ML20210B857

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Forwards Addl Info Supplementing 860801 Response to SER on Operability/Reliability of Tdi Emergency Diesel Generators
ML20210B857
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 09/11/1986
From: Tucker H
DUKE POWER CO.
To: Harold Denton, Youngblood B
Office of Nuclear Reactor Regulation
References
NUDOCS 8609180187
Download: ML20210B857 (16)
v • d • e


Text

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DUKE POWER GOMPANY P.O. 390X 33189 CHARLOTTE, N.O. 98949

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USIEEt September 11, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. B. J. Youngblood, Project Director PWR' Project Directorate No. 4 Ret Catawba Nuclear Station Docket Nos. 50-413 and 50-414 Dear Sir On August 1,1986, Duke Power Company submitted a response to the Staff's Safety Evaluation Report on Operability / Reliability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc. The purpose of that letter was to address plant specific itema identified in the SER. As a result of discussions with the Staff, please find attached information to supplement the August 1, 1986 submittal.

Very truly yours, C.- g b, 4 Hal B. Tucker ROS/15/ sib Attachment xc Dr. J. Nelson Grace, Regional Administration U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Catawba Nuclear Station 0609100107 86071' PDR S

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Duke Power Company Catawba Nuclear Station Response to NRC Question on TDI D/G's References

1. Letter from H. B. Tucker to H. R. Denton, June 29, 1984, forwarding 1A inspection report.
2. Letter from H. B. Tucker to H. R. Denton, Oct. 6,1984, forwarding 1B inspection report.
3. Letter from H. B. Tucker to H. R. Denton, Oct. 2,1985, forwarding 2A inspection report.
4. Letter from H. B. Tucker to H. R. Denton, Dec. 23, 1985, forwarding 28 inspection report.
5. Letter from H. B. Tucker to H. R. Denton, June 21, 1985, providing resolu-tion of DRQR items on CNS 1A D/G.
6. Letter from H. B. Tucker to H. R. Denton, Jan. 13, 1986, providing resolu-tion of DRQR items on CNS 2A, 2B D/G's.
7. Letter from H. B. Tucker to H. R. Denton, May 19, 1986 providing resolution of 09QR items.
8. Letter from H. B. Tucker to H. R. Denton, August 1,1986, addressing the TDI Generic SER.
9. Letter frcia H. B. Tucker to H. R. Denton, August 6,1986, addressing Catawb3 Opn cting License requirements on TDI Diesel Engines.
10. Review of .tesolution of Known Problems in Engine Components For Trans#merica DeLaval Inc. Emergency Diesel Generators, PNL-5600, Dec. 1985.
11. TDI 91est! r ' .arator Design Review and Quality Revalidation Report, Appen-dix .I R e't . :, April 1986.
12. Safety ~ valuation Report - Operability / Reliability of Emergency Diesel Generatu s Manufactured by Transamerica DeLaval, Inc. (NUREG-1216)
1. NRC Question.;

Verify that the Design Review and Quality Revalidation (DRQR) requirements have been addressed on all Catawba Nuclear Station (CNS) Emergency Diesel Generators (D/G)

DPCo. Response: DROR Inspections DPCo. considers that all of the requirements of the TDI Owner's Group DRQR Inspection Program have been addressed. This is discussed in general terms below and in detail in the references provided.

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. Page 2 question No. 1 Continued The inspection of the CNS 1A D/G was completed before the TDI Owner's Group DRQR Program-was developed. Reference 1 provided the scope and results of this inspection. This program was reviewed by the NRC and its consultants and found to be acceptable. DPCo. provided documentation and justification of the differ-ences between the CNS 1A program and the TDI Owner's Group DRQR in Reference 5.

CNS 1B D/G inspection was also completed prior to the development of the DRQR.

The 18 D/G was considered a . follow engine in accordance with general DRQR criteria. As a follow engine less stringent inspection requirements were applied to the D/G based on the favorable results of the 1A D/G inspection. The scope and results of this inspection were reviewed and approved by the NRC and their PNL Consultants.

CNS 2A and 28 D/G were also considered to be follow engines. The inspections on these engines were conducted in accordance with the DRQR since it was available when these were carried out. References 3 and 4 provided the results of these inspections. There were some differences between the CNS 2A, 28 D/G inspections and the DRQR. These are discussed in detail in Reference 6.

OPCo. Response: DRQR Modifications ,

All modifications recommended by the DRQR will be accomplished by the end of the first refueling outage with the exception of those noted in References 5 and 7.

Detailed justification for these exceptions is provided in the references.

2. NRC Question:

The NRC expressed a concern that the 5 year Appendix II requirement could be exceeded due to the variations in fuel cycle lengths.

DPC3. Response:

The definition of the frequencies is provided in Reference 1, Part A, Page II-A-3. This definition accounts for the variation in fuel cycle length.

3. NRC Question:

Provide a status on Items B, I, K and 0 in Attachment I of Reference 11.

DPCo. Response:

Item B: Auxiliar3 Module Wiring and Terminations Action Required: Verify that the States sliding link terminal blocks were not manufactured between 1974 and 1976.

DPCo. Status: The manufacture date for the States sliding link terminal blocks on the generator control panel have been investigated. All of the States CWH:09:05:86:B3

Page 3 Question No. 3 Continued' sliding link terninal-blocks installed on this equipment were purchased by RTE Delta on or after June 27, 1978. Documentation of the exact manufacture date is not available. However, the supplier stated that inventories of greater than 6 months have never been maintained on these components. On this basis there is a very low probability that these sliding links were manufactured in the 1974 to 1976 period. Other panels associated with the engine do not utilize States sliding links.

Item I: Engine Base and Bearing Caps Action Required: Take replicas of the CNS 1A and 1B engine bases prior to the end of the first refueling outage (RFO). Other actions required in this item apply to Unit 2 engines only.

OPCo. Status: Replicas are being taken of both the CNS 1A and IB engine bases. i These will be evaluated before the end of- the f*.rst RFO. Any degenerate Widmanstaetten structure detected will be addressed and reported to the NRC in accordance with the SER.

Item K: Jacket Water Pump Action Required: Verify the torque on the nut holding the external spline to pump shaft is a minimum of 120-ft-lbs. on CNS IB D/G.

OPCo. Status: The torque on the CNS IB D/G jacket water pump will be verified to be a minimum of 120-ft-lbs prior to the end of the first RF0.

Item 0: Turbochargers Action Required: Replace the CNS 1A D/G turbocharger bracket bolting by the end of the first RFO.

OPCo. Status: The CNS 1A D/G turbocharger bracket bolting has been replaced.

4. NRC Question:

The TDI SER required quarterly ferrographic analysis of engine oil while the 0wner's Group Maintenance and Surveillance Program, Appendix II requires ferro-graphic analysis only when the monthly spectrographic analysis indicates a need.

DPCo's response on these items differed. Provide resolution.

OPCo. Response:

Currently spectrographic analysis is conducted on a monthly basis and ferro-i graphic analysis is conducted on a quarterly basis. This practice will contin-ue. On this basis the response provided to the SER in Reference 8 Attachment 1, Item 0.3. is amended to read.

"A ferrographic analysis will be conducted on a quarterly basis."

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5. NRC Question:

The Maintenance and Surveillance Program Appendix II Rev. 2, Part No. 02-315A Page II-D-CAT 3 Item I was changed by Reference 8 Attachment 1, Item' F. The recommended change should be included as an additional Maintenance and Surveillance Matrix item or as a comment.

DPCo. Response:

The change recommended in the above letter will be included as a comment on Item 1, Part No. 02-315A Page II-D-CAT 3. The original Item will be left as is. This change will be made in accordance with existing company procedures for changing controlled documents.

6. NRC Question:

The TDI Diesel Generator Design Review and Quality Revalidation Report, Appendix II Rev. 2 port E contains the engine part number cross reference. Some compo-nents were left blank for CNS. Provide a description of the surveillance DPCo.

plans on these components.

DPCo. Response:

DPCo. will perform maintenance on those components without numbers in the cross reference (TDI DRQR App. II Part E) per the table below. The components in the table harq missing part numbers due to 1) the CNS engines do not have the part or 2) the part was purchased from a vendor other than TDI.

Comanchee Peak' CNS Maintenance Part Description Part No. Follows App. II Rev. 2

, Air start block valves 03-441B Yes l

Aux. Sub-Base & Oil & Water Piping 02-717C Yes Jacket Water: Pipe, Couplings, Fittings, j etc.

. Aux. Sub. L.0. Pipe & Fittings 02-717F Yes l

Aux. Sub-Base L.O./F.0. Valves02-717 G/K Yesi ,

Barring Device Air Filter 02-525C Do Not'Have l Barring Device Control Valve / Pressure 02-525B Yes -

Regulator Control Valve Only l

i

Crank Case Vacuum Fan 02-387A Do Not Have Diesel Starting Air Compressors 02-835B Yes

! Emergency Generator Control Panel CP-102 Yes CWH:09:05:86:B3 w - - - -ye. -

Page 5 Question No. 6 Continued Comanchee Peak CNS Maintenance Part Description part No. Follows App. II Rev. 2

  • Fly Wheel Bolting 02-330B Not in Matrix Gear Train None Yes- Inspected per App. II while inspecting other components e.g. cam, crankshaft, governor, Hydraulic Valve Lifters 02-390F Do Not Have

~

Jacket Water Fittings, Pipe. 02-435A Yes (Small Bore Only)

Jacket Water Stand-pipe & Misc. 02-700F Yes Bolting L.0. Keep-warm Strainer 02-800D Yes- Same as 02-820D Should have been 02-8200 Piping System No Number Yes

  • No Comanchee. Peak Number was assigned. Part number listed was for Shoreham Nuclear Station D/G. No requirements were listed in the matrix for the Flywheel or the Flywheel bolting. This bolting was inspected on the lead engine as part of the DRQR.

t 7. NRC Question:

l For those items in the DRQR Appendix II, Rev. 2 where the frequency is not specifically given, provide frequency. (List of components was provided during l

8/21/86 phone call between DPCo. and NRC)

DpCo. Response:

l The list of components provided has been reviewed and a specific definition of the frequency for performing each item is given in the table below.

Part Part Problem Number Description Definition problem Disposition 02-425A Jacket Water Define Frequency Recommended torque values in Pump gear - Item 3 Item 3 have been incorporated in the maintenance procedures for the jacket water pump.

These procedures are used when maintenance is performed on the pump.

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Page 6 Question No. 7 Continued Part Part Problem Number Description Definition Problem Disposition F-068. Intercoolers Define Frequency Intercooler shell and tubes

- Item 2 will be inspected and cleaned whenever monthly temperature readings indicate that fouling has occurred.

CP-102 Emergency Define Frequency 48 Months.

Generator - Item 5 Control Panel 02-371A Fuel Pump Define Frequency 6 Months.

Control Shaft - Item 1 02-410C Overspeed Trip Status of L-110 The L-110 Lovejoy coupling Drive Coupling Lovejoy have been replaced in replacement. accordance with SIM363.

02-455B Fuel Oil Define Frequency Air is purged from the stand-Strainers - Item 2 by strainers whenever a high pressure drop is indicated during accomplishment of Item 1.

02-500A Engine Control Define Frequency Elastomeric parts are replaced Cabinet - Item 5 when results of system test indicate ' control air pressure is not being maintained within prescribed limits.

02-500C Circuit Breakers Define Frequency 36 Months.

and Contact - Item 3 Blocks 02-525B Barring Device Define Frequency When leakage occurs.

Control Valve & - Items 1 & 2.

Pressure Regulator 02-525C Barring Device Define Frequency N/A at CNS.

Air Filter - Items 1 & 2 02-540C Lube Oil Sump Define Frequency 18 Months.

Tank - Item 3 02-6300 Thermocouples Define Frequency 18 Months.

- Item 2 CWH:09:05:86:B3

Page 7 NRC Question No. 7 Continued Part Part Problem Number Description Definition Problem Disposition 02-695B Engine Control Define Frequency The engine control air Air Pressure - Item 2 pressure regulator will have Regulator elastomeric parts and gaskets replaced whenever inspection required in Item 1 indicates degradation.

02-695C Engine Control Define Frequency 18 Months.

Pneumatic Trip - Items 1 & 2 Switches 02-700B Jacket Water Define Frequency When leakage occurs.

Stand Pipe Valves - Item 1.

02-717GK Auxiliary Sub- Define Frequency When leakage occurs.

Base L.0./F.0. - Item 1.

Valves 02-810C Jacket Water Define Frequency When Item 4 is done.

Heat Exchanger - Item 5 02-810D Thermostatic Define Frequency The thermal power elements Valves - Item 1 will be replaced when during the monthly test degradation is indicated.

02-810E Jacket Water Define Frequency 18 Months.

Heaters - Item 1 02-820A L.O. Sump Tank Define Frequency 18 Months.

Heaters - Item 2 02-820F Full Flow L.O. Define Frequency 12 Months.

Filters - Item 3 02-820G L.O. Heat Define Frequency When item 3 is done.

Exchanger - Item 4 02-820H Full Pressure Define Frequency 18 Months L.0. Strainer - Item 3 02-835J Starting Air Define Frequency 18 Months.

Storage Tank - Items 2 & 3 CWH:09:05:86:B3

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8. NRC Question:

Provide .a response _ to the optional and suggested actions provided in the SER.

(A list was provided by the NRC during 8/21/86 phone call).

DPCo. Response:

The optional and suggested items included in the SER have been reviewed. These items are addressed in the table below:

SER SER PNL Section Pg. # Section SER Recommendation DPCo Response 2.1.3.4 2-6 4.5.4.2 Increase main lube oil A joint program between pressure 10%. DPCo. and TDI has indicated that the L.0.

pressure regulating valves installed on the '

engine will not allow increased pressure operation. However, all

, problems-experienced with the engine L.O. system to date have been adequately addressed by the turbo-charger prelube modifica-

. tion. On this basis DPCo.

will not increase main L.0. pressure.

2.1.3.4 2-6 None PNL recommendation to DPCo. concurs with the OG extend the critical findings with respect to zone of R.T. all- the the R.T. zone and will way to_the bearing continue to R.T. in end vs. 1/4 in from accordance with original end as originally OG plan. In addition required by the OG. this recommendation i

applied to 8 cylinder engines only.

I 2.1.3.7 2-7 4.4.4.4.1 U.T. of DSRV connect- DPCo. has incorporated ing rod pre and post U.T. extension measuring tensioning. of con rod bolting in the maintenance procedure for this component.

2.1.3.7 2-8 4.4.4.4.2 Inspection of con rod ECT will be used to bolt holes should be inspect the con rod bolt by (1) ECT, (2) holes. An alternate alternate method method of equal equivalent to ECT. sensitivity is under NRC development.

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Page 9 Question No. 8 Continued.

SER SER PNL Section Pg. # Section SER Recommendation. DPCo Response 2.1.3.8 2-10 None Actions should be Cautions have been added taken to prevent to the DRQR App. II and sustained engine to operating procedures operation in an un- to' prevent unbalanced balanced condition. operation. See H.B. Tucker's letter to H.R. Denton, Aug. 1, 1986, Att. 1,-Para. E.

2.1.3.11 2-13 4.7.8.3 Revise the DRQR App. The DRQR App. II Part D II plant specific will be modified to section.to require an include the required inspection of the inspections at the 10 yr.

crankshaft at 10 yr. overhauls.

overhaul vs. 5 yr. 1 time.

2.1.3.11 2-13 4.7.9 Complete DRQR require- The requirements of the ments including DRQR have been completed torsiograph, material for the CNS 1 engines certification and including these preservice crankshaft recommendations.

inspections.

2.1.3.13 2-16 4.9.5.2 Inspection of blocks DPCo. engines have with known or assumed neither known or assumed lig.~ cracks at each cracks. DPCo. will RF0 in accordance with inspect the block in PNL recommendations. accordance with the DRQR App. II Part D, which incorporates the PNL 5600 requirements.

2.1.3.13 2-16 4.5.9.2 Visual inspection of DPCo. believes that the block under intense inspections required by light. Inspections of DRQR App. II Part D the liner and cam will be adequate to gallery and M.T./ECT detect block cracking.

per PNL.

2.1.3.13 2-15 4.9.5.2 Recommendations on the DPCo. believes that the inspection methods for inspection procedures and block tops. acceptance criteria currently in use are adequate to ensure reliable engine opera-tion.

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Page 10 NRC Question No. 8 Continued SER SER PNL Section Pg. # Section SER Recommendation DPCo Response 2.1.3.13 2-17 4.9.5.2 Do not put any engine DPCo. examined the micro-with degraded micro- structure of all of the structure into service CNS engine blocks and has without providing no degraded justification to NRC. microstructure on any engine.

2.1.3.14 2-18 4.10.4.3 Do not put into All CNS cylinder heads service any cylinder with weld repairs from heads with repairs to one side only have been the injector bore hole removed from service.

made from one side This was verified through only. Incorporate inspection. In addition this in the DRQR App. station ~ procedures II. preclude the use of this type head.

2.1.3.14 2-18 4.10.4.3 Use ASME Section V, OPCo. considers the Article 7,_and ASME inspection methods and SA-613 Section 19 and acceptance criteria used 20 for acceptance currently to be criteria. completely adequate.

2.1.3.16 2-19 4.13.4.2 Mo'nitor any engine DPCo. has no known engine base cracks at base cracking. The bases alternate refueling on all engines have been outages. inspected for degraded microstructure and for the existence of cracks.

The DRQR App. II Rev. 2 includes periodic inspec-tion of the engine base.

2.1.3.16 2-19 4.13.4.2 Check all engine The bases for all CNS bases for degenerate engines have been l checked for proper micro-Widmannstatten i microstructure. structure. CNS 2 engines have proper structure.

CNS 1 engines have been i checked and are being i evaluated. Any degraded microstructure will be addressed in accordance with the SER paragraph 2.1.3.16.

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Page 11 NRC Question No. 8 Continued SER SER PNL Section Pg. # Section SER Recommendation DPCo Response 2.1.3.17 2-19 4.14.42 Fabricate fuel lines DPCo. uses 1008 steel from 1010 steel vice tubes supplied by TDI.

1008. Use shrouded These tubes are pre-fuel lines. service tested using eddy current. OPCo. has had no failures of injection tubing and feels that the currently supplied tubing is adequate.

2.1.3.14 2-2 4.14.4.2 Installation of tubing OPCo. has included should include specific instructions for specific instructions tightening fuel injection for fittings. tubing fittings in the maintenance procedures.

2.1.3.14 2-20 4.14.4.2 Check fuel tubing The OG M&S App. II fittings for signs of includes this recommenda-leakage after each tion to be carried out on shutdown. a monthly basis. In addition App. II Section A, Table 1 includes a provision' to check the engine for leaks on an hourly basis.

l 2.2.3.22 2-21 4.17.4.3 R.T. friction welded DPCo. will follow OG

! push rods. Destruc- recommendation to P.T.

! tively test period- all push rods. Based

! ically a friction on this inspection and welded push rod, the satisfactory perfor-mance of the friction welded design the PNL recommendations will not be performed.

2.1.3.24 2-22 4.19.4.3 Implement full lubri- Based on the performance cation of turbo's of the turbos with the during coast-down. modified pre and post L.O. system DPCo. does not l

feel the PNL recommenda-tion is justified. The turbo performance will continue to be evaluated.

If degradation is noted this recommendation can be reconsidered.

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Page 12 NRC Question No. 8 Continued SER SER PNL Section Pg. # Section SER Recommendation DPCo Response 2.1.3.24 2-22 4.19.4.3 Spectrographic and. DPCo. will conduct these ferrographic analysis analyses on a quarterly should be conducted basis, on a quarterly basis.

2.2 2-24 None Recommendations from See NRC Question 9.

detailed review by PNL in PNL 5444, 10 components.

2.2 2-24 None Implement all 0/G DPCo. has implemented all Phase II recommenda- recommendations with the tions, exception of those noted in References 5, 6, 7, 8 and 9.

9. NRC Question:

Provide a response to the plant specific items noted in Section 2.2 of the SER.

DPCo. Response:

Component Part No. PNL-5444 Recom/Sug. DPCo. Response Intercooler F-068 Monitor Air Temp. and A trend analysis is air and waterside AP included in App. II for trend analysis. of the DRQR to monitor intercooler performance.

Main Bearing Shells 02-310D NRC confirmation No action required review of Failure on DPCo's part.

Analysis Associates Review of OG component discrepancies.

Cam Shaft - 02-350C Redesign to eliminate No problems assoc.

supports, bolting the.use of cotter pins. with the use of cotter pins has been seen. DPCo. proce-dures and DRQR App.

II cover the roper installation of cotter pins. DPCo.

feels that the current design is adequate.

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Page 13 NRC Question No. 9 Continued Component Part No. PNL-5444 Recom/Sug. DpCo. Response Idler Gear 02-355B Redesign to eliminate Same as 02-350C Assembly cotter pins.

Intake and exhaust 02-360B Replace valves if This recommendation valves flaking or loss of is included in DPCo.

chrome plating is procedures.

_present.

Air Intake Manifold 02-375 Further incidence of The station has cracking should be procedures in place investigated thoroughly. which would require full investigation of such cracking.

Intake / Intermediate 02-390A/B Inspect rocker boxes at This inspection is and exhaust rocker the rocker shaft bolts included in DRQR shaft assemblies. during RFO's. App. II, component 02-362A at overhaul.

A TDI SIM has been ,

issued which addresses the potential for crack-ing in this area.

Intercooler Pipe 02-436A If a seismic event In the event of an Coupling exceeding the Site event exceeding 1/2 Seismic Limits occurs, SSE then this system inspect and evaluate would be inspected, couplings. evaluated, and reported to the NRC in accordance with 10CFR, Part 100,

Appendix A, l Paragraph V.(a)(2).

Misc. Equipment- 02-810E Record jacket water Jacket water Jacket Water Stand temperatures daily temperatures are Pipe Heater and trend monthly recorded daily dur-excursions above ing engine standby set-point. and hourly during operation. These logs are reviewed by f personnel responsi-ble for engine performance.

Oil Pre-lube Filter 02-820E Maintain records and DRQR Appendix II trend AP versus time. includes this recommendation.

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Page 14

10. NRC Question:

What is DPCo's response to any Part 21 item received after Dec.19857 How does DPCo keep abreast of significant events occurring on TDI engines at other plants. A review of the LER's associated with .the TDI's engine received since the generic SER was drafted (Dec. 1985) was requested.

DPCo. Response:

Only one Part 21 item has been received since Dec.1985. (10CFR Part 21 No.

136, dated July 2,1986 and follow up letter dated Aug. 13,1986). This item is addressed below:

10CFR21 notification by TDI (July 2,1986) concerned a potential problem with the fastening of the engine's connection rod assembly.

The TDI investigation revealed that the connecting rod cracking was caused by insufficient clamping force applied through the rod bolting. Torque methods were used to apply fastener preload. Galling between the washer surface and the bolt head reduced the amount of torque that was converted preload.

Duke Power Company procedures for con rod- bolt installation -include determining preload with Raymond Bolt Gauge ultrasonic equipment. With this method, the desired preload is achieved regardless of galling or other frictional losses.

All Catawba con rod bolts have been installed using this method.

The nickel plated washers, recommended by TDI's August 13, 1986 letter, will be installed as the con rods are disassembled for inspection or repair.

We therefore conclude that this problem will not occur at Catawba and no further action will be necessary beyond those described in o^ur preventative maintenance program.

With respect to LER's the following is submitted:

i The staff also requested that Duke Power review any LER's which concerned TDI diesel generators, that were reported since the Staff's generic SER was drafted i in December 1985. Duke Power does not receive copies of LER's from other licensees with TDI diesel generators. Furthermore, diesel failures would be reported. to the NRC by way of Special Reports (Technical Specification 6.9.2) and not in LER's.

s Information on problems with diesel generators is received from a variety of i sources, including:

1. Part 21 reports (vendor).
2. IE Bulletins, IE Information Notices, and Generic Letters (NRC). IEIN l 86-73 dated August 20, 1986 advised the industry of recent diesel i generator problems.
3. NRC/INPO Daily Status Report (INPO).
4. Nuclear Network (INPO).
5. NPRDS (INPO).
6. NOMIS (NUS).

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Page 15 Question No. 10 Continued Through these sources and personal contacts with counterparts at other utili-ties, we feel that we are well informed as to significant problems with TDI or other vendor diesel generators.

11. NRC Question:

Address Catawba's program for investigating the root cause of D/G failures such as the recent problems with the fuel racks at Catawba Unit 2.

DPCo Response:

As discussed in the Special Report submitted to NRC/ Region II on August 7, 1986, failures number three through eight on D/G 2A were attributed to bi, ding of the fuel racks. A description of each failure, the corrective action and the successful retest of D/G 2A were documented in a Special Report to the NRC.

Following each failure, actions deemed appropriate to resolve the problem were taken. The 2A D/G was later declared operable based on the successful comple-tion of a re-test. Therefore there was no reason to believe that corrective actions were inappropriate or inadequate.

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