IR 05000245/1989004
| ML20247E195 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/03/1989 |
| From: | Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20247E167 | List: |
| References | |
| 50-245-89-04, 50-245-89-4, NUDOCS 8905260159 | |
| Download: ML20247E195 (156) | |
Text
{{#Wiki_filter:-- _ _ - _ - - - - _ i
- * . 4 * ,.
i w
'
L U.S. NUCLEAR REGULATORY COMMISSION REGION I l l Report N /89-04 Docket N License N DPR-21 l.
l' Licensee: Northeast Nuclear Energy Company Facility: Millstone Nuclear Power Station, Unit 1 Inspection At: Waterford, Connecticut Dates: February 14 through March 27, 1989
.
Inspectors: William Raymond, Senior Resident Inspector Lynn Kolonauski, Resident Inspector, Millstone 1 Paul Kaufman, Project Engineer Theodore Rebelowski, Senior Reaccor Engineer
. Approved by: $ lo h M , y g-/y/n E. C. McCabe, Chief', Reactor Project 3 Section IB Date Inspection Summary: Inspection from February 14 to March 27, 1989 (Report N /89-04)-
Areas Inspected: previously identified items, plant operations, physical secur-ity, ultrasonic testing of the condensate storage tank, maintenance program implementation, reactor building closed coolirg water design deficiencies, de-ficient end plug welds on new fuel for Cycle 13, maintenance and surveillance, licensee event reports and committee activities. The inspection involved 207 ! inspection hours, of which 13 were backshift hours, including eight deep back- l shift hour Results: no unsafe plant conditions were identifie Follow-up is planned for specific inadequacies in housekeeping and diagram upgrades noted during main-tenance inspection (Detail 6.0), reactor building closed cooling water (RBCCW) system design deficiencies and modifications (Detail 7.0), and timeliness in providing Millstone 1 Nuclear Review Board (NRB) members with briefing packages (Detail 13.0).
89052601DY 890511 PDR ADOCK 05000245 O PDC _ _ _--_ _ ____ -_ - __- ___ _
__ - _ _ l1 . . *
' , *
TABLE OF CONTENTS i
'
PAGE
' Persons Contacted............... ......................... .......... 1 : 2.0 S umma ry o f Fa c i l i ty Ac ti v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 3.0_ Status of Previous Inspection Findings (93702/71707)................. -1 3.1 (Closed) IFI 50-245/86-04-01, 50-336/86-04-01: Measurement Control Evaluation for Nonradiological Chemistry.............. 1 3.2 (Closed) IR 50-245/88-11, Detail 3.3: Illegible Drawing in Surveillance Procedure SP 623.148, "H2/02 PASS Leak Rate Test".. 2 3.3 (Closed) VIO 50-245/87-33-01: Deportability of APR Chedk Valve Failures....................................................... 2 3.4 (Closed) UNR 50-245/88-21-02: Operations Procedure for Diving in the "E" Intake Structure Bay. ............................... 3 4.0 Facility Tours and Operational Status Reviews (71707/81700).......... 3 i 4.1 Safety System Operability....................................... 4 4.2 Plant Incident Reports.......................................... 5 5.0 Condensate Storage Tank Ultrasonic Test (71707)...................... 5 6.0 Maintenance Program Implementation (62700/62702/62704) . . . . . . . . . . . . . . . 6 7.0 Reactor Building Closed Cooling Water (RBCCW) System Design (71707).. 11 8.0 Deficient End Plug Welds on New Fuel for Cycle 13(71707)............ 13 9.0 Maintenance (62703).................................................. 14 10.0 Surveillance (61726)................ ................................ 15 11. 0 Licen see Event Report s ( 92700) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 12.0 Plant Operations Review Committee (40500)............................ 16 13.0 Nuclear Review Board (40500)........... ............................. 16 14.0 Management Meetings (30703)........................ ................. 17 .
_ _ _ _ _ - _ . _ _ _ _ .
. _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
l l DETAILS 1.0 Persons Contacted
J. Stetz, Unit 1 Superintendent R. Palmieri, Operations Supervisor P. Prezkop, Instrumentation and Controls Supervisor l N. Bergh, Maintenance Supervisor l' W. Vogel, Engineering Supervisor M. Brennan, Health Physics Supervisor The inspectors also contacted other Operations, Instrumentation and Con-trol, Maintenance, Engineering, and Health Physics personne .0 Summary of Facility Activities , Millstone 1 operated at full power during the inspection period with the exception of short-terni power reductions for routine surveillance, and main condenser backwashing and tube plugging. Also, on March 2 at 9:10
.p.m., the licensee commenced a power reduction (to 65%) to allow back flushing of the instrument lines for "B" main steam line flow indication (Detail 4.0). Full power operation resumed at 3:30 a.m. on March .0 Status of Previous Inspection Findings 3.1 { Closed) IFI 50-245/86-04-01, 50-336/86-04-01: Measurement Control Evaluation for Nonradiological Chemistry Upon completion of water samples analyses by the licensee and Brook-haven National Laboratory, an evaluation was made. The data are listed belo Millstone Units 1 and 2 Split Sample Results
BNL Millstone ' Boron (ppm) SBLC-YA 25,400 25,560 +/- 112 Ammonia (ppb) Steam Generator 3A 117 +/- 0 110 +/- 10 , Steam Generator 38 118 +/- 0 Chloride (ppb) l Steam Generator 1A 1 .3 +/- 1.72 Steam Generator 18 1 The comparisons are acceptabl This item is close J I
-__.-__-_-____.n_ _ _ . - _ _ _ _ - _ _ -
. , '
3.2 (Closed) IR 50-245/88-11, Detail 3.3: Illegible Drawing in Surveillance Procedure SP 623.14B, "H2/02 PASS Leak Rate Test" While reviewing surveillance procedure SP 623.14B, "H2/02 Leak Rate Test," the inspector noted that Figure 10.2, a hand drawn sketch of the Post A cident Sampling System (PASS), was illegible. The in-spector ver fied that the 'icensee has since reissued SP 623.14B (Revision 1, U ted March 15,1989). It now contains a legible, com-puter generated drawing of the PASS. This inspector follow-up item is close .3 (Closed) VIO 50-245/87-33-01: Deportability of APR Check Valve Failures Violation 50-245/87-33-01 involves the licensee"s failure to re* ort the November 2,1985 check valve failures in the nitrocjen supp- to the Automatic Pressure Relief (APR) system per 10 CFR 50.72. The NRC found the licensee's November 20, 1987 response adequate to address APR system operability, but licensee actions to preclude recurrence of the reporting failure remained an open issu As documented in NRC IR 50-245/88-05, the licensee later stated that reports would be made for future events of the type cited in the vio-lation; that is, postulated accidents would be considered in address-
.
l ing deficiency reporting under 10 CFR 50.72(b)(2)(iii). Sech report- l ing covers "any event or condition that alone could have prevented ' the fulfillment of the safety function of structures or systems that , are needed to... mitigate the consequences of an accident." The pre- 1 vious licensee position was to consider postulated accidents only ' when reviewing deficiencies for deportability under 10 CFR 50.72(b)(2)(i), which addresses "any event, found while the reactor is shut down, that, had it been found while the reactor was in opera- [ tion, would have resulted in the nuclear power plant, including its I principal safety barriers, being seriously degraded or being in an j unanalyzed condition that significantly compromises plant safety."
This issue has remained open for further review and discussion be-tween the NRC and the licensee. In a letter dated April 14, 1988, NNECO committed to maintaining increased awareness and sensitivity to the need to pron;ptly inform the NRC of significant plant condition Implementation of this commitment is evidenced by the following lic-ensee event reports (LERs) made under 10 CFR 50.73(a)(2)(v), which corresponds to 10 CFR 50.72(b)(2)(iii).
88-04-01 "Potentul feuling of ECCS Suction Strainers" 88-05-00 " Insufficient Containment Spray Interlock Setpoint" 88-13-00 " Inadequate Seismic Anchorage af Bus 14D" ) 89-01-00 " Reactor Water Cleanup System environmental Qualification" 1 This item is closed.
L-__----_---
. . . ,~
t - n 3.4 (Closed) UNR 50-245/88-21-02: Operations Procedure for [ jiving in the "E" Intake Structure Bay
! On February 16, 1989, the licensee issued Revision 4 to Operations Instruction 1-0PS-6.01, " Divers Working at Intake." 'It now contains specific guidance for diving operations in the "E" bay: the emergency service water (ESW) pump breakers will be racked down and the pumps will be declared inoperable per TS 3.5.B.6. The instruction also states that this measure will only be considered in an emergency situation and must be discussed with the Duty Officer,~0perations Supervisor, or Unit Superintended.t prior to taking the ESW pumps out of service. The inspector found the procedure revision.to provide adequate diver ' protection, appropriate emphasis on the need for prior communication with' licensee management, and assurance that Technical Specifications requirements will be me This item is close .0 Facility Tours and Operational Status Reviews The inspector reviewed control indications for proper functioning, cor- ! relation between ch_annels, and conformance with-Technical Specifications
-
I (TSs). The inspector verified proper control room manning and discussed alarm conditions in effect and alarms received with the operators and found them to be cognizant of plant conditions and indications. The in-spector observed prompt and appropriate operator response to'offnormal and changing plant conditions. Shift turnovers were found to be thorough and in conformance with ACF 6.12, " Shift Relief Procedure." . Operating logs and Plant Incident % ports (PIRs) were reviewed for accuracy and adherence to station procedures. During plant tours, posting, control, and the use of persannel moni;oring devices for radiation, contamination, and high radiation areas were inspected. plant housekeeping controls were ob-served, including control of flammable and other hazardous materials. The inspectors conducted backshift inspections of the control room and found all- shift personnel to be alert and attentive to their duties. No unac-ceptable conditions were identifie The inspectors also verified proper implementation of selected aspects of the station security program, including site access controls, personnel i searches, compensatory measures, adequacy of physical barriers, and guard force response to alarms and degraded conditions. No inadequacies were J identified. The inspectors also addressed the following activitie , I During turbine stop valve (TSV) testing at 5:32 a.m. on March 2, the lic-ensee noted sluggish response in "B" main steam line (MSL) flow indica-tion. This behavior had been previously observed during startup on Novem-ber 17, 1988, when it eventually caused a primary containment Group I isolation on high MSL flow (see NRC IR 50-245/88-21). At that time, the licensee back flushed the "B" MSL flow indication instrument lines with demineralized water and observed improved responsiveness in "B" MSL flow indication. On March 2 at 9:10 p.m., the licensee reduced power to 65% to
)
s 1
- - _ _ _ _ _ _ - _ _ - - _ _ _ _ _ _ . ___- . _ - - _ _ _ _
allow isolation of the "B" MSL and conducted back flushing as a precau-tionary measure. The inspector attended the plant operations review com-mittee (PORC) meeting where the special procedure was evaluated and ap-proved. The inspector identified no inadequacies in the procedure, noting that'it provided precautions and direction that limited the potential for inadvertent MSL isolation. The procedure also instructed the operators to monitor MSL flows and manually isolate the "B" MSL should a high flow condition occur while the isolation instrumentation was out of servic The inspector noted the emphasis given to this instruction during the thorough pre-job brief conducted with the Operations and Instrumentation and Control department Technical Specification (TS) 3.2.A states that the requirements of TS l Table 3.2.1, " Instrumentation that Initiates Primary Containment Isolation ' Functions," must be met when primary containment is required. For in-dividual MSL flow indication, two instruments per MSL are required unless both main steam isolation valves (MSIVs) are closed. If this is not at- i tainable, Action B of Table 3.2.1 requites that the unit be placed in hot ! standby within eight hour The inspector observed the downpower, the back flushing evolution, and system restoratio The sequence of events is listed belo :26 "B" MSL flow instrumentation isolated; TS limiting condi-tion for operation (LCO) 3.2. A is entere :34 Both "B" main steam isolation valves (MSIVs) closed; TS LC0 exited. Back flushing evolution begins, 10:41 Back flushing evolution completed; "B" outboard MSIV (1-MS-28) reopened, necessitating reentry into the TS LC :42 "B" inSoard MSIV (1-MS-1B) opene :51 "B" MSL flow instrumentation returned to service, TS LC0 exite The inspector noted that the licensee was in TS LC0 3.2.A for a total of eighteen minutes, which is a small percentage of the eight hour action time dictated by TS Table 3.2.1. Also, while the "B" MSL flow indication j was inoperable for input to the Group I isolation logic, all remaining MSL flow and low-low reactor vessel level inputs were operable. The in-spector concluded that the evolution was conducted safely and identified no inadequacie i 4.1 Safety System Operability l Standby emergency systems were reviewed to determine system oper- d ability and readiness for automatic initiatio The following sys-tems were reviewed: feedwater coolant injection, automatic pressure
-_-- _ _ _ - _ _ _ _ _ - _ .
- _ _ _ _ _
)
5 ! relief, low pressure coolant injection, emergency service water, core spray, standby gas treatment, and standby liquid control. The status ! of the control rod drive hydraulic control units, emergency diesel generator, gas turbine, station batteries, and isolation condenser was also inspected. The reviews considered proper positioning of major flow path valves, operable normal and emergency power sources, proper operation of indications and controls, and proper cooling and i lubrication. References used for the review included the Updated Final Safety Analysis Report, system diagrams, and operating pro-cedures. No inadequacies were identifie .2 Plant Incident Reports Selected plant incident reports (PIRs) were reviewed to (1) determine the significance of the events, (ii) review the licensee's evalu-ations, (iii) verify the licensee's response and corrective actions, and (iv) verify whether the licensee reported the events in accord-ance with applicable requirements. Selected events are described below or elsewhere in this report as referenced. The following PIRs were reviewed: 1-89-13, 1-89-15, 1-89-16 (Detail 7.0), 1-89-17 (De-tail 8.0). No inadequacies were identifie While removing hydraulic control unit (HCU) 18-03 from service for maintenance overhaul, an operator removed the wrong fuses, inadvert-ently " scramming" control rod 18-05 from position "48" to "00" (ful' out to full in). The incident occurred on March 27 with the plant at 76% power. As documented in PIR 1-89-15, n, safety consequences re-sulted. The reactor engineer was present in the control room, and advised the operators to return control rod 18-05 to position "48."
The fuses for control rod 18-03, which had been previously inserted to "00," were then pulled and the overhaul proceeded without inci-dent. The inspector learned that the operator had misread the fuse labels. Inspector review of the labeling within the fuse cabinets noted that each control rod fuse pair is marked with a letter desig- , nation ("A", "B", etc.) that matches the respective control rod de- ! signation listed on a sipo mounted on the cabinet's center post. The inspector concluded that r,his labeling scheme was adequat .0 Condensate Storage Tank Ultrasonic Test On March 3 and 10, the licensee conducted visual and ultrasonic testing (UT) to determine the integrity and bottom wall thickness of the conden-sate storage tank (CST) per Special Procedure 1-89-006. The licensee had originally planned to use a diver for the inspection, but later obtained ' and used a small submarine with a camera and spring-loaded UT probe that maintained constant contact with the CST floor. Sufficient lighting and a rubber-edged tool were used to facilitate visual inspection. The licensee secured the submarine to a wheeled platform to allow more complete cover-age of the CST floor than would have been possible by inspecting discrete floor areas. The inspector verified that the examinations were conducted
)
I n-------.-u--- . - - - - - ----
- _ _ _ _ _ _ _ _ _ _ _ _ _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ .. , , ..
.
by a UT technician certified to Level III per ANSI /ASME Standard N45. .The inspector reviewed portions of the inspection video tapes and observed no signs of degradation and no UT indications less than the original floor thickness of 0.25".
The inspector verified that the licensee entered Technical Specification-
-(TS) action' statement 3.5.C.3 which allows the feedwater coolant injection (FWCI) system to be inoperable for a periou v+ to exceed seven day This action was appropriate since the CST provides makeup water to the main condenser hotwells via the emergency condensate transfer (ECT) pum (FWCI is designed to provide high pressure makeup to the reactor vessel in the event of'a small break loss of coolant accident (LOCA) using either the "A" or "B" normal feed and condensate system trains.) The inspector also noted that the inspection team maintained constant communications with the control room so that, if FWCI had been required, the inspection team would have retrieved the submarine while Operations reopened the ECT discharge valve (1-MW-96A) and racked down the ECT pump breaker. The in-spector estimated that the CST could be restored in a few minutes and noted that normal hotwell levels can sustain a single feed water train for approximately thirteen minutes. In addition, SP 625.4 was perforrned at the conclusion of each inspection to verify ECT pump and discharge valve operability prior to exiting TS 3.5.C.3. .The inspector concluded that the licensee's inspections were well managed and had no further question .0 Maintenance program Implementation The maintenance program was inspected for quality and compliance with 10 CFR 50 Appendix B and American National Standard Institute (ANSI) Standard N-18.7. The inspection included a review of the plant's operating his-tory, interviews with maintenance management and technicians, and review of safety and non-safety related maintenance procedures and maintenance documentation packages. The inspector also observed ongoing maintenance activities and reviewed completed work orders for evolutions requiring a plant shutdown or power reductio .1 Maintenance Work Order Review The inspector reviewed the Millstone 1 backlog of outstanding cor-rective and preventive maintenance work orders to determine the im-pact, if any, on safety-related equipment operabilit Work orders are tracked by the computer-based Production Maintenance Management System (PMMS), which is maintained by the PMMS planne PMMS performance reports are prepared to trend numerous work order .
program parameters described in procedure ACP-QA-2.02C, " Work Orders." Monthly PMMS performance reports are issued to plant men-agement to allow assessment of maintenance program effectiveness and efficiency.
l-l
________ - _ _ _______ ____________ __ - _ _ _ __ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l
)
A review of PMHS performance reports and discussions with the PMMS planner revealed that the licensee has a total of 1248 work orders outstanding as of March 2, 1989. Approximately 950 are for preven-tive maintenance (PM) and 298 are for corrective maintenance (CM).
While the quantity appears high, the licensee explained that the backlog includes 1147 refueling work order The licensee's current trend indicates that approximately 100 pre-ventive maintenance work orders are being completed weekly. Also, 13 electrical and 55 mechanical preventive maintenance items were de-ferred and over one month old. The licensee trends the ratio between corrective and preventive work orders based on manhsurs and has established a 30% to 70% acceptance ratio per Institute of Nuclear Power Operations (INPO) guidelines. The approximate CM/PM ratios for the for the period of March 1988 to March 1989 are: Maintenance 45/55, I&C 27/73, for an average of 36/64. The inspector noted that, since this time period did not include an outage, the lower Mainten-ance CM/PM ratio was not unexpecte The inspector concluded that the backlog of work orders is not exces-sive considering the upcoming outage. The licensee's overall control of maintenance work orders appears adequate to maintain equipment reliability, and the Production Maintenance Management System is useful in controlling, conducting, and tracking maintenance activi-tie .2 Maintenance Procedures f In June 1988, the licensee established a procedure upgrade program encompassing the Operations, Engineering, Instrumentation and Con-trol, and Maintenance department procedures. The program consists of an evaluation of procedure content and technical adequacy and re-quires that activity objectives, limits and restraints be define I In May 1988, the licensee issued a new writers' guide (ACP 3.02A) which implements several current INP0 guidelines concerning procedure format. Both Maintenance and Instrumentation and Control fell short of the 1988 goal for revised procedures. The licensee has committed to address the lack of progress in revising Maintenance procedures and expend additional effort to complete the program by the estab-lished completion date of June 199 The inspector reviewed current procedures in use and during completed i work order review and concluded that they were satisfactory. At the ' management exit meeting conducted on March 23, the licensee stated that he would consider monitoring initial use of the newly revised procedure The inspector had no further comment _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
6.3 Maintenance Activities Observed Hydraulic Control Unit (HCU) Repairs Approximately one-third of the control rod drive system HCUs are overhauled during each refueling outage as part of the licensee's i preventive maintenance program. The inspector observed maintenance i ' personnel using procedure MP 703.7 at the work site, in accordance with work order M1 88-08799, to overhaul the scram pilot valves. The automated work order (AWO) package included applicable procedures, material requisition forms, shelf life information, a quality assur-ance (QA) inspection plan, and radiation control requirements during diaphragm replacemen The inspector observed that appropriate per-sonnel protection practices for safety and health physics were fol-lowed. A QA inspector was at the job site performing a random sur-veillance, and a job supervisor was in the immediate work area. Upon completion of the work, a retest was performed per the acceptance criteria established in the procedure. No inadequacies were iden-tifie Control Room Supply Fan Assembly AWO M1 89-02180 was issued for resolution of intermittent air con-ditioning starting failures; the system provides control room tem-perature control. The inspector observed that the technician's ability to determine the failure cause was hampered by incomplete piping and instrumentation diagrams (P& ids), but the technician was knowledgeable and overcame that difficulty. The inspector learned that the licensee had conducted an earlier P&ID review which indi-cated that control system drawings were not updated, and issued AWO M1 88-00818 on February 4, 1988 to request a P&ID upgrade from cor-porate headquarters. The upgrades have not yet arrived onsite. The inspector discussed licensee action to review and correct P& ids, and will further assess the long-standing issue of P&ID adequacy in a future inspectio The inspector observed partial testing that identified the need to calibrate outdoor air temperature inputs, and the air compressor cutout solenoid to control coolant flow. Additional investigation regarding the master thermostat and economizer was planne The temperature in the control room after preliminary troubleshooting was < 78 degrees F, which was acceptabl During inspection of housekeeping in the fan room areas (turbine building, elevation 42' 6"), the inspector observed missing insula-tion from coolant piping and ductwork, miscellaneous material stor-age, and inadequate lighting that could contribute to accident Licensee management stated that the area would be examined to address
- _ ___ - _____---
_ - _ _ _ . -- - _ _ _ _ 3, .
, . .. "
9 1
.
'
<
,
'
these. concerns. The inspector will review licensee actions relative ! to.both housekeeping and P&ID adequacy in a future inspection:(UNR 50-245/88-04-01).
Drywell H2/02 Analyzer Functional Test L . Instrumentation and Control (I&C) Procedure IC 421G tests the Drywell L H2/02 Analyzer for proper. operation against known'and serialized ! hydrogen and oxygen gas samples. The inspector observed that the technicians were knowledgeable and had placed the unit in a 45 minute stabilization phase in accordance with. step 7.5 of.IC 421G. At the conclusion of the stabilization period, the as-found span could. not be. recorded be'ause the test gas had been depleted. The test was terminated for test gas bottle replacement. Discussions with the licensee indicated that the bottles have been in place'for over one year. _The licensee will determine when gas bottle replacement is necessary to ensure gas availability for future analyzer calibra-tions. No additional inadequacies were identifie I 6.4 Review of Completed Work Orders The inspector reviewed operating maintenance history through selected completed AW0s. The following AW0s required shutdown of equipment or addressed equipment failures leading to reduced capability of safety related systems.
,, Main Steam Safety Relief "D" Target Rock Valve Millstone 1 shut down to hot standby in November 1988 (See NRC IR 50-245/88-21) due to leaking Main Steam Safety Relief Valve 1-MS-3 Repairs were conducted under AWD M1 88-09104 and included removal of the valve's topworks, lapping of lower inner gasket seat, and in-sta11ation of a rebuilt valve (No. 1038). The AWO contained all necessary documents including the material requisition, proper torquing specifications and a certificate of compliance for repairs performed per ASME Code Section X Procedure MP 717.7 Rev. 2,
"Topworks Changeout" and MP 790.8 " Installation of Lockwire" were included in the package. The inspector identified no inadequacie " Vacuum Breaker 1-MS-1120 During a licenne tour of the drywell prior to reaching cold shutdown to repair 1-MS-30, unusual noises prompted an inspection of the are The licensee identified misalignment caused by disc thread wear. AWO M1-88-9219 was issued to resolve misalignment of the valve disc and seat. The AWO documented that temporary repairs, consisting of a fabricated shim washer and disc nut pin, were performed on November 15, 1988. Parts are to be purchased, and installed during the 1989 refueling outage per AWO M1-88-09290. A nonconformance report (188-065) identified and evaluated the replacement parts. During
_ _ __ _ __ - _-_ - - -
l i
. ..
..' m
'
10 J
~
\
weld documentation' review, the.11censee's Quality Services Department
. inspector documented the wrong-welding procedure (108 vs. 118). 1 Discussions'with QSD and review of material requisition documentation '
showed that the correct procedure was used. The documentation was corrected to reflect the appropriate procedur No additional in- . adequacies were note .j Other completed AWO reviews included: M1-88-09298, Main Steam Line
"D" Safety Relief Valve line 10" vacuum breaker (whose failure was caused by SRV pilot leakage); M1-88-09235, Emergency Gas Turbine-Generator. Motor Repair; M1-87-10943, ID Service Water Pump Assembly; and M1-88-09781, 18 Service Water Pump Assembl No deficiencies were identified in the AW0s. The inspector concluded that the work orders were satisfactory except as noted~above. The in-spector had no further comment .5 Overtime Control i-Maintenance Department. Instruction 1-MPM-2.04 and Millstone Admini-strative Procedure (MAP).4.17 address overtime control. The in-structions equalize overtime (OT).among department personnel. .A review of OT through December 31, 1988 noted minimal OT use'with an average of less than 225 hours per man per year. No inadequacies were identifie .6 Maintenance Training Program The Millstone 1 Maintenance training program was accredited by INP0 on December 15, 1987. The licensee has established well-equipped laboratories that allow performance-based training with traditional on-the-job-training (0JT) methods. Also, safety of training in the field is improved by the reduction of radiation exposure and chal-1enges to safety systems caused by personnel error '
Forthcoming outage activities are to be supported by additional snub- , ber and work site training to enhance personnel efficienc l All technicians in the Instrumentation and Controls department are qualified to Level II, as specified per IC 490A and ACP-QA-8.16,
" Training, Certification and Qualification of Examination and Testing Personnel." Level II qualification, as defined in the procedures, meets the standards specified in ANSI /ASME N45. The inspector i also noted that, as of January 1989, Millstone 1 was the only NU nuc- l 1 ear unit to have all I&C technicians certified to Level I The inspector found the mechanical, electrical, and instrumentation i training offered at the training center to have course plans which fit individual educational levels and account for the limits of each
_ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _
e ' . Job task. The inspector identified no training program inadequacies and concluded that the licensee has a comprehensive maintenance training program supported by dedicated managemen .7 Vendor Manuals The licensee's vendor manual control program is documented in ACP QA 3.23, " Control of Vendor Manuals.' Millstone 1 uses a controlled listing of current manual revisit,ns. No defir.iencies were identi-fied by inspector revie .8 Quality Service Department The inspector reviewed Quality Services Department (QSD) surveillance findings (including QS 188-001, 188-008, 188-010 and 188-015)' and the Millstone 1 responses for resolution of identified concerns. The inspector found the responses to be satisfactory. Surveillance areas included housekeeping, application of Belonza S-Metal requirements, temperature requirements for. fire foam application, and documentation of additional work performed beyond the scope of the original work order. The responses addressed and resolved the identified problem No deficiencies were identifie .9 Conclusions The Unit 1 maintenance department, under a new supervisor since Sep-tember 1988, is functioning effectively with knowledgeable supervi-sion and technicians that exhibit good work habit The maintenance planner, with supplementary clerical help, manages the high workload for the forthcoming outage and daily preventive and corrective maintenance work orders effectively. The need for addi-tional technical personnel support is recognized by the license Considering outage werk, the preventive and corrective maintenance backlogs are low, although they do not meet the current CM to PM ratio goa Several opec maintenance positions have not been fille The inspector had no further comment .0 Reactor Building Closed Ceoling Water (RBCCW) System Design On March 22, the licensee completed a design evaluation on the installa-tion of variable speed fan drives for the eight drywell ventilation coolers. Variable speed drives will allow drywell cocler operation during ; the high pressures and te,aperatures expected during post-accident condi- i tions, which is not possible with the current drives. The licensee in-itially postule.ted that extended drywell cooler operation under these conditions could cause RBCCW drywell cooler outlet temperature to rise _ - _ _ _ - - - _ _ - _ _ _ _
_ - _. ._ g ..
*
. ~
above the system design temperature and proceeded with an evaluation to quantify the thermal margi In conducting this analysis, a number of RBCCW design deficiencies were identified:
(1) The RBCCW piping in the drywell was thought-to be designed for a maximum op. rating temperature of 125 F; it is actually designed for a maximum op! rating temperature of 85 (2) The RBCCW supply and return lines-in the drywell rre r,ot designed to withstand the temperatures resulting frem a high ensrgf pipe break (HEPB).
(3) A break in the RBCCW system caused by a HEPB could result in a breach of primary containment integrity because the system is not equipped with isolation valves qualified per 10 CFR 50 Appendice's A and The licensee's original RBCCW engineering analysis considered er RBCCW piping as a closed loop system and did not consider the effect> of an HEPB. The RBCCW supply line has an isolation check valve (1-RC-6) located inside the drywell and a remotely operated MOV gate valve (1-RC-15) located outside of the drywell. The licensee considered this arrangement to cause the system to act as an internal extension of the primary con-tainment boundary, as documented in an April 29, 1988 Appendix J exemption request to the NRC. To date, the NRC has made no determination on the exemption reques The licensee developed a Justification for Continued Operation (JCO) for the time period between discovery of the deficiencies and their correction during the 1989 refueling outage starting April 8. The individual justi-fications are listed belo (1) Since current RBCCW temperatures are less than 85 degrees and are projected to stay in this range until summer, the licensee determined that the first finding had no current safety impact. The licensee plans to perform piping support modifications to resolve this de-ficiency prior to RBCCW '.emperature exceeding 85 (2) The licensee has determined that the maximum primary containment temperature following an HEPB would be 340 F based on the limiting break used in the Environmental Equipment Qualification (EEQ) pro-
"
gram. However, the licensee does not expect RBCCW piping to reach this temperature because of the short duration of this event (100 seconds), the heat capacity of the water in the RBCCW piping, and the insulation on the RBCCW pipin The maximum long-term pipe temperature based on the EEQ profile (a one to fourteen hour tina frame) is 305 F, which is not expected to cause structural failure of the RBCCW piping or drywell coolers. The licensee bases this assessment on the nature of thermal expansion r
-_ . _ _ _ - _ _ _
_ _-
'
stresses resulting from the temperature excursion. The thermal ex-pansion of the piping is restricted by supports and the stiffness of i the piping. As the piping loads increase, the piping will yield to j accommodate the expansion and relieve'the stress. The ASME code does ' not require evaluation of thermal (secondary) stresses because of the self-limiting nature of secondary stresses. There is a code allow-ance for a single'occurrance during the life cf the plant. There- ' fore, a loss of containment integrity is not expected to occur from the HEPB thermal excursio ;
(3) While the RBCCW integrity and therefore primary containment integrity is maintained during the thermal excursion from an HEPB, it is not pr;tected against the mechanistic effects of an HEPB, namely pipe whip and jet impingement. The JC0 stated that the probability of an HEPB occurring prior to the outage is low [0.0001]. The JC0 also ' indicated that an RBCCW system release would only be possible if the RBCCW system had been drained, and the check valve and MOV would significantly reduce release rates by increasing the RBCCW system drain time. The licensee has initiated a design change to install four remotely operated MOVs to meet 10 CFR 50, Appendix A, General Design Criteria 54 and 57. The valves will have no automatic isola-tion functions. The modification will also include the addition of a relief valve and local leak rate test connection The inspector found no JC0 inadequacie The licensee revieo+ 'he re-maining penetration exemption requests listed in the April 29, 1988 letter and concluded that none are subject to the same concerns as RBCC In addition, preliminary inspector review indicated a need to address the following: design and installation of RBCCW system modifications required to address the errors; potential improvements in the design review process that would avoid recurrence of similar errors; and the seismic adequacy of existing and proposed RBCCW designs per the requirements of Section 3.0 of the Millstone 1 UFSA The licensee reported the event per 10 CFR 50.72 (b)(2)(iii); the inspec- l tor will review the corresponding licensee event report (LER) upon re- (
ceip .0 Deficient End Plug Welds on New Fuel for Cycle 13 On February 28, General Electric (GE) discovered that an automatic welding machine, used in welding new fuel pin bottom end plugs since December 1988, had produced undersized weld By tracing fuel pin identification numbers, GE determined that 1409 fuel pins located in 148 of the 196 Mill-stone 1 reload fuel assemblies (FAs) had potentially defective welds. GE notified the licensee, who halted new fuel receipt inspections in pro-gress. Although GE determined that the fuel pins would be acceptable due to the margin provided in the weld thickness specification, the licensee chose to return the FAs to GE for disassembly, rewelding of the suspect _ _ _ _ _ _ - _ - _ _ - _ _
_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
l' 14 i l
fuel pins in a more reliable, semiautomatic welding machine, and re-assembl Licensee engineering and QA personnel observed the repair ac- 'l tivities at the GE fuel plant. About 70% of the fuel was rewelded, with-out additional filler. About 30% of the pins were replace The licensee chose to delay the start of the Cycle 12 refueling outage by one week (to April 8) to allow for inspection and channeling of the re-worked FAs. The inspector had no further question .0 Maintenance The inspectors observed and reviewed selected aspects of the following safety-related maintenance, including procedure adherence, obtaining re-quired administrative approvals and tagouts prior to work initiation, proper quality assurance and personnel protection measures, and verifi-cation of proper system restoration and retest prior to its return to servic No inadequacies were identifie Backflush of the "B" Main Steam Line Flow Indication Sensing Lines, on March 2 (See Detail 4.0)
--
Service Water Pump Assembly On November 23, 1988, the licensee's Inservice Inspection (ISI) Pro-gram revealed vibration levels in the Alert Range on the "B" Service Water (SW) pump. The I$1 technician compiled Trouble Report 23M1160302 and denoted the suspected cause as worn shaft bearing Upon receipt of the trouble report, the Production Maintenance Man-agement System (PMMS) planner initiated corrective maintenance work order M1-88-09781. The work order, issued to the maintenance staff on February 14, was to remove, disassemble', inspect, and repair /re-niace any worn or damaged parts. Actual work started on February 2 The inspector examined the disassembled (Worthington) SW pump in the maintenan';e shop, witnessed clearance measurements on the new upper and lower impeller wear rings, and reviewed tie work order package and vendor manual. The inspector noted that ine line shaft betrings exhibited wear caused by excessive vibration. The me.chanical over-haul of the pump assembly consisted of replacing the line shaft bear-ings, the upper and lower impeller wear rings, and the lower suction bel This same type of overhaul had previcusly been performed on September 12, 1987. The interval between SW pump overhauls has ranged, on the average, from 12 to 14 months. The licensee stated that this par-ticular 17 month interval was longer than expecte The inspector noted that the cognizant assistant maintenance super-visor was present and that the mechanic conducting the mechanical overhaul had extensive experience and knowledge of the work being performed. All activities were conducted per procedure MP 722.2, _ - - _ _ _ - _ _
_ _ - _ _ -
-
)
!
"Worthington Vertical Double Suction Pumps." Upon review of the )
procedure, the inspe'ctor found that the bearing clearances were I not documented on Figure 8.5 as require The mechanic explained that, if the bearing clearance range is out-side the acceptabl'e range of 0.008 to 0.013 inches, he automatically i replaces the worn bearings without recording the clearance data on 1: Figure 8,5. The inspector informed the mechanic and s->pervisor about the discrepancy in procedure compliance, and noted that, while the licensee failed to adhere to the procedure, there was no impact on the "B" service water pump overhaul or safety because the worn bear-ings were replaced. The inspector noted that unapproved deviations from procedures and failurc to annotate completion of procedural steps could lead to imptoper maintenance and reduction of equipment availability. The inspector had no further comment Standby Liquid Control Pump Assembly The inspector observed the performance of preventive maintenance on the "A" Standby Liquid Control Pump (SBLC) assembly per work order M1-83-06652. The work scope consistr.d of inspection, lubrication, and changing oil. These activities were conducted by two mechanical
'
maintenance personnel. One of the mechanics had never performed this task in his seven years in the maintenance organization. The other mechanic had performed this activity numerous times throughout his 10 year maintenance career at Millstone. Since the above work could be accomplished within "the skills of the trade," all that was utilized at the work station was the work order packag Prior to performing maintenance activities on the "A" SBLC pump, the maintenance organization contacted operations to place out-of-service t ciecrance tag 1-143-89 on the pump power supply breaker. When the maintenance activities were completed, the mechanics notified opera-tions in a timely manner so that S6LC pump operational readiness sur-veillance could be performed per SP 66 The inspector witnessed the satisfactory performance of the above, surveillance and valve restoration. The inspector concluded that-departmental interface was adequate and the licensee personnel were i knowledgeable of their respective tasks. The inspector had no fur-ther questions, 10.0 Surveillance The inspectors observed and reviewed selected aspects of the following surveillance for conduct in accordance with current, approved procedures, for test result compliance with administrative regt.irements and technical specifications, and for deficiency correction in accordance with admini-strative requirements. No inadequacies were identified.
l L l !
. _ _ _ - - _ . - - _
, _- _ _ _ -_ _ - _ _ - _ - - _- - _ - - -_-_ _ - , _ -_ _ - _ _ _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ _ - _ _ i r
.,
?
., .,
)
~
.
*
--
SP 661'.4, "SBLC Puinp Operational Readiness Test" on March 1 R -- SP 408 F, " Turbine Stop Valve Closure Functional Test" on March 2 11.0~ Licensee Event Reports
~
The following Licensee Event Reports (LERs) were reviewed to assess LER - accuracy and completeness, adequacy of corrective actions, and compliance with 10 CFR reporting requirements. The events were covered in previous NRC inspection reports as referenced. The inspector found the LERs to be accurate and sufficiently detailed, and identified no inadequacie " Standby Gas Treatment Initiation-Due to Reactor Building Ven-tilation Exhaust High Radiation" (50-245/88-25) 88-13-00 " Inadequate Seismic Anchorage of Bus 14D" (50-245/88-25) 89-01-00 " Reactor Water Cleanup System Environmental Qualif'ication" (50-245/89-02) 12.0 Plant Operations Review Committee The inspector attended several Plant Operations Review Committee (PORC) meetings and verified that Technical Specification 6.5.1 requirements for committee quorum were met. The meeting agenda included reviews of plant incident reports, plant design modifications, procedure revisions, and new procedures. The inspector noted that the committee discharged their func- , tions in accordance with TS 6.5.1 and that frank discussion and probing 1 questions were encouraged. No inadequacies were identifie .0 Nuclear Review Board The inspector attended Millstone 1 Nuclear Review Board (NRB) meeting 89-3 on March 14. The meeting convened concurrently with the Millstone 1 Plant Operations Review Committee (PORC) to review the implementation of the Revision 4 Emergency Operating Procedures (EOPs). The licensee plans to finalize the Revision 4 E0Ps by April 1, complete the verification and validation process by May 15, and complete two cycles of operator training by June. The meeting provided a. comprehensive, multidisciplinary evalu-ation of the proposed deviations from the Revision 4 EPGs, developed mainly because of the differences in plant systems available at Millstone I compared to those assumed in the generic guidelines. The inspector had no concerns about the proposed deviation The NRB devoted the remainder of the meeting to routine topic reviews such as LERs, NRC inspection reports, and Plant Design Change Records (PDCRs).
The inspector noted that each member was provided with a meeting briefing package containing copies of the documents scheduled for review. The in-spector supports this practice as it allows informed assessment and evaluation. However, the inspector learned that NRB members normally receive their briefing packages approximately one week prior to the meet-ing. Considering the amount and diversity of material under evaluation, l
) .
__.___.__.__i______.____.__.__._.._______-_---_
- - - . _ _ - _ - - .__ .- _ - _ _ _ _ _ _ _ _ _ _ _ _ _
._ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ - _ _ ___ ,
_
the licensee should provide the NRB members with more timely informatio The licensee stated that the HRB was both aware of and sensitive to this issue. The inspector had no further comments on the meetin .0 Management Meetings Periodic meetings were held with station management to discuss inspection findings during the inspection .oeriod. A summary of findings was also discussed at the conclusion of the inspection. No proprietary information was covered within the scope of the inspection. The inspectors provided no written material to the license On March 16, 1989, during a licensee-requested management meeting in NRC Region I, Northeast Utilities made a presentation on the performance of Millstone 1 and Millstone 3. The presentation materials are appended to this report for record purpose ; I - _ _ - _ - _ _ - _ - _ _ _ _ _ _ _
N O I S S I A I MNA
.
M V OL C Y Y SN 98 R N 19 O E T P 6 , A ,1 L A U I H G S S R C E U R R A P M R A F t s : E O s e O L a i T C G U N e t i D E N IK
.
h t l i T S
.
t N r E
.
o U S E U N R P &
.
r g a i n e g s l c n n s u 1 3 i e e r c e s N o
.
o
.
e i n e L d o e N N n n e in t a o t t i g e s r ts i n i n n i t t U U Ey i t e l l i l p A OM i e e t ac
, n n e F r o o f a
t n t t a n e e l s l l s S o l c d l i i r i t n N u t e MM ae ar , c l e
, n ,
t u n i n t n e o n t r n e e p i e eNG a dn d n t d i u r
,
r
,
s e S S t e te o o s s n n t r n i i P r i i r v v o e r r r e i t wp e pe pe pe c a o u i t u u u t V S P S S S S s s - - - - - - a i e g r e t n n e t i b mc e z e me c n e n n h t l i R o
.
S a c S t t e l e C P l a a v dr c t . . . . o r D E . P H A P o o U N
. . .
WS
. .
J C R G
.
N
.
,
.
_ G R - E B Z E E M T C C O E A A T L R 8 S P C a . 8 S
.
d D 9 . 1 P A E . n . e g W N J
. .
R S . I A E C S GN E N A I I T N T M I O S T E R V I G N EO I T S N E MF T A E I D M R C A N T V I N SS b E E T I OP 1
.
MIA F E I S E U S N OE N L T WF SSA I O PNE SI I
.
P F TM I V F C t s N U R O N I U 4 E R 1 E O RE I s e OPW N P Y a E V O E R N I . T A E
/ .i I E e t C D V N E T OR S L A M G A G i U N R T P L T MI h l D E E S F t i O GV L OI U U S t R T A O L E MOS S r -
N I M A B C D E o
- . . . . . . .
L I A B
.
N
. I I I . .
l l
N E N N E T D G N R R E O E M O B E N M L n O a C a v R d . . n H P
.
D e . . g C
.
G W A S E I N T I O I V S S I S TE U CV I C AT S I 3A I S E D
.
T OIW NNE I T I L A t s T I I V R s I3 V E I a .i e N ERE T C N E U NP A e i t EO E G G
/
Y - h t l i NT G OSLA N I S R A _ t T IU LT N _ r - S L E M o L L I MAB MO
. .
C I L M U S - N I I I
.
V I
.
V
.
_ _ _ _ _.
_ _ -
: .
- -
-
G R E B M O D B d
:
y E N Y
-
t e A w n W e i e s e r v r P e v U N O l
r t o c a F y t Y% i c 4 i% a a C 6 c6 o5 p 6 a C
-
e ' ' c n a Fa I~ m ' 3% t l a% r
=
i5 n o 5 o 4 U7 6 G6 f r e P
8
1 c' 2%
-,
t i8 l a% o n U7 5 c65 w e
,i
- v r 1* t n i% a o i* U c87 e v O- - - - W 0 5 0 5 0 7 5 2
. . !
l'l l!
- - A R A m m L e e A R- R-
-
n l n e l l a l a c n 7 l M i M l
'l a
l l l i a a 1 o l m G o i 5 G l 3 i
f oY 1 r f oY 2 f o % I 3 % l r l
I
l
e l 7 !
P i i
- i -
8 2 l
I t Y
1 i n C U m e m R- e n R-i a l n w I l M "l I a i e lb' a o G i l I
1 la G o l l M
v l f oY 0 f oY 3 7 2 r % % I 1 l 5 l
e i I
-
l l
- -
v i I
t i l 3 t O . i U n i U n
, ~
s s l l
,;1l i jiII!! !
!l)lj
..
.
.
i _ t e _ _ s a W _ e i v t c k ' a 23 o 2 i d ODcgg -y a R sg a p 3
-
e @4*mg
@8a c
n g a m @Nggs _
.
_
-
-
r o Oa3g f r e
'
OCcg@D9y
^
c Nugs m o a P - y 8 D ~,
9
@Ggy Cg @ coy #
e
, w-cg
~
Oa3o w- e
,
z 3' g a u
$Ucg mg , - " ' '
_ h%sg8 0& Ow.,;t , w %sg i e h@9we -e g n @O'*g
'
'
'
@Uae d* s
m O2 : e
~
-
,
,,
m u
*me E "' t v Ogg Osg r @Ea=g,
* w y *@U#gU*gh#sg
~ "e g s,e hsge n g r ege e ;
%
v l a
a o l a o k e e l a o U N O 1 co f..fG o 2 cf. 'o
.r G
3c f* f . G o
'na Y n
.f c o
_ t 4 i4% t 4% t i3 9% n 32% _ n i
n28 n 57 08 o94 U86 U45 U45 C48 .
-
. -
-
l: :! l l I
l c i ei n D n io3 i o eie ct e e dt a r icU an i d n eck ef v i apa n t l isa - i oi a n s nu s N i e e t enY n in iq me n dRm I h e k imn a ao A n a MeC Ar a Ct on t c i k Y n T Rae Ne p r O i i o n o
< gi Oa l
o C j pi L Af($j ei S d i 9 l 8 g i
-
+ ui 1 A i
' l i
n g lui _ o n J i it in _ 3 . a v ia l
.M~ ,
r it r T n e n i U c,O - n
.
s r o ui o b t J i t ei ct c n ap3e n si enn t d O ar O P N O I f e p o l y i ai Mi w 1 it n iU im a a e Me l n U T ri p i A i i vs r t e a 2 i i t s e v d i s o i t n o a u a M l r i i u it r i eO i n t e l U c P a l A v b i P E vi n C L e F i U s l e R A A N Of R u e N l i a c S f d o
&
E O n ai Ji l i 9 e P n l - 8 p - - 9 1 S E N I - - _ - - - _ - _ _ _ . - - _ - - - . - - - -
r S e heU s t l a Y ) t e t e o C l a nht B G d u i r 9 n n gn o 8 : a n ni i s 2 9 f , 1 o 2)e A( t t an f o r o 1,g 3 a e Rla g n t e r PP i c a ne n ov o Ll l t a F t sA t s AA R y l l Sf r C eo O l l t i i a P Me MRl i e c c a p rY r Nt i N n r I fo e a a o na n e f au mC r a %h % eQ r a e o 4T 5 v r v w f r i n 7( 6 ee e i e P e t t a - - i h p h cp i c A AU A v r a r l e c
- - -
e N u
- - v - - -
O '
, -
. .
Z T E T S
.
yP b dN e nH t e s sO e 1t P rJ egh ni t olh s g l i l iH M i
. < l
.
_ S E R U D E A C O D R N P E G G S N E A I T V I G A T N R A E I W I P T E T O I N I V E I E E Y s C E N R P 1t M N E O E egh C R N G R E T S L G A T nil / M L I M U O toh s g U N E
- - -
l i l iH M s e
'
t n l a P t e S a r s E e e p r R O u U y d e D l c E f e o r C )n a P Oo S Rit o 2 Pa T n t e o n i s Ge t a i v Nm I e u q e Tlp s e R
'
d e Am RI P O A i s v s E 4 E r e P e t o R s Ono n a r o 1t O e T Yis p n eg h Cv Ne i t i n O i o s E (R U d ni G f o n a i c e t olh R i t s e D s E d r u sg M 8 u u o l i E
9 A d e i c l s iH 1 E C R c o r n o M N U J N
-
P
-
C
-
, ,
-
S E R U D E C )n Oio d Rt a e Pt n d e s s e s e r Gm Ne i v e d d Il Tp R A s Am e r s n RI u r E4 d e c P e n n c s Oo i 8 o r C o s 8 1t Yi v 9 P t h Ce 1 2 i d eg NR R n o u E( E A ni G R B i i s v C t olh E O T R e R N s g M E C O - - l i l
.
iH M
a
S E R U D E C) Ono e s Rit t e s e Pa t l c p o n Ge m P r Nm o C I e C n R Tl o Ap s e i t Rm E I 9 r u d i a / C 8 d P 4 R l n 9 e c a s Ooi
Y o r V O P 1t Yi s A P
/
n / egh Cve N M 4 i o B R _ n t E (R o a ni G
.
H
-
i s i c N ol th R C i v e f i r e i t n E R o s g M A R V J l i - - - l E M i H M
. . .
S E R U D E C )n Oio s e Rta r u Pt n d e e Gm Ne c o r Il Tp P s Am r o
RI 9 n E4 8
t a i o P 1 r s n e i s Oo i T S O p v e 1t Yi s U R egh f Cve G o t n N U g e ni E (R n m G A i n e t olh R E
- i a
r l p g E N T m s M U I l i - - l E J iH M . .
S T N E M E V T O N R E P S M M E E I V V D N L I O T A V A I S N I L Y T I O H R R P O N T O S I N S I V O O G E C N R s N L L I H I N E P 1t O A P N U eg h E C I G G A L P S E N N N nil O T O L I T A E G I L toh s g S L L O I D A R E P A T U T S R I l i I R O O F l M - - - - iH M . .
S T N E M E V O R P M I D N A S L S O T R R T O F N F s O E K 1t C N C O egh I A L T R A A E ni C I N I R t olh G E T M A L O sg O S A T O P L N s A l i O W O L R l D C 'M E A i H I D A A R E D C P U F L A M R - - - - -
. l
A e v d I R t y s u n
:.. \ ' l
8 W P I R / W B d e tc e g
. / 6
s .N ll r P A R . 5
A L A .
- -x4 l
R A
! l
8 E Y
.\-
1t s / .
- . l
8 egh ~ nil . . _
. l
8 t oh s g e n .
- . 0 l l
o r l e i H t m s
-
M-u
- - - - 9 - . - - .I- 7 0 0 0 e O 0 0 0 e 0 5 0 e 2 1 1 N R y s
.
r_ Y H P O
*
S O L R I O H H T C P T T A S G F G R N s N I F E L Y T
.
1t I T Y E I C egh T S A E ' L C A P R F R E Y A ni E P A S L C C t olh O - - - - s g l i l iH M
, .
, l
!lil, j ) . - - - -
_
. _
.
.
-
.
.
_
-
-
.
_ _ r p9
., :
A8 e [ : r a9 M 8 m i
: b9 Fe8 r : a n96 -
r s /g J
-
d : e c8 D 8 oT t e c v 8 tN j o e 4 : o N 8 rED P r e : c t O 8
eI j CC : e p8 8 xC */ S g s A 1 : u8 A8 s / : u l
n u ,- J6 n8 u H
. :
o ' J 8 T N n y
: a 8O M 8M e/* : A 6 r
p8
/ r a8 s /'
:
M 8 1t : b8 Fe8 egh '.
/,
: a n8 J 8 ni /
: e c7 8 D
ol th */
: o v 7 N 8 sg : c t 78 O
p8 l i 8 : S e 8 l I i 7 g u7 I M0
:
A 8
-
-
-
-
-
- -
-
-
- -
-
-
-
-
- -
-
e/+J lu 7
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 9 8 7 6 S 4 3 2 1 N Ho "
. .
i1l l ?l'
Y T I n L g i o I t n a B i l e r A t n o u o p R e f e r E m v e P ip i s o w s O q u e c p e x e G e e u n N I k a t o t i t n L n e u o i r c O f o d s o t O n n o e c C r e i t a n e c T n l l r r o i c u N c s c E d e o r o n o c s p c M n e t a r t e m s N i r e p k s a s i n a I e o a p p A p x e b A m b t o T e s u h s n u N s e c a a r e e p p d n O v s t r W m a a e h c u s C w d s a s C p n o
/
i h o h g t w g t W i t R i h ig n e i h e s C i d E h h e c n n o f o n o T d o s A n a d n a l l s a s p p s e s s o c t n 1t W d s n h t s n i t r r n l o l a p egh p p i t E i w i o m r e n m u e u o C g n 0 t n p o w d s r e I 3 niV R i s a e
>
s i d e W C
)
p g i p r t i f f c olh O l r n E c d l a ( i e n n c r c e r y S I i e u t t 8 8 8 w c e t d h T u s g l i Y C
1
.
n o
- 8
1 d e n n a n e W a e d e r e n o D f s e l N 1 o 2
. i a t i
r t e t s i r iHG
E n r 2 t s m a C r a l l b R e R u t i S E S M 'B S M S R t E ' M f B A B - - - - - - E O y O M T l r T 5 0 5 6 7 0 C 5 0 0 0 0 1
.
E a C 3 4 5 5 5 5 O E f 0 0 0 0 0 0 e s
'
: )
t p ) e m 'B k u Y c o p
'
t p T I r p Bn e e c s de r x L f n e e I f o a sc ( ht B n Ar t A i a
( e v
m e i h R h g.oy l b e v E c e nr o r a P v ir sa p h O i r ac e f d d r s o s l u o i
( ci r t r G e eb e b c de s e N
l n t I b a r wd og o d r ht a L e l n s e c f o g p f i i n O o n mu s b r i s s e i n O i t e a c d e e k a t a o C s a s yd se f o i m i t n l f d t T e d n gu g d e m e t s p d o N i f al r l b r m o i a o i f u E t n ep e r p w r r e l c p o f M d i uhg s su
) a f t
c e o sy N n e l a eo s p l d e p ei t I e i r r l i e s cl i e A) m pt m t s p n y ib Tde r c s o e g e g u p s s i o i t pa r n r r p w l de Nun t a a i e o np k e h h W m s r b a i o Oin t a v o c c S E u p l s e v r e f y Co t n b is s i r n p i p t uf
/ c i
a d d u W i s m d o br i
,e ( B '
2 sn o C n u w r nv R . s ae e e r f e e p o f o oo E d e d e l c l l C'
'
r c W l l a n i t cp t T e bs a d s C u u p i t a' s n o r sm A s d n rE e e s a k e
'B n t
s e r pu n p'. a e mp W
'
a o u ' p a i n) o A t n d e r m s E m o h p ig di n h h
'.r i l
l e t a r c s u p p m uW p S C t m el r o ic e A t
'B u i nE I h t
0 ao h w S
'n W p iAs'
g 6 c c o S l V
.
w g . r R o u o es du r ( p n d e i t E W S be 'na r n i h r E b t g po e e
% v i r
a g u u o E dr S s n mT r 4 m p f ot s p i t ur pof c 4 p e a c 'D
' ne Y m s u
s e t a m r e t u d dTn u Wg n o i g p n C e p s k a g n r e e e ip d a i f sl e N r d Sn Ei n t n i d ht r c e g C' rl ee E i c n ' n i l a e s C g
'
vp e i o ' V a ' , . . . G R W Aru
'
E'
'
I I W B
' P T B
'
im D R i _ _
- - - - - - - -
E - - _ .
-
_ . _ _ M 0
8
8
3
0
8
0
2
1
0
5
_ _ _ _ E 5
5
5
7
8
0
0
2
2
4
4
_ _ _ _ _ _ _ . _ _ .
.
- , 8
e g ,
~
e\ - 8 ly a r O n
e , 8 s R' v N E L A *f l e 5
O e n e y , 4
n o t r l t ls s 3 i M u 8
*/
*
*'
d 2 I n 8 t y 1 i
* 8 r u
R S c e E , 0
R A
+
e n L 9Y
E O e n
' t o !, 8
l l i M s
-
7 * ~ s 7 1t 6 7 E egh G A g* 5 R 7 E V nhh o 4
A Y R T S t U s g D
7 N I l i 2 E l . iH -
M.- .
,e -
4
" "3 0 - - .
2
- -
2
- -
1
- -
1
-
-
-
-
-
1
N E" OF R s
C ; ; ;i _
, .
_
. %
7
- .. .. . . - .
5 s l e 2 c 1 y c _ #
1 g R i n o t O T C A F t Y a r #f 9 T I C A P A C e E L p 8 C Y C o 7 C E L
*
Y C N 6 H T G N s E L E 1t 5 L C
/
Y C egh , 4 a ni s t olh 3 s g 2 l i l iH 1 M .
5
0
6
.
, , . . . . . . . . ~ - -
0
- . ; Ta a i
_ _
d
-
r - t o '
- -
c 0
a F 9
8 y 8 t 7 i 8 c a - 6
p - a 5 8 E G C 4
A R E V A e
-
8 R g A E a 2
Y
r e a e 1
H v T G A 0 8 N E_
!
E 9 G 7 A T
'
s 8
U O lt 7 E egh
6
nil 5
t oh s g
7
l i 7 l iH 2
M- -
' -
7 . .
e 7 2 0 7 0 2 0 0 0 0 2 W 8 4 4 9 7 4 4 8 9 8 5 9 8 8 5 5 6 6 1, M 1 S 0 0 4 8 0 0 0 5 0 5 R 8 0 3 7 7 7 5 3 0 1 O 1,
4, 3, 9, 2, 6, 3, 6, 0, 7, 7 7 2 4 0 5 7 7 T
h ss r 3 0 0 3 1 8 4 C A Wo Mg r 7 8,
7, 3, 8 7 7 7, 5, 4 4 5 M, 85, 5 9 7, 7, 4, F e Y u s T I t y ed t i s i C c a 8 7 9 0 4 2 6 9 8 4 a re 7 8 7 6 3 9 5 6 4 4
8 A p a n 0 9 9 8 8 7 6 5 5 5 9
P C g e 0 9 9 9 9 9 9 9 9 9 ,. A 1
y C r a
) u Y % b r
B ( r e kn o F
,
S a t c k R 0 e R fa 1 2 3 4 5 6 7 8 9 1 e O W T s s C A i c n 1t E o e egP h R t y r n d a a n a a a a d d d a a a l N c u u S a n S p S aa a a Sn Sn n nil O T C o U CU J UCCCU U f m o r toh s g1
8
N e m a 2 6g nan - 2-
- -
u a 5 7 e r1 - er 2-d t t e c a r x e
- g g p e f e l i r o
i n A 2 2 n n e n o e u e h a dy er er e L o s n O
-
l c r i i - i i iH l t t c t b L k t k k n l a a c o r l il n T e S P NSen aFri icP cPioP MSa
.
t i M R * - 3
t
e u s i s vr a u e n a m J ife%, t 4 8 3.7.2 6 6 5 9 8 3 8 3 1 54 l a n iF 90499878987371 85 o LL 6887766766665644 i t a R n r e O t n T l a I C u% n g n A nF
,
7349883.9764979 04 i r F ) AL 61 6441 86443629 29 99888877777665 54 e e
8 n Dl p i g n A e E OSu r ) r a Lh t s s e a o l c Y D t a r ) u g 4 R( : e ) )1
)
9 N sT N r oW 0 8 )
799
2 7
2 m o t cM 6: ) ) r 1t U al ea 1
)0 )0)
7 9)8
4
1 )1
: 6)9696 2:
f eghOC d rt (06 3:29 0 959)43
8 : 71 4 9 t e ot
.o e0757)1 2((0 44 2 ()
n41(5 5 1 :
a y8 18 1 5 n0 c a r N O2: 4: d:87 2: 8 en2:9 5 :i3 t n a:64 : 2 a3 x ni ( y r e4( s( yl tod r aeu( a 51 1 r
:
r (m 8 n (( ed om36(0 aKr( n1 5 r (i eB6 t
: e e
t olh t n u o l l n sagzindat GnawA n a a l ni t i n uwlepwaoRa gia e nu h e a( ct piaS a ei r rd ( l b T a C MFHSBSSCSFJTUF GI i n s g * l i l i H M
.
.'
4 ., ' 8 e
/ .
g ' 7
as r r e o \
.
t vtc Aa yF rd y/ v *" 4 e
8 n ao 5
u C oL _ _
,N l 4 A R .- ,
8 E _ Y
./ ,. -
. ' 8 N
A s P A J ,. 1t egh
. 8 n
o .h D N ,i A L N I t h - F 1
s g l .i l - ,a iH - ,
8 M- -
% ,_ ,, % %
_ _
%
mi
8
7
S
4
^ :NUAL TOAD A TO
. .
N O I T A R E P O Y G G G N E N I T A I R N U R T N D S E P A E C E O s L N G C 1t P A A S N T G egh E G E T U O N I ni A N I N I t olh T I A N I F E s g U M M D l i l O - - - iH M .
s T N E M E V L O V N I R O S I V R S E G s P N U I T 1t S E egh E E E M M N ni I L I T Y L t olh T D L K E E E s g S R I F W l i I l - - F iH % F M
.
t s n e K m e R t s n v o O e r p m W e c I m n a e E l p i r s e r G e A n o c R A e n o e c i t a s S T v i t c i v c e x o U i l a e r f n B e i i a O V t o S d o r r r r s t e o P d r M S t a s e s R t a r e n a e n e r e W u O e g a t i o n t i q 1t J O p l t n e s n i b r a r e h n egh A o m e u W s n c r v r u T T e e M i o d e r d s s u r d n T
.
ni 9 M o U n t s n S t u G a T o C o I S t olh 8
1
= -
I
- - - - -
I
-
s g l i l iH M .
-
.
E L U D E H C S E G
.
A R T I U A O P E O R T D Y D L A S L E L s M E W E E W D 1t R L E K egh
-
G V E B U O E O L W nil R P P D D L E toh s g L E N E E W N O l i l U - - - F iH s M . .
E C A L P
. '
A T y R b d E s e t B t n O e hg s e r R i P l hg Ei SH N .
.
n i o t c j e I n n t o n i t a c l o e p o
t s n C i I r n l t e U a n a r n o v i o i t d e t c a n Fe S t u e F /r n mt e o e a s l t s t s w t l i y d e S h M y F e g f t e / i a t e l S a hg s n e d Ei n o SH C N
.
. .
~
e n t o l a l s i l c i e M p n g S - 3 l r i s o o e t i r i s t D n n v r
/U o e g e C p n n s d u i
r t o i s n S e s y a l' e l o
- n l i
l a t n t r i g M n e n n - A m o E r y u C e t r d
- g f e t s n s n a
n S a n a t a I t o - - n h i t M r r es e g i s o t c e e et c m i p e n ne u3 rt l mjor i g n i gojt nr s i h o E EP IU n n g C P Ei m- - - - SH T a e N . .
t g n i n e r m e t e r n a e i g p e n e k D n n t s E e a i o e y c Y t c T t e i v t u
/f a r u r e e c t s
c S S i t n n r y c o a a e l l e t i n C i e l c l a n n v u u o o r C u N- Q-i t
-
a S r r r r e s e e e e e e n e t n n n G n i i i hg i t o g n n g g n r
-
i s E E E e e i o r r e r n l p o o c o mn i i i n n i n g h o e e a e n g C S S n S e E Ei m- - t n - -
.
SH T a e i M a N .
-
g i n r e e 2 i n t g i n n U E s e y n n t e o o f i t t s a a r l l S
.
e i r p M a e O r
- l c
e u . s
-
i s N n v - t o r r e o h i i t p u s g s o p S r e i v r i f t d e l mi p a u h o hS e S g C L Ei m-a m-a SH T e T e N
l
I d e n r t e t a Pl a e n u qi o i t nc hncu eF T n me ot is t
.
cy eS p st y If ne s e a cS t i l Cn S hg I F S l ant Ro i S c c i ire r teps t l 1 e ef hg n o VAI n t Ei l s SH l i M N
.
.
. 1
d n a l a m r o n ht o b i
~
n n i o t cndes fu o n m s o l l iy t i s wc h u sn c me l g n tere o s g i l C ym Se h l l a g r e Ei v SH O N . .
y a 8 8 M 8 8 8 8 9 9 y 8 8 3 8 / / 8 8 r / 8 8 / / 2 / / a h
/ / 0 6 1 1 9 4 1 u r c 8 9 2 2 / / 1 1 r b a / / / / 1 2 / / e 8 9 9 9 1 1 1 2 F M t
m g g t M e s B M r t e ' R t
d t e t o t l p P N V m& g i n c e p r a m o O
t M2 o t E i n Y P p s S t s p A de I t n n o i i n o N U C M o o t o t o r t n t t d t t c c c e n n n n h d e l e d e e e u p p s i i i io o o o g L a e S e i s e s n s n I s t t a t t a t t a t t a i mR I I t r n n n n l me a t C mmo a a p es e e s e e s e e s e s y R h e T S N T T R P P P P e e e r r r r g l e u Ei d e
- - - - - - - - - -
SH h S c N
-
s s e e c r o r u s n P d o e i c t
-
n o r a v o P r I i e F t c / s S e b S l e na O
. 1 S f o
t P s i n m e 'kr s u t U t s o t a h e n S y WS t g t o s - - - i l l l i h M g Ei SH N . .
l a n g t c i S e r deom r t gr I o o d d nf C C N ne n at aB W i y ce s h 4 C& F a a it gn e v t nR o M LoUs 97A s CAS n i e t Sy 2 - - 4 c e Cla - Ce 1 3W t i R oF o t NU t p e ER F - o on S f e R1 N Did l omCs s s e o go De e eb r v o ri t i nS Pl a ev Dno ur d c o t n t e s e v n
-
Vi 0t i a t 6- a e c es Cu o Te okc oD wn aoocA i i t eL t Ni r s ou c ny cl Cn Pa I ga l FR a a iBt f s 1I eC ni pmi l l Mirtd en s l vWt ir st e mor uf et vi r u Mw ot a n e 9 t s aF ei TrC p u c o n o V a d p Si r mdp h ie t n e c e emt e n C esFoem t e g a v r e t ao s ne l l nc a na Fu P e no yfC r t i ci So e i e s i t e p o c f a it I s v dl o s c te t l b vec f u u C uiss O nC r a o Wa t h t o o uc s c e r t n Ct SA RP nA FSP a t g a I . Ei t r o
- - - - -
SH I p m N . .
n g l t o i s i l y a e W b n D g o I m z C e n l e t s i l e B W y u g F S f r I e n R i s f o C s W r Up n e p rmi o F o f u t yn d a f e nP m io ri t s ore r et c Vn i e t o T at sf ou s i co I f o n t F n o n i i g s B t m n g e ue i t i t i t s Ja s t r a se o t y s l an p nD e
.
b1 c e p s u i nd u mtI 8 u s S 2 hcon dS I 6 g ocm t s n CP TeCn n ai n Dof r h o WS iFc e t i n n sk n c t ner g t a e n v r n a po e r o as iL i t oa eP r ay i e l as pl s Oi e per l pr l i l b yv A E u ci s Ap h Ol nr u o v. aas n OS NF CB NP i l o r o g t a Ei t r - - - - SH o p m N I
e
.
. l s a i c s i a n B h c n e i g T k s y a e f i e D r Wy f V e s i i r o n e t o V g i t y i n t a l e t s n t a e n e mqu T i o I t u e X a c d c o A n i f D o i t s ot s ie t t t s c c u t e Nne Sa en J l
.
e R De om Ei e l l a c t s e sr c t s u Mr i v i h n n eq Su c h a n Te AS eR foon T e g s n o i t e n cl na an yt ca i t e a i ia t l o ac u l a l q v M ii et uif qi e h r e s t s o v c rn e ec d a uu d p n g b P SF AS I Ei O
- - - -
SH l a b l o - N G
# *
_ - - t o
:
e h l a i a v . A o n t o s Ni det g sa d n nt e i on e wie a t amN r s u ru l i D ct i s s l s s d an a r o CI B gd n
.
c . e nn g R A R i r a es i s e r ei s S F a e i na D f U gB s o l c n Nu Eg n no n t i i i s e f ods n e a h s n i c y aD t t g i t o a a r u i l t i i t t nr o n m e i v c b op u l r c i p p c e a g e t eu o h b s I n L SS D g O
- - - -
Ei l a b SH l G o N
-
t e l l
~
i c g o L f l o e e n c n n o a s r l l e i e P d v e e r t v u a r o S o r t p p n r m e o I t m C i s r d s a n s p a e g e t c n D i o i n r d l o U P n r e e t n g r n e n g T o g e s , h a i n r C n t e i n w n te t C i e n d i a B hg h t s n g T a r ma a tn r n T o g r r i i l n s a ey a t e i e r D to P mtr c ar i l t a l ui r u n e r e c h c po t S n e s hg t d a p ei s r e o e l ni t o P OD IC T C N Ei - - - - - - SH m a e T N . l
, . . . . . -
_
.
E - C A C S
.
E s N - e E u n byH - s de P _ so t n E _ Ii e s T t e S i cu rl o P r e s ne G eR _
. .
lIl l1
l a n c i o n U i t c s a i r g e r e n u m e p n i y s o e l n s r O r o I f r G d e i t t i n o l a n a n o f i t U t S Ui a t d e n e e c s e r n i r m s t o u o e r e P s t n o r n s e f d l n d d e E d l i GI A i f i oe t s Mde e s u l y t n e es t o i f a l e s r u d i a c n C t d s i i t I a d i r e e to e I n ' s Ct A n d I o u s n s e u I F S Ra od on GF e y S I R f o Ss n s o I s s 2 o nde l l a S f t nn s Ii i oi i o eo I
&ta if t mi t
ws a t i F n t icu r o l S S c 1 c ep n i l l at une te e su ad vI o P v i el s e s v a i t om Es e es R AE e s f c iac t I s ne ep pm l l i in MU UI t i t u u nss ss - - G eR SI
- - -
I
-
. . ll
s i e c
, n g e
n i c s i p i f e s e e i c e e D n u s k t n e I s e s s e i o t i s n u t t a s s o o e n n i t H R fc o i c i o
( r t t snt)s de su In t
a i a - _ S r - - one r J no e - e d Ol _ i s n t i i s e t o s amkr r s e s i a c t a r n o o n e C u l l d e p s n i M is s n s Whce O s e - _ - s o c oA d e T . s a _ i r Cl a t f s v B Ii _ - - e c c a o - t n i i n mh n - c e mh R g iu o _ - - t - G s c t p A i s - i e e u e S e - - _ rl o l a ST A D F D - - _ e s i t n
-
_ - - - ne t e o
- - - - -
eR - P _ - G _ - _ .
. .
_
w
.
T N E M E L C
.
y H b L e R d . s t A 3t n C e eg h s e r P nil . t oh s g l i l iH m M m m m m m m m m i
. .
l
E C ' s N V A O T N S S N E E E E T V V N I L L M S A A A S M E V V E N S C N S A O I O A-P T I E S T F R P A A L U L L E O O O S T H S S S E C S I I R U O C s R L M R N A A E T A 3t T N E T I S N N egh E K O I T T S A W O M E T N ni A I D N I D E D I olh T N D A E A A M t g I A M F R s l i
- - - - - -
l iH M . . .
.'
r _ _ _ _ _
. .
_
. . . ._
_ _
. _
_ _ _ _ _ E R U . T C U L R A T E S C V G E R O N _ OM _ I K L
-
A F E E m K R
.
T L V - N S S O A I AI R R R Y T B T T H E E N P R D O & 9
- -
O U K C H - S T N S O EP C C O A s L O U AE IS WS R RD I 3t HC NN P T HAO EE egh S S R R EE ni E E GG E A KRP SGR O RR CC AA A TUC SS t olh T T UU T - - - s g OO N I l .n l y - - - i Myu . .
' . - . . - . .
P O H S E C N A E Y NEo N I H P E C O A H T u M S N i ~ A o I M r O Mc ' O R L P O
^
O T YOH P S R I A O H W E
> P E
R S C E L YN H E s C E M h
-
3t L O I O P O egh _ O R H Y S A B E ni N A R Y t ol hg _ C s l i l i I I M -
.
_ ,llllLI
P O H S E _
~ , s<
C . j '
'
'
N
.
', n;,L
,
'
%"
A
' . ' 4 ~~ , ' -
g
,
?~ -
N E E-- f l' e a! '. S l > ' C*' s
' - . C- * ','/3,
.
E o
^ ,
,
< c , >' o: N<,
-
: A;E A
,51 , ,
,
S
; ~c ; 'Rs c N R l,. ' ' ,#(f ,
T i A s ^
~ ,~
E E P N n .,
;,
e , ., 's M . T P
. +:) ' .. R,N4O:95s xAi ^ y:.:_ ',
A H i': - : ', O A o J . I
~
I H
,
s
, 'J OxM F S : .
r E , :. 3,
,
',y 1~,'* ?,V '
:.s
','L
: v s, s
r S Mu
',
' ~ .~ -
'
IC F ,' ^ '~
,' , ~ ,
D F : ':,,:. L
",',,j<
s,
: '
O S
- '
, +
, :' 'A /s A
,
O M A - M O R
~ P O F R H I
N hA P E R S C E O I L S s H C E N 3t A i E h M O O P P egh L O L O
~ IO R E H X Y WS E A
B ni o E olh N A R _ C t s g l i l iH M . .
.
R O D T I - I K NS N S OT
.
O T S MNE S T I S S E T NM N E R R O I E E S P O T N O
.
TV M T P I I . E N U N R T A . . V I S O E A IR O O D T T DP . R P N M U N T P AM RI P M S E S A N O T M E M I T O T O E E N T I U C L C I R T P P O E C R N P L N O M A E I T I N T A T R . E I E E S N O E N R S T S O R T O U E N P U s I A S E I T A E P M D E G N 3t C I S M N C A M I O egh O D O O I O H E R A N C T R C V P R D A P E D nil I T C D E D E E V E L I D A T N R A toh s g E R R G N A G N A O R P L A T S R W I O P T W T F O H H M N E E O l i C C C I I N S S l iH - - - - - - - - M- .
. .
T N E E C Su N S A E N S E S S T A- N N I F T O i t N I T E E mS M A N S D S N A E E L S P S M N S T A- M O L F O I U s L C T S E E C E 3t S R A R egh - - - - ni t olh s g l i l iH M . G . l
' * R * O E T "* C N
A N
" A I
I D
"" S P
I L P M R O O R O C T C R K E N R S T O I O R F T W O A C S S T N E N E s A W T O R U 3t I C O O I T D egh N U D L R P E A R E C ni N O R E P O t olh N A O C I F O R P s g - - - - - l i l iH M e
I
_ _ _
' .
_ _
* _
. -
,
-
-
. -
.
N . i O I - T C g n U i l e D I du r i f E l he TR R 7 R I 0 - O 6
9 T 1 1 A I l C 6 2 g N l 9 8 di n U 9 1I nle o u N cf ee SR
.
-
N l A .
2
8
1 g s 3
g l i l n e 3t h 7 I tsfu ir e FR eg 3
8
1 n .h l
'
toh sg
5 6
9
l ias cn l r o l i I ei mar me op t _ I l CO M . . l l
Il lIIll ! 1 !
. . . . . ,
k
.
-
K CY O L R N RS A O I R E TS E NC E T T F I C ~ A NE U J ON N D I TU E I _ -s pyS * S S R y _ C N OT _
~
PN M Rj_ _ !
! h a EE VV
$ s LE A ~
,IA mN AR L VP
-
e w A r n . n o i
p$ g* s#
i w
. .
t
-
g g%t - -
-
Ry hb i hhk 3t s m-( Nk b! f
$ ' I_ _ b!
egh m fd E fd
! R bM O F
n .h R hh E B bh i r toh s g EE CG V N I
fi g f
-
R A l .n l I E H SC M$ T i X I FE OT M TA UE OH
'
#
.
.
l Illll
~ -
s
*
.
*
.
.
-
_ _ _ _ T N U O
: 0
HN W TO I I _ O i WTA D mON 5G L wTA I
/T 0I I
-
2G 1M O /T I O 0I 1 M C 0 - P I
/ 6 _
P R I R T _ T S T N- R R x O E T P 0 F _ _ 4 A
*
S Z E T U N I M s - - D E 0 3t
- -
RT 2 A egh S L MO _ 9 S
I ni _
/
2 1N T O t ol hg / s l i - - - - - - . l i I
9
8
7
6
5
4
3
2 I 5 5 5 5 5 5 5 5 M
.
_
. . ^ .
ll l!lLl ! ll il l l
N O I T E C E C T N O A E R I L GS S P P NN L E M I O T P O R O S S R I F C E E T G T RNO N E R I C O C L N E A T H B L A C A L I C T s L I A E N W 3t R V U O R N E egh O U D S N A R I F ni t olh - - - - s g . l i l iH M . . ll l
T U G O N I E R S E O E L N N C O I I G T T S N I A E L X N H A E A C L T L N E A P U R R P O W N M P
.
E U R I O I U O V T C C s E E A R L V H 3t E P T T egh I C M N W N O E n .h A L C M E C toh s g L I E T C E N I A A F R l .i V J T E l R O N T iH U S R P O C N M - - - I
-
. . l i'
A I S S R E E C C T A N E I I E P R R S C E R E H E C E F C C NIT E R E T N A AR Y H T S T LC L CS P N L T T AC E IW EE C E E P C C E M VI R)S MS A E RV R OECES CHR O R I UE U CP VI ET F Q SR )S T T D L C H C HS E I RER T EC J EC T XES UCE M
(T( B A SA P S TS O E M NE SN I R C L OM H LO I
C LT D I U T TY AL E s OA E MLT T RC C E UC S 3t TI OH CE TE NIF R T LR eg h OC P N AI E C DM CEP E I T D ni TS C S G O O S olh E LA NE N N H I C ER I RE E T t s g T RIC A LL EN l i EN E I U NEA M l TH S C V QI T T iH A R E GA S MTESU FR ET NH TE M~ - - - - -
. .
\ : ;
_
. . . .
-
-
- -
.
i a xER i r o iU t e rD i r s s e iE C mi e c
-
cC n
-
iO v w l b e iR e o i cP S i v r c eE T _ i L w e P f e rCU s NS l y i e R r D
-
t AE s v e o e u e r n c i LR o R o i n cL W i Ma i nE I v r M uVIE e o r s l r f a l i cRV P g o e v 8U E
.
n s e d 1SR L d C wi ne i mn e O t e a S r u T e a t I h l u e
.
Mimn v e e o i t a b v a l n R R i t Wte E r t sMs i c s s mmmA s s mt mpo 3t h I t e e e o eo t I I t NINI t t e e R eg n *l i 6 2 4 8 5 3 toh s g
2
1 9 3
0
2
2 l *1 l Y1 i Y1 M
-
_ _
,l!
n i uu * cm s is
8
1 t tm i us vi 8 ac u
9
sm r a e Y
8
1 s 6 3t 8 egh
1 ni t ol h s g_ _
- -
- - - -
l i4 1 l i H s M R E L .
c rY ~I e D uTI r e oV t h s t I c cI s O me ]
[
O 8G sT t n o t
1 e t s l u oC y I md u wg aS J rU c
]
6 r CD D o f
-
s k i n [ I A p p u o eo 8 n c a ar n G r cR 2 3 T T r ]
I J a t u o cP [ e t c s O 7 Clo I g 8 n 9 P C P in I lu
C D n J f P a o r n M p t r i s I A a y n t S r o o i i n t it a n e l J e s l v p n m t c 3 t i l o I O 6 a C eg h T t o l t a I l u
9
o J T n *h r I p I A toh s g2 8 7
6 2 2 5 4
2
1
l *i l iH l t a "* s o *'w M T " o -
* '
- -
s
% m
t e sy s % S
%
t m4 e
7 k j r e I h t s '
;
t n e P 2 8 3 :, O 3 ?
-
,
t o r ,, m== u c o y n,
'n g ,
;. .
..
O r e v naC a ug d e a f;~; n o s s; r u i
"" ~
R' C g;; T e g "
'
D
^
.
n e gv'g:
~ ^ & T e o S ^ '
E hq h m
'
[6'
,l ;
t c W i
^ ' . g' ;. %
^:
c
,.
N"
*"
;
. yh:y,m,
/
* :
- * y5' y :: t s ' D'
& *
yJ ,f d g :: ,. N f{
,j ,-
** ;
:, ;
?{:b$<c 4:
* }
, ^ ' f:
f
:'
;,'
-
;
. ' .,
*
** h c; fSg,
^
;
, '
s
'
s$ s.' ~
.'*.
.
.
h -c j ;' ,
; p' * ^ '
'
<
[
3t
[
*
!j ( '
$ '
,$K es U :'
e hs
$ , -
$ -
$ p c s gi2 tm2 e f
$ .
.,'Q
. t une r i "ws.,:~; 4 n o
niw n $ i ec : o 2 v V~ h S i; t ef 1 it a l D x
~ -
' ; - r
.ic' 7,- D M^ ,;:,. u e to h g k
a w L*
't ' ' '
s
,"
.
;?' ~, a n #
: r
. 'lsx j ' h7
,
[-
l'
-
;
O p s
,'
l
: y;
,s
% N %,
'
e ' . n,s q j' , .-
.
i a l i 4 ~
:
.
-
c r l s .
's .
iHt e
,
m# ~
* ,cm
;
<
-
,I.< _
e 3'
-
-
'
; m l'
m M I k 0 % j o 0 % % % 1 C 0 5 6 6 5 t 6 3 A y % y
. .
,
* ' . . . . . .
S M E L 4 B O cR i RP ET nN . eE SM S oN MI M E _ TA L B
-
i T nN S O w _ UO S E R SC S I r E R E R U D T J U S N T I T I s A R T 3t E A L h H E A eg - - - nil toh s g l .i l y i Myu
. -
_
- .
. -
-
. _
- . -
lII )I J
. .
9 4 E R U S I S S N E O E G N YE T R I I B G S PS S E DT RA S TU D OU OK E NT IO C EA N MH FA C T I O IT DE A MS H EL R N I E T I RW F T AT E AG W EIS SM T TN S RS NT T NA T UY EC E OH SL PN B CC N OA E PN MO M I S XA OS O N E S CN R A EO F R NU S SI S T OOY AT T E I TVIA EC I F s R AE R LR I ET 3t U IR P E RST NN egh S SS D A P SE EE SN R EO RN AR BM nil RI AOF GR EN PTI E H VI toh s g TD T IT T S SD I EE LT BH IA TT I MN FSE SN l i TO FE R OG OO l i I CC OL C NIT PC I -
- - - -
M . .
' .
T S I L S K T G R o N E N O N I W IEM RC E T E T EA E R EF v M O NR O F 1E R T F oTe N NM N E E EII F M O S N L FN G I E OR ~ S V E S E SC A N ON L T A I O s C F SC S E O 3t J UC I h O T CT eg R P N E SA I DM n .h D M YM toh s g D E V P O L LA HR l .i R E TG l V NO iH P M E D OR MP M I
- - - . . .:
O C S T U U E N O G H E A S T O E T I L U U W S S C S O N E T I E O C S T R I A I N O T F L U F A S R H O E U I S E C B L Y T N M A L N U E S V A I P S Y E O A N N R D K A O I E 0 A E T H 9 E D E T D L O s L F E R M 3t P O R E egh M E T E N V A R O O I U n .h C T I T L E W L I toh s g C E U L D s E C I A F
.
l .i J O R V V l O S C R I i H R P E R D P E S S M M - - - - - . .
L O R T N O C S
'
N L S O O E I R C T T C A I N A D O A A C E R N R O A I L T O A R N I T M N 3 A A O C T R e N A D n O C L A A R t o - - - l s l i M
9
t M e e 'l A F 7 5 1 R e 2 9 2 G r 5, 0, 9, a 0 7 5 O u 1 R q P S N O I T C U D E s R 3t N egh O I T
'l nil A r
a e
8
8
8 toh s g N I M Y
1
1
1 l i A l T i H N O M C . .
T T T D E E E E E E E T F F F E E E E L R R R P A A A MM U U U AOC Q Q S Q S R S GA 0
0
0
OE 0, 0, 0, R R 6 4 0 P A 1 2 4 G N I E
:
T T s N A I A D 3t P O egh T L ni R 8 9 A tolh s g ' A E Y
9
8
1 T O T l i l iH M
. .
-
e) * nm 7 to e 6 5 2 2 9 l l( sR 3 i M R W mm E P)m e 3 7 5 e e R ge 9 9 4 R R U 8 2 aR r( 3 3 3 4 9 S e O v : r : s P A i a n X p i o 3t E R e t a n egh 3 p i u m E C E i l O nil N O g n s s P N oh i a t T k c o p y I
:
S r
.
s g l i L L a e
8
7
9
8
L P B D e c r u l I Y 1 1 1 C T o iHM R
*
R S M . .
m e R e iN 0 r l l1 1 u s i 7
=
o p s
* s x a E T', 'A mp ey l
a / hre t ) oer ht
$
O RB 4D l
?l " A Tu s SO 8T oo 4 . Tp x =Rd sE e n r
r% o t 0 u a u3 s r oi b= pa i rb s xp t o nJ ;y< EeR s o2 ? I
! ~Y l
ap 3t C( [ 5 ::: (:; gY
t ou egh TCg t n a c n ni i f i k olh i n c g o t i L s g l i S P l C i H R M . . .
'
' . . . . . . . .
_ _
- .
_ _ MM E M E E RR R 4 6 0 2 5 8
: : )
Y E R R A U _ S _ _ U O R P B X E E
: ( L S E L N G A O A L s E I T T A 3t h R AU T URO O
_ eg S E P N T ni olh OOW P O _ _ _ _ _ _ _ R _ t XE DT _ _ s g E WU _ l i OH _ l i I 9 P S I 8 M
- -
1 _ _
. . . -
i . .
.
-
a
-
-
.
~ _-
+
e M E R
0
_- R E E C N TRE I I' OD A E N MA TRA T EN TO DS TN CGI P A NI IT RADU M AC S E TI RN P S : ME G I T P B O NLLO E S ES J A E E T s E SG VN I I E RE V EVOP A 3t BN TR VEL LO M E OI TI L/ LI LE I D egh R JL CE I EE EB TWHOE I T U V I U RB ESSPR S RU nil S O TEI I F O N RIS CS PCCCH ERRRT E L toh P T R X E N A - sg E P E O T l i 9 R N O - l I 8 - . T i 9 I 1 M
'
. .
.
I llll1t
S A E R A L T N I I,
.*,
441 (' A 4 s ; O s 'p'> S P 'y pe'~, C I ES TS OE NC
*sp g ~ ,>
fgog3' ,rt ~.. S F ? OG EC DA
. .
d's
, ,'
,-
TO .'e.f';:L .,;
;,g f, ,
.
E P a 0 1w,s - yf-x~
\ -'_,
SL s
'J- xs ;,'s y' n,s : 't .' .l x<',,
SO
'
>
. ;
yb
'A q ., ' . >,; 3 l'4 s EI O w, P;y ,7 ;Q , $,
:s CD 1 t
O
' 4.;. 1 ~ ,,
;. , - ; .,; ,, >,',;
+
. '
o7
' s k;.y"'
~ a 'v ,-:
CA C ; 2E e ,["?, E z,$",'J'i
$
-
R -
-
AR y' ;;'(f 7,, ,'J,--
-
'D,t - ;
e :;, '3 )g >,C'
,- ,' 9 g k^rg:*~' s ,0 '- ,^
_:~
;
-
'
' a ~, T
"
;M' e" ..
v .a ~ >g-. - t f , ; Ou T'g M'j ; J
.l e ' t ,
s e, m 'p '.<;> '~~., b s[e,' .' [ , ..,
~
l s 7's >;'-
.
m x '7 ,'w
'.!.Sv c.',,
'
O xf';s .
's
'
x.:' E 'c
' - , -, - ;P s G O
':x.{
. ,; ,
, ' ., '-;uy . , y ,.
s$
~ ,'7
)
-
,
,
L sm c yt. ,$;-iJ 3t E I B L E G (l
.
-
~ , R ,, f-D[
e hg U D lVs p. . Tft go gj r:' %. 4F miD L B fL O C y ~v
.
* ~'
x u e: SB- 2 '+ n i . e*Om A E -E .
:,)',; . '
d
+, .
.
~
SE . G O <, T 1
.'a 'xs
.
S G olh l
'(
t AD W
,B L
- -
:s (d
- 48 nu
. ,
^
n4E f~ G D ,_
.
s g
-
;4
.,lf T
:m
.f 4 N0' 0 l i t; Ns-. IA *1 l
iH ,1.'*. -s
.
s M- . .
l<j !i ,;
- . . . . . ;
_ R B
E L M t I A C R P i S T S c i E TB E T O1 O c NM N o EC DP E D t E 3
.
2" fs oT i M gy$> s[
.lg g[f;0 w'
oA iD g..* g' e2 n s% sf9 e a nPU
,*
P*
" g 5'" .Ede
'
m.$a o m s
'
.Y: yk$s
;eE^;j$e
~
.s3 .
rSA
.
ggQg3;wEm pmS g;gg s sE c G W@g;gQbgaCa yg. geMaw g ij:d eR 2 lj :, g 4' ,g
${a y&Aj9pa#
cA c Oo m o
,
i
,i 3:
"
i jg xk f@gp>mii NgyWl$gW?
- . QLh
[' g,.rNqMeMM
.
?gid j]t*a n; !
%
A
*
t % o i u e _fmg,. i
$
dwgp Qg%f i ii Qg-
$
gahqhhg!N iim !
!
r 1 gh #nF$
.
s s[ i e
$gg ig g % @i F
.$ge: $
Ig;f_N jjayb%f GUI#
s G D E gjsg .
iaRg*3 y AmN@n!W 3t 5 i L 7. ~
'
B ,. E d _i
, .f#
g..CC g.%aj!@ 4a ?6-egh L G E U D sVM t
@rg smE F
m t B u%Rl.ihg s Mw t,eD}Y G x p&.u! s. l tg'- [ * sis * d u ee: _ A c^+ 2S5
:g6D n *h
,,
. o'& e, u
s eun d'
,
WeDW O6i B4 toh "_ _ i a ,s E ju s R w C- eM>4E c 7 a$
.
t
, i simp f*
s g n;- sE < T 4Pc s l '1 ~ ' ^ -y M, C . l i Y1 .
,
.
t - m'? U-T1 M
.
,l .t ,,1
s o i rS uTu o o t su y n T S C y y o S E S D N R I y m T S O O A C E I P E B R T E J U L C R O T O E E R R P G L P E S N U L T N I D R B N I P E O M O L I P s H J I C E C A H f U W 3t S M T H F S egh - - - - - - ni t olh s g l i l iH M . .
,
l lll i1l l1 1I
. . . . .
e
.
.
-
s S T l5 % t S u E
-
3 0 l _ o P jT l 0
s T S U 5. S O _ u u l T 2 C 2 A1 I S T 0 - c
-
T E R 5 _ Y 2 s "A l T I H H 1 o " Fl
R L P W O x R l S Yl I E P i E L E t / B W S e % l P M O P I A
.
u g
0 l 4 O L E S W R
4 4 S e 1
A O n O T x L l
% R 0 T
l l S 1 D u 0 A T 3 - N 5 O " S Y 1 L B W L " s Y A O B
L E l F l 2 S 3t D D M U E egh L E F l
/
2 O S P 5 S l
Ol A O 2 L ni C
/
S olh I l N D t W 5 x s g l i O D
1
.
R
T 1 l i I l Ul .
-
I 2 H
-
M I S l
-
. .
-
-
.
-
1llIo
-
* " N " OG IN "* SI ON "
RA RE
* OC L ' C " /
I R
" NU O
I T SN NOE G ORV S N NIEW IT O CC E O s I NE D I L 3t T APSF G C LSN YRN egh E P S EIREI G RA T ST ni N D ED A E TUBINWT t olh I L T CLBOD V s g E ULR ESUCE O l i l GGNEE FISSSSFM iH - M
-
e
! l
S T N E M S T N R S G SN I EF S TEI S S A TIW IL Y R O T ME O A T C SR L RsA N F RD E J A RE ATIC O R ETI N C RD R P T AL RSN IC I LE EH N CR L V W E E ERO R E V LE GE s T D GNL 3t GAW EA L L RI egh EWOC L D LADE O T E BSLDP n .h O EGMOIC HFSACWR toh s g
- - - - . - - -
l .i l iH M . .
E C N A M R O F R E P R T O I N T S C P U A I 8 F R 8 T
1 Y R T O I C T Y C T A E P A F s A C E R A S 3t egh
- - -
nil toh s g l i l iH M~
. .
-
_
. ~ .
_
. .
y ' E g L
, C Y
c, . C y 1 E y 3 L
, ,
0 C 8 Y c, C
, 9 , 7 c 5 7 I8 9
%
5 8 s
7 I8 9
3t egh 7
9 nil 1 toh sg
.
_ _ l i l - 8 l I i
0 9 _ I 1 M ~
-
. .
' . . . . ~ .
_ _
.
'
'
8 '
, 9
_
.
7 '
.
9
-
8 9 ,
-
. . - - . +
6 4 2 o*e42 0 3 s - i O 1 1 1 i 2 i O s 3t h . eg ds nr ni d d au so tolh sg e s n p ni ar e n po nih ar suh l a l i l pT l pT rt Tci l I i UR nx nx er URpc i I M
. .
lll llll
A 9
T 9
Ur N Ou A J Hs To I i Wcc SA R - Ue Omi Hr / K Rrs OO Wt
/
8
1 N s A J 3t eg h -
- - - - - - - - - - -
0 0 nil 0
0
0
0
0
0
0
toh s g
0
7
0
6
0
5
0
0
2
0
l i l E S iH VR T U I AO L H UK M~ MR UO CW . .
.
N E N N E D R O O N n a v
. .
s y P gi e b D R d nit e A i t n R s v e E s e G nit r ec P iAc L .
M O S P T S G C S EE N R vV I I I K E N 'M P rT A T F S H I CA iI M T CO E T I R OTI L N W N SU R PIN U A R L N HT P OS T ITA C IR
.
R T T A AO WSS N T S S N E I C C NE I C NE OS T N U SP IS SA E MN S N S S E E MI U C DE NU s M R OT S P CN IAS S g .e i S S E V D TDE DEI Z E L E NI CIT n .t i N O S E S ITN i A E DIE sn i L V I E NI E P R Q U R OR IO R ED RI R ec M U SA C RN ERU T N I N I iA c I FA PPC L - - - - - - . e-l
.
.
y r
; ' ; a s
.
u s ;?E r b r e e ; e h i n 1 F y
]
t O
/
l e -
:,l'- j r a 1 e . t
[[~; u z
n mDa
.
,i a
.m
-
: , ;i '7
' J T
i l r e Eeu ( D
[
:
b e m o c e c N
..
e n D e l r e d N's b la n ^ f+
' ':
,
m e v
]
t it o o N m p l b u s ' r S e -
, .
e b e r {~ '\ o t c
[
t a r ' O L o 1 C '{' , ,
, ; ^ -.
l ^ I;*
-
r e b m
'g [ { e la v h', - ;
, 7, h ' t p
t t i
- e S m l
b t u s S
. : ,] ('^ '
' '
u g u e
.
{L '~ A m s h >
l i T n i , l ' g. ^'s 4,, y lu O n .,f :- -- l J i l la
.i s .IV '
t
e it n u m J b u nt l S ly eC - h' .
~
y a E r a CA
' 1 ~ r .I . . - - - - - -
o L 5
o
<
s
0
5
0
5
' i 5 o
. .
N G S O
N E I S E I D N N K A A O C R P T A G X S R P E L T C U L N Y I E N N T M MOI O I I C D T T S A N A C N P E L E O A MU A S T E I T P C N 'D M L E I E E O S E N SUE G X L O s E BC A E U P e C N T J D L gi I L TA L X E E nit L N OI D C HU i D OE V F s v A VT R N O N E E S T ni ec t L 0I E 6A D P N P T N R EP R 4MU A L
iAc I S L - - - - - - . .
T T N S E E M T N I N I D 3 A A E L T O N E N L-O U O F T F C S O-L T D C S L N E I S I E H R O M C E L M I H E D R P L L N N S U A E E O R S I M N T A R M T O I N E L T U I I E HO A O T B K A F s S G I O U C O g ,ei N E C HP FL S C A L I F N n ,t I OE O I D O i L T B I i EU O T s v i D G F E N M U n ,t A AT G O I S L ec O L RN OE N A T A W O S iAc E TP H T T E R
.
R SS C S A L - - - - - -
.
- c
. -. : . - -
j l l MILLSTONE 1 HIGHLIGHTS l
)
,
Presented by JOHN P. STETZ
. ;
,_ -
, . . : - .
REVISION IMPLEMENTATION- '
- -
Writer's Guide Rewritten
-
Administrative Procedure
-
Verification / Validation Procedure
-
PSTG !
-
Justification / Deviation Report
-
Finalize Calculations
-
Human Factors Reviews
-
Staging of Equipment
-
Referenced Procedures
-
Equipment Surveillance
-
PDCR's to Support
-
Venting Philosophy
-
Safety Evaluations
-
Technical Basis Document
-
Training
-
Resolve Design Basis Concern OCTOBER 1988 REVISION
-
Resolved Majority of NRC Audit Items
-
PSTG
-
Writer's Guide
-
Justification / Deviation Report
-
Technical Basis Document
-
Resolve TechnicalIssues
-
Flow Stagnation
-
Max CRD Flow
-
Pressure Suppression Pressure Curve
-
Cont. Pressure - Design Vs Limit
-
NPSH Curves
-
Referenced Procedures
-
Verification / Validation of Technical Issues
-
Safety Evaluation
-
Accessible Equipment '
-
Labeling
-
Operator Aids
-
Some Equipment Staging
-
Administrative Procedure _ _ _ _
. .
. !
'
-
ItADIOLOGICAL CONTROLS AND IMPROVEMENTS RADWASTE RADWASTE CLEANUP
-
Minimize Sources to Liquid Radwaste by Replacing, Flanging or Removing Piping J283 Removed 100 feet Pipe, Replaced 60 feet Pipe
.
Repacked 20 Valves, Replaced 5 Valves, Overhauled 30 Valves
-
Decontaminate Radwaste lower Levels and Paint to Allow Access Without Protective Clothing
-
Repair Pumps and Valves to Optimize Radwaste Processing J283 Overhauled 8 Pumps
-
Chem Nuclear Skid Installed to Replace Radwaste Concentrators
.
2:1 reduction in generated waste per year
. $22,000 savings in burial charges per year .
6.3 Man Rem ALARA savings per year DECONTAMINATION EFFORTS
-
12 ,290 ft2Decontaminated 128, ft2 DecontaminatedtoDate 5,700 ft2Scheduled for Decontamination
-
1990-1995 8,550 ft2 Decontaminated by 1-1-89 (projected) 29,753 ft2 Scheduled for Decontamination Total Area Deconed By 1995: 36,013 ft2 (projected) 100% of the Contaminated Area Available to Decon NOTE: Decontamination Schedule Dependent on ALARA Budget Constraints Unit One Data Radiological Controlled Area 246,040 ft2 Total Contaminated Area 75,351 ft2 (31% of RCA) Permanently Contaminated Area - 39.338 ft2 (16% of RCA) Contammated Area Available to Decon 36,013 ft2 (15% of RCA) ._
n
, .. .
-
l-
~ Permanentiv Contaminated Areas l <
Drywell Radwaste Tank Rooms Steam Tunnel Turbine Deck Storage Area Condenser Bay Equipment Area C/U and F/P Demin Filter Areas Contaminated Tool Storage Areas HCU Accumulator. Area Equipment Decon and Rebuild Rooms Stack Lower and Upper Levels C/U Rooms Misc. Skids and Pump Beds i PCM's
-
Better Hot Particle Detection
-
Improved Contamination Monitoring
-
Reduced Numberof Access / Egress Paths
- Before: 12
- After: 8 during power operation 9 during outages
-+ Positive Control of Radiological Area FUEL POOL RERACK RADWASTE DISPOSAL
-
Cleanup Phase - 222.7 ft3 of Irradiated Hardware Shipped (LPRM's and Control Rods)
-
Rerack Phase- -1400 ft3 of Misc. Spent Fuel Pool Components to Be Decontaminated and Sold for Scrap (Seismic Restraints and Old Control Rod Racks) SPENT FUEL POOL CAPACITY
-
Capacity Before Rerack - Available: 2184 Fuel Assemblies Used: 1732 Fuel Assemblies Remaining Cycles: Until 1992 (2 w/o Full Core Offload)
- Canacity After Rerack - Available: 3229 Fuel Assemblies (1045 more)
Used: 1732 Fuel Assemblies Remaining Cycles: Until 2003 (7 w/o Full Core Offload) Until 1997 (4 with Full Core Offload) - _ _ _ _ - _ _ _ _ - . _ _ _ - _ _ _ _ _ _ _ _ - _ - _ _ . _ _ _ _ . . - _ - _ - _ _ - _ _ _-_ _ . _ _ _ . _ _ _ _ - -- ___-_
_ - _ _ - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ . _ _ - _ - _ _ _ _ _ _ - - _
, . . . . .. * FUEL CONSOLIDATION --
Fuel Consolidation Gives a 2:1 Reduction
-
New Racks Qualified for Fuel Consolidation
-
Purchased Qualified Fuel Storage Racks for Use in U-3 Spent Fuel Pool ALARA
-
M Millstone One: 608 Man Rem BWRInd. Ave: 744 Man Rem PWRInd. Ave: 422 Man Rem
-
M Millstone One 150 Man Rem BWRInd. Ave: 649 Man Rem PWRInd. Ave: 393 Man Rem
-
M Millstone One: 684 Man Rem BWRInd. Ave: 622 Man Rem PWRInd. Ave: 397 Man Rem
-
M Millstone One: 157 Man Rem BWRInd. Ave: 600 Man Rem (projected) PWRInd. Ave: 380 Man Rem (projected)
-
GEZIP + Pilot Program - Reduces Recontamination of Recire System .
(subsequent to outage decontamination process) *
Theoretical Benefit - 2.5:1 Reduction in Radiation Levels i l
,
I L--_____-____________-_-_ . _ _ _ _ _ _ _
. _ _ - _ _ _ _ _ _ _ _ _ - _ _ . . . . '
OPERATING PHILOSOPHY SAFETY FIRST ACCIDENT RATE
-
LOSTTIME: - July 1987 Last Lost Time Accident
.
April 1989 Projected Million Work Hours
-
RECORDABLE: . 1 Recordable Accident in 1988
-
1988 Unit Goal ~7 Recordable Accidents
-
UNIT ONE SAFETY COMMITTEE MAJOR CONTRIBUTOR
*
All management actively participated on the committee
.
Members encouraged to set the pace within their respective departments for an accident free yea * Departmental personnel held responsible for their safety performance
.
Departmental incentives (Lunches, etc) 4 Excellent safety record achieved in 1988 ESW OPERABILITY
-
Weather Conditions Extreme
-
Equipment Problems Occurring in Quick Succession
-
Iessons Learned
. Impmved Communications
1
.
, _ _ . _ . _ _ . _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
_ _ _ _
. . , . ' . .
LERS
-
YEAR UNIT ONE INDUSTRY AVE SEC. EVENTS 1984 12 LERs 26 LERs 8 1985 34 LERs 31 LERs - 14 1986 32 LERs 27 LERs 19 198 LERs 26 LERs 15 1988 14 LERs 21 LERs None
-
Number of Unit One Daly LER's per Year Below industry Average
-
1987: 6 Outage Related Scrams / Actuation
-
All Security Events for Millstone Station Reponed Under Unit One Until 1987
-
Security Events ~50% of All LER's in '85, '86 and '87 (Millstone Three Computer Tie In) LENGTHENING OPERATING CYCLE Studies were performed to lengthen the operating cycle in pursuit ofimproved unit availabilit Cycle lengths based on present core conditions and a 95% capacity factor between outages:
# MONTHS FULL PWR - FULL PWR CYCLE # PER CYCLE MWD /STU D A YS(100 %) D AYS(95 %)
10- 17 8,192 46 .0 11 18 8,744 49 .0 12 19 10,000 56 .0 13 22 10,780 61 .0 14 21 10,200 (w/present fuel) 58 .0 22 10,800 (w/ axial enrich) 61 .0
,
CAPACITY FACTOR I
-
Millstone One Ranked 9th in 1988 - Worldwide
-
1988 3 Year Average - 86% '
-
Millstone One Capacity Factor Above Japan Since 1980
!
I l l I
- - _ _ _ _ - - _ _
__ . - _ - - _ - _ _
* .
in
.
OUTAGE PLANNING i (- MINIMIZE OUTAGE LENGTHE L PERFORMING MAINTENANCE DURING POWER OPERATION
-
Scheduling Significant Maintenance Evolutions During the Operating Cycle That Would l Normally Be Planned for the Refuel Outage l
-
Minimize LCO's for Maintenance APPLYING MINI OUTAGE STRATEGY
-
Taking Advantage of Mini Outages to Perform Inspections in Inaccessible Areas for Outage , Related Work j
! -
Equipment Operability (ESWl.ue)
] -
Open Comrnunicatian - Both More Sensitive DEFINING WORK SCOPE
-
Clearly Defining Outage Coortlination Responsibilities in the Maintenances' Departments
-
Providing Direction for Each Techniw! S:2 Member
!
!
. _ - - - _ - - _ _ _ _ - _ _ _ _
_ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ ..
.
*
,
.
FIRST .LINE SUPERVISOR INVOLVEMENT FIELD TIME Unit One Maintenance and I&C have instituted programs within their departments to increase first line supervisor time spent in the field. This keeps supervision abreast of activities conducted in the
' field and allows a first hand review of departmental procedures and policies at wor WEEKLY MEETINGS
-
Enhances Supervisor /Depanmental Personnel Pelationchip Via Open Communication
-
Provides Opportunity for Discussion of Company and Department Procedures Relative to Other Working Depanments
:
:
< _ _ . _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ i
- _-_ __-_ _ ______ _ _
.
>
'
I 1989 I l MAJOR OUTAGE WORK I l-LP-15 A/B.1-LP-16 A/B.1 CU-2. and 1-CU-3 MOV Replacement Replacing the MOV's with environmentally qualified operator LP-15 and 16 (drywell sprays) can be used for accident mitigation to limit drywell pressur Revision 4 of the EOP's take credit for these valve CU- 2 and 3 (Cleanup containment isolation valves) require envimamental qualification inorder to close during a LOCA in the drywell and a cleanup break outside the drywell Undervolinee Protection Degraded and loss of voltage protection will be relocated to the Class IE buses and the automatic reinstatement of the load shed featur: will be included. This modification will upgrade Millstone One's bus protection to the requirements of IEEE 279-1971 and meet the intent of the NRC Branch Technical Position PSB- Instrument and Service Air Improvements The existing station air compressor, aftercooler, instrument air compressor, aftercooler, and air dryers will be removed and replaced with new equipmen This modification will:
-
rectify the compressor and dryer failures
-
significantly improve the quainy oi use air exiting the dryers thereby extending the life of the air piping, air valves and insuuments
-
provide additional air volume to meet existing high system demand periods
-
locate new dryers upstream of the receiver
-
eliminate the need for auxiliary cooling Stud Tensioners Replace Unit One's stud tensioning system with a Q-D (quick disconnect) stud tensioning syste The ALARA savings realized from this change will amount to 250 Man-Rem for the remaining life of the uni _ _ _ _ _ _ _ _ - - _ _
m
' ..
L , _ Gas Turbine Governor Control and Circuit Modifications L Modificationsinclude:
-
The existing Electro-Hydraulic Gas Turbine (G/T) Governor Control System will be replred with Microprocessor Based Hardwar Timers, relays and speed switches will be replace The protective logic will be modified to remove pmtective trips under emergency start condition Changes will increase the G/r Governor relhbility from a current 86.4% to 94.4%, substantially reducing the public risk associated with the probability of a core melt. (GTG failures contribute 8% out of 28% of the probability of a core melt) Torus Water Strainers Larger torus strainers will be installed in the suction line to the LPCI/CS pumps. This will eliminate the possibility ofinsulation debris clogging the forus strainers during a LOCA. A concem surfaced identifying that during long tenn recin:ulation, insulation could migrate to the ECCS pump strainers and effect the performance of the pumps by collecting on the strainers, resulting on a loss of net positive suction hea Performing this work underwater, in conjunction with a Torus underwater surface inspection, will save 50 Man-Rem this outag Condenser Water Box Screen
Engineering continues to evaluate the placement of screens in front of the tube sheet or at the inlet of the waterbox for the 1989 outage. Screens will minimize the intrusion of mussels into the condenser tubes. Mussels have been linked to localized high velocity erosion of the condenser tube ISi New Ta=k=8 anew Unit One has been working with Westinghouse to perform automated remote ultrasonic inspection of the Unit One reactor pressure vessel welds and vessel flange to shell welds. This has only been perfomsd in Sweden and Finland since 196 By performing the UT inspection underwa::;r from the the inside of the vessel, instead of ultrasonically testing the welds manually from the vessel flarac and from inside the drywell, an ALARA savings of ~50. Man-Rem per outage will resul _ _ _ - _ __ _
- - - - _ - . . . . .. . :
' MILLSTONE UNIT 3 HIGHLIGHTS ! Presented by CARL H. CLEMENT l
I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __-----1-
_ - _ _ _ .
- - .
~
[ l- MILLSTONE UNIT 3 NRC PRESENTATION MARCH 16,1989
!
UNIT PERFORMANCE CAPACITY FACTOR 1986 84.1 % (Apr. 23 - Dec. 31) 1987 67.4 % (RF01 Oct. 31 - Dec. 31) 1988 76.5 % (RF01 Jan.1 - Feb. 25) 1989 75.7% YTD (Jan.1 - Mar. 4 -- RF02 May 20 - July 15) Cycle 1 80.3 % (Apr. 23,1986 - Oct. 31,1987) Cycle 2 85.0% EST (Feb.15,1988 - May 20,1989 LONGEST RUNS 163 days Apr. 28,1988 thru Oct. 6,1988 128 days Sept. 7,1986 thru Jan. 13,1987 100 days June 15,1987 thru Sept. 23,1987 REACTOR TRIPS Numbers include manual trips in response to equipment failures which would have resulted in an automatic tri Trips 7 Human Error (includes 6 Feedwater Control) 3 Procedure Deficiency (includes 2 Feedwater Control) 6 Equipment Failure 1987 - 10 Trips 3 Human Error (Includes 2 Feedwater Contro') 1 Procedure Deficiency 5 Equipment Failure 1 Unknown 1988 - 5 Trips i Human Error 2 Procedure Deficiency 2 Equipment Related - Intake Structure IMPROVEMENTS TO REDUCE TRIPS Feedwater Isolation Valves SOV coils replaced with lower wattage model to improve mean time between failures. SOVs reolaced on PM schedul ___ __ _. _ _ _ _ _ _ _ _ _ _ -
- _ - - _ _ _ _ _ . _ . _
.-_
. -
,.
-
.
Foul-Weather . Response . Weather Conditions. are Monitored more Closely. Raised consciousness of offshore conditions, seaweed ' growth periods, and.long periods with no storms which raise the potential for debris loading. Also, lowered the threshold for bringing in support personnel'to assist in debris remova 'Feedwater Control Task Force - Review procedures, maintenance equipment and trainin . Recommend any changes necessary to ensure that a simulator-trained reactor operator can - control steam-operator level' without challenging the low-level' trip setpoints. The task force included people from Training, Operations, Engineering and Instrument & Contro Recommendations ' Feed Reg. Valve checks to include freedom of movement, valve reliability improvements and , ability of the control system to achieve full valve strok Feedwater Reg. Valve PM Program revised based on-reliability evaluation -to include diaphragm replacement, positioner replacement and disassembly inspection Feedwater Reg. Valve positioner will be replaced with upgraded model less susceptible to vibration damag A similar upgrade has proven reliable on the FRV Bypas Document Lessons Learned. Since steam generator level is a complex interaction which is not consistent between plants, it is important that the lessons learned during actual plant operation be dnoumented. This will ensure that cause and effect of a large omber of evolutions can be predicted and most importantly those events which lead to unstable level control be avoided. This is especially true when the simulator does not experience the same behavio The documentation will provide to management a reference for planning of plant evolutions or procedure changes. This will avoid unnecessarily repeating plant
_ _ - _ -_ _ _ ___ . _ _ _ _ _ .__ (. .
.i . .
l k . trip Restrictions written in plant -procedures to j avoid unstable operation will not be' eliminate Operators will also better understand the reasons behind procedure restriction Digital Feedwater Control System recommended for ' long-term consideration. Similar systems are t currently in use in Belgium and some U.S. plants. The , digital system would compensate for' feedwater ! temperature, anticipate shrink / swell and automatically transition between the FRV bypass Valve and the FRV during plant start-ups. Improvements are dramati I
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ .
-__ _ _ _ _ _ _ - - _ _ _ _ . .,
- $afety -
Line-management respon6oility aspect- of safety has
.been re-emphasize Management Safety Teams meet monthly to set safety goals and review safety performanc Safety Observation Program puts line management in the
. field to observe for. safety first-hand. Line management from .first-line supervisors to executive VP make dedicated safety observations from twice per week to twice per mont Safety'is equal to other aspects of the job--ALARA, Budget, Schedule. It is incorporated as an integral element of job planning and executio Lost-time Accidents
.35 rate in 1988
'
' 12 . months, 600,000 work hours with no lost-time accident Recordables 10 in 1988 -- non-serious 3.5 rate in 1988 I
- _-__
- _ _ _ _ _ _ __ _ _- . ... , .. . .1989 : Rx Trips February' 10 Low-power = feedwater - control - problem experienced at 20% power when removing the turbine from the grid _fo overspeed testing. Steam Generator low-level trip receivei Feedwater Task Group addressed the areas of control instabilit Only trip due to feedwater control difficulties in 198 April _13 Trip from 100%' power. Loss of circulating water'- ,
pumps due to fouling of traveling screens. One of the screenwash pumps was being rebuilt. The second screenwash pump'was removed from service to
.
facilitate shiftina screenwash strainer October 5 Trip from 100% power. The MSIV_ closed during part stroke testin The procedure was not clear on all thel attenuators that were required. In addition to improvements in the procedure, a' new test method was-
' instituted that .was less stroke-time sensitive. The revised method checks b'oth-trains with' a visicorder allowing both test trains to .be done simultaneousl This results in a slow stroke closed to 90% while still verifying the operability of both trains of solenoid October 22
> The operators tripped the plant from 100% power when several circulating water pumps tripped _ due to storm induced fouling of the intake screens. The screenwash cleaning system was unable to keep up with the rate cf seaweed loading. To increase the trash removal l capacity during extremely high storm loading, a [ alternate debris removal section has been added to the debris conveyer syste _ _ _ _ _ - - _ _ _ ._
- _-______ - ' *
- .
.
December 29 The plant tripped from 100% power while testing the Emergency Diesel Generator. Offsite power was being supplied from the reserve transformer. When the diesel is aligned to the plant electrical system, a
- protective relay limits the power that may be supplied to the non-vital electrical bus. A combination of loads resulted in deenergizing the non-vital bus. The rod drive power which hold the rods up was lost and the plant trippe !
.
i
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ \
- - _ _ _ _ _ _ _ - _ - -_ _ - I
.
,
'
!
!
MILLSTONE UNIT 3 { NRC PRESENTATION l MARCH 16,1989 l MAINTENANCE OUTAGE PHILOSOPHY i intake structure work previously scheduled during refueling outages now scheduled during Fall or Winter operating period Advantages Minimizing Work Scope during Refuel Levelize Work Load Additional Management involvement Disadvantages increased Risk of Trip if Sister Pump Stops increased Reliability of Intake Structure Balances the Risk INTAKE WORKSCOPE Cire. Water Pumps 3 - October 88 - February 89 3 - October 87 - January 88 100% Inspection - Pump & Motor No Major Problems Removed Low Lube Water Pump Trip Service Water Pump I December 1988 100% inspection Pump ; Morel Bearing Journals Replaced with Chrome Phted t Impellar Replaced - Erosion; Previously Shaved to Meet Performance Requirements Screen Wash Pump A - April 83 (High Vibration) B- Feb.89 100% Inspection - Pump & Motor Rebuilt Pumps - Bearings, Bearing Supports, Shafts, Impellars New Materials to Prevent Galvanic Corrosion
_ - _ - . _ . - - - - . - - - - - - - - - - _ _ _ _ _ -_ -- _- - - - - - - - - _ - - - - - - - - - . - _ _ - - - _ _ -
, . * , .
Traveling Screens 3 - Oct. 87 - Jan. 8 Oct. 88 - Feb. 89 Replaced Panels Lower Spindle Rebuilt Carbon Steel Chain Replaced with Stainless Steel Service Water Pump Strainer Tubesheets Replaced with Monel General Lube Water Strainers Rebuilt Corrosion Protection Too Early to Fully Assess Results of Maintenance Efforts R and improvements, but Operators Express a Much Higher Confidence Level in the intake Structure Additional Shop Space The new addition to the Maintenance shop was completed in November. The shop was the functional center for Maintenance activities in December. The shop will be fully. operational by the end of March. The expanded shop adds the following capabilitie , High bay work area with two 10-ton crane All major pumps can be worked in the sho Tool crib expanded from 500 to 1500 square fee Consolidation of 4 satellite tool storage area Electrical Shop expanded from 400 square feet to 1200 square feet.
I
<
' Machine Shop expandad from 2000 square feet to 3500 j square feet allowing full use of machines.
l Total shop area was expanded from 4800 square feet to 12,000 square fee f l
l l-
- _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _
. . , ..
MSIV SOLENOID PROBLEMS AND REPAIRS August 1, 1986 Failure:-The C MSIV failed to open due to sticking (energize to open) solenoids. The problem was due to the inability of the solenoids -to overcome their internal drag with current attenuators installed to increase the EEQ life. The drag problem was exacerbated by bent stem . Corrective Action: The plant was cooled down. The stems I where straightened . , Long Term Corrective Action initiated: The procedures ! for valve testing were modified to bypass the attenuators when testing or opening the valve ; April 6, 1987 i Failure: During a mid cycle shutdown for surve',Ilance the C MSIV closed completely during part stroke testing. The cause was attributed to insufficient air gap between tae plunger and the armature of the solenoid. This resu;ted in magnetic coupling that prevents the valve from closing when require The gap spacing was reduced when the solenoid seat was lappe Corrective Action: The armature was machined to establish , the proper air ga Long Term Corrective Action: The maintenance procedures were modified to measure the air ga June 6,1987 , Failure: During a plant shutdovin the A MSIV would not part I stroke during test Of the train B solenoids. The problem was : found to be a combination of bent sicms and insufficient air gap Corrsctive Action: The plant was cooled down to repair the valv Long Term Corrective Action initiated: the air gaps on all energized solenoids were checked and the stems were ' examined for straightness and corrected as necessar i
9
__ _ . _ _ _ -. _-- _-__-
.. , .
July -27, 1987 . Note: Informed by Sultzer that an . iron oxide film . develops on l-the solenoid pilot plug and positioner indicator. Test have-shown that the iron oxide can develop within 24 hours at lapping valves. Heat treated parts prevent the probler,. l November 20, 1987 Note: Design change is approved to incorporate recommended material change ]
(
!
December 8, 1987 Corrective Action Update: Available recommended materials'were placed in the D MSIV . October 5, 1988 Failure:' The C MSIV closed during part stroke testing at 100% power. The failure occurred due to not completely bypassing
.
l
all attenuator l Corrective . Action: The procedure was changed-to clearly ! identify all jumpers require l Long - Term Corrective Action Initiated:. N/A October 22, 1938 Failure: A solenoid stuck on the A MSIV during part stroke testing. The sticking was caused by an indentation on the plunger apparently the- result of localized compressive force Corrective Action: The plant was cooled down and the solenoid internals were replace Long ; Term Corrective Action initiated: The material changes previously identified and approved were installed in the solenoids used to ensure valve closure. In addition , maintenance has employed a method (reverse peening) for stem I straightening that does nnt leave residual stresse l October 31, 1988 Failure: During repair testing, the A MSIV showed evidence of , sticking at various positions. The sticking was determined to ) be caused by a sheared pilot piston pin. Excessive forces occurs in the open direction if an interval of less than two ] i minutes is used between valve strokes. This prevents the i pressure from being developed above the pilot piston and acting to dampen the spring forc _ - - _ . _ _ _ _ - - - - - _ _ - _ -
.
)
l
'
l ' l
' Corrective Action: The solenoid was ~ repaire l 'Long Term Corrective Action initiated: The procedures l
which stroke the MSIVs have been modified to ensure sufficient time between valve stroke February 12, 1989 Failure: The A MSIV "A" train vent solenoid did not close when l deenergized. The pilot was bound in the mac, valve due to uneven spring pressur Corrective Action: The effected solenoid disc and pilot were replaced. The springs were machined to obtain parallel end
~ face Long Term Corrective Action initiated: All valves were inspected and the springs machined as required to meet specification Remaining Long Term Corrective Action Planned: The ,
solenoid valves without upgraded materials >will be rebuil '
s _ _ - _ _ _ _ - - _ - _ _ - _ - - _
_ - _ _ _ _ _ _ - _ _ - _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _
. . , .
MAIN STEAM ISOLATION VALVES CORRECTIVE ACTION SUMMARY Materials Have_ Been Changed on the Pilot Plug and ' Position Indicator Tests have shown that the existing similar materials can produce a I-mil thick oxide' film between two mating surfaces within 24 hours of lapping valves. Heat-treated parts prevent the problem. Plants in Switzerland and Sweden have been operating with the new material since last Octobe Air Gaps-Have Been Machined Too small of an air gap has been shown to permit too much l magnetic coupling. It is desirable.to have air gaps at the high' I end of toleranc Stems Have Been Straightened Stem material has been changed to a material less susceptible to' bending. Maintenance has developed a method of straightening stems which does not leave residual stresses , and has refined installation technique Attenuators Added to increase EEQ Life are Bypassed
'
During Testing - Limitations on Time Between Valve Strokes imposed When the valve is stroked in a short time interval, the
. pressure is not allowed to equalize. The spring when not restrained by steam pressure above the seat can create a sufficient dynamic load at the end of travel to shear the pins in the valve pilo Springs Dimensionally Tested for Flatness A number of opening springs did not meet the specification for flatness. Binding occurred which could prevent pilot movement. All Springs have been correcte _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
n,
'
,
+
,
.,
i
' Maintenance Self-Assessment I in March 1987, INPO requested that NU participate in an . industry-initiative by performing a Maintenance Self- !
Assessment. This initiative was based on the program
]'
sponsored by the NUMARC Maintenance Working Group. The _ self-assessment was based on INPO 85-038, Guidelines for the Conduct o Maintenance at Nuclear Power Station ! In April 1987, an NU team was formed to oversee and
'
coordinate the efforts of the working group- who would conduct the assessment. The Steering Committee was selected from NE&O Management and three included former Maintenance Department supervisors. Members of the working group were i
. drawn from all disciplines of NE&O as a particular expertise was require The conduct'of the assessment was structured to use a list of standard questions developed for each of the 16 Chapters in 1 'INPO 85-038. The questions-were used in an interview " . process. When feasible, observations of actual practices were made part of the interview process. LThe assessment effort compared the unit's maintenance program to the programs described by the guidelines. When a guideline item and existing situation was sufficiently divergent, and it was felt that a problem existed that required resolution, that item. was identified. The team then generated a recommendation to address that ite W Based on the recommendations, line management developed an integrated Management Action Plan. The plan addressed each assessment recommendation with respect to implementation responsibility, improvement action and milestone planr,'ag dates. The plan integrated, among other things, resource availability and consistency between units and station (Copies of several examples are attached.) The implementation schedule is tracked and periodic progress reports are made to senior NE&O managemen l , 1
_ - - _ - _ _ - - - - _ - _ - !
.. i, -
. , , .
Several examples of major topics identified and the manner in which they were addressed are as follows: item: There are no Corporate policies or Corporate-level procedures specific to Maintenanc I Resolution: In October 1988, an NE&O Policy Statement i addressing Maintenance was issued by the Senior Vice-
{
President. Subsequent review indicated that no sub-tier i procedures were require j ltem: Resource availability was highlighted by questioning the processing delay to fill personnel vacancie ' Resolution: A memo of understanding was issued by Vice-President, Nuclear Operations which has significantly reduced the processing time for replacement peopl Item: Interview results indicated a desire for more supervisory presence in the fiel i Resolution: In mid-1988, a task analysis was performed to determine in what areas first-line supervisor (FLS) were spending time. The results were analyzed, a number of initiatives resulted based on a particular department's needs. Examples are: Operations Work Coordinator is being used on a pilot- 3 basis to streamline planning and communications j between department j l An Assistant Engineering Supervisor has been ] temporarily assigned to Maintenance. This provides a ! focal point for Engineering problems and also results I in reducing the administrative load of the Maintenance Superviso Work Order package preparation responsibility has been transferred from the FLS to the Department Planning j Grou ,
_ _ _ _ _ _ _ - - _ - _ - _
" ' . . , , '
1 .*' Item:. PM ' Program implementation was addressed-by two 'l separate items. The first indicated that it was a common .. practice to defer / cancel PMs due to lack of manpower. The
- second identified that delayed PMs were not - - reviewed / approved' by the appropriate level of department.
g supervisio Resolution: The PM procedure was revised to provide .
.
guidelines on the deferred PM grace period which'a first-line supervisor can approve and when the concurrence of-the ! Maintenance Supervisor is required. The deferral of PMs j was in part an equipment and PM program maturation ~ proces A' review of the INPO Quarterly Maintenance Data for the past I - l 1/2 years shows an average of 1000 PMs l performed each quarter with only approximately 25 PMs :not' completed within the' scheduled interval. Both _ improvements indicated that the Maintenance PM . Program is improving.
. L
> ,- l . ,
L l
.
i MILLSTONE UNIT 3 l
.
NRC PRESENTATION j MARCH 16,1989 1 l
L OPERATIONS Annunciators
'Since power Ascension testing, we have been working .
toward the " blackboard" Control Board annunciator panels. The methods to reduce' lit annunciators include correcting plant conditions that result in annunciators, removing unnecessary annunciators, changing setpoints and engineering design changes to the annunciator's logi j This has reduced lit annunciators from 75 in 1986 to 29 , in 1989. $750,000 has been expended for this effort.' By ! the end of the third refuel, we expect to reach no more ' than ten of approximately 900 main board annunciator lit at power operatio J , Cooldown after Rx Trip During 'the October 5,1988, trip recovery, of the operating shift experienced some concerns on the cooldown magnitude experienced after a trip from 100% powe The RCS cooled down from 557 degrees F to 53 degrees F over 40 minutes. The plant design should limit cooldown .to 550 degrees F. Although the cooldown did not exceed any magnitude or rate limits, there was confusion generated by the fact that the EOP on Reactor Trip directs the operator to shut the MSIVs if an uncontrolled cooldown exists. No definition of
" Uncontrolled" is given. Instead we rely on the experience and training of the operators to evaluate . plant conditions at the time. The review included Operations, Engineering, Westinghouse and GE and resulted in the following action '
)
i L- _ _ . _ _ _ _ _ - . - _ _ - _ _ _ _ _ _ _
g *
.. . As 'a result of the actions taken during that trip and a subsequent trip on October 22,1985, the AOP on Turbine Trip has been modified to include a list of possible ~ areas to isolate on a turbine / reactor trip to minimize heat losses. These include:
a) Turbine stop valve.before seat drains b) Condenser Steam Dump Valves c) Main Turbine Driven Feed Pump steam supply d) Main Steam to Auxiliary Steam 2. - Additional maintenance and training has been performed on the units auxiliary boilers to enhance availability and minimize potential for problems-in this area. Although not a factor in these trips, availability of the auxiliary boilers had been a concern in a. previous tri . A calculation was performed to establish a " worst case" allowable' cooldown. This indicated that 520-degrees is the lowest we would want to go, in order to avoid any _ concerns with shutdown margin. It should be noted that during these trips, plant safety was never antissue. The plant is protected against excessive cooldown by an MSIV isolation on low steamline pressure corresponding to approximately 506 degrees in the reactor plan . An evaluation is ongoing to delete the trip open feature of the turbine stop' valve before seat drains. This would - decrease heat losses by 25 M . The operation of the Moisture Separator control valves is being evaluated. A problem that occurred early in Cycle 2 with the' valves required them-to be operated in Manual for the rest of the cycle. This causes a several minute delay to automatically isolate the MSR steam pat !
!
17 I i ___ _
- _ _ _ _ - _ - .
i Fire Protection Compliance L Fire Door Labeling
Provides on-the-spot information to personnel using a bold red sign' with white lettering identifying the. door as a FIRE DOOR accompanied by the instructions DO NOT OBSTRUCT. Additionally, each fire door has been '
.
labeled with its unique identification number to ensure communications between personnel specify the correct doo Surveillance Testing improvements Periodic surveillance testing of fire panels and detectors is being accomplished with an improved surveillance procedure which provides more detail. This included dividing the procedure into additional sections to remove potential confusion caused by having a generic procedure for all zone panels. For example, instead of saying, "If the zone panet. . . ," the procedure directs ' specific action and does' not use "If" statement Annunciator Response improvement OP 3341D, Fire Protection Detection and Control, has been revised to provide clearer and more detailed guidance to the operators for responding to Control Room fire panel (Simplex) alarms. Specifically, each alarm message that can appear on the fire panel is duplicated in the operating procedure, accompanied by required action and reference to figures that show all the affected fire-detector location _ _ - _ _ _ _ _ _ _ _ - -_ ---
-
.
.
.
,
'
Fire Watch Controls Surveillance. Procedure 3641E.1, Fire Watch, was approved in September 1987, as a result of fire watch 1- problems. Two changes' have been incorporated since f then. First, to provide guidance when an area has two-levels; and second, to' clarify when a fire watch can be cancelled following maintenance on a fire barrier ~ (after acceptance.by Operations). Additionally, the roving fire watch has recently commenced carrying'the list of-stations to ensure no area is missed. It is important to note that the_ practice of having an SS or SCO to tour each
-
shift to check fire watches has continued to be a major source of early identification and correction of-problem i
;
_ ______-_-__ _ -
___ ___ __-___ _ -
- . .
Operations Work Coordinator
.
Allows Consistent Interface with Sup' port Department Pre-planning and pre-packaging of work orders allows the release of certain known work activities within hours of a forced outage.- Allows for Long-Range Plannin Equipment outages planned quarterly, semi-quarterly and annuall Preventive Maintenance of Equipment integrated ~ with Surveillance Test Feedback'to Operations personnel on the status of equipment has led to better coordination of equipment outage Generations of exception reports allows department supervision to track and evaluate repetitive chronic problems, i
! - - _ _ _ _ _ _ _ _ _ . I
_ _ _ ___ _ - _ _ _ _
._ _ - = _ _ _ _ _ _ _ - _ _ - _ _ _ - _ _ - _ . _-_ _ - _ _ _ _ - _
J - t- . .
, .
RADIATION MONITORS I System Description The Radiation Monitor System' consists of liquid, particulate' and gas, and area radiation monitors, connected to Radiation Monitor Computer. Process monitors--liquid , monitors or particulate and . gas monitors--are microprocess-controlled skids containing the piping, . valves, pumps, sample chambers,. detectors, electronics, and instrumentation needed to sample a process stream. Area monitors have
~
microprocess-controlled electronics and a detector which monitor an area of the plant.
p Millstone Unit 3 has 15 liquid monitors,13 particulate and gas monitors, and 36 area monitor < A Radiation Monitor Computer communicates with each monitor to record radiation levels, trends, equipment status,
'and alarms. Operation of monitors which are not safety-related can be changed locally, or from operator consoles in the Control Room, Computer Room, and Health Physics laboratory.. Operation 'of safety-related monitors can only be changed locally or from the Control Room radiation monitor pane ~ Printers in the Control Room and Computer Room provide ha'rd copies of changes in the- status of each radiation monitor. A main control board annunciator alerts operators of alarms in the radiation monitor syste The Radiation Monitor System was built by Kaman, which has since eliminated their radiation monitor business. Many -
components in the skids are subject to frequent breakdowns, which initiate alarms. Alarms from fail components occur and reset continuously, until repaired. The high-gain amplifier circuits and microprocessors are susceptible to electromagnetic interference, which includes spurious alarms that reset almost immediatel The program to reduce the number of radiation monitor alarms has emphasized correcting system-wide problems which cause the most alarms, and then targeting specific monitors which cause frequent alarms. This program has
L_-_-- - - -
i
- ,
I
.
successfully reduced the frequency of alarms from roughly fifty alarms per hour to an average of 5 alarms per hour, l Improvements i j Corrective Maintenance improvement I Many alarms are caused by equipment malfunctions such as binding in paper drive systems, debris in process lines from sumps, check source solenoid failures, etc. Field kits to correct paper drive problems have been ordered, and design changes have been made to improve reliability of other components. Operational experience has streamlined troubleshooting and repair tim Changed Process Setpoints Many alarms where caused by process setpoints (Iow and high flow, pressure, temperature, etc.) which were set based on estimations of the parameters which were made prior to plant operation. Operational experience has guided the program to change process setpoints to better value Changed Radiation Alert Setpoints Like the process setpoints, radiation alarm and alert levels were estimated prior to plant operation and have been changed to be consistent with operational experienc Improved Noise Protection and Suppression Since they employ large gain amplifiers, radiation monitors are susceptible to low-level electromagnetic noise. Design changes to limit electromagnetic interference have been incorporated on monitors in high-noise environment Installed Computer input to Monitor Test Skid A spare radiation monitor was converted to a test skid, so that design changes could be tested prior to modification of operating monitors. An input to the Radiation Monitor Computer was added to allow recording and trending of the test skid performanc New Radiation Monitor Computer The Digital Equipment Corporation model PDP-11/34 Computer, which is used as the Radiation Monitor Computer,
22 L_ _ _________ - - - - - - -
E. a-
. .
^
was replaced with 'a' PDP-11/84 compute This. improved alarm logging? processing and handlin Setpoint Procedure Implementation p Some radiation monitor alarms were due to. planned evolutions An Operating Procedure was written to allow-l alarm setpoints to; be changed for short periods when alarms,- q are expected. An ' example is transporting radioactive,
'
L material past an area monitor: the alarm setpoint'is~ temporarily raised 'which the' material is transported'past the monitor, and then reset to the- original,valu Software Changea A set of-default setpoints resides in memory in .each monitor.- Default setpoints are used when the monitor has lost power and cannot communicate with the Radiation Monitor - Computer. Default setpoints installed at the factory;were modified to plant-specific values. Also,- a software ' noise filter is being developed to eliminate- noise-induced. alarm Control Building LRadiation -Monitor The control building ventilation inlet radiation . monitors represent the worst-case alarm generation scenari Exhaustive testing has revealed that these monitors are
. . particularly susceptible to electromagnetic interferenc . Further. tests indicate that half the spurious alarms can be eliminated by noise suppression circuits. A software- filter, which will reject alarms that occur and clear almost instantly,-is being developed to eliminate the remaining spurious alarm The work which led to these conclusions involved many man-
, months of extensive testing: Exchanged components with functioning monitor Replaced components with new part Provided separate ground to monitors.
, Contacted Kaman for recommendation Contacted other radiation' monitor vendors for recommendation Compared experiences with other Utilities which use Kaman , radiation monitor ~I
23 ] l
< - - - . _ - - . A
, - __ _- - _- _ ._--
, :L! .
? Performed engineering analysis of grounding and shielding system, and tested- modifications Developed test skid for design change Installed a spare radiation monitor computer drop to allow is , computer trending of test ski Performed an extensive in-service test to collect data on spurious alarms, using spectrum analyzers, power disturbance monitors, logic recorders, et Verified that DC power cupply voltages were not affected and were not an introduction pat Found relation between electrical disturbances in the area and alarm Tested power supply filters and isolation transformers to enhance noise rejectio Started development of software noise filte ; l
I l t ,
l L___ _
_- _ _ _ _ _ _ __--- _ _-.
. . .
MILLSTONE UNIT 3 NRC PRESENTATION
,
MARCH 16,1989 l ENGINEERING SURVEILLANCE REVIEW PLAN Technical Specification Surveillance Procedure Review Background: After identifying several occasions where Technical Specification Surveillance were missed due to Surveillance Procedure inadequacy, MP3 committed to performing a complete Surveillance Procedure / Technical Specification review per LER 87-042-00. This effort was completed at the end of 1988 and involved the review of 1028 line items in the Master Test Control List (MTCL). The review criteria and results are summarized on the slide Solution: The three reportable issues were documented via LERs and corrective action was completed in December 198 The identified minor problems will be addressed as a part of MP3's bi-annual procedure review progra PROJECT COMPLETION PUNCHLIST Numerous system / component deficiencies were identified during MP3 startup which did not degrade power operations, but were still administrative problems. MP3 and the NRC l agreed to a Project Completion Punchlist (PCP) closeout { schedule to review and address all open startup deficiencies j over a two-year period. At the end of 1988, all but 328 ; items had been closed out, and these have been transferred to other tracking systems for prioritization and eventual closure as manpower is availabl I i REFUEL OUTAGE HIGHLIGHTS i Thimble Tube ECT During RF01, ECT of the incore Thimble Tubes indicated up to 50 percent degradation in some instances. The l 25
:
_ _ _ - _ _ _ _ _ - _ _ _ - _ . _ _ _
pq.-- q
. .
, I
.
affected tubes were moved out of the core by one inch to cover the degraded. areas and follow-up ECT will be performed during RF02 to detect further problem Hf Control Rods Westinghouse Hafnium control rods have experienced hydriding degradation at other similar plants. M P3's I control rods will be inspected during RF02 to assess the extent of the problem. Control rods will be replaced if d required during the outag Fuel Inspection Eighty-four fuel assemblies will undergo ultrasonic testing (UT) to detect potential leaks (reactor coolant radionuclides analysis indicates same fuel leakage does exist). Lithium inspections (ECT and profilometry) will be performed to determine fuel crud thicknes SW Piping Repairs MP3 has experienced severe erosion / corrosion damage in small-bore elbows. Suspect areas have been examined by UT and will be cut out and replaced with longer radii piping which should resolve the proble OUTAGEITEMS ILRT The first post-commercial containment Integrated Leak Rate Test (ILRT) will be performed during RF0 Containment will be pressurized to approximately 40 psig and held for 24-hours to perform the test using the Total Time metho , SG ECT Steam Generator Eddy Current Testing (ECT) will be performed on approximately 5000 tubes in 2 steam generators. RF01 inspection yielded no pluggable indications, and these excellent results are expected to continu SG Sludge Lancing Steam Generator Sludge Lancing will be performed on all four steam generators. RF01 lancing removed only 1
4 _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _
_
. _ _ .
_ ._ _ __- - __ -
.
>
, , .
approximately 45 pounds of sludge' per SG, and these-excellent results are expected to continu Snubber inspection
'
Approximately 950 snubbers will be visually examined -
- and'80 will be' removed for functional testing during
-
RF02.
" Secondary Side Erosion / Corrosion During _ RF01, baseline UT data was obtained to meet th concerns of NRC Bulletin- 87-01. Examinations of these -
- high-risk piping segments!will continue in accordanc with NUMARC guideline Feedwater Flow Venturi Cleaning
' The Feedwater. Flow Venturi will be hydrolazed to
.
remove the deposited corrosion layer buildup to allow more accurate calibration of Nuclear Instrumentation. In addition, continuous cleaning equipment will .be installe to help ' minimize the corrosion layer buildu MOV Testing The Motor Operated Valve (MOV) test program established under' NRC Bulletin 85-03 will continue. Efforts will be made to change to a new style test equipment which will provide more accuracy and easier test set-u PROJECT ASSIGNMENTS Hot Leg Level Transmitters Three level transmitters will be installed to allow accurate indication of reactor vessel water level as it approaches the loop centerline during a maintenance
-
draindow Feedwater Heater Reliefs - Feedwater heater shell side relief discharges will be redirected to the Turbine Building roof to eliminate a significant personnel safety hazard. Reliefs were previously directed to the Turbine Building floo SG Blowdown Line Flow inst New SG blowdown line flow instrumentation will be added to more accurately represent blowdown flow and thus' improve calorimetric accuracy and SG chemistry contro _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _
_ _ -_ . - _ _ _ - _ _ _ . _
, . .W i ...
AMSAC-Modifies Auxiliary- Feedwater Pump start .and turbine trip circuitry to meet ATWS concern Cold-Leg Recirc Array Modifies the Main Control Board Cold-Leg Recirc Array.so that it matches the procedural steps.as sequenced in the EOPs. This project addresses a human factors concern.
L Wide Range RCS RTDs Replaces existing RCS wide range loop RTDs with better designed models to meet EEQ and ALARA concerns.
s RCP Oil Level Indicators Adds RCP Oil Level ' indicators to circuitry. Previously,
.
operator indication of RCP oil level was via level alarm only, and this project provides continuous-level monitoring capabilit CONTAINMENT VACUUM RELAXATION The Millstone 3 containment is operated at a subatmospheric pressure of about 10 psia based on original design. The containment pressure is such that partial pressure requirements for oxygen are not met.. While the atmosphere is not life threatening, it is . difficult to perform physical activities such as carrying tools, stair climbing, etc. The pressure is about equal to 10,000. feet above sea' level. The
.
only. enriched oxygen breathing system approved by OSHA is a rebreather. system with positive pressure maintained by addition of oxygen. Subatmospheric pressure is required prior - to increasing plant temperature above 200 degree l During initial entries in 1986 a high incidence of ear injuries )
(18)' were experienced which included bleeding ear drums, i swollen ear drums, etc. Additionally, two individuals experienced a heat stress problem on an elevated platform j even though the ambient temperature and humidity was well within safety standards. A significant number of individuals are unable to physically enter containmen To limit the potential for injury, strict medical controls have been placed on containment entrie j
..
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ )
'
.
.
- Background Medical checks. In addition to normal requirements, a Tympanic ear check is performed and a l blood test for oxygen capability is performe Pre-entry Medical checks: Hydration; limited alcohol within 24 hours, proper meals, no strenuous exercise i'
within-24 hours. Head Congestion; tympanometer exam, no colds. Stress / pressure tolerance; blood pressure, pulse, no dental wor Post Screening: A nurse checks blood pressure, pulse, and any other symptom the individual experience Other controls include limiting containment entries to 2 hours and only allowing i entry per day. Each entry team must have an assigned individual to monitor heat stress and stringent briefing requirements are imposed. The rate of pressurization /depressurization are controlled and a special door operator is assigned. Even with the above controls, 2 ear injuries and 1 ocular migraine headache occurred in 198 Long Term Solution: Modify the design operating pressure of the c.ontainment from the existing range to a maximum of 14.2 psia. The new pressure would permit the elimination of the supplemental oxy 0en requirement. This would reduce the heat stress problem since the rebreather limits the ability of the body to remove heat. Additionally, the effects of working at low pressures would be essentially eliminated. The ear problems would be limited to that experienced by a 1000 to 2000 ft, change in altitude. The pressure selected would l still permit detection of a breach in the containment i pressure envelop i I l , !
[ l L___ _ _ - - ---- - - - J
-_
e
.a# . .
ENGINEERING SUPPORT ENGINEERING INTERFACE IMPROVEMENTS Improved Project Assignment Meeting Manager-level people attending. Better working level meeting. Includes " Level of Effort". Corporate Engineering work item Development of a Level of Effort Work List ' During the closeout of PCP both NUSCO and the plant recognized the value of developing a mutually agreed upon list of level of effort work. The plant and NUSCO have been working to develop such a list for all LOE work with NUSCO and will discuss the status of this list after all future" Project Assignment meeting Monthly Discussion of Programmatic Concerns During the PCP closeout effort, plant and NUSCO personnel met biweekly to review the status of items assigned to NUSCO. These meetings also proved invaluable in identifying and resolving. programmatic concerns of interest to both groups. Because of their value, NUSCO and plant personnel will continue to meet on a monthly basis in order to keep each other hformed about mutual concerns and items of interes INTERFACE WITH NUSCO Project Completion Punchlist Closeout in 1988 the plant closed 1544 open PCP items and transferred 382 PCP items to permanent plant tracking systems. NUSCO frequently supplied information which helped to define and resolve some of these item I
1 _ _ _ _ _ _ _ _ _ _ _ - - - - - - - _ _ _ _ _ _ _ J
_ _ _ - _ - - - - - _ - - - -
-, . .
Resolution of the Rosemount issue During the February RCP Outage, NUSCO supplied the ' direction necessary to resolve the Rosemount transmitter issue. This information was supplied in l a timely manner despite the original schedule which did not expect to address this until the refuel outage in Ma .
!
PDCRs Delivered 90-Days Before Outage l All PDCRs were delivered to the plant 90 days before ( the upcoming refueling outage, with the exception of f those which have been delayed with the consent of the plan Service Water Leak Evaluations NUSCO has been available 24 hours a day to support the seismic evaluation of service water leaks for continued operatio MSIV Failure Mode Analysis NUSCO identified the failure mechanism of the MSIV solenoid during the February Outage after the Plant and the vendor had failed to do s I o
- _-_ _ _ _ }}