ML20214M680
| ML20214M680 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/22/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| LIC-87-347, NUDOCS 8706010399 | |
| Download: ML20214M680 (21) | |
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MM-mm-Omaha Public Power District 1623 Harney Omaha. Nebraska 68102-2247 402/536 4000 May 22, 1987 J [ I D [i)'
LIC-87-347 t; j MAY ? 6i987 J. E. Gagliardo, Chief Reactor Projects Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Tx. 76011
References:
1.
Docket No. 50-285 2.
Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated May 8, 1987 (IER 50-285/87-05) 3.
Letter NRC (J. E. Gagliardo) to OPPD (R. L. Andrews) dated May 8, 1987 (IER 50-285/87-08)
Gentlemen:
SUBJECT:
Inspection Reports 87-05 and 87-08 On May 14, 1987, an enforcement conference was held at Region IV's offices on the subject inspection reports. We discussed with you the apparent violations described in the reports, the reasons for the occurrences and our proposed corrective actions.
Specific short term commitments made at the meeting are enclosed as Attachment No. 1.
The time frame required for the completion of each activity is specified in terms of plant start up milestones.
In addition, copies of the overhead projections used in the presentation are included as Attachment No. 2.
Should you have any questions concerning the attachments, please do not hesitate to contact us.
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R. L. Andrews Division Manager Nuclear Production g 60gDob 500 85 G
PDR RLA/me c:
LeBoeuf, Lamb, Leiby & MacRae R. D. Martin, NRC Regional Administrator W. A. Paulson, NRC Project Manager P. H. Harrell, NRC Senior Resident Inspector l \\
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i ATTACHMENT N0. 1 Action Schedule
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1.
System Acceptance Committee acceptance in Before Reactor Coolant System I
accordance with Standing Order G-21 of (RCS) temperature exceeds 515'F.
modification MR FC-81-180 Masonry Unit Walls Seismic Restraints 2.
Emergency Feedwater Storage Tank (FW-19).
Before reaching an RCS
inspection.
- b. Sandblast prior to coating the tank
- c. Coat the tank
- d. Hydrostatically test the tank 3.
Welding performed on Critical Quality Prior to affected system being Elements during the 1987 refueling outage made operable per Technical was/will be performed by qualified weldors Specification requirements.
using qualified weld procedures.
4.
Main steam safety valves are adequately Prior to exceeding RCS installed. This includes replacing studs, temperature of 210' F.
Installing new gaskets and using correct torque values to tighten bolting.
5.
Pressurizer Safety Valves are adequately Prior to exceeding RCS installed. Verification of proper torque temperature of 210' F.
values was completed.
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6.
Limitorque Operators that are part of the Prior to exceeding RCS Electrical Equipment Qualification Program temperature of 210' F.
l have had grease flushed / removed and
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approved lubricant added.
7.
Containment ventilation fans are properly Prior to exceeding RCS installed.
temperature of 210' F.
- a. Megger Cables
- b. Contact vendor to ensure correct torque values for fan blade bolting are known and verify torque used.
- c. Retrieve original specification require-ments for blade settings and verify actual settings are in accordance with specification.
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8.
The Maintenance Orders (M0s) written for Prior to affected system being the 1987 refueling outage have been made operable per Technical l
reviewed to determine which M0s installed Specification requirements.
bolting without specific torque values.
Of the M0s reviewed, 181 completed CQE M0s did not have specific torque values.
For those 181 M0s, OPPD will either verify i
that correct torque values are determined and ensure bolting is installed to those l
values or provide analyses to show that failure of bolting does not involve an
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unreviewed safety question.
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ATTACHMENT NO. 2 J
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UNRESOLVED ITEM (285/8705-13)
LUBRICATION OF CONTAINMENT COOLING FAN MOTORS AND LIMITOR0VE OPERATORS THE LICENSEE WAS LUBRICATING RELIANCE MOTORS IN CONTAINMENT ON AN 18-MONTH (REFUELING OUTAGE) IN LIEU OF 3-6 MONTH PERIODICITY, AND HAD USED MARFAK LUBRICATION IN LIEU OF NEBULA EP-0 IN LIMITORQUE OPERATORS IN CONTAINMENT.
THIS WILL REMAIN AN UNRESOLVED ITEM PENDING FURTHER REVIEW DURING A SU INSPECTION (285/8705-13).
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CONTAINMENT FAN LUBRICATION VA-3A, 38, 7C, 7D THE LUBRICATION FREQUENCY OF THE CONTAINMENT VENTILATION FAN MOTORS (VA-3A, 3B, 7C, 70) IS BASED ON APPENDIX B,
" GENERAL DESIGN COMMENTS FOR RELIANCE N0 TOR...," 0F " SIMULATED ENVIRONMENT TEST FOR J0Y AXIVANE FAN / MOTOR FOR NUCLEAR CONTAINMENT FOR THE FORT CALHOUN NUCLEAR POWER, STATION...," WHICH RECOMMENDS A MAXIMUM LUBRICATING FREQUENCY OF TWO YEARS.
THIS INFORMATION WAS REVIEWED BY S&L AS PART OF OUR 1985/1986 EE0 COMM TO REVIEW MOTOR MAINTENANCE IN THE EEQ PROGRAM TO CLOSE OUT THE 1985 IN TION REPORT ON OPPD'S EEQ PROGRAM.
BASED ON THE AB0VE INFORMATION, A MAINTENANCE FREQUENCY OF EVERY REFUELING OUTAGE IS ADOPTED FOR LUBRICATION OF THE FAN MOTORS.
OPPD BELIEVES THAT 00R PRESENT LUBRICATION SCHEDULE IS ADEQUATE.
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3 POTENTIAL VIOLATION FAILURE TO IDENTIFY AND RETRIEVE RECORDS 3.b.2 THE NRC INSPECTOR REQUESTED THE ORIGINAL DESIGN BASE CALCULATION ORIGINAL INSTALLATION RECORDS (" CODE DATA PACKAGE") FOR THE MS SAFETY RELIEF VALVE LINE FLANGE JOINT BOLT STRESS LEVEL.
THE LICENSEE WAS UNABLE TO RETRIEVE THESE RECORDS.
... VIOLATION OF 10 CFR 50 APPENDIX B CRITERIA XVII.
3.c.2 THE NRC INSPECTOR REQUESTED ORIGINAL DESIGN BASE CALCULATIONS INSTALLED RECORDS FOR THE PRESSURIZER SRV LINE FLANGE JOINT BO STRESS LEVEL AND BOLT TORQUE.
... VIOLATION OF 10 CFR 50 APPENDIX B CRITERIA XVII.
3.d.3.a THE FAILURE OF THE LICENSEE TO IDENTIFY AND RETRIEVE ORIGINAL CALCULATIONS FOR BLADE ANGLES ON FANS VA-3A. VA-38, VA-7C, AND VA-70 IS ANOTHER EXAMPLE OF POTENTIAL VIOLATION (285/8705-02), FAILURE TO MEET 10 CFR 50, APPENDIX B, CRITERION XVII.
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SUMMARY
1.
DESIGN BASIS RECORDS ARE NOT EASILY RETRIEVABLE.
2.
TORQUE VALUES FOR THREADED FASTENERS ARE NOT TRACEABLE TO THE DESIGN BASI DOCUMENTS.
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DBP,
DBP CALCULATIONS BY VENDOR SPECIFICATIONS --7 DBP y
j INDUSTRY DBP CODES & STAND.
DRAWINGS BY NDOR
- DBP
,f CALCULATIONS!
DESIGN DBP TOROUE VALUES REGULATORY DBP CALCULATED BASIS REQUIREMENTS
$y3 BY A/E VENDOR DOCUMENTS 3
MANUALS BY A/E DBP 3
j FUNCTIONAL DBP REQUIREMENTS DRAWINGS
- m BY A/E Y
- TYPE OF HARDWARE AND APPLICABLE CODE SPECIFIED.(NOTE il DBP AS BUILT
- CONSTRUCTION INSTALLATION DRAWINGS DOCUMENTS LUES AND TEST PROCEDURES j
UPDATED VENDOR MANUALS i
WORK INSTRUCTIONS MAINTENANCE TDROUE VALUES PROCEDURES SPECIFIED DBP - DESIGN BASIS
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PROJECT SCOPE l
- - FOR MOST PART THIS INFORMATION
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IS EASILY RETIEABLE.
NDTE 1 -__NEEDS TO BE VERIFZED0
1 LONG TERM CORRECTIVE ACTIONS 1.
REVIEW MAINTENANCE PROCEDURES TO VERIFY THAT APPLICABLE DESIGN DRAWINGS /
CODES AND/0R VENDOR MANUALS ARE REFERENCED ON THE MAINTENANCE PROCEDURES.
2.
REVISE MAINTENANCE PROCEDURES TO INCLUDE INSTRUCTIONS THAT ONLY ONE FOR ONE FASTENER REPLACEMENT IS ACCEPTABLE.
3.
TORQUE VALUES SPECIFIED SHALL BE CONSISTENT WITH THE TYPE OF HARDWARE PER EPRI PUBLICATION AND DESIGN DRAWINGS AND APPLICABLE CONSTRUCTION CODE REQUIREMENTS.
4.
GSE REVIEW APPLICABLE DESIGN DRAWINGS TO ENSURE THAT ACCURATE FASTENERS DATA IS AVAILABLE ON DESIGN DRAWINGS REFERENCED IN MAINTENANCE PROCEDURES.
(PIPE SUPPORTS, PIPING IS0 METRICS, SEISMIC SUPPORTS FOR MECHANICAL AND ELECTRICAL EQUIPMENT.)
5.
DEVELOP THE FOLLOWING DOCUMENTS TO SUPPLEMENT THE AB0VE ACTIONS:
- CRITERIA FOR USE OF FASTENERS (SPECIFY ACCEPTABLE FASTENERS, APPROVED LUBRICANTS, STRESS VALUES, TORQUE REQUIREMENTS, ETC.).
- DESIGN GUIDE - DISCUSS APPLICATION OF THE CRITERIA.
- FC STANDING ORDER ON FASTENERS TO DOCUMENT REVIEW PROCESS.
l SCHEDULE THE AB0VE ACTIONS ARE PLANNED TO BE COMPLETED BY 6/88.
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POTENTIAL VIOLATION 50-285/8705-14 FAILURE TO USE REQUIRED LUBRICANT IN ELECTRICAL EQUIPMENT-QUA LIMITORQUE VALVE OPERATORS.
THE LICENSE INDICATED THAT HCV-383-4-0, HCV-347-0, HCV-348-0, HCV-33I-0, HCV-383-3-0, AND HCV-333-0 LIMITORQUE OPERATORS CONTAINED A MIXTURE OF NEBULA EP-1 AND MARFAX GREASES WHICH THEY CONSIDERED QUALIFIED EVEN THO PRACTICE CONTRADICTED THE SPECIFIC REQUIREMENTS OF THE APPLICAB TYPE SMB INSTRUCTION AND MAINTENANCE MANUAL, BULLETIN SMB1-828. THE DOCUMENT USED AS JUSTIFICATION WAS BOLT AND ASSOCIATES LETTER DATED JUNE 17, 1986,
" MIXING MARFAK WITH NEBULA EB OR (SUN OIL COMPANY) PRESTIGE 50 EP."
THE LETTER BEGINS WITH A STATEMENT THAT NO PROBLEM EXISTS WITH ATORS BECAUSE OF MIXING, SINCE INCOMPATIBILITY IS LIKELY TO RESULT IN " SOFTEN-ING" ( A DE-HYOROLYZATION OR DE-SAPONIFICATION OF THE GREASE INCREA FLUIDITY). THE LETTER STATES THAT THIS WOULD BE NO PROBLEM SINC CONTAINED IN THE GEAR BOX.
ADVERSE CHEMICAL REACTIONS (BEARING CORROSION.
ETC.). REDUCTION OR LOSS OF EXTREME PRESSURE (EP) CHARACTERIS TION OF OIL FROM THE MIXTURE. ALL OF WHICH MAY-RESULT FROM INCO THE GREASES. WERE NOT ADDRESSED.
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Tile LETTER SUMMARIZES WITH A PARAGRAPH WHICH STATES:
"I DO NOT WISH MY COMMENTS ON MIXING GREASES TO BE CONSTRUED AS ENDORS-ING SUCH A PRACTICE.
l I AGREED WITH LIMITORQUE (BULLETIN SMBL-80) THAT THIS SHOULD NOT BE DONE AS A MATTER OF POLICY.IT IS NOT A GOOD IDEA, PARTICULARLY IF THE GREASES MIXED INVOLVE DIFFERENT GELLING AGENTS, AS IS TRUE WITH THE SITUATION AT HAND. THE BEST PRACTICE IS TO PICK AN APPROVED GREASE (NEBULA IS THE ONLY ONE APPROVED FOR EVERYTHING)
STAY WITH THIS PRODUCT DOWN THE ROAD. IF MORE THAN ONE SUPPLIER IS DESIRED OR AS OTHER PRODUCTS ARE QUALIFIED, IT WOULD KEEP WITH MATE-RIALS CONTAINING AT LEAST THE SAME GELLING AGENTS."
MARFAK AND NEBULA EP GREASES HAVE DIFFERENT GELLING AGENTS.
LIMITORQUE HAS STATED THAT QUALIFICATION OF THEIR OPERATORS IN CONT CONTINGENT UPON THE SOLE USE OF EXXON NEBULA EP GREASES.
FAILURE TO USE THE REQUIRED GREASE IS A POTENTIAL VIOLATION OF 10 CFR 50 (285/8705-14).
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LIMITORQUE LUBRICATION DISCUSSION BACKGROUND:
UP UNTIL AUGUST OF 1986, OPPD'.. POSITION ON LIMITORQUE LUBRICATION WAS THAT TEXACO MARFAX GREASE ALONG WITH LIMITORQUE QUALIFIED EXXON EP-0, AND A MIX-TURE OF MARFAK AND EP-0 WERE ADEQUATE FOR USE IN VALVE OPERATORS.
THE MARFAX WAS JUDGED ADEQUATE BASED ON INFORMATION SUPPLIED BY TE THE MIXTURE WAS CONSIDERED ADEQUATE BASED ON INFORMATION WHICH T MIX THE GREASE AND SEE IF IT SEPARATED, WHICH IT DID NOT.
(LIST REFERENCE AND SUMMARIZE)
MIXING IS BELIEVED TO HAVE OCCURRED IN 383-3 AND 383-4.* THIS STANCE
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BASED ON THE ANALYSIS WHICH OPPD BELIEVED TO BE ALLOWED UNDER TH GUIDELINES.
(NEED COPY OF 00R GUIDELINES)
OPPD HAD INFORMED THE NRC EARLIER IN THE 1984 TER MEETING RESPON MARFAK GREASE WAS CONSIDERED QUALIFIED.
ON AUGUST OF 1986, OPPD LEARNED THROUGH INFORMATION SUPPLIED ON TVA AND DUKE POWER STATIONS AUDITS THAT OPPD'S POSITION ON LIMITORQUE LUBRICAN l
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BE RE-EXAMINED.
- EXXON EP-0 WAS CONSIDERED TO BE THE PRIMARY LUBRICANT
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4 BASED ON INFORMATION SUPPLIED BY DUKE POWER, IT WAS-LEARNED THAT MIXING IS NOT A GOOD PRACTICE AND THAT THE MARFAX 2 ANALYSIS MAY BE INADEQUATE TO ENSURE THAT NORMAL OPERATION COULD CONTINUE AND COULD BE CONSIDERE SAFELY, A JC0 WAS PREPARED AND DOCUMENTED IN GSE-FC-86-822.
i GREASE CHANGE OUT DURING THE 1987 REFUELING OUTAGE WAS RECOMMENDED.
4 TO DATE, NEARLY ALL OF THE GREASE HAS BEEN CHANGED OUT INCLUDING 383-3 AND 383-4.
DISCUSSION WITH PLANT MAINTENANCE INDICATED THAT NO DAMAGE TO T BEARINGS HAS OCCURRED WITH ANY OF THE GREASE CONFIGURATION.
IN ADDITION, THE GREASE THAT WAS FOUND IN 383-3 AND 383-4 LOOKED IN GOOD t
CONDITION.
THE GREASE WAS FOUND TO BE OF A "DIFFERENT COLOR" DUE TO MIXING, BUT SHOWED NO SIGNS OF SEPARATION OR HARDENING.
MOV TESTING BY M0 VATS INDICATED THAT MOV VALVE OPERATORS AT FCS W
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BEING IMPACTED BY SUCH THINGS AS LUBRICANTS SUBSTANTIATING OPPD'Si THAT LUBRICATION WAS ADEQUATE.
A MAY 11, 1987 CONVERSATION WITH EPRI'S LUBRICANT CONSULTANT DR. ROBERT 0.
1 BOLT, INDICATED THE FOLLOWING:
- THERE SHOULD BE NO CHEMICAL REACTION ONLY A POSSIBLE CHANGE IN AGENT COULD OCCUR.
IF THE GREASE HAD NOT HARDENED OR SEPARATED IT SHOULD 1
BE OK - WHICH IT APPEARED TO BE.
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- THE BEST WAY TO DETERMINE DAMAGE VIA LUBRICATION PROBLEMS, WOULD BE TO INSPECT.
THE GREASE CHANGE OUT PLUS M0 VAT TESTING SHOWED N0 GEAR OR BEARING PROBLEMS.
- COLOR IS NOT A PROBLEM - IT IS COSMETIC ONLY.
l DURING EARLIER REPLACEMENT OF MARFAX WITH EP-0 IN THE 1983-1984 TIME FRAME, THERE WAS NO LUBRICATION DAMAGE QUESTION RAISED, WHICH FURTHER SUBSTANTIAT OPPD'S JUDGMENT WHICH DETERMINED THAT A JC0 COULD BE SUPPORTED.
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CONCLUSIONS IN 1985, BASED ON GOOD FAITH, OPPD CONCLUDED THAT MIXED GREASES WERE ACCEP ABLE PER 00R GUIDELINES.
AFTER LEARNING THE RESULTS OF DUKE POWER AUDIT, OPPD TOOK PROMPT ACTION TO ANALYZE THE SITUATION AND PREPARED A JCO.
DURING 1987 OUTAGE GREASES IN ALL LIMITORQUES WERE REPLACED W GREASE.
MOVAT TESTING HAS VERIFIED THAT NO DAMAGE WAS CAUSED BECAUSE GREASE.
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e FORT CALHOUN WELDING PROGRAM I.
History A.
Procedures were adapted from construction procedures.
B.
Original basis - high quality welds, but limited number.
C.
Centralized nuclear / fossil welding program developed 1977.
D.
Extensive modifications, especially structural, showed program needed improvement.
E.
AWS procedures added to program in 1986.
II.
1985 SS0MI and QA audit findings A.
Workmanship - generally adequate, but could be better.
B.
QC inspections - greater consistency needed among inspectors.
C.
QC inpsection forms required additional detail.
D.
Welder qualification and performance records needed improvement.
III.
Corrective actions for SS0MI and QA audit findings A.
Maintenance training program.
B.
QC inspector training - permanent employees and contractors.
C.
Revised QC inspection log, documentation forms.
D.
Upgraded records program.
IV. Welding program revisions - 1986 A.
Developed separate Standing Order (G-12A) to address just welding.
- including documentation requirements.
B.
Centralized weld rod issue.
C.
Added additional inspection requirements.
D.
Added weld design data forms.
V.
1987 Welding Inspections A.
Les Gilbert - 3/87 B.
John Tetreault - ANI/ANII - 3/87-4/87.
C.
Hartford steam boiler ANSI N626.1 and ASME Section XI, Division 14/87.
D.
OPPD Quality Assurance audit of welding program 4/87.
E.
Summary of problems identified.
l.
Weld procedures should have additional detail - code references, materials, etc.
2.
Qualification records are scattered, maintenance of qualification is difficult to verify.
3.
Additional detail is needed in QC inspection records - code references, etc.
F.
Basic reason for problems - lack of awareness.
VI. Generic program improvements (in progress)
A.
Additional Technical review and revision of ASME welding procedures.
B.
Additional Technical review and revision of AWS welding procedures.
C.
Automated welder qualification documentation program.
- ready for data entry D.
Additional Technical review and revision of NDE procedures.
VII.
Specific responses to Inspection Reports 87-08 and 87-14 A.
Welder qualification records 1.
Complete review of all available documentation back to 1973 - 8 man weeks.
2.
One safety-related weld made by a welder whose certification had lapsed.
3.
Evaluation to be completed prior to restart.
B.
WPS-51 thickness range - to be corrected by revision to program.
C.
F1 vs F4 filler metal - believed to be a typographical error - to be corrected by revision to program.
D.
Postweld heat treatment for WPS-1 to be corrected by revis' ion to program.
PWHT will not be used unless it is adequately addressed in.a procedure.
E.
Completion of MR-81-180 An engineering analysis has been performed to echress the $trength requirements of as-built configuration. A flare 2aevel procedure has been developed and qualified using the same tecnnigres that were used to make the field welds.
Field welds kill be reinspected and this data will be used to provide additional support for the justification of the existing welds.
F.
Pentrameter placement on radiography of EFWST OPPD believes we are on solid technical ground, position is supported by ANI. Nevertheless, all radiography of repair welds since inspection 87-14 has been done with the penetrameter on the source side and the first two repair welds have been re-examined in this manner.
e G.
Hydrostatic test pressure.
Has been revised to 55 psig (1.1 X design pressure) per ASME Section XI.
Note: operating pressure is 0.5 psig N over head pressure.
2 VIII.
1987 Refueling Outage As a result of SSOMI, strong emphasis has been placed on high qsality welds and inspections.
Quality has been demonstrated on jobs such as replacement of pressurizer spray valves and piping, installation of RCS root valves and replacement of HCV-247 and HCV-248. The efforts have also extended to structural welding on such modifications as the inverter bypass transformers and the storage platform in the containment.
OPPD does not believe that the problems identified are ' serious enough to affect restart of the unit.
They are largely documentation problems and not problems with weld quality. The problems, however, will be corrected.
IX.
Corrective action schedule A.
Confirmatory reviews of welding and NDE in progress.
B.
Procedure revisions to be in place by 9/1/87.
C.
Automated qualification records program under development.
- ready for data entry D.
Welder qualifications to be updated and records system fully operational-by 10/1/87 (Revised welding procedures must be in place first).
X.
Safety related welding 1
A.
Will be done by qualified people using qualified procedures.
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B.
Special attention during interim until all upgrades are in place.
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EMERGENCY FEEDWATER TANK AND OTHER EATON TANKS I.
Discovery A.
Planned to sandblast and recoat.
B.
High crowns and rough welds on inside of tanks-concerned about coating adhesion.
C.
Decided to grind welds flush - MT to verify no surface or wear-surface defects.
D.
MT showed substantial indications.
E.
RT of all tanks welds to determine extent of repairs required.
II.
Design conditions A.
ASME Section VIII, Division 1, 1965.
B.
Base metal A 285 grade C plate, nominal thickness 1".
C.
Weld metal 1.
Inside - manual using Lincoln Shield Arc 85 rod (equivalent to 7010-A1).
2.
Outside - submerged arc multi-pass after air arc gouge to root pass.
D.
Design pressure 50 psig - hydrostatically tested to 75 psig.
E.
Seismic joint efficiency - 85% - partial RT F.
Built by Eaton Metal Products,1969.
III.
Operating conditions - 0.5 psig N over head pressure 2
IV.
Probable cause and extent of defects A.
Cracks, slag inclusions, lack of fusion.
B.
Approximately 40% of total weld requires repair.
C.
Probable cause - contributing factors 1.
Use of Shield Arc 85 rod without preheat - shrinkage.
2.
Improper cleaning of copper deposits from arc gouge - leads to lack of fusion.
3.
Poor workmanship.
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Se D.
Metallurgical analysis - brittle fracture, no fatigue (not service - induced)
V.
Repair procedures A.
Grind or arc gouge to remove defects.
B.
QC inspection to verify cleaning, MT to verify that defect has been removed.
C.
Weld repair using E7018 rod, 200 F preheat.
D.
E.
Hydro to 55 psig following completion of repairs.
F.
EFW tank is part of our ISI program.
Examined under ASME Section XI.
Repaired to ASME SectionJ31, Subsection ND 1983, summer 1984.
G.
Repair procedure approved by ANI.
VI.
Eaton tanks A.
Survey performed to determine what tanks were constructed by this manufacturer, followed by failure assesment.
B.
EFW tank is most critical.
C.
Diesel generator fuel oil tank.
1.
Cleaned and inspected 1987 - no readily apparent problems.
2.
Petro-Tite leaks test performed - ok.
3.
Buried tanks - soil support.
4.
Engine and wall-mounted day tanks.
D.
CCW tank 1.
Operating pressure is a fraction of design (20%).
2.
Fluid is clean, non-corrosive.
3.
Hydrotest to 55 psig in 1983.
4.
RW is installed back up.
VII. General considerations on return to operation A.
Catastrophic failure is unlikely.
B.
Leaks are detectable.
C.
Leaks can be dealt with - commercial consideration, not a nuclear safety problem.
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