ML20126A287

Confirms Findings of V Thomas 850528 Telcon Re Close Out of IE Bulletin 79-25.Completion of Replacement of Remaining Original Affected Relays Per IE Bulletin 82-63 Not Reported by Util or Region III

ML20126A287
Person / Time
Site:	Point Beach
Issue date:	05/30/1985
From:	Foley W PARAMETER, INC.
To:	Baer R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
CON-NRC-05-82-249, CON-NRC-5-82-249 IEB-79-25, IEB-82-4, IEB-82-63, NUDOCS 8506130296
Download: ML20126A287 (2)

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Mechanical Design and Analysis 13300 WATERTOWN PLANK ROAD, ELM OROVE, WISCONSIN 53122 4i4-786 7580 May 30, 1985 Mr. Robert L. Baer, Branch Chief Engineering & Generic Communications Branch

-Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Copy: R. E. Shewmaker V. D. Thomas

Reference:

NRC Contract No. 05-82-249 PAR: NRC/IE-82/83, Task 66

Subject:

Closeout of IE Bulletin 79-25 Gentlemen:

The purpose of this letter is to confirm the findings of the telephone call of May 28 from Vince Thomas to Walter Foley and Alan Hennick.

Finding No. 1 is that we were correct in calling the bulletin open for Point Beach 1 & 2, because neither WEPC0 nor Region III has reported completion of replacement of the remaining original affected relays scheduled by the Fall of 1981.

Finding No. 2 is that Region III was premature in closing out the bulletin per Inspection Report No. 80-17 dated December 4, 1980, because completion of the replacement program was scheduled for about a year later. In addition, we agree with Vince that the inspection report was not specific in its treatment of IEB 79-25, because 13 bulletins were followed up in -

one paragraph.

FindingENo. 3 is that two page references given on Page C-3 are incorrect. Pages "A-14" and A-18" should be "A-16" and "A-20",

respectively. ~We should have made these changes when we added Attachment A of IEB 76-05 to Appendix A in our submittal of March 5, 1985.

Finding No. 4 is that the sticking problem described in IEB 79-25 is not the same as the problem described in IEIN 82-02.

The final sentence of the second paragraph on Page C-3 would be more precise if the words "similar to that" were added and "the" were changed to "a" in one place, as follows:

" Review of the LER n ted therein indicates that these failures were caused by a sticking problem similar to that described in IEB 79-25." '

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coNsutHNG - EMotNEEns May 30, 1985 E un o n o vE, wisconsin Mr.' Robert L. Baer U.S. Nuclear Regulatory Commission sBecause of'the. apparent misunderstanding' described in Findina No. 2, I decided to review IE-Procedure No. 92703 issued 10-1-80.

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to specify inspection followup requirements. It appears to me that~.the following procedures on Page II-2 could be interpreted

-incorrectly to imply that scheduling of corrective action.

isuffices for bulletin closeout:

.f) " Corrective action taken by the licensee was as

described in the written response."

c) "For circulars:or Bulletins applicable to the facility.

appropriate corrective actions have been taken or are scheduled to be taken."

+ ;To the best of our knowledge, a temporary instruction (TI) has not been issued for IEB 79-25. Referring to Page A-10 of NUREG/CR-3795 on' closeout of IEB_82-04,-note that we included the applicable TI in that report. Alan Hennick has instructions

'to sear'ch for applicable tis on the new bulletins and for a possible later issue of procedure No. 92703. As a further

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. thought, it occurs to me that referencing applicable tis in-new

. task orders for bulletin closeout would be helpful.

In addition to-confirming the findings which we discussed with Vince on May 28, we have pointed out for your consideration that IE Procedure No. 92703 possibly could be misinterpreted by a regional' inspector. Going through this exercise in documentation has been helpful ~in keeping us reminded that technical statements must be~ worded-very carefully.and that painful review to detect even small editing errors is necessary.

.To. sum up, we agree with Vince.

Very truly yours, PARAMETER, Inc.

b f.

Walter J. Foley .

WJF mak Copy: RA.Lofy

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