ML20238C580

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Safety Evaluation Concluding That Facility May Resume Startup Testing & Operation for First Operating Cycle W/ Installed Refurbished Msivs.Necessity of Addl Leak Testing to Be Determined After Review of Prototype Test Results
ML20238C580
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 02/02/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20238A944 List:
References
FOIA-87-438 NUDOCS 8709100218
Download: ML20238C580 (9)


Text

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%....# SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CONCERNING MAIN STEAM ISOLATION VALVE LEAKAGE PROBLEM NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT UNIT 2 DOCKET NO. 50-410

1.0 INTRODUCTION

The following three problems were uncovered during the preoperational test program concerning the main steam isolation valves (MSIVs): (1) defective actuators that affected valve closure time and latch disengagement, (2) defective actuation logic for revised actuator control system, and (3) leakage rates that exceeded the 6-SCFH Technical Specification limit. The resolution of the first two problems is being addressed in separate safety evaluations.

In SSER 5 dated October 1986, the staff concluded that the root cause of the excess MSIV leakage was identified and the design deficiency was corrected by modifying the seat spring configuration and recoating the balls with turgsten carbide. The modified seat spring configuration was tested in conjunction with a new tungsten carbide coated ball for 75 operating cycles, which was the upper bound estimate of the number of cycles for operation to the first refueling outage. After the 75 valve cycles, Type "C" leak testing indicated ecceptable sealing integrity of less than 6 SCFH. On the basis of this test program and contingent on prototype test performance, the staff concluded that the refurbished MSIVs were acceptable for plant use up to the first refueling. The license was conditioned (license condition M of Facility Operating License No. NPF-54) to require confirmatory MSIV leak tests no later than the first outage (but within 30 days) of the 100-hour warranty run, and 3 required a prototype test report confirming the acceptability of the valves i for the first operating cycle by May 15, 1987.

The MSIV leakage rates beyond the Technical Specification limit recurred during preoperational testing in December 1986 (licensee letters dated January 14 and 24, 1987 (NMP2LO971 and 0977)). Following reassembly of the MSIVs, with the revised seat spring configuration and tungsten carbide recoated balls, preoperational testing was performed. Type "C" (10 CFR 50, Appendix J) leak tests performed between the valve seats indicated that acceptable leak rates of less than 6 SCFH for all valves were recorded, with the exception of valve 6b which had a leak rate of 8.9 SCFH (this would not represent a failure, on the basis of current staff interpretation of an acceptable limit, as discussed in Section 2.5). The MSIVs averaged 11 full fast closures and 7 partial six degree closures (partial closure required for monthly Technical Specification Surveillance for the Reactor Protective System trip test). The ball from the 6b valve, which sustained the most ball and seat damage, was inserted into the i body of valve 7d to determine the potential increase in valve leakage due to  ;

continued coating degradation as a function of valve stroking. In this test i' series, a combination of 54 full and 54 partial closures were conducted to l

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envehdthema,timumexpectedvalveclosuresuptothe"trstrefuelingoutage.

After i.umpletion of the tast, a Type "C" leakage test indicated 16.9, SCFH.

leakage through the valve.. Although this leak rata exceeds the Technical Specification value of 6 SCFH, the licensee perfctmed an evaluation, based on

.HUREG 1169, indicating that a maximum MSIV leak cate of 38 SCFH per valve would i

'not exceed 10 CFR Part 100 or 10 CFR Part 50, Appendix A, General Design Criterla (600) 19 requirements.

' The licen m has' reassembled the vatves containing the balls with the slightly damaged c m.ings (in valves 6c, 6d and 7d) and installed a new tungsten carbide l t coated ball into the fourth MSIV, replacing the ball in valve 6b which was used in the test described above. Following preoperational testing, all eight j HSIVs have passed the Technical Specification leakage tests (less than 6 SCFH

] between the seats) successfully. ,

. I TFe licensee has requested appioval to ecntique~ the startup testing and operation r of Nina Mile Point l' nit 2 for the first plant' operating cycle with the ex' sting refurbished MSIW in ncordance with the Ope'.ating License and Technical Specificadens. The basis for She licensee's request is the following: 1) the MSIVs have been t?sted and four.d to leak at rates below the Technical Specifi-cation liinit; 2) operation of the MSIVs between leak tests is unlikely to result in ?e0kage degradation to values greater than the Technical Specification limit; 3) if ~leakaoe beyond the Technical' Specification limit is discovered during testing, the valves will be refurbished to amt the limit; and 4) in the wilikely eunt that leakage values are significantly in excess of the Technical Specification limit, 10 CFR 100 offsite and General Design Criterion 19 control rcom operator dose guicelines would not be exceeded.

2.0 EVALUATplN As des:ribed in the licensee's January 23, 1987 letter (NMP2LO977), the MSIV preaperational tests have been oerfomed satisfactorily and operational sicceptance was achieved. All eight MSIVs meet the the Technical Specifications i for a Type ".C" leak test of less than 6 SCFH and a valve closure time of less than ti>Je seconds. The regulatory concern is the extent of possible continued degrahtion of the MSIV lok tightness by continued dating delamination during the first operational cycle of Nine Mile PoiV;. Unit 2.

2.1 Expected MSIV Performance After compledon af the December 1986 preoperational test, the 6b valve was i disasse.nbled to determine the possf tle cause of Type "C" leak test failure.  :

The ' licensee reported that considerable damage was observed on the tungsten carbide coating on the ball and cn the mating stellite seat surfaces. The  ;

licensee also reported that slight damage was observed on the ball surfaces of i val ws 6c, 6d and 7d when the bonnets of the m valves were removed. The damage to the ball surfaces were reported to be in the same location, about 12 i degrees from the full open positicn, as was previously observed. The licensee reported thcy believed that the ede of failure of the tungsten carbide costing was the same as that previously stated. The previously reported i failure mode is as follows:

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1) High local contact stresses occur when the seats " rock", causing the softer stellite 6 seat material to be smeared onto the harder tungsten carbide ball surface when the valve is cycled open.
2) When the stellite 6 material is present both on the ball surface and the seat, the high local contact stresses cause localized cold welding of portions of the seat to the ball surface.
3) Subsequent cycling of the valve causes local delamination of portions of the tungsten carbide coating when the local cold welded areas are pulled apart. This premise is supported by the observations of the ball and simulated seat surfaces in the friction test performed at about 55 ksi ball pressure. Pock marks were observed on both the seat and ball after 30 strokes of the valve during the test.
4) The loose hard tungsten carbide flakes removed from the ball surface cut the softer seat surface when the valve is cycled, causing the seal between the seat and ball surfaces to degrade.

'The licensee reported no identification of the root cause for the current problem leading to degradation of the tungsten carbide coating, but believes that several factors may be contributors. These factors are possible build-up of allowable tolerances in the valve conponents, valve assembly problems, and a gap to provide clearance for thermal Expansion when the valve is hot. In addition, the preoperational testing of the valves that has been performed to date has been done cold and dry, which deviates from inservice wetted conditions.

The staff agrees that the factors discussed above could lead to situations where the friction between the ball and the seats could increase, the contact pressures could increase, and the propensity for " rocking" of the seats could also increase. Further, the staff believes that the stroking of the MSIVs dry during the preoperational testing is a significantly different operating condition from the 75 cycle test that was performed previously. In the 75 cycle test the licensee stated that the valve was wetted periodically during the test.

The licensee has performed an additional test. Specifically, the ball and seats from valve 6b were cycled 54 full and 54 partial strokes above the 10 full and 11 partial strokes accumulated from the preoperational testing to bound the expected number of valve closures at Nine Mile Point Unit 2 up to the first refueling outage. The licensee selected this particular ball and seats for additional testing because they were most severely degraded during the preoper-ational testing. The licensee intended this additional testing to be a demonstration that they had bounded any future degradation that might occur I if a valve with a delaminated ball surface and scratched i, eats were operated l

for.the balance of the first operating cycle. The staff believes that the results from this test, as well as the results from previous tests where the MSIVs have been cycled with the ball and seats damaged, indicate a low likeli-hood of catastrophic failure of the seats, therefore, any leakage that would L___-____-_-___.

occur would be around the degraded seats. However, the staff does not agree that this 54 stroke test provides a quantitative bound on the maximum leakage for a valve with a damaged ball and seat that was operated for the balance of the operating cycle. Nevertheless, the prototype testing committed to by the _ licensee should provide additional insights concerning maximum leak rates.

2.2 MSIV Leakage Testing For the first 38 full and 38 partial closures of the test with the valve with the 6b ball, the ball was wetted with water prior to closure to simulate normal plant operation due to steam condensation on the outer surface of the ball. During testing with the wetted ball, the leakage increased from 5.5 to 8.8 SCFH. After 16 full and 16 partial closures with a dry ball the leakage increased from 8.8 to 16.9 SCFH. This test indicated that the rate of increase in leakage per valve cycle was reduced by a factor of 6 by wetting the ball. The 75 cycle test with balls periodically wetted also showed reduced wear. From these observations it is surmised that the wetted ball, ,

and possibly a film of condensate on the ball during normal plant operation, ,

may reduce wear and enhance valve performance. The effectiveness of film s condensation on the ball will be demonstrated during prototype testing.

To monitor MSIV valve leakage performance during the first fuel cycle of plant

operation, Type "C" leakage tests will be performed after the first outage (but I within 30 days of), after the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run, during the mid-cycle outage, j and after shutdown at the end of the cycle. The .100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run Type "C" I test is expected to occur about 8 months after criticality, after 17 full and 8 partial valve closures. The mid-cycle Type "C" test is expected to occur about 14 months after criticality, with a total of 28 full and_14 partial valve closures. The first refueling outage is projected to occur about 26 months I after criticality, with a total of 33 full and 26 partial valve closures. The 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run Type "C" testing is required by a license condition and the mid-cycle Type "C"' testing is required to meet the 18 month requirement in the Technical Specifications. The licensee, in a letter dated January 27, 1987 (NMP2LO980),hascommittedtorestoreNineMiiePointUnjt2MSIVssuchthat they meet Technical Specification limit during the first refuel
infcycle if l Type "C" testing exceeds 6 SCFH. Furthermore, the licensee has' expressed confidence that these valves will meet Technical Specification requirements when tested after the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warran',y run. By letter dated January 23, 1987 (NMP2LO977) as supplemented by their letter of February 3,1987 (NMP2L 0990),

the licensee states that future MSIV 10 CFR 50, Appendix J Type "C" leak rate testing will meet Technical Specification surveillance requirements.

2.3 Prototype Test Program The prototype testing of the MSIV is described in a licensee letter dated January 27, 1987 (NMP2LO981). The prototype testing is scheduled to be completed in the spring of 1987. The prototype test results will be available to the staff about six months prior to the plant Type "C" MSIV leakage test following the 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run. The results of the prototype test will determine the need for additional MSIV leakage testing at Nine Mile Point Unit  ;

2. The prototype test objectives are:

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. - . Verification of the mechanical integrity of th'e valve and the actuator for the expected operating and test cycles.

Demonstration of valve leak tightness for the expected valve duty cycles.

. Den.onstration of the ability to close the valve within the Technical Specification limits under normal operating pressure, temperature and steam conditions.

Verification of.the conservatism of the between-the-seat leak test method as an alternative to across-the-valve seat leakage tests.

- Provision of baseline data for the evaluation of (1) the long-term suitability of the valve and (2) potential design and material improvements.

As part of the long term MSIV prototype test program the following additional areas will be investigated:

1. Further evaluation of the effects of valve ball to seat interface and orientation.
2. Further evaluation of friction effects between the ball and seat.
3. Furtner evaluation of packing design, alternate coatings, alternate spring loads, and seat rocking.

The prototype test program is intended to simulate the valve cycles that the MSIVs are projected to experience during the first operating cycle. The prototype test will simulate the valve closure cycles under p hnt inservice conditions of normal operating temperat:Jre, pressure, and best achievable steam flow conditions (minimum of 300,000 lbs/hr: ~ 8% of full power steam flow). Type "C" leakage tests will be performed after valves have been :ycled to simulate the plant MSIV leakage tests at a) 100 hour0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> warranty run, b) mini outage, and c) end of first operational cycle. There will be an additional leakage test in the prototype test series midway between the mini outage and the end of the operational cycle. The performance criterion for these tests is a leak rate not exceeding 17 SCFH (leakage for valve with the 6b ball after completion of the testing cycle). The licensee has committed to inform the NRC when the leakage rate in the prototype test exceeds the Technical Specifi-cation limit of 6 SCFH in a letter dated February 3,1987 (NMP2LO990). In contrast to MSIV maintenance during the first operating cycle at Nine Mile Point Unit 2, the prototype test valve will not be restored to meet the 6 SCFH Technical Specification leakage limit. Should the leakage exceed 6 SCFH, the prototype test will be continued to completion to confirm that the 17 SCFH leakage rate observed in the 6b ball test is the upper bound for one operating cycle. The licensee has committed to restore Nine Mile Point Unit 2 MSIVs such that they meet Technical Specification limits during the first refueling cycle when Type "C" testing exceeds 6 SCFH.

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l At the completion of the simulated first operating cycle of the prototype test, the valve will be disassembled partially and the ball and seat wili be inspected l for wear, scoring and/or damage marks. The valve will be reassembled with replacement packings and a bonnet seal. A second prototype test series will l be conducted to simulate again valve closures and operational conditions during plant MSIV preoperational testing and inservice operation for the first operational cycle. Prior to the simulated startup phase of the second test series, the prototype valve will be cycled in a manner similar to that experienced at ni.ne Mile Point Unit 2 during preoperational non-steam conditions (12 full and 7 partial cycles). The balls will be stroked both wetted and dry, in l order to simulate the conditions experienced during plant preoperational testing. Type "C" leakage test will be performed to meet the 6 SCFH (across the valves) Technical Specification limit. The preoperational test sequence should provide information on the effect of valve stroking in the dry condition on leakage rates. The preoperational test will be followed by the complete hot operational test sequence performed in the first prototype test series. The first and second test series will be repeated with a second tungsten carbide coated ball to gain additional confidence on valve leakage performance (NMP2LO990 dated February 3, 1987) and to demonstrate repeatability of the test.

The staff will review the results of the prototype testing and will make a determination whether the additional Type "C" leakage test presently scheduled for the Nine Mile Point Unit 2 MSIVs is adequate. Additional Type "C" leakage tests may be required if the leakage rate exceeds 6 SCFH during L the prototype test program.

2.4 Radiological Evaluation The damaged ball and seats of valve 6b were tested to determine the potential for degradation in valve leak tightness capability. The test was performed for a number of valve cycles that is greater than that expected to be experienced by the Nine Mile Point Unit 2 MSIV during the first refueling cycle. The leakage rate at the> conclusion of the test was 16.9 SCFH through the seats. The concern with respect to this leakage rate, which exceeds the 6 SCFH Technical Specification'11mit, is whether it will affect the health '

and safety of the prblic as well as the control room operators.

Three radiologically related criteria have been used to evaluate possible potential leakage rates which can exceed Technical Specifications. These

criteria are applied to the estimation of offsite and control room operator doses assuming a design basis loss of coolant accident (LOCA). Other design bases accidents for which the MSIVs can contribute to the dose consequences l include a steam line break. However, they are not considered bounding because of the conservative substantial core melt fission product assumptions used in the LOCA assessment.

The staff has reviewed the licensee's submittal dated January 14, 1987,  ;

(NMP2L0971). In this submittal, the licensee provides calculations to evaluate l the impact of increasing the total MSIV leakage rate to 150 SCFH on the post- '

LOCA radiological doses. Specifically, the licensee estimates post-LOCA doses l

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at the exclusion area boundary (EAB) the outer boundary of the low population zone (LPZ) and the control room. The EAB and LPZ dose estimates are used to show compliance with 10 CFR 100, and the control room operator doses are used to show compliance with the dose guidelines of GDC 19, Appendix A of 10 CFR 50.

This analysis is based on the isolated condenser case of NUREG-1169, using the large volume of the condenser to hold up the MSIV leakage. The holdup permits the consideration of radioactivity decay and iodine plateout for the bounding design basis LOCA. The licensee's analysis indicates that the p-skin dose in the control room is the limiting dose. Specifically, the licensee indicates that the MSIV leakage can be as high as 38 SCFH per valve, or 150 SCFH total for the four lines without the control room p-skin dose exceeding GDC 19 dose guidelines. On the basis of our review the staff concludes that the licensee's estimate of dose reduction by taking credit for the isolated condenser is reasonable.

Thyroid doses at the EAB, the LPZ and in the control room are estimated to be below the 10 CFR Part 100 and GDC 19 guidelines because of the additional credit for plateout in the isolated condenser. Whole body doses at EAB, LPZ and control room are estimated to be comparatively low, and are not expected to exceed the above guidelines. That is, given the unlikely event that an accident as severe as a design basis LOCA were to occur during the first fuel cycle, a quasi-realistic assessment of the offsite and onsite doses indicates that both 10 CFR 100 and GDC 19 of 10 CFR 50 are met.

2.r Types of Leakage Tests Two types of leakage tests have been performed on the MSIVs. The normal through the valve test, which tests leakage in tt.e same direction as would be required for the valves to perform their safety function, is used for demonstrating conformance with the Technical Specifications. The licensee also has been using between the seat leakage testing for simplicity and reduced testing time. This test measures the total leakage through both the inlet and outlet seats. The leakage through the valve should not exceed half the  !

total leakage through the inlet and outlet seats. Therefore, a 6 SCFH through "

, - l the valve leakage is equivalent to a minimum value of 12 SCFH between the seat {

leakage. In letter dated August 21, 1986 (NMP2LO835), the licensee indicates ^

that the calculated maximum between the seat leakage is 14.86 SCFH (a factor of ,c ,

2.5 greater than the allowable 6 SFCH through the valve leakage). During 6b _

valve testing both between the seats and through the valve leakage testing were conducted. The average ratio of between the seats to through the valve leakage was 3.3, with a range of 2.6 to 4.3. However, leakage tests on the new .

tungsten carbide coated ball and modified seat spring configuration after 75 )

cycles, indicated ratios slightly above 2.0, as well as values below 2.0. The I data has been reviewed and the values below 2.0 are believed to be due to test inaccuracies since normal Appendix J testing procedures were not followed for '

' these test data. Nevertheless, on the basis of information available, the staff cannot support a between the seat to through the valve leakage ratio greater than 2.0. Therefore, the staff would accept a 12 SCFH between the seat leakage test as meeting the 6 SCFH Technical Specification limit that applies to through the valve testing. The 12 SCFH acceptance criterion for between the l seat testing Nine Mile Point Unit 2 MSIVs will be incorporated into the Technical Specifications issued with the fbil power operating license.

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3.0 CONCLUSION

S On the basis of the evaluation above, the staff concludes that Nine Mile Point Unit 2 may resume plant startup testing and operation for the first operating cycle with the installed refurbished MSIVs. However, due to lack of resolution of the. root cause of the valve' leakage degradation problem and uncertainty in valve performance during the first refueling cycle, the staff intends to assess

. carefully the results of the prototype test. On the basis of this assessment, the staff may determine it to be necessary to require additional leakage testing of the plant MSIVs, above and beyond that which is required in the current license condition.

The staff's review of the licensee's realistic dose estimates indicates that in the event a bounding design basis LOCA and for reasonable assumptions of leakage in excess of Technical Specification values (the licensee evaluated a total leakage up to 150 SCFH through all four MSIV lines), doses exceeding the guidelines of 10 CFR.100 and GDC 19 would not occur. The staff has reasonable assurance that MSIV total line leakage will be less than Technical Specifica-tion values. However, if leakage were to exceed those values, our review indicates that through the first refueling cycle accidents should not affect the health and safety of.the public or control room operators.

Between the seat leakage testing of the ball type MSIVs has been found expedient and provides conservative results in comparison to through the valve testing.

The staff concludes that a between the seat leakage test of 12 SCFH is equiva-lent to a through the valve test of 6 SCFH. The 12 SCFH leakage test will be incorporated into the Technical Specifications issued with the full power operating licensee.

Principle Reviewers:

K. Campe A. Chu T. Collins '

R. Hermann J. Kudrick F. Witt

1.

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.l SALP INPUT FROM THE PLANT' SYSTEMS BRANCH FOR NINE MILE POINT, UNIT 2 (TAC # 63454)~

1 A. Licensing t-+4vities i N '1.- Management Involvement in Assuring Quality.

1 During the initial review process, there was early evidence.~of.

valve problems at another plant. Management involvement should -

.have prevented the issue from occurring, or occurring so late in - 1 the licensing process by getting involved early to fix the problem.

Rating: F  ;

2. Approach to Resolution of Technical Issues from a' Safety Standpoint.

'During the review there was generally timely resolution of issues.

Rating: 2

3. Responsiveness to NRC Initiatives.

The licensee has applied a comprehensive effort to resolve this problem and has expedited a prototype program to verify acceptable plant MSIV performance. Considerable NRC effort was expended on obtaining information needed for the review from the licensee.

Rating: 2

4. Staffing (Including Management)

Rating: N/A

5. Reporting and Analysis of Reportable Events.

l Rating: N/A

6. Training and Qualification Effectiveness.

Rating: N/A

7. Overall Rating for Licensing Activity Functional Area: '

Rating: 3 l

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' 50 410 DISTRIBUTION:

-Docket No.:

Docket Files

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MEMORANDUM FOR: Elinor Adensam, Director DBL:PSB Rdg File Project Directorate #3 FWitt Division of BWR Licensing JKudrick WHodges

[ PHermann Glainas FROM: Gus C. Lainas, Assistant Director BDLiaw Division of BWR Licensing TCollins

SUBJECT:

SAFETY EVALUATION FOR OPERATION OF MAIN STEAM ISOLATION VALVES DURING FIRST FUEL CYCLE WITH REFURBISHED SEAT AND BALL (LEAK INTEGRITY PROBLEM - TAC # 63454)

By letters dated January 14, 23 and 27 and February 3, 1987 (NMP2L 0971, 0977, 0980, 0981, and 0990), the licensee has provided additional information on the Nine Mile Point Unit 2 Main Steam Isolation Valve'(MSIV) leakage problem which supplements that which.was evaluated in our October 27, 1966 SER. Thic information describes the recurrence of the MSIV leakage problem during preoperational testing in December,1986, additional valve stroking and leak testing, as well as details on the MSIV prototype test program.

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The enclosed SER covers the expected MSIV performance, MSIV leakage testing, the prototype test program, the radiological evaluation of MSIV leakage greater than Technical Specificatier, limits, and the equivalence of a 12 SCFH between the seat leakage test to that of a 6 SCFH through the valve test. From the standpoint of valve leak tightness, we find that Nine Mile Point Unit 2 may resume startup testing'and operation for the first operating cycle with the installed refurbished MSIVs. The two additional MSIV problems on defective actuator and actuator control system logic are being addressed in separate SEPs. ,

Our SALP input is also enclosed, w

Gus C. Lainas, Assistant Director Division Qf BWR Licensing

Enclosures:

As stated cc w/ enclosures:

R. W. Houston M. Haughey C. McCracken R. Hermann J. Calvo R. Stevens R. Bosnak J. Lombardo F. Witt, X29440 PSB:D AD:

Contact:

y' AChu  %-X[L mpe GL - s (5520 Document Name: NMP-2 MAIN STEAM ISOLATION) 2Pg 07) 2/(e/87 2/ /87

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