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Category:INTERNAL OR EXTERNAL MEMORANDUM
MONTHYEARML20205B6111999-03-26026 March 1999 Notification of 990419 Meeting with Util in Rockville,Md to Discuss Licensing Issues at Plant,Including Racking of Cask Pit for Storage of Spent Fuel ML20153F8291998-09-23023 September 1998 Forwards NRC Approved Operator Licensing Exam Facility Outline & Initial Exam Submittal & as-given Operating Exam for Tests Administered During Wk of 980803 ML20153F7981998-09-23023 September 1998 Forwards NRC Operator Licensing Exam Rept 50-346/98-301OL, (Including Completed & Graded Tests) for Tests Administered on 980803-07 ML20236F3581998-06-26026 June 1998 Forwards NRC Insp Mc 0350, Staff Guidelines for Restart Approval, for Oversight Activities for Davis Besse Station ML20236N8641998-06-11011 June 1998 Discusses TS Interpretation on Application of Davis Besse TS 3.6.5.1 & 3.6.5.2.TB Branch Recommends That Davis Besse Consider Converting TS to Improved Standard TS ML20216F3291998-04-13013 April 1998 Accepts 980406 Licensee Request for Approval to Install machine-welded SG Tube Plugs in Accordance W/Provisions of Paragraph IWB-4230, Tube or Tubesheet Hole Plugging by Fusion Welding, of Section XI ML20202E6241997-11-26026 November 1997 Notification of 971215 Meeting W/Util in Rockville,Md to Discuss Quality Assurance Program at Davis-Besse ML20211Q4711997-10-16016 October 1997 Notification of 971113 Meeting W/Toledo Edison Co in Rockville,Md to Discuss Ultimate Heat Sink at Davis-Besse ML20211C5091997-09-23023 September 1997 Forwards NRC Operator Licensing Exam Rept 50-346/97-308OL (Including as-given Writtem Exam) for Tests Administered on 970707-10 ML20211B5561997-09-23023 September 1997 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 970707-11 ML20149E7411997-07-16016 July 1997 Notification of 970821 Meeting W/Util in Rockville,Md to Discuss Instrument Drift Study ML20137U2051997-04-14014 April 1997 Informs That Davis-Besse Nuclear Power Station Nuclear Assurance Dept Will Be Reorganized Into Two Separate Dept; DB Nuclear Assurance & DB Nuclear Support Svc,Effective, 970414 ML20136F9491997-03-13013 March 1997 Notification of 970403 Meeting W/Util in Rockville,Md to Discuss Progress on Thermo-Lag Issue Resolution ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20134P9011996-11-26026 November 1996 Notification of 961204 Meeting W/Clei & Teco in Rockville,Md to Discuss Potential Submittals Concerning Proposed Merger of Centerior Energy Co & Oec ML20149E8161994-08-0202 August 1994 Forwards Fr Notice of License Amend Requests Proposed Merger of Toledo Edison Co & Cleveland Electric Illumianting Co Antitrust Determination ML20059H8361994-01-19019 January 1994 Notification of 940201 Meeting W/Util in Rockville,Md to Discuss Pending Davis-Besse Licensing Actions ML20057F1311993-10-0707 October 1993 Notification of 931020 Meeting W/Util in Rockville,Md to Discuss Davis-Besse Implementation of Reg Guide 1.97 for Steam Generator Pressure Instruments ML20127N6121993-01-25025 January 1993 Notification of 920205 Meeting W/Util in Rockville,Md to Discuss Emergency Action Levels Proposed Rev,Submitted 930112 ML20127C0411993-01-0808 January 1993 Notification of 930112 Meeting W/B&W Owners Group in Clearwater Beach,Fl to Discuss Generic Program Plan for License Renewal Initiative ML20127F5461993-01-0707 January 1993 Notification of 930115 Meeting W/Util in Rockville,Md to Discuss Plant Containment Penetration Bellows Tests.Draft Agenda Encl ML20126F5541992-12-0808 December 1992 Notification of 921215 Meeting W/Util in Rockville,Md to Discuss Proposed License Amend to Change from Automatic to Manual Closure of Containment Purge & Exhaust Valves in Mode 6 ML20128C2071992-11-0606 November 1992 Notification of 921202 Meeting W/Util in Rockville,Md to Discuss Upcoming Refueling Outage Plans & Recent Plant Performance ML20127C4131992-07-24024 July 1992 Responds to 910322 Memo Requesting Assistance on Whether 10CFR50.59 Review Should Have Been Performed for Broken Pipe in Station Drainage & Discharge Sys Releasing low-level Radioactivity Onsite ML20059D2711990-08-0606 August 1990 Discusses Review of State of Oh & Local Radiological Emergency Response Plans.Determined That No Issues Identified During 890809-09 Exercise to Prevent Finding of Reasonable Assurance for Site ML20148T1891990-04-10010 April 1990 Responds to Request for Info Re Congressional Inquiries on Tracking & Closeout of Issues Raised Re Incident Investigation Team (IIT) Investigations of Plants.Actions Assigned by EDO in Response to Plant IITs Addressed ML20246N8091989-08-30030 August 1989 Notification of 890907 Meeting W/Util in Rockville,Md to Discuss Exemption from App R to 10CFR50 for Specific Configuration of Pressurizer Instrumentation ML20244A4611989-06-0606 June 1989 Notification of 890615 Meeting W/Util & Westinghouse Owners Group in Rockville,Md to Discuss Reactor Vessel Support Embrittlement ML20247B9481989-03-23023 March 1989 Notification of 890404 Meeting W/Util in Rockville,Md to Discuss Applicability of Test of Bunker Ramo Penetrations for Meeting Environ Qualification Requirements at Facility ML20195G8751988-11-25025 November 1988 Forwards Signed,Original Order Modifying License Issued to Util on 881121 for Transmittal to Fr for Publication.W/O Encl ML20206A1171988-11-0808 November 1988 Notification of 881117 Meeting W/Util in Rockville,Md to Discuss Proposed Fuel Enrichment Change Application ML20151U1241988-08-11011 August 1988 Forwards Fr Notice Extending Time for Comments on Request of Cleveland Electric Illuminating Co & Toledo Edison Co to Suspend Plant Antitrust License Conditions ML20151T3371988-08-0909 August 1988 Notification of 880817 Meeting W/Util in Rockville,Md to Discuss SER on ATWS Issued by Staff to Utils ML20151E1981988-07-14014 July 1988 Notification of 880721 Meeting W/Util in Rockville,Md to Discuss Licensee Response to Questions on Fire Protection Program ML20150E8851988-07-0707 July 1988 Notification of 880725 Meeting W/Util in Rockville,Md to Discuss Status of Refuel Outage & Configuration of Mgt Sys ML20151L9961988-06-16016 June 1988 Discusses Engineering Insp DRP-07 Re Safety Sys Outage Mod Involving Auxiliary Feedwater Sys.Insp Identified Several Instances of Inadequate Engineering Review.Addl Insp of Engineering Design Review Requested in Jul-Aug ML20195E5431988-06-10010 June 1988 Submits Status Summary Rept on Multi-Plant Action B-66, Natural Circulation Cooldown. Near-term OLs Should Not Be Added to Safety Issues Mgt Sys Listing for Subj Action ML20154R8651988-06-0808 June 1988 Requests That Encl Slides from 860627 Presentation to ACRS Re Maint Review at Facility Be Placed in PDR ML20148T0851988-06-0303 June 1988 Discusses Multiplant Action F-58,Items II.K.3.30 & II.K.3.31 Compliance w/10CFR50.46 ML20151N8041988-04-18018 April 1988 Notification of 880428 Meeting W/Util in Oak Harbor,Oh Re Technical Discussions Concerning Plant Control Ctr ML20151B7141988-04-0606 April 1988 Comments on Cj Papariello 880323 Memo Re Insp of Allegations at Plants.Significance of Allegations Low & Do Not Warrant Immediate Review & Closure ML20148E3191988-03-18018 March 1988 Notification of 880330 Meeting W/Util in Oak Harbor,Oh to Discuss SALP 6 Rept ML20150B9671988-03-11011 March 1988 Requests That Encl 870911 Memo from J Scinto Be Included in Docket Files.Memo Relates to 870122 Application for Amend to License NPF-3 Re Organization Changes ML20155K2001988-03-0909 March 1988 Discusses Topics for Senior Mgt Meeting & Submits Partial Listing of Facilities Where Vendor Support Has Been Problem,Vendor Involved & Component/Issue of Interest. W/Copyrighted Matl IA-88-165, Discusses Topics for Senior Mgt Meeting & Submits Partial Listing of Facilities Where Vendor Support Has Been Problem,Vendor Involved & Component/Issue of Interest. W/Copyrighted Matl1988-03-0909 March 1988 Discusses Topics for Senior Mgt Meeting & Submits Partial Listing of Facilities Where Vendor Support Has Been Problem,Vendor Involved & Component/Issue of Interest. W/Copyrighted Matl ML20236U6471987-11-27027 November 1987 Forwards Safety Evaluation Re Assessment of Errors in Util Analysis for Small Break Loca,Per 860718 Request.Incorrect Values Used in Analysis Result in Incomplete Compliance W/ 10CFR50,App K.Performance Requirements of 10CFR50.46 Met ML20153E9181987-11-16016 November 1987 Forwards Oct 1987 Significant Intergovernmental Activities & Issues Rept.Rept Represents Combined Efforts of NRC Regional State Liaison Officers,State,Local & Indian Tribes Programs Staff & Regional State Agreement Representatives ML20236A6081987-10-20020 October 1987 Notification of 871113 Meeting W/Util in Bethesda,Md to Discuss Util Reassessment of Programs,Priorities & Planned Fifth Refueling Outage Work Items ML20236A6171987-10-20020 October 1987 Notification of 871029 & 30 Meetings W/Util in Bethesda,Md to Discuss Facility Fire Protection Program ML20236A9711987-10-19019 October 1987 Forwards Biweekly Status Rept for 870926-1009 1999-03-26
[Table view] Category:MEMORANDUMS-CORRESPONDENCE
MONTHYEARML20205B6111999-03-26026 March 1999 Notification of 990419 Meeting with Util in Rockville,Md to Discuss Licensing Issues at Plant,Including Racking of Cask Pit for Storage of Spent Fuel ML20153F7981998-09-23023 September 1998 Forwards NRC Operator Licensing Exam Rept 50-346/98-301OL, (Including Completed & Graded Tests) for Tests Administered on 980803-07 ML20153F8291998-09-23023 September 1998 Forwards NRC Approved Operator Licensing Exam Facility Outline & Initial Exam Submittal & as-given Operating Exam for Tests Administered During Wk of 980803 ML20236F3581998-06-26026 June 1998 Forwards NRC Insp Mc 0350, Staff Guidelines for Restart Approval, for Oversight Activities for Davis Besse Station ML20236N8641998-06-11011 June 1998 Discusses TS Interpretation on Application of Davis Besse TS 3.6.5.1 & 3.6.5.2.TB Branch Recommends That Davis Besse Consider Converting TS to Improved Standard TS ML20216F3291998-04-13013 April 1998 Accepts 980406 Licensee Request for Approval to Install machine-welded SG Tube Plugs in Accordance W/Provisions of Paragraph IWB-4230, Tube or Tubesheet Hole Plugging by Fusion Welding, of Section XI ML20202E6241997-11-26026 November 1997 Notification of 971215 Meeting W/Util in Rockville,Md to Discuss Quality Assurance Program at Davis-Besse ML20211Q4711997-10-16016 October 1997 Notification of 971113 Meeting W/Toledo Edison Co in Rockville,Md to Discuss Ultimate Heat Sink at Davis-Besse ML20211C5091997-09-23023 September 1997 Forwards NRC Operator Licensing Exam Rept 50-346/97-308OL (Including as-given Writtem Exam) for Tests Administered on 970707-10 ML20211B5561997-09-23023 September 1997 Forwards NRC Approved Operator Licensing Exam (Facility Outline & Initial Exam Submittal & as-given Operating Exam) for Tests Administered on 970707-11 ML20149E7411997-07-16016 July 1997 Notification of 970821 Meeting W/Util in Rockville,Md to Discuss Instrument Drift Study ML20137U2051997-04-14014 April 1997 Informs That Davis-Besse Nuclear Power Station Nuclear Assurance Dept Will Be Reorganized Into Two Separate Dept; DB Nuclear Assurance & DB Nuclear Support Svc,Effective, 970414 ML20136F9491997-03-13013 March 1997 Notification of 970403 Meeting W/Util in Rockville,Md to Discuss Progress on Thermo-Lag Issue Resolution ML20138J7671997-02-0505 February 1997 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licenseing Exam on 970409. Ltr W/Copy to Chief,Operator Licensing Branch Must Be Submitted to Listed Address in Order to Register Personnel ML20134P9011996-11-26026 November 1996 Notification of 961204 Meeting W/Clei & Teco in Rockville,Md to Discuss Potential Submittals Concerning Proposed Merger of Centerior Energy Co & Oec ML20149E8161994-08-0202 August 1994 Forwards Fr Notice of License Amend Requests Proposed Merger of Toledo Edison Co & Cleveland Electric Illumianting Co Antitrust Determination ML20059H8361994-01-19019 January 1994 Notification of 940201 Meeting W/Util in Rockville,Md to Discuss Pending Davis-Besse Licensing Actions ML20057F1311993-10-0707 October 1993 Notification of 931020 Meeting W/Util in Rockville,Md to Discuss Davis-Besse Implementation of Reg Guide 1.97 for Steam Generator Pressure Instruments ML20127N6121993-01-25025 January 1993 Notification of 920205 Meeting W/Util in Rockville,Md to Discuss Emergency Action Levels Proposed Rev,Submitted 930112 ML20127C0411993-01-0808 January 1993 Notification of 930112 Meeting W/B&W Owners Group in Clearwater Beach,Fl to Discuss Generic Program Plan for License Renewal Initiative ML20127F5461993-01-0707 January 1993 Notification of 930115 Meeting W/Util in Rockville,Md to Discuss Plant Containment Penetration Bellows Tests.Draft Agenda Encl ML20126F5541992-12-0808 December 1992 Notification of 921215 Meeting W/Util in Rockville,Md to Discuss Proposed License Amend to Change from Automatic to Manual Closure of Containment Purge & Exhaust Valves in Mode 6 ML20128C2071992-11-0606 November 1992 Notification of 921202 Meeting W/Util in Rockville,Md to Discuss Upcoming Refueling Outage Plans & Recent Plant Performance ML20127C4131992-07-24024 July 1992 Responds to 910322 Memo Requesting Assistance on Whether 10CFR50.59 Review Should Have Been Performed for Broken Pipe in Station Drainage & Discharge Sys Releasing low-level Radioactivity Onsite ML20059D2711990-08-0606 August 1990 Discusses Review of State of Oh & Local Radiological Emergency Response Plans.Determined That No Issues Identified During 890809-09 Exercise to Prevent Finding of Reasonable Assurance for Site ML20148T1891990-04-10010 April 1990 Responds to Request for Info Re Congressional Inquiries on Tracking & Closeout of Issues Raised Re Incident Investigation Team (IIT) Investigations of Plants.Actions Assigned by EDO in Response to Plant IITs Addressed ML20246N8091989-08-30030 August 1989 Notification of 890907 Meeting W/Util in Rockville,Md to Discuss Exemption from App R to 10CFR50 for Specific Configuration of Pressurizer Instrumentation ML20244A4611989-06-0606 June 1989 Notification of 890615 Meeting W/Util & Westinghouse Owners Group in Rockville,Md to Discuss Reactor Vessel Support Embrittlement ML20247B9481989-03-23023 March 1989 Notification of 890404 Meeting W/Util in Rockville,Md to Discuss Applicability of Test of Bunker Ramo Penetrations for Meeting Environ Qualification Requirements at Facility ML20195G8751988-11-25025 November 1988 Forwards Signed,Original Order Modifying License Issued to Util on 881121 for Transmittal to Fr for Publication.W/O Encl ML20206A1171988-11-0808 November 1988 Notification of 881117 Meeting W/Util in Rockville,Md to Discuss Proposed Fuel Enrichment Change Application ML20151U1241988-08-11011 August 1988 Forwards Fr Notice Extending Time for Comments on Request of Cleveland Electric Illuminating Co & Toledo Edison Co to Suspend Plant Antitrust License Conditions ML20151T3371988-08-0909 August 1988 Notification of 880817 Meeting W/Util in Rockville,Md to Discuss SER on ATWS Issued by Staff to Utils ML20151E1981988-07-14014 July 1988 Notification of 880721 Meeting W/Util in Rockville,Md to Discuss Licensee Response to Questions on Fire Protection Program ML20150E8851988-07-0707 July 1988 Notification of 880725 Meeting W/Util in Rockville,Md to Discuss Status of Refuel Outage & Configuration of Mgt Sys ML20151L9961988-06-16016 June 1988 Discusses Engineering Insp DRP-07 Re Safety Sys Outage Mod Involving Auxiliary Feedwater Sys.Insp Identified Several Instances of Inadequate Engineering Review.Addl Insp of Engineering Design Review Requested in Jul-Aug ML20195E5431988-06-10010 June 1988 Submits Status Summary Rept on Multi-Plant Action B-66, Natural Circulation Cooldown. Near-term OLs Should Not Be Added to Safety Issues Mgt Sys Listing for Subj Action ML20154R8651988-06-0808 June 1988 Requests That Encl Slides from 860627 Presentation to ACRS Re Maint Review at Facility Be Placed in PDR ML20148T0851988-06-0303 June 1988 Discusses Multiplant Action F-58,Items II.K.3.30 & II.K.3.31 Compliance w/10CFR50.46 ML20151N8041988-04-18018 April 1988 Notification of 880428 Meeting W/Util in Oak Harbor,Oh Re Technical Discussions Concerning Plant Control Ctr ML20151B7141988-04-0606 April 1988 Comments on Cj Papariello 880323 Memo Re Insp of Allegations at Plants.Significance of Allegations Low & Do Not Warrant Immediate Review & Closure ML20148E3191988-03-18018 March 1988 Notification of 880330 Meeting W/Util in Oak Harbor,Oh to Discuss SALP 6 Rept ML20150B9671988-03-11011 March 1988 Requests That Encl 870911 Memo from J Scinto Be Included in Docket Files.Memo Relates to 870122 Application for Amend to License NPF-3 Re Organization Changes IA-88-165, Discusses Topics for Senior Mgt Meeting & Submits Partial Listing of Facilities Where Vendor Support Has Been Problem,Vendor Involved & Component/Issue of Interest. W/Copyrighted Matl1988-03-0909 March 1988 Discusses Topics for Senior Mgt Meeting & Submits Partial Listing of Facilities Where Vendor Support Has Been Problem,Vendor Involved & Component/Issue of Interest. W/Copyrighted Matl ML20155K2001988-03-0909 March 1988 Discusses Topics for Senior Mgt Meeting & Submits Partial Listing of Facilities Where Vendor Support Has Been Problem,Vendor Involved & Component/Issue of Interest. W/Copyrighted Matl ML20236U6471987-11-27027 November 1987 Forwards Safety Evaluation Re Assessment of Errors in Util Analysis for Small Break Loca,Per 860718 Request.Incorrect Values Used in Analysis Result in Incomplete Compliance W/ 10CFR50,App K.Performance Requirements of 10CFR50.46 Met ML20153E9181987-11-16016 November 1987 Forwards Oct 1987 Significant Intergovernmental Activities & Issues Rept.Rept Represents Combined Efforts of NRC Regional State Liaison Officers,State,Local & Indian Tribes Programs Staff & Regional State Agreement Representatives ML20236A6081987-10-20020 October 1987 Notification of 871113 Meeting W/Util in Bethesda,Md to Discuss Util Reassessment of Programs,Priorities & Planned Fifth Refueling Outage Work Items ML20236A6171987-10-20020 October 1987 Notification of 871029 & 30 Meetings W/Util in Bethesda,Md to Discuss Facility Fire Protection Program ML20236A9711987-10-19019 October 1987 Forwards Biweekly Status Rept for 870926-1009 1999-03-26
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l June 20, 1985 k
NOTE TO: William J. Dircks Executive Director for Operations FROM: C. J. Heltemes, Jr.,' Director Office for~ Analysis and Evaluation of>0perational Data
SUBJECT:
STATUSREPdRTFROMTHENRCINCIDENTINVESTIGATIONTEAMAT
- DAVIS BESSE (CONFERENCE CALL AT 3:30pm AND DISCUSSION AT APPROXIMATELY 9:00pm ON JUNE 19,1985)
During the subject calls, E. Rossi reported on the status of the team's activities as follows:
- 1. He indicated that the fundamental activities of the team during the time at the. site have been to: (a) interview people that had direct knowledge of the event or were involved in the event; (b) review pertinent records and documentation; (c) tour the plant and inspect plant equipment involved withtheevent;and(d)reviewthelicensee'splansonhowtohandlethe quarantined equipment. The team mentioned that the first three items have been largely completed.
-2. Activities remaining to be completed on Thursday and Friday of this week include: (a) Two or three interviews (these include reinterviews of Davis Besse operations personnel and discussions with the NRC Senior Resident, Walt Rogers); and (b) reviewing the action plans for several -
items on the freeze list. Items on the freeze list of particular interest to the team include the steam feedwater rupture control system, AFW turbine and controls, and the PORV and controls. As noted previously, the team
. plans to return on Saturday morning and will reconvene next week in order to start preparation of the report. They plan to return to the site perhaps
~
- for three or four days after the licensee has completed its inspection and troubleshooting procedures of the quarantined equipment. The trouble-shooting of equipment is proceeding slowly, and the schedule for completion is not known; however, the team has assumed the availability of-results by July 5. Assuming the availability of the information and other support-ing analysis, the team is estimating that its report can be completed and issued to the Connission and the EDO by July 22. Distribution as a NUREG document would follow.
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l William J. Dircks -
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[ 3. The sequence of events, as forwarded by the team, was considered to be fundamentally sound, although it is anticipated that there will be some
~
changes and additions.
- 4. During the conference call, the team discussed the loss of both trains of the AFW. It was noted that both trains of the AFW were lost because of the failure of two valves and the loss of both pumps. Either one of these alone would have caused both trains to be lost (i.e., one pump and one valve must be operable in order for an AFW train to be functional). The team also mentioned the difficulty and the number of actions necessary to
- get the startup pump back into action. It was noted that four valves had ,
i to be opened and a fuse had to be installed for the breaker control. It ,
was also noted that the valves were not designed to be opened from the control room, and that these actions were necessary because the particular pump is not seismically qualified nor safety-related, and its associated piping runs through the safety-related AFW pump rooms. A number of actions were also necessary in order to return the AFW pumps and valves to service.
In order to reach much of the equipment, the equipment operators had to pass through key-locked doors which were a potential area of concern.
- 5. The team has initiated review of procedures applicable to the event.
4 In this review, the team has reinterviewed the Shift Supervisor and Assistant Shift Supervisor together on the AT0G procedures and the extent these procedures were.followed during the event.
- 6. A question was raised concerning the sequence of events as to how 50-100 gallons of water was injected if the primary system pressure was 1720 psi although the HPI had a cut-off of around 1680 or so.
The team responded that the piggyback approach using the low pressure i
! ECCS system feeding the high pressure system allows the discharge pressure
- of the HPI to be increased to approximately 1800 psi. It is believed that 1 this pressure was sufficient to allow a small amount of water to be injected into the system.
- 7. A question was raised as to the status of the two makeup pumps. Each
! is rated at approximately 150 gpm. It was indicated that one makeup pump was running at all times and the second one was startod right after the trip. Further, letdown was isolated immediately following the trip.
- 8. A question was raised about the performance of the plant operators. It j was indicated that the equipment operators performed well, and that they i seemed to have a good knowledge of the plant and were able to accomplish a number of complex actions in a short time. Other performance aspects
} remain under study; for example, whether further actions were required
- by procedures. A question was raised whether the team was pursuing
! whether any NRC regulations, requirements, or procedures influenced or impacted the event. The team confirmed that it was understood that this j subject was within their scope and they have been addressing it during their onsite investigation.
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William J. Dircks .
-9. The team also indicated that they are focusing on some design-related aspects of the event, including the steam and feedwater rupture control system; performance of valves under potential high delta pressure conditions; and alignment of steam to the AFW pumps. These and other design aspects are under current study.
(siged)
C. J. Heltemes, Jr., Director Office for Analysis and Evaluation of Operational Data cc: H. Denton J. Taylor i J. Keppler ,,
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