 17, 1986 (G02-86-885) letter and in our January 20, 1988 (G02-88-023) letter which responded to the NRC's Inspection No. 50-397/86-12 report and the NRC's Notice of Violation respectively.
POTENTIAL ENFORCEMENT/UNRESOLVED ITEM 2 Contrary to paragraphs (f) and (k) of 10 CFR 50.49 and section 5.0 of NUREG-0588 Category II, at the time of the inspection, 'HPPSS's files did not adequately document qualification of Limitorque operators because var ious internal parts and materials and installation features had not been identified and documented to be qualified. (Paragraph 4.D.'2), Item 50-397/86-12-2).
SUPPLY SYSTEM'S RESPONSE TO UNRESOLVED ITEM 2 The "various internal parts, materials, and installation features" identified in the 1986 audit consist of a mixture of those that may have an impact on qualification and those that are discretionary maintenance practice. The particular issues identified in the supplemental inspection of Oct. 6/7, 1988 are:
A. "T" drains not installed in several units.
B. Gear grease not sampled in two units and not identified in four units.
C. Relief valves on the gear box had a shipping cover still in place. Note that the NRC did not cite this in their 1986 audit report but did state that the Supply System's NCR had identified that this condition existed.
Of these only the "T" drain issue is germane to qualification. Other concerns raised in the 1986 audit were addressed and resolved by the supplemental inspection of Oct 6/7, 1988 and will not be addressed here.
Page 3 of 7 MOTOR HOUSING "T'RAINS Limitorque calls for "T" drains to be installed on motors of in-containment operators to insure pressure equalization and moisture drainage during LOCA exposure.
The Supply System documented that a deficiency existed through the NCR process (RHR-MO-9 was cited) prior to the 1986 audit. This NCR noted that the installed condition did not match the configuration of the tested operator used to establish qualification for WNP-2 in-containment operators (Rptt 600376A).
This information was provided to the NRC at the entr ance meeting "T" of the audit.
The Supply System contends that even if the concern about drains is regarded as a violation, a notice of violation should not be issued under the self-identification and correction provisions of 10 CFR 2, Appendix C, Section IV.
The Supply System did not know that this condition existed at WNP-2. We believed that "T" drains had been installed where required. The information provided in NRC notices about missing drain plugs in operators ( IEN-83-2) was not specific to motors. The condition was also focused on a specific plant.
Information received from Limitorque indicated that this was a unique condition and did not recon+end any cor rective action be taken as a result of the IEN. A later condition found at another plant also appeared to be plant specific.
The NRC had specifi.cally audited our Limitorque qualification file and conducted plant walkdowns in February 1983 and found that installation and documentation was acceptable for all in-containment actuators including RHR-MO-9 (See NUREG 0892 Appendix C, page 3C-384). The NRC had issued the IEN in October 1983 and our SER indicating acceptable operators two months later in December 1983. The above IEN was formally reviewed and dispositioned in accordance with procedures in July 1985. The issue of motor "T" drains was specifically addressed and"T" the disposition based on the judgement that the operators which required drains included the hardware and instructions to require their installation. The "T" drains and installation instructions were shipped within the limit switch compartment. Limitorque did provide informa-tion in their 800058 qualification report section 8.0 that called for their installation in accordance with information provided on a Limitorque supplied tag on the operator. They did not state that the operators would not be quali-fied without them. It was reasonable given the above history to conclude on November 30, 1985 that "T" drains were installed in the Limitorque operators in-containment.
Page 4 of 7 Wher, IEN-86-03 was issued in January 1986, the Integrated Limitorque Oualifica-tion Program (ILOP) inspection plan was established because we began to doubt our earl i er belief that Limi torque conf i gurati on problems were isolated concerns. This program was structured around detailed walkdown confirmation of the configuration of each operator.
This specific issue ("T" drains) was incorporated into the WNP-2 ILOP because we deemed it good practice to affirm our earlier assumptions (i.e. because instructions to install "T" drains were supplied with the operator, and there were no adverse NRC audit findings in February 1983). Our ILQP program uncovered the fact that contrary to our previous judgement (i.e. "T" drains were installed where required) some operators had them and some did not. Of the 8 operators in-containment 2 were correctly configured. Note that "T" drains are not required for Secondary Containment application because Limitorque conducted qualification tests without "T" drains for outside containment applications (Rpt 0 .B0003). We found in our ILgP inspection that complete implementation as we had assumed did not occur.
Notwithstanding the test sample configuration versus as installed configura-tion issue, the "T" drains have not been shown to be critical to proper opera-tion of the'perater when subjected to high temperature steam exposure. There have been at least three steam tests where the drain ports were plugged and no "T" drain installed in the tested operator.
Limitorque test report B0003 exposed a Limitorque operator to 250 degrees satur ated steam for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by an additional 14 days at 200 degrees successfully. The Limitorque operator did not have "T" drains in the motor housing. Likewise test reports 600198 and F-3271 were performed without "T" drains as part of the test sample configuration. In test 600198 the exposure included boric acid spray and temperatures of near 300 degrees were reached for several hours. The motor was still operable 7 days later with average steam temperature maintained around 230 degrees throughout. The F-C3271 test was lower in temperature (210 degrees) and time (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />), but still affirms the ability of the motor to operate in a steam"T"environment without "T" drains. We submit that the above demonstrates that drains in Limitorque operators are not critical to operation in long term steam exposure conditions. We do not contend the configuration issue, but judge that it is a minor E(} concern. We are not aware of a failure of a motor operator to operate correctly in a quali-fication program because the motor housing "T" drains were not installed.
Page 5 of 7 Our position is that we acted in good faith with reasonable and prudent effort to insure the configuration was correct prior to November 30, 1985. In addi-tion, when configuration problems became known to us (i.e. IEN-86-03IEN-86-03 January 1986), we acted promptly to address not only the specific issue of (unqualified internal wire) but included a thorough effort to deal with every known configuration issue or maintenance issue and to recheck previous conclu-sions to affirm their accuracy. Finally, we identified these problems to the NRC prior to conduct of their 1986 audit and took prompt action to correct all deficiencies found in the plant whether qualification or maintenance related, prior to restart from the refueling outage underway at the time.
LUBRICATION GREASE ISSUE The lubrication issue stems from the identification in the NCR that incorrect lubricant type was discovered in the geared limit switch of the operator. The NRC inspection report generalized this and the details contained in the IL()P inspection data as "Gear grease not sampled in two or more units" and "not identified in four units" as a deficiency. The Supply System disagrees that this is a (}ualification deficiency. The basis for the concern stems from an IEN-79-03 notice that describes a condition of hardening at a specific plant where continuous operation above 140 degrees F occurred. In May of 1979 Limitorque was contacted and responded by letter that the Beacon 325 grease that was described in the IEN was picked "to add safety factor to the design" and that its temperature range was from -65 to 250 degrees F. The letter also stated that the maintenance manual did not indicate that the grease is permanent and that periodic inspection was recommended as a means to determine when replacement was warranted. They also stated tHat "A temperature rating of 150 degrees F continuous operating ambient was placed on the Beacon 325 lubr icant, in order to achieve a maximum lubricant life for the device." In July 1978, 6 months earlier, the Supply System received an information letter'from General Electric describing the hardening condition in environments above 140 degrees F and recommended a Mobil 28 which GE stated was "accepted by Limitor que as a replacement for Beacon 325".."and meets the same qualification parameters as Beacon 325".
No where, to our knowledge has the Beacon 325 grease been deemed "not quali-fied" for in-containment service. The lubrication manual supplied by Limitorque states that the geared limit switch should be lubricated with Beacon 325 and that Mobil 28 is an acceptable substitute. Limitorque lubrication data form LC8 recommends an inspection of the Geared limit switch every 36 months unless operating experience shows that a differ ent interval is warranted. It also describes the Beacon 325 as a light gray in color.
Page 6 of 7 The MNP-2 containment has not had a continuous service period above 150 degrees F. Average levels are nearer 130 degrees or below. During the ILOP inspection, samples of the grease were taken initially. They were reported to be gray in color and that no hardening as described in the IEN had occurred. Even though the 36 month period had not elapsed and the Beacon 325 grease was acceptable, the Supply System elected to replace the geared limit switch grease with the recommended Mobil 28. It was also decided, that after taking the .first few samples in the hottest plant location (i n-containment) and finding no problems, that continued sampling or analysis of the samples was meaningless. It was prudent maintenance practice to simply change out all in-containment geared limit switch grease with the Mobil 28 currently favored by Limitorque. Positive identification that the gray grease was Beacon 325 was not performed. Me however, did not have any reason to believe that the grease found was anything other than that originally provided by Limitorque and treated this as a normal maintenance activity.
The reference in the NCR to incorrect grease was based on it not being the favored Mobil 28 which is reddish in color.
To summarize, the frequency of grease change out is based on surveillance and the initial frequency of 18 months for the main gear box and 36 months for the geared limit switch is recommended. The surveillance period may be adjusted (shortened or lengthened) depending on the surveillance results. The conditions cited in the the 1986 NCR and 1986 Audit report are not a qualification issue and should not be considered as part of various internal parts and materials that had not been identified and documented to be qualified.
GREASE RELIEF SHIPPING CAP LEFT IN PLACE ISSUE The 1986 NCR that identified potential problems with the configuration of RHR-MO-9 also identified a new potential concern. The relief valve that was installed on the main gear box had a "plastic shipping cap installed". This cap as found inside containment at NNP-2 was a PVC shrink tube type cap. There is another type cap that was found in the warehouse that was a pop-in type, red in color. This latter cap, supplied by the relief valve manufacture, is installed in the relief valve when shipped to Limitorque.
The type cap found on RHR-MO-9 was the PVC shrink tube type. Limitorque replaces the pop-in type with a shrink tube type. The purpose of these caps is not only for shipping but to insure that during final painting at Limitorque no fouling of the relief valve occurs. The cap is not readily distinguishable because it is painted the same color as the operator. In addition, one of the final activities in completing construction of a nuclear plant containment is a final cleaning and coating program to reduce the contamination potential of equipment and structural surfaces. This cap also serves to prevent fouling of the relief valve during this final coating program.
Page 7 of 7 No specific instructions are provided by Limitorque to require removal of this cap prior to operation. In fact, this cap is not identified on any detail drawings supplied by Limitorque. It is not addressed in maintenance manuals, qualification documentation, or in instructions packed with the operator (as was the case with the "T" drains).
Subsequent to our identification of this concern to the NRC, preceding the 1986 audit, other utilities have been cited for inadequate qualification documenta-tion concerning this item. In other words, the Supply System was the first to discover and disclose this concern to the NRC, Limitorque, and the industry.
Prior to November 30, 1985 we did not know of this concern nor should we have known.
I Our corrective action was to remove the caps. He judged that the likelihood of these plastic caps causing delayed relief valve actuation and over pressuriza-tion (should an over pressure condition occur due to the high temperature occurring during a LOCA) to be remote. This is because the plastic would become soft at high temperatures and its ability to prevent relief valve actua-tion reduced. The cap may possibly impair relief valve actuation at low temperatures where it is hard and has a greater tensile str ength, but no relief valve actuation would be needed at that level. Even at normal ambient levels the ability to allow a pressure build up through some unknown cause is small.
For the above reasons we contend that modified enforcement action in not warranted for this condition.
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