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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17313B0991999-10-14014 October 1999 Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing ML17313B0881999-10-12012 October 1999 Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2 ML17300B3501999-09-29029 September 1999 Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7 ML17300B3551999-09-28028 September 1999 Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl ML17313B0851999-09-24024 September 1999 Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles ML17313B0781999-09-20020 September 1999 Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included ML17300B3331999-09-14014 September 1999 Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3 ML17300B3351999-09-0808 September 1999 Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met ML17313B0761999-09-0303 September 1999 Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H ML17313B0731999-08-31031 August 1999 Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML17313B0581999-08-0606 August 1999 Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included ML17313B0311999-08-0303 August 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17313B0431999-07-30030 July 1999 Advises of Listed Senior Mgt Changes That Have Taken Place at Plant ML17313B0441999-07-30030 July 1999 Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps. ML17313B0151999-07-20020 July 1999 Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys ML17313B0091999-07-20020 July 1999 Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1 ML17313B0171999-07-16016 July 1999 Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations ML17300B3111999-07-15015 July 1999 Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr ML17300B3141999-07-15015 July 1999 Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790 ML20209G6771999-07-0808 July 1999 Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl ML17300B2931999-07-0202 July 1999 Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval ML17313A9951999-06-26026 June 1999 Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML17300B2831999-06-26026 June 1999 Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl ML17313A9901999-06-15015 June 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr ML17313A9521999-05-24024 May 1999 Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55 ML20206Q3111999-05-18018 May 1999 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety ML17313A9311999-05-13013 May 1999 Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload ML17313A9481999-05-12012 May 1999 Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address ML17313A9261999-05-0707 May 1999 Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML17313A9091999-04-30030 April 1999 Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld ML17313A9181999-04-30030 April 1999 Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790 ML17313A9191999-04-30030 April 1999 Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422 ML17300B3751999-04-23023 April 1999 Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool ML17313A9081999-04-23023 April 1999 Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531 ML20205T7421999-04-21021 April 1999 Forwards Partially Withheld Insp Repts 50-528/99-05, 50-529/99-05 & 50-530/99-05 on 990322-26.Determined That Security Program Properly Implemented.Insp Repts Details Withheld (Ref 10CFR73.21) ML17313B0271999-04-21021 April 1999 Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl ML17313A9031999-04-21021 April 1999 Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection ML17313A8971999-04-20020 April 1999 Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections 05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999 Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing ML17313A8931999-04-14014 April 1999 Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met ML20205Q0821999-04-13013 April 1999 Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item ML17313A8901999-04-13013 April 1999 Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing ML17313A8831999-04-0808 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3 ML20205F3491999-03-30030 March 1999 Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1) ML17313A8671999-03-24024 March 1999 Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3) ML17313A8601999-03-16016 March 1999 Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon ML17313A8551999-03-0505 March 1999 Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17313B0991999-10-14014 October 1999 Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing ML17313B0881999-10-12012 October 1999 Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2 ML17300B3501999-09-29029 September 1999 Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7 ML17300B3551999-09-28028 September 1999 Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl ML17313B0851999-09-24024 September 1999 Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles ML17313B0781999-09-20020 September 1999 Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included ML17300B3331999-09-14014 September 1999 Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3 ML17300B3351999-09-0808 September 1999 Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met ML17313B0761999-09-0303 September 1999 Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H ML17313B0731999-08-31031 August 1999 Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55 ML17313B0581999-08-0606 August 1999 Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included ML17313B0311999-08-0303 August 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001 ML17313B0441999-07-30030 July 1999 Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps. ML17313B0431999-07-30030 July 1999 Advises of Listed Senior Mgt Changes That Have Taken Place at Plant ML17313B0151999-07-20020 July 1999 Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys ML17313B0091999-07-20020 July 1999 Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1 ML17313B0171999-07-16016 July 1999 Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations ML17300B3111999-07-15015 July 1999 Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr ML17300B3141999-07-15015 July 1999 Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790 ML20209G6771999-07-0808 July 1999 Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl ML17300B2931999-07-0202 July 1999 Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval ML17313A9951999-06-26026 June 1999 Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML17300B2831999-06-26026 June 1999 Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl ML17313A9901999-06-15015 June 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr ML17313A9521999-05-24024 May 1999 Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55 ML17313A9311999-05-13013 May 1999 Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload ML17313A9481999-05-12012 May 1999 Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address ML17313A9261999-05-0707 May 1999 Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML17313A9191999-04-30030 April 1999 Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422 ML17313A9181999-04-30030 April 1999 Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790 ML17313A9091999-04-30030 April 1999 Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld ML17313A9081999-04-23023 April 1999 Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531 ML17300B3751999-04-23023 April 1999 Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool ML17313B0271999-04-21021 April 1999 Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl ML17313A9031999-04-21021 April 1999 Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection ML17313A8971999-04-20020 April 1999 Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections 05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999 Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing ML17313A8931999-04-14014 April 1999 Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met ML20205Q0821999-04-13013 April 1999 Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item ML17313A8901999-04-13013 April 1999 Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing ML17313A8831999-04-0808 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3 ML20205F3491999-03-30030 March 1999 Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1) ML17313A8671999-03-24024 March 1999 Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3) ML17313A8601999-03-16016 March 1999 Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon ML17313A8551999-03-0505 March 1999 Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe ML17313A8241999-02-23023 February 1999 Advises That Kp Jarvis,License OP-50287-1,no Longer Needs to Maintain License as Permanently Assigned to Position Requiring No License ML17313A8111999-02-18018 February 1999 Forwards PVNGS Unit 3 7th Refueling Outage, Which Provides Complete Results of SG Tube Inservice Insp Performed,Per TS 5.6.8 ML17313A8721999-02-16016 February 1999 Discusses Resolution of Generic Safety Issue 171, ESF Failures from Loss-of-Offsite Power Subsequent to Loca. Util Has Low Vulnerability to Loca/Grid Collapse/Loop Scenario ML17313A7611999-01-22022 January 1999 Forwards PVNGS Unit 3 Inservice Insp Rept Seventh Refueling Outage, Per 10CFR50.55a.Ltr Contains No New Commitments 1999-09-08
[Table view] Category:UTILITY TO NRC
MONTHYEARML17305B0681990-09-17017 September 1990 Forwards Response to Generic Ltr 90-07, Operator Licensing Natl Exam Schedule. Exam Dates,Anticipated Number of Candidates & Requalification Exam Schedules for FY91-FY94 Also Encl ML17305B0491990-09-12012 September 1990 Forwards Palo Verde Nuclear Generating Station Unit 2 Steam Generator Eddy Current Exam,Second Refueling Outage Apr 1990. ML17305B0281990-08-27027 August 1990 Forwards fitness-for-duty Semiannual Performance Rept for Period of Jan-June 1990,per 10CFR26.71(d) ML17305B0111990-08-15015 August 1990 Responds to Request for Addl Info Re Emergency Lighting,Per Insp Repts 50-528/90-25,50-529/90-25 & 50-530/90-25. Availability Info Provided in Ref 2,most Appropriate Analysis of Lighting Sys Availability ML17305B0021990-08-0909 August 1990 Provides Update on Status of Record 546 post-restart Item, Per 900412 Ltr.Record Will Revise Procedures for Analyzing & Disseminating Incident Investigation,Operations & Maint Experience to Appropriate Dept ML17305A9871990-08-0303 August 1990 Forwards Rev 1 to Abb Impell Rept 01-1658-1815, Emergency Lighting Independent Review, Per Insp Repts 50-528/90-25, 50-529/90-25 & 50-530/90-25 ML17305A9791990-07-31031 July 1990 Forwards, Conceptual Design for Palo Verde Nuclear Generating Station for Diverse Auxiliary Feedwater Actuation Sys (Dafas) for Review.Schedule of Implementation as Indicated ML20056A4161990-07-31031 July 1990 Forwards Revised Security Plan Implementing Procedures.Encl Withheld (Ref 10CFR2.790) ML17305A9831990-07-27027 July 1990 Requests Temporary Waiver of Compliance from Limiting Condition for Operation 3.6.3 to Allow Corrective Maint to Be Performed on Main Feedwater Isolation Valves by Extending Allowed Outage Time to 12 H Instead of 4 H ML20055J2671990-07-25025 July 1990 Forwards Info Constituting Decommissioning Financial Assurance Certification Rept,Per 10CFR50.33(k)(2) & 50.75(b) ML17305A9771990-07-25025 July 1990 Forwards Status of Corrective Actions to Min Multiple Control Element Assembly Drop Events at Plant.Insp of Insulation Coils & Replacement of Defective Coils for Units 1 & 2 Completed ML20055J1031990-07-25025 July 1990 Forwards Certification of Decommissioning Financial Assurances ML20055J1711990-07-25025 July 1990 Forwards Certification of Decommissioning Financial Assurances for Plant,Per 10CFR50.75(b) & 50.33(k)(2) ML17305A9411990-07-20020 July 1990 Forwards Response to NRC Bulletin 90-001, Loss of Fill Oil in Transmitters Mfg by Rosemount. ML17305A9431990-07-17017 July 1990 Forwards Rev 1 to Palo Verde Nuclear Generating Station Annual Radiological Environ Operating Rept for 1987. Rev Results from Internal Review Bu Nuclear Safety Group & Audit Performed by Radiation Protection Stds ML17305A9601990-07-13013 July 1990 Forwards Preliminary Response Re Justification for Continued Operation of Fire Protection Sys Equipment,Per Insp Repts 50-528/90-25,50-529/90-25 & 50-530/90-25 ML17305A9331990-07-12012 July 1990 Discusses Util Compliance w/fitness-for-duty Program Implementation.Lab Specialists,Inc Audited & Monitored W/ Satisfactory Results.Ltr of Agreement Has Been in Place Since 900202 ML17305A9391990-07-0909 July 1990 Forwards Endorsement 44 to Maelu Policy MF-116 & Endorsement 62 to Nelia Policy NF-266 ML17305A9341990-07-0909 July 1990 Submits Results of 900514-18 NUREG-1220 Audit,Per NRC 900608 Request,Per Insp of Plant.Remaining Licensed Operators Found to Be in Conformance W/Medical Exam Requirements of 10CFR50.55 ML17305A9151990-06-29029 June 1990 Forwards Emergency Lighting Failure Data Update,Per 900621 Request ML17305A9061990-06-26026 June 1990 Suppls 891114 Response to Violations Noted in Insp Rept 50-528/89-16.Application for Amend to License NPF-41 Will Be Submitted in Oct 1990 to Permit Lower Flow Rate for RCS & Shutdown Cooling Sys ML17305A9111990-06-25025 June 1990 Responds to Generic Ltr 90-04, Status of Implementation of Generic Safety Issues. ML17305A9081990-06-25025 June 1990 Forwards Schedule Reiterating Util Plans for Implementation of USIs A-9 & A-44 & Provides Current Forecast Refuel Dates ML17305A9051990-06-25025 June 1990 Forwards Endorsement 45 to Maelu Policy MF-116 & Endorsement 63 to Nelia Policy NF-266 ML17305A9121990-06-24024 June 1990 Forwards Discharge Test Voltage Curve,Per 900623 Request for Completion of Emergency Lighting Exide Power Supply Prior to Entry Into Mode 2 ML17305A9171990-06-24024 June 1990 Confirms Compliance W/Agreed Upon Course of Action for Restart of Facility as Outlined in 891224 Ltr & Completion of Items Contained in Restart List Provided as Attachment to 900111 Ltr ML17305A8961990-06-20020 June 1990 Responds to NRC 900521 Ltr Re Violations Noted in Insp Repts 50-528/90-12,50-529/90-12 & 50-530/90-12.Corrective Action: Wiring in PPS Cabinets & Cabinet Drawers Reworked in Accordance W/Approved Work Authorization Documents IR 05000528/19900021990-06-19019 June 1990 Describes Current Status & Provides Description of Actions Taken to Ensure Continued High Reliability of Emergency Lighting Sys,Per Insp Repts 50-528/90-02,50-529/90-02 & 50-530/90-02.Emergency Lights Mfg by Emergi-Lite ML17305A9041990-06-19019 June 1990 Describes Current Status & Provides Description of Actions Taken to Ensure Continued High Reliability of Emergency Lighting Sys,Per Insp Repts 50-528/90-02,50-529/90-02 & 50-530/90-02.Emergency Lights Mfg by Emergi-Lite ML17305A8891990-06-15015 June 1990 Informs NRC That post-restart Items Due Prior to Scheduled Restart Have Been Completed on Schedule W/Listed Exceptions ML17305A8871990-06-14014 June 1990 Advises That Fuel Pool Cooling & Cleanup Procedures Being Restructured,Per Response to Violations in Insp Repts 50-528/89-36 & 50-530/89-36 ML17305A8731990-06-0808 June 1990 Responds to Bulletin 88-005 Re Product Forms Other than Fittings & Flanges for Plant.Significant Number of Lugs Delivered to Plant.Util Should Be Notified,If NRC Previous Review of Records Has Identified Other Product Forms ML17305A9421990-06-0101 June 1990 Forwards Pinnacle West Response to State of Az Corp Commission Complaint Filed W/Us Securities & Exchange Commission on 900521,to Revoke Exemption from Public Utils Holding Co Act ML17305A8391990-05-31031 May 1990 Forwards 1990 Reactor Containment Bldg Integrated Leak Rate Test,Final Rept. ML17305A8571990-05-31031 May 1990 Forwards Amended Pages of Feb,Mar & Apr 1990 Monthly Operating Repts for Palo Verde Nuclear Generating Station Unit 2 ML17305A8661990-05-31031 May 1990 Forwards Projected 1990 Cash Flow Statements ML17305A8201990-05-23023 May 1990 Provides Status of Improvements to Eliminate Possibility of Multiple Control Element Assembly Drop Events.Licensee Developed Mod to Ground Fault Detection Sys to Assure Continuous Monitoring & Annunciation of Any Future Faults ML20043B6421990-05-19019 May 1990 Forwards Amend 26 to Security Plan.Amend Withheld (Ref 10CFR2.790(d) & 10CFR73.21) ML17305A7841990-05-15015 May 1990 Forwards Special Rept 2-SR-90-002 Re Steam Generator Tube Plugging Due to Inservice Insp Activities.Twenty Tubes Plugged in Steam Generator 1 & ninety-one Tubes Plugged in Steam Generator 2 ML17305A8721990-05-14014 May 1990 Forwards Arizona Corp Commission Complaint Filed W/Us Securities & Exchange Commission Seeking Revocation or Mod of Exemption of Pinnacle West Capital Corp.Complaint Wholly W/O Merit ML17305A7621990-05-11011 May 1990 Responds to NRC 900413 Ltr Re Violations Noted in Insp Repts 50-528/90-03,50-529/90-03 & 50-530/90-03.Corrective Actions: Night Order Written for Guidance on Use of Instrumentation W/Maint Tag Present ML17305A7921990-05-0808 May 1990 Forwards Public Version of Rev 2 to EPIP-14, Dose Assessment. W/900523 Release Memo ML20043A0511990-05-0303 May 1990 Forwards Public Version of Revised Epips,Including Procedure Change Notice 11 to Rev 12 to EPIP-04 & Procedure Change Notice 1 to Rev 6 to EPIP-15 ML17305A7421990-05-0303 May 1990 Responds to 900330 Enforcement Conference Re Violations Noted in Insp Repts 50-528/90-04,50-529/90-13 & 50-530/90-13.Corrective Action:Special Locking Mechanisms Installed on Currently Posted Radiation Area Doors & Gates ML17305A8861990-04-30030 April 1990 Forwards EPIP Update,Including Rev 7 to EPIP 02,Rev 12 to EPIP 03 & Rev 9 to EPIP 20.W/o Encl ML17305A7381990-04-30030 April 1990 Forwards Annual Environ Operating Rept for 1989 & Annual Rept for Salt Deposition Monitoring Program 1989. ML17305A7131990-04-20020 April 1990 Responds to NRC 900321 Ltr Re Violations Noted in Insp Rept 50-530/90-08.Corrective Action:Plant Guideline Providing Addl Guidance Re Prioritization of Work Promulgated ML17305A6891990-04-16016 April 1990 Forwards Rev to Cycle 3 Reload Analysis Rept,Submitted 891024.Rev Reflects Early end-of-cycle Unit Shutdown & Replacement of Eight New Fuel Assemblies ML17305A7011990-04-12012 April 1990 Forwards Rev 3 to Palo Verde Nuclear Generating Station Post-Restart Actions, Per JB Martin 891224 Ltr ML17305A7081990-04-0909 April 1990 Forwards post-exam Security Agreements for Dk Hendrick, D Ensign,M Alavi & Author.Agreement Certifies That Signatories Will Not Divulge Info Re 900320 Exams 1990-09-17
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fFl Arizona Public Service Company I535 HhR I l g) 8: ~.
p ANPP-32088;PEVB Jr/WE I/WFQ March', ""1985""
U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane Suite 210 Walnut Creek, California Attention: Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3 Docket Nos. 50-528 (License No. NPF-34)/529/530 Investigation of Allegation NRC Concern RV-84-A&87; No. 154 File: 85-019-026 D.4.33.2
Reference:
NRC Letter from D. F. Kirsch to E. E. Van Brunt, Jr.,
dated January 31, 1985
Dear Sir:
As requested in the referenced letter, ANPP has investigated the concerns expressed by a confidential alleger. The results of this investigation are attached. Several of these concerns had previously been investigated by ANPP. However, based on our review, further investigation is required on the first concern. This investigation is expected to be completed on April 15, 1985.
If there are questions regarding these investigations or the results, please contact us.
Very truly yours, E. E. Van Brunt, Jr.
Executive Vice President Prospect,Director EEVB/WEI/dim Attachment cc: L. F. Miller R. P. Zimmerman E. A. Licitra A. C. Gehr 85032 lpq26 850307 PgR ADOOC~ ggPOO528 PDR P
n e 4 3 ~
ATTACHMENT A Down adin of Test ui ment S ecifications RV&4-A-87'o. 154'oncern 1 Concern:
ll Test e ui ment '
ecifications were arbitraril modified (e. . rod oven thermometers micrometers Holida detectors and Ashcroft ressure au es .
Xnvesti ation Results:
Work Plan Procedure, WPP/QCI 7.0, entitled, "Calibration and Control of Con-struction Measuring and Test Equipment", allows the Instrument Control Lead Engineer (ICLE) to establish accuracies for Measuring and Testing Equipment based on Project requirements. This accuracy may be different than that specified by the manufacturer, depending on the use of the Measuring and Test Equipment. A review was conducted of the equipment specified in this concern to identify if the accuracy specified by the ICLE was different than that The results of that review specified by the instrument and manufacturer.
indicate the following:
- a. Rod Oven Thermometers:
The manufacturer's specified accuracy is +10'F. The accuracy speci-fied by the ICLE for use at PVNGS was +20'F. Given the broad acceptable range of temperatures at which weld rod can be stored; i.e., 200'F-350'F, the range specified by the ICLE appears prudent.
However, as a result of this investigation, it appears that, in the worst case, rod oven temperature could be allowed to drop below Therefore, this matter is currently being investigated. '00'F.
- b. Micrometers:
Micrometers are calibrated utilizing gauge block sets traceable to the National Bureau of Standards. In reviewing this concern, cali-bration records associated with five (5) micrometer sets were reviewed. It appears that, in one case, an error which exceeded the manufacturer's tolerance was accepted. Additional investigation is required to determine if and why this error was accepted.
- c. Holida Detectors:
Holiday detectors do not require rigorous calibration. Rather, detectors are field adjusted. The field adjustment is clearly defined in the Project Specifications 13-PM-204 and 13-PM-205. Dis-cussions were conducted with cognizant personnel and provided assur-ance that personnel'nderstood the procedure. No discrepancies were noted.
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Attachment,A ANPP-32088 Page Two
- d. Ashcroft Pressure Gau es'.
Ashcroft Pressure Gauge Model 1320A has a manufacturer's specified accuracy of +1/2X. The required accuracy at PVNGS has been specified by the ICLE as +1X. Based on the use of this type of gauge in hydro-static testing, this accuracy appears acceptable. However, this evaluation is not complete considering the potential uses of these gauges.
Based on the initial results of this investigation, a more detailed investiga-tion is necessary and will be conducted. The scheduled completion date for this investigation is April 15, 1985.
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Attachment A ANPP-32088 Page Three Weld-AMP Monitors (RV-84-A-87'o. 15 Concern 2)
Concern:
The use of Weld-AMP Monitors was arbitraril sus ended and the Weld Monitors were not calibrated when the were used.
Investi ation Results:
Procedure Change Notice (PCN) No. 27 was approved July 30, 1979 and deleted the requirements of Paragraph 11.0, WPP/QCI No. 101.0. The PCN deleted the procedural requirement for checking voltage and amperage during in-process welding operations on material requiring Charpy "V" Notch (CVN) testing. The monitoring of voltage/amperage is not a Code requirement and is not an essen-tial welding performance variable. The reason for, deletion, stated on the PCN is as follows:
"Current and voltage variables do not require measurement or recording based on their self limiting nature and the insensitivity of P-1 and P-3 materials to the reduction of notch toughness properties with increasing heat input."
Further investigation for the procedural change was established by Bechtel Research and Engineering, Materials and Quality Services Department in their report, "Technical and ASME Code Considerations For Notch Toughness Tested Welding Procedure Qualifications", dated May 1978. Their data showed that for all likely conditions of welding, toughness was not diminished and that specific values of voltage, amperage or travel speed are not critical in developing acceptable toughness. M&QS also concluded that the materials of interest in the temperature range of interest are not toughness sensitive to welding variables.
Prior to the deletion of the voltage/amperage check, a calibrated Neoweld Model No. 38005 current/voltage monitor was utilized to check in-process welding operations. The instruments were maintained and calibrated by the Measuring and Test Equipment Lab (M&TE) until they were decontrolled on February 12, 1981.
Based on a review of ASME Section IX and the M&QS technical report, the sus-pension of voltage/amperage monitoring was not arbitrary, but rather )ustified and can be substantiated.
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Attachment A ANPP-32088 Page Four Weldin Ox en Monitors (RV-84-A&4: No. 154 Concern 3)
Concern.'eldin ox en monitors were not ro erl calibrated.
Investi ation Results:
Welding oxygen indicators utilized at the Arizona Nuclear Power Project are Bacharach Instrument Company's Model K525. The Measuring and Test Equipment Lab (MSTE) performs maintenance on these instruments which includes reacti-vation of the oxygen cells and replacement of batteries. M&TE also performs a functional check of each unit prior to its leaving the Lab. Actual adjustment of the instrument is performed by the user in the field. Operation of the instrument is normal if the meter can be set to read 21X in atmospheric air (atmospheric air is the adjustment standard). The manufacturer's operating procedure is attached to t'e side of each unit and is self-explanatory. The program described above complies with the manufacturer's instructions.
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Attachment A ANPP-32088 Page Five Vendor Calibration (RV-84-A&7 No. 154'oncern 4)
Concern:
Test e ui ment vendor calibration standards were not traceable to the National Bureau of Standards.
Investi ation Results:
A review 'of the calibration, standards used by the Bechtel Metrology Laboratory was conducted to investing'ate the referenced, concern.
The scope of the review consisted of the following:
- 1. A review of the calibration log to identify those items used as standards.
- 2. From a review of the standards, identify those calibrated by an outside source.
- 3. Review the calibration certificates received to assure items were calibrated with traceability to NBS.
The investigation revealed:
- 1. All certificates reviewed, with the exception of two (2), either stated that the calibration was traceable to NBS or listed an NBS traceability number.
- 2. In the case of the two (2) exceptions, one (1) of the items was calibrated by another Calibration Lab prior to use by BPC. The Cali-bration Lab that did calibrate the item, did state the calibration was traceable to NBS. The other item has not been used as of this date. Calibration by an approved source with traceability to NBS will be required prior to use.
Based on the review of on-site documentation, it appears that vendor calibra-tion standazds are traceable to NBS. Audits of calibration vendors which have been conducted in the past have verified calibration standards traceable to NBS. Future audits of calibration vendors will verify the traceability of calibration standards to NBS.
Based on the investigation conducted as a result of this concern, additional questions were developed unrelated to this concern. These additional questions will be resolved in accordance with our quality program.
p Attachment A ANPP-32088 Page Six Field Test Instrument Re uest Multi le Use Lo RV-84-A-87; No. 154; Concern 5 Concern:
The Field Test Instrument Re uest-Multi le Use Lo did not accuratel record how test e ui ment was used b Bechtel or APS ersonnel.
Investi ation Results:
This concern had previously been investigation by ANPP. Previous reviews of the Measuring and Test Equipment (M&TE) program had revealed concerns related to the subject documents and their use. ANPP Audit C&3-3 conducted in February and March, 1983 noted deficiencies in the completion of the FTIR. As a result of the audit, the procedures were revised to include the Multiple Use Log (MUL).
A more recent investigation revealed that during the last Quarter of 1983, a significant portion of the entries on the FTIRWUL had to be corrected before they 'were acceptable administratively. A similar review for July, 1984 indicated a significant improvement in the Log. Additionally, it was found that in 'June/July, 1984, there were some minor problems in the issuance of M&TE when 'Calibration"Lab personnel were not -available. This,has been deter-mined to have been caused by unfamiliarity with a procedure change issued in June, 1984. More recent implementation has been acceptable.
ll C A more recent sample of sixty-six (66) instruments used for acceptance was conducted by reviewing whether the instruments indicated as used on acceptance work documents were so indicated on the FTIR-MUL. No discrepancies were noted. Additionally, nine (9) activities involving the use of M&TE were monitored in October, 1984. The use of the FTIR-MUL was observed to be proper for all of the monitored activities.
In summary, ANPP's review of this area had previously noted problems in the use of the FTIR MUL. Corrective action was taken. More recent reviews of the FTIR-MUL have indicated that the system has improved significantly and is working effectively.
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Attachment A ANPP-32088 Page Seven Corroded Structural Bolts (RV-84-A-87'o. 154 Concern 6)
Concern:
Some corroded structural boltin ma have been used in structures at Palo Verde.
Investi ation Results:
This concern had been thoroughly investigated prior to receiving the NRC concerns' search into the specific issue of possible usage of rusted bolts and the adequacy of bolting, in general, at PVNGS revealed the following:
Prior to October 3, 1984, there were not specific instructions on WPP/QCI No.
58.0 (Structural Steel Installation) concerning cleanliness and thread adequacy for bolted connections. Bolts were installed to standard industry practice with Craftsmen being instructed to only install clean and lubricated bolts (
Reference:
CAR CA-84-0343, Corrective Action Item 3). An Interoffice Memorandum had been generated on March 15, 1983 by the Bechtel Construction Manager reminding the Crafts of the importance of proper storage, preparation and installation of structural bolts.
On November 30, 1984, CAR CA-84-0343 was issued due to discovery of some rusty bolts in Unit 3 storage (outdoor) area during an ANPP investigation. At this point, it should be noted that discovery of rusted bolts in storage implies the possibility only, but does not necessarily mean that rusted bolts have been used.
Assuming a worst case scenario with the Crafts not taking any steps to clean the bolts before usage, the implication is that exerted torque may not induce the required tension in the bolt. This was examined by Bechtel under a more general scope of bolting adequacy with bolts being tested under various thread conditions and various lubricants used. It was discovered that even a light coating of rust does not prevent the bolts from being tensioned to acceptable values.
1 A secondary implication is that the bolt cross section is reduced due to rust. However, this is of no significance because properly torqued bolts experience the higher stress during installation due to: (a) Combination of tensile and torquing induced shear stresses; and (b) Subsequent time depen-dent relaxation of the induced stress. If the bolt "survives" installation, it will present no problems in the future.
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Attachment A ANPP-32088 Page Eight In addition, as a result of NRC's Construction Assessment Team (CAT) inspec-tion during September of 1983, all Accessible Critical Friction type connec-tions were re-torqued. (Inaccessible connections were determined that they will function satisfactorily per Reference B/ANPP-E-114700 letter, dated May 9, 1984. Also see NCRS CC-4689, 4690 and 4691).
The response to CAR CA&4-0343 also stated that (a) a search for identifica-tion of any other rusted bolts was made, and (b) there are no prior audits, surveillances or inspection reports identifying problems with installations of rusty bolts. In addition, Bechtel conducted a review of the Civil NCR Log to determine if such a concern had been identified in the past. This review, consisting of roughly 5,000 NCR's, identified only two (2) NCR's with the same concern (CC-2277, Steam Generator Anchor Bolt, dated November 18, 1980 and CY-4876, Spare Start-Up Transformer Foundation Anchor Bolts, dated September 14, 1984) which (a) is not considered a significant number, and (b) demon-strates the availability and usage of proper nonconformance and correcting mechanisms where bolt corrosion is considered significant.
Additionally, an independent assessment of bolting adequacy was conducted for ANPP entitled, "An Assessment of Bolting Integrity at PVNGS Units 1, 2 and 3",
by Structural Integrity Associates, Incorporated. This Report evaluates the use of rusted fasteners. It noted that visible surfaces of bolts observed were clean. The failure mechanisms for both overtorqued and undertorqued fasteners was examined. The Report concluded that because of the conservative design and correction of noted deficiencies 'in critical connections, bolting joint integrity at PVNGS is acceptable. This Report was forwarded to NRC Region V by Letter ANPP-31904-EEVB/WEI~Q on February 11, 1985.
Based on the 'evidence presented, as well as examination of design practices followed and resulting ample design margins, it is concluded that the concern of possible usage, of rusted bolts presents an insignificant possibility and, furthermore, the implied resulting undertorquing poses no concern to the safe operation of the plant.
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Attachment A ANPP-32088 Page Nine Tie Wra s Bolt Lubricant Cable Stri RV-84-A-87'o. 154'oncern 7 i
Concern:
Cable Tie Wra s were ti htened sufficientl to dama e lant cablin "WD-40" was ina ro riatel used for bolt lubricant and ocket knives were ina-ro riatel used to stri cable insulation.
Investi ation Results:
These 'conc'erne had previously been identified to ANPP and addressed. Each concern is addressed separately below:
- a. Cable Tie Wra s:
A review of project specifications/procedures produced no evidence of restrictive measures that require the control of installation of
'able ties. A recent Corrective Action Report (CAR) identified the concern. The engineering response to the subject explains that the cable jacket is a protective dielectric covering for the inner, insulated conductors and fillers. The primary purpose of the outer jacket is to protect the insulation of the inner conductors from damage throughout the life of the cable. Tie wraps may indent or extrude the outer jacket, but due to the inherent design pliability/
durability of the cable jacket, insulation damage of the inner conductors will not occur. To ensure a quality cable installation, cables axe required by specification to be sufficiently secured in vertical tray sections to prevent droop and sag. Technical guidance and surveillance is provided to prevent damage to the cable jacket and/or inner conductors. There has not been any conductor insulation failures at ANPP due to cable tie installation.
- b. "WD-40" was ina ro riatel used for bolt lubrication:
A review of procedures, specifications and Qality Assurance concerns revealed that the subject use of WD-40 has been previously addressed. Evaluation and acceptance of the construction practice has been a part of a Corrective Action response. There was no evidence found to indicate that WD-40 was used for other than the structural applications where WD-40 was approved for use. No safety concern was substantiated during the investigation.
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Attachment A ANPP-32088 Page Ten
- c. Pocket knives were ina ro riatel used to stri cable insulation:
A review of prospect specifications/procedures and Corrective Action Reports produced supporting evidence that recommends the use of knives and/or various other tools for wire/cable insulation strip-ping. A guide for performance of cable terminations in Specification No. 13-EH-306, Section 4.6, suggests that knives be used, particu-larly when types of insulation render stripping tools ineffective such as coaxial, triaxial, braided jacket, and heat/trace protective cables. Knives may also be used for the stripping of smaller gauge solid wire, if used properly. Inspection criteria is clearly defined in procedures/specifications. Individuals responsible for cable installation quality confirmed that the wire stripping level of acceptance is understood and imposed as required.
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