IR 05000293/1989001
| ML20245H986 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/24/1989 |
| From: | Blough A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245H958 | List: |
| References | |
| 50-293-89-01, 50-293-89-1, NUDOCS 8905030602 | |
| Download: ML20245H986 (72) | |
Text
._
n ,
,e ,,;
. . .
\
U. S. NUCLEAR REGULATORY COMMISSION !
Region I Docket No.: '50-293 Report N /89-01 Licensee: Boston' Edison Company ,
800 Boylston Street Boston, Massachusetts 02199 Facility: Pilgrim Nuclear Power Station Location: Plymouth, Massachusetts Datas: February 6 - March 10, 1989 Inspectors: C. Warren, Senior Resident Inspector and Restart Manager T. Kim, Resident Inspector, Pilgrim Station C. Carpenter, Resident Inspector, Pilgrim Station A. Howe, Senior Operations Engineer, RI 6. Bethke, NRC Contractor G. Bryan, NRC Contractor J. Lyash, Project Engineer, RI F. McManus, NRC Contractor T. Rebelowski, Senior Reactor Engineer, RI P. Drysdale, Reactor Engineer, RI M. Kohl, Reactor Engineer, RI P. Wilson, Reactor Engineer, RI N. Dudley, Project Engineer, RI R. Latta, Resident Inspector, Comanche Peak D. Carpenter, NRC Site Manager, Brown's Ferry Station M. Dev, Reactor Engineer, RI G. Smith Safeguards Specialist, RI
~
W. Olsen, Physical Security Inspector, RI J. Furia, Radiation Specialist, RI R. Winters, Reactor Engineer, RI Approved by: M A. Randy Blougif; Chlef b-Di Date
'
Reactor Projects Section No. 3B Division of Reactor Projects
.
A 0 0 6
_ _ _ _ _ _ _ _ _ . _ _ _ _
.-
. ,
.
~
Inspection Summary:
Areas Inspected: Restart staff inspection to assess licensee management con-trols, conduct 4 operations and startup testing activities during the licen-see's Power Ascension Progra Results: The report documents the licensee's successful completion of the Residual Heat Removal- system boundary leak rate test and the Main Steam Isola-tion Valve opening test (Sections 3.3 and 3.6). These tests were directly responsive to the technical issues associated with NRC Confirmatory Action Letter 86-1 Violation: The licensee failed to identify the presence of . Iron-55 and the activity resulting from the radionuclides en the shipping papers for seventeen shipments of contaminated laundry between January 1988 and February 1989 (Section 8.',2).
Unresolved Items: The licensee's root cause evaluation for observed foreign material intru-sion into the MSIV 4-way valves and development of an inspection schedule for the valves will be reviewed (Section 5.1). L i c o . . .+. to review its policy regarding determination of deportability of missed Technical Specification Fire Watches (Section 7.4).
Strengths:
~ Operational evolutions continue to be performed in a competent and pro-fessional manner (Section 2.0). The licensee's approach to determining the root cause and formulating cor-rective measures following the March 4,1989, reactor scram was prudent, thorough, and consistent with good engineering practices (Section 2.3.7). Good coordination between the engineering department and the station main-tenance section was noted during the HPCI outboard steam isolation valve repair work (Section 5.4).
Weakness: Lack of preplanning to backfeed electrical power to the plant delayed recovery from the loss of offsite power (Section 2.3.5).
_ _ - - _ _ - _ - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - - _ _ _ _ . - _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _
_ _ _ - _ _ - . . _ - . ._ __
..
, ,
l l
..
l TABLE OF CONTENTS Page Summary of Facility Activities............................ 1 1 Operations (Modules 71707,71710,71715,62703,61726).... 2 Startup Testing Activities (Module 72700) . . . . . . . . . . . . . . . . . 12 Surve111ances(Module 61726).............................. 16 Maintenance and Modifications (Modules 62703,62700)...... 16 Security (Module 85700)................................... 20 Fi re Protection Review (Module 64704) . . . . . . . . . . . . . . . . . . . . . 21 Radiological Controls (Modules 84722,86740).............. 23 Cracking in RHR System Drain Lines (Module 37700). . . . . . . . . 28 1 Review of NRC Temporary Instructions (Module TI 2515/100)............................................... 28 1 Review of Licensee Self Assessment Activities (Module 40500).......................................... 29 12. Management Meetings (Module 30703)........................ 30 Attachment I - Persons Contacted Attachment II - Licensee handout for February 16, 1989 Restart Assessment Panel Presentation i
i j
!
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ l
- _ - _ - - _ _ - _ _ - .
..
. .
S DETAILS 1.0 Summary of Facility Activities At the end of the last report period, the plant remained in cold shutdown while the licensee performed modifications and repairs to the air supply system of the torus vacuum breaker block valve accumulators. Due to indi-cations of increased air leakage on the valve accumulators, the licensee had commenced a reactor shutdown on January 27, 1989. The licensee deter-mined that the air leakage was due to the relief valves on the two accumu-lators lifting at varying pressures and not tightly reseating. The licen-see installed spare relief valves to correct the problem and the plant returned to criticality at 9:25 a.m. on February 10, 198 The licensee subsequently completed MSIV testing at 270 psig, SRV testing at 350 psig, RHR system and drywell leakage inspections at 600 and 950 psig, and HPCI and RCIC tehting at 950 psi Following the licensee's successful completion of their planned testing activities up to the 5% power plateau the licensee formally requested NRC release to proceed with power ascension from 5% to 25% power on February 16, 1989. On February 18,1989, the licensee initiated a con-trolled plant shutdown to perform maintenance and awalt NRC approval to procee Cold shutdown was achieved on February 19, 198 On February 21, 1989, at 1:00 a.m., a partial loss of offsite power occurred due to an electrical fault in a cable associated with the startup transformer. The two station emergency diesel generators automatically started as designed to provide station power. The licensee restored off-site power to the plant via a second transformer at 4:20 Following repairs to the damaged electrical cable associated with the startup transformer, the licensee brought the reactor critical at 9:00 a.m. on February 28, 1989, and commenced plant heatup while awaiting NRC approval to continue startup testing to the 25% power plateau. The reactor was at rated pressura of approximately 1000 psig on March 1,1989, at approximately 4% of rated powe At 1:30 p.m. on March 3,1989, Mr. James M. Allan, acting for the Region I Regional Administrator, approved the NRC Restart Assessment Panel's recom-mendation to release the licensee from the second NRC approval point (5%
to 25% of rated power) in the Power Ascension Test Program. The program includes NRC Regional Administrator approval points at 5%, 25%, 50% and 75% of full power as well as a licensee formal assessment and NRC review after completion of the Power Ascension Program, including testing at full powe !
_ _ _ _ _ - _
_ _ _ _ - _ - - - - - -_
,
.
,'
'
-
, At 3:40 p.m. on March 4,1989, the turbine generator was synchronized to the grid. The licensee exr- 8enced minor vibrations on two turbine bear- !
ings and removed the turbk snerator from service after about an hour of l operation. At 5:49 p.m. , a turbine bypass valve system anomaly occurred causing the bypass valves to close then fully open, producing a reactor ,
'
pressure drop which resulted in an automatic MSIV closure and reactor scram. All safety systems responded as designed. The licensee performed a plant cooldown and placed the reactor in cold shutdown on March 5, 198 The licensee's investigation was unsuccessful in determining the root cause of the turbine bypass valve behavior. Licensee management presented the results of their investigation at a management meeting conducted on March 9,1989, at NRC Region I. The results of that meeting are docu-mented in NRC meeting report 89-04 NRC inspection ectivities during this report period were conducted by the onsite Pilgrim Restart Staff led by Mr. Clay C. Warren, Senior Resident !
Inspector and Restart Manager. The Pilgrim Restart Staff is composed of the Pilgrim resident inspectors, resident inspectors from other plants, NRC regional-based and headquarters-based inspectors and NRC contractor On February 8,1989, the Pilgrim Restart Staff began 24-hour shift cover-age in anticipation of plant startu This coverage was reduced to extended day shift coverage at times, consistent with reduced testing activity and plant condition .0 Operations 2.1 Sustained Control Room Observations Based on over 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of - around-the-clock on-shift observations, the inspectors determined that control room activities were conducted in a safety-conscious professional manne Communications in the control room continued to be clear and forma Information flow among shift personnel was generally good, such that all members were aware of plant status and planned evolution However, a weakness was noted in the control room staff's knowledge of maintenance activ-ities near the end of the shift as described below. Shift turnovers j were conducted in a formal manner and information about system status l and work in progress was conveyed to the on-coming shift through l individual operator turnovers and pre-shift briefings. The pre-shift j briefings by the offgoing Watch Engineer covered upcoming evolutions in sufficient detail to keep the on-coming personnel abreast of over-all plant status. Attendance at these briefings was consistent and 1 included representatives from Chemistry, Health Physics, Maintenance, and Outage Management groups.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
j
__ _ - . _ _ _ _ _
.-
q
. .
-
!
4 3 )
l l
Shift staffing levels remain adequate. The licensee began this period with a four-shift rotation consisting of three senior reactor operators (SR0s) and two reactor operators (R0s) per shift. The
-
temporary addition of an extra SR0 to each shift appears to have enhance:I the shift organization with added experience. Eight R0s have unrestricted licenses while the 14 newly licensed R0s have limited licenses, pending completion of on-watch training and reactivity manipulations during the power ascension progra l The control room staff continued to exhibit a safety-conscious and !
conservative attitude. The operators stop work to resolve problems and correct procedures during testing and other evolutions when appropriate. The Technical Specifications (TS) were conservatively ;
applied. The control room operators were attentive to their panels, L alarms and indications. Their response to alarms and system }
parameter trends was appropriat During three events affecting j overall plant status (i.e. Group I isolation, loss of startup trans-former, and Group I isolation and scram), the operators initial actions were prompt and effective in placing the plant in a stable, safe conditio The inspecto,s routinely reviewed various control room logs including the Limiting Condition fu Operations (LCO) Log, the disabled Annun-ciator Alarm Log, the Operations Supervisor Log, the Reactor Opera- [
tors Log, the Lifted Lead and Jumper Log, and the Component Leak Lo l The inspectors noted that items were properly logged and tracke l
!
The inspectors noted on occasions that coordination between opera-tions and other organizations needed improvement. An example is the l licensee's effort to schedule and perform post work testing (PWT) on l a group of maintenance requests (MRs). The PWTs to be conducted at i rated reactor pressure, following completion of Power Ascension Test-ing at 5% power, were hampered by lack of coordination. Many of the i PWTs involved inspection of plant components for steam leaks. It was i noted that certain PWTs were performed redundantly by both operations and maintenance while some PWTs were not performed due to unclear ownership of the MRs. The licensee's outage and planning group sub-sequently coordinated the performance of these PWTs with satisfactory result The inspectors also noted that the control room staff, especially at the end of midnight shift exhibited weak knowledge of the status of station maintenance activities, apparently due to lack of communica-tion between operations and maintenance during the shif The inspectors brought this observation to licensee management's atten-tion and will continue to monitor this area in future inspection !
!
(
1 E___________ :
i'
.
8 4
.
!
Control room operators received good support from the shift technical l advisors (STA) and administrative assistants. The STAS were used in !
developing failure and malfunction reports and maintaining various control room logs. The administrative assistants do much of the !
administrative paperwork which helps to reduce traffic in the control roo Operations management, particularly the Chief Operating Engineer, provided effective oversight of operation Operations management '
was observed tou a g n the control room frequently and discussing plant status and evobtuns with the Watch Engineer. Complete briefings were conducted < tt all shifts to identify and discuss all procedure changes prior a fr.plementatio .2 Plant Tour Observations The inspectors routinely conducted plant tours and noted that the overall material condition of rooms and equipment remained excellent during the report period. The licensee personnel interviewed during ,
the tours (HP, security, operations, contractor) had experience in 5 their positions and were knowledgeable about their work and dutie HPs were cognizant of work activities in progres Housekeeping '
controls were being maintained during work in progres .3 Review of Plant Events i
2. Partial Reactor Water Cleanup System (RWCU) Isolation At 1:20 p.m. on February 10, 1989, a partial isolation of l the RWCU system occurred when the inboard suction valve I (M0-1201-02) closed. The licensee halted the plant heatup that was in progress, manually completed the isolations, !
walked down the system (and verified no leaks) and notified the NRC via the Emergency Notification System (ENS). The isolation was caused by a sensed system high flow that cleared about 10 minutes after it occurre Licensee investigation found air in the instrument line The licensee refilled the lines and restored RWCU to servic Air in these instrument sensing lines has been a. recurring situation. An Engineering Service Request (ESR) has been initiated to evaluate the instrumentation tubing configura-tion and other RWCU system anomalies which cause inadver-tent RWCU isolations. The inspectors will follow licensee actions in this are __ __ __ _ _ _ _ _ _ _ -.
-- _ _
'
.
- 4 > 4 4 '
^
i 5 l
2. Group I Isolation Due to Level Swell During Special Main Steam Isolation Valve (MSIV) Testing
I At about 9:23 a.m. , on February 11, 1989, during the con-duct of a test . per Temporary Procedure (TP)87-219, MSIV Opening Test, the licensee received ar. inadvertent Group I Isolation (MSIVs, Main Steam Line Drains, and Recirculation 'l Loop Sampling Lines) as a result of reactor vessel level 1 indication swell, caused by opening the "C" MSIV. The test j involved individually opening MSIVs against approximately
~
i 100 psid to prove operability. This test was conducted in response to Confirmatory Action Letter 86-10.'
i The operators were well briefed prior to implementation of the procedure. The briefing included precautions concern- {
ing possible power excursions which might be caused by. con-duct of the test. Upon testing the first two MSIVs, the power transient was negligible, but reactor level increased 1 by about 4 inches. Continuing the test, the "B" outboard MSIV fhiled to open. The test was continued, bypassing the
"B" valve testing and proceeding on to the "C" outboard isolation valve. When the "C" valve was opened, a Group I Isolation was initiated as reactor vessel level swelled from 28 inches to about 44 inches. The Technical Specifi-cation limit on this isolation is 48 inches, but the actual isolation setpoint is set conservatively lower. The licensee considered two factors to have contributed to the larger level swell associated with ' testing the "C" MSIV compared to the "A" and "B" MSIV The "C" MSIV cycled -
open in a shorter time perio Also, there had been a delay after testing the "B" MSIV during which steam was isolated from the main steam lines, allowing them to coo .These two factors resulted in a greater steam flow in a shorter time frame, exaggerating the level swel The shift operators did an excellent job of responding to i the inadvertent isolation. The licensee made the proper 10 CFR 50.72 notification for an inadvertent ESF actuation via the ENS at about 10:02 a.m. The isolation was reset and operators continued testin The licensee inspected and repaired the "B" and "C" out-board MSIVs (discussed in Section 5.1), and inspected the
"A" and "D" outboard valves to insure similar repairs were not required, then satisfactorily completed MSIV testing on I all valves.
l The problems described above have been determined to have 1 l no relationship to the previous (1986) MSIV problems caused I I by the pilot valve stem becoming disconnected from the ]
pilot valve discs. The inspector had no further question _'
. _ _ _ _
.
.
.
. .
.
2. Isolation of Reactor Water Cleanup System (RWCU)
At 2:40 a.m., on February 16, 1989, a RWCU isolation occurred, causing the system suction and return valves to close (valves MO-1201-5 and MO-1201-80). The actuation occurred due to a sensed system high flow The sensed high flow was caused by a brief system pressure fluctuation that resulted from operator manipulation of the system flow adjustment valve (MO-1201-85). The licensee made an ENS notification, reset the isolation, and restored RWCU to service. The licensee is evaluating the system design for permanent resolutio The inspector had no further question .3.4 Malfunction of the Drywell Airlock Door Interlock At 2:30 a.m., on February 16, 1989, with the reactor cri-t'l cal at approximately 2.5% power and holding at 600 psig for testing and drywell inspection, a malfunction of an interlock designed to prevent simultaneous opening of the inner and outer drywell personnel access doors occurre Two groups were to makt: drywell inspections for different reasons. The first group had the inner drywell door open preparing to exit when the second group was trying to enter through the outer door. When the outer daor wouldn't open they realized the inner door was open and attempted to clcse the inner door from the ou*. side. The inner door had not fully latched when the outer devr began to open. This condition existed for about 5 seconds before the inner door was secured. The Nuclear Watch Engineer (NWE) held a critique, attended by the NRC shift inspector, to discuss this event. As a result of the critique, the Nuclear Oper-ations Supervisor (NOS) posted a security guard at the door with instructions that no entry was to be made without NOS briefing and approval, and that only one group could enter ;
the drywell at a time. The licensee made the proper 10 CFR j 50.72 notification via the ENS syste j The interlock's failure mechanism was determined to be an operating cam misadjustment. The cams were subsequently adjusted and the interlock successfully teste The inspector had no further question l
c ~l
. ..
...
i
l
2.3.5 Partial Loss of Offsite Power At 1:00 a.m., on February 21, 1989, the plant experienced a partial loss of offsite power for a period of about 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. At the time of the event the plant was in the cold shutdown condition. The partial loss of offsite power was initiated when the startup transformer _ tripped and locked-out on a' ground differential relay actuation causing the 345 KV ring bus breakers' to - tri Both emergency diesel generators started and assumed loads on the emergency buses. The partial loss of offsite power was reported to the NRC at 1:52 a.m. via the ENS system. At 4:20 p.m.,
offsite power was restored by backfeeding via the auxiliary
_
>
transformer. The emergency diesel generators were unloaded and shut down soon thereafte The operational staff responded well to the even The 23 kV offsite power supply was available via the shutdown transformer through-out the event, The licensee's analysis of this event found the following:
--
Restoration of offsite power was delayed for several hours when the operators failed to initiate a Main-tenance Work Request (MR) to control the work asso-ciated with the establishment of offsite power by backfeedin A second delay resulted from a proced-ural requirement that the MR be processed and issued as a prerequisite to backfeeding offsite powe The fault was located on one of the four phase C cables on the secondary winding side of the startup transforme I The licensee is evaluating the root cause of the delay !
The licensee was unable to determine the root cause of the l fault in the cable, however, the licensee believes that 1 insulation damage during original cable installation could J be the cause. The damaged cable was replaced and power restored via the startup transformer on February 28, 198 The inspector found that the licensee took the appropriate action to restore power to the facility via the auxiliary transformer. However, these efforts were hindered because the contingency planning which had taken place for this event lacked sufficient detail to ensure that backfeeding j via the auxiliary transformer could be accomplished in a timely fashio The delay while processing and getting approval of the MR could have been anticipated by the ,
license !
l
!
_ . _ . . _ _ _ . _ ___________..___._________.___________..________._._.________.____o
_ _ - - _-_-
.. 1
. . . .
. .
1
The licensee established a preapproved MR to initiate back-feeding via the auxiliary transformer for use should a similar event occur in the future.
.
j!
! The inspector had no further question . Increasing Suppression Pool Level ^
On March 1,1989, the licensee noted that suppression pool level was increasing. The licensee began an investigation .
and found Residual Heat Removal '(RHR) controlled leakoff'
valves (10-HO-502C and 10-H0-503C) open instead of close These valves are located on a 2. inch bypass line around the discharge check valve on "C" RHR pump. The source of water to the RHR system was the RHR keepfill . system. The licen-
.see closed these valves and verified the suppression pool level increase stopped. Further licensee investigation found that the valves were opened by an operator on February 18, 1989, while placing RHR into shutdown cooling per procedure ~2.2.8 The operator stated that the valves were opened to position them consistent with piping and instrument diagram (P&ID) M241 which showed them ope The complete sp tem valve lineup was not available to the oper-ator in procedure 2.2.86, and since he reviewed M-241 with the Nuclear Operations Supervisor (N0S) prior to the evolu-tion, he believed these valves were supposed to be ope The valve lineup for RHR indicating these valves as closed, is located in procedure 2.2.19, Low Pressure Coolant Injectio The licensee performed a system walkdown of the "B" RHR system, the "A" RHR system and the "A" and "B" core spray subsystems outside containment. No further discrepancies were foun The licensee's corrective actions include revision to pro-cedure 2.2.19 (procedures 2.2.86 and 2.2.19 will be com-bined into a single procedure) and a change to P&ID M241 to correctly show these valves close PCAQ SO 89-017 was written to ensure that the P&ID is update i I
The changes to procedure 2.2.19 and the P&ID should prevent i this event from recurrin The inspector had no further j question '
i
)
l l
- -_ - 1
_ - .
.
. .
,
2. Overview of March 4,1989 Reactor Scram Caused by Turbine Bypass Valve Opening and MSIV Closure At 3:40 p.m. , on March 4,1989, the Turbine Generator (TG)
was synchronized to the grid. Vibration , noted on a 1 turbine bearing and, as a result, the TG ,'., disconnected from the grid and tripped. At 5:49 p.m., aear the end of the TG coast down, a reactor scram occurred when the Main Steam Isolation Valves (MSIVs) shut on a low reactor pressure signal. Observations of this event in the control room by NRC staff indicated t%t the control room operators were quick to recognize the even Operators properly utilized procedures and rapidly placed the reactor in a safe shutdown condition. Boston Edison conducted a post-event critique on the evening of March 4,198 It was determined that the scram was due to the bypass valves shutting for about 5 to 10 seconds, then going to full open for about 20 seconds, thereby decreasing reactor pressure to the MSIV closure setpoint. The plant response to low pressure resulting from the bypass valves shutting then opening was in accordance with the plant design. The root cause of the bypass valves close to full open cycling had not been determined during the post trip review, but it did appear to be related to vacuum trip signals. Boston Edison assembled a task group to fully investigate this occurrence prior to reactor restar On the morning of March 5,1989, the task group was organ-ized into three teams to investigate the following:
Team Investigate and determine cause of failure of the Main Steam Line (A) Rosemount flow detecto While it is not believed to be related to the reactor scram event, Main Steam Line (A) flow failed high shortly before the scra Team Assemble and analyze all data just prior to and l following the scram to insure all the facts are !
recorded and understoo ]
Team Prepare and implement a formal program to deter-mine the cause of the bypass valve cycling during the TG coast dow The work performed by each of the teams and the results at the end of the inspection are summarized below:
g- . .
.
.: ..
x ,
- 10 Team l'(Main Steam Line "A" Flow Detector Failed High)
A new. transmitter calibration card: was inserte 'The instrument was calibrated, and returned to' servic The entire' instrument has since been replaced. The failed instrument will be- sent to .the manufacturer, for evaluatio This failure had no effect.on the reactor scram caused by:
the bypass valve cyclin Team 2 (Post Trip Data Analysis) 4 All lof the Honeywell process computer points and the e sequence of events related to the event-were thoroughly re-b viewed by the . licensee's. team. All of the new EPIC com-puter system (which is still preoperational at 'this time)-
<
data points and trend plots related to'this event were also reviewed.
L All operator logs and control- panel strip recorder print-outs were reviewe Turbine oil system checks and tests performed about 10 days prior to the scram. were reviewed. All oil samples were satisfactory (no entrained ' air and sediment), and all j filters clea All recent surveillance and calibrations of the Electric and Mechanical Pressure.. Regulators (EPR and MPR) were reviewed. No problems were identifie '
Detailed discussions were held by the licensee's team with the onsite General Electric turbine technical representa-tive concerning all work performed during the outage. and preparations which had been made for initial turbine start-up and testing. Although a detailed review was conducted of the post trip data, no evidence to establish a root cause of the transient was identifie l Team 3 (Root Cause Analysis)
Interviews were conducted by the licensee's team with all operators who were in the control room at the time of the !
even Statements from those personnel identified no indication of any intentional or inadvertent operation of i any of the controls on the C2 turbine panel during the !
even i
~
I I
l
'
_ _ _ _ _ _ _ _ . _ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _
. -
,
's'
-
.e ...
- . :
-
l All vacuum trip unit linkage clearances were measured and found satisfactor Oil system pressure perturbations-of approximately 150 psig and physical shocking of the linkages were conducted with-no resulting trips of the vacuum trip unit Oil system perturbations also caused no resets of the trip A loss of control oil pressure was simulate The loss causes a trip of vacuum trip 1 (VT1), but not of vacuum trip 2 (VT2). (VT2 is the unit which controls shutting of a the bypass valves). These responses were as designe All turbine and. bypass valve control circuits ' and limit '
switches were checked 'for . continuity, loose terminals, grounds, and short No problems were identifie >
The licensee analyzed the possibility of an individual per-forming a trip and reset of VT1 and VT2 from the turbine
>
front standar This scenario is not considered probable, since the trips are about 4 feet apart, and the resets.not in -close proximity to the trip The licensee concluded that this scenario would require an overt action by a per-son very knowledgeable of the turbine front standard control Although detailed, comprehensive methodical testing and inspection of all of the mechanical and electrical equip-ment involved was conducted, no definitive root cause of the event could be identifie Future Actions Planned / Contemplated by the Licensee The licensee is evaluating possible adjustments to the Main
-
Steam Line low pressure trips (Group 1 Isolation) and the EPR control point to provide an increased operating band in which the EPR could control the bypass valves and prevent a Group 1 Isolation should this event be repeate The front standard of the turbine was instrumented with temporary strip recorders, pressure instruments, etc. to facilitate additional monitoring of trip unit performance during the next turbine operation l
)
l
_ -
,
y-e> s i .-
!
,
The licensee is considering installing " barrel covers" on
!? the VT1.and VT2 manual trip buttons on control room panel C2 to help prevent any future inadvertent actuation o these trip Based on the above, attendance at the initial team meet-ings, and discussions with the. licensee, the NRC staff con-cluded that the~ licensee's approach to determining the root cause end formulating corrective measures following n this event were prudent, thorough, and consistent with good-
! engineering practice At the close of this inspection h period, the licensee had not reached a final- conclusion as to root cause. On March 9,1989, a publicly noticed meet-ing was held at Region I in King of Prussia, Pennsylvania, between the licensee and NRC managament to discuss the results of the licensee's efforts well as additional '
plan The details of this meeting a -e documented in NRC Region I Meeting Report Number M89-043. Based on the evaluation and proposed monitoring instrumentation pre-sented at the meeting, plant restart was considered acceptabl .4 Failure and Malfunction Reports (F&MR)
The Failure and Malfunction Report (F&MR) is used to document and evaluate failures, malfunctions and aSormal operating event A sample of recently closed F&MR's showed those F&MR's to be appropri-ately dispositioned with appropriate management revie No.inade-quacies were identified with respect to open or recently closed F&MR' .0 Startup Testing Activities
3.1 HPCI Operability Testing The licensee conducted testing of the High Pressure Coolant Injection (HPCI) system to ensure HPCI operability as required by Technical Specification (TS) 4.5 The inspector reviewed the completed results of procedure 8.5.4.1, HPCI Pump Operability and Flow Rate !
Test at 1000 psig and procedure 8.5.4.3, HPCI Simulated Automatic Actuation and Flow Rate Test at 150 psi The inspector also wit-nessed the conduct of procedure 8.5.4.1 and discussed the results of this test with cognizant licensee personne !
.i
- l .
,
l r j
m
.
. .
.
The inspector noted that the above procedures verified the HPCI oper-ability surveillance requirements of TS 4.5. Review of the com-pleted test procedures indicated that the tests were performed in accordance with those procedures, cognizant personnel reviewed the test results, and adequate documentation was provided. However, the inspector noted that the serial number of the measuring and test equipment (MT&E) used for these tests was not recorded on the test document. This information is instead recorded in the M&TE signout records. The inspector discussed this issue with the licensee who stated that MT&E identification would be incorporated into the pro-cedure to provide for additional traceabilit The inspector also noted that conduct of personnel during the performance of procedure 8.5.4.1 was satisfactory and that the licensee's quality assurance surveillance group had observed test activities and verified test adequacy. The surveillance tests were adequate and the inspector had no other question .2 RCIC Operability Testing The licensee performed Procedure 8.5.5.3, Reactor Core Isolation Cooling System (RCIC) Flow Rate Test at 150 PSIG, to verify the RCIC operability surveillance requirements of TS 4.5.D.1 at 150 psig. The test was performed in two phase The first phase tested system operability with the test line restricting orifice removed and the second phase verified operability with the test line restricting orifice installed. The inspector reviewed the completed test results and discussed them with cognizant licensee personnel. The inspector noted that approved test procedures were used, test results were ade-quately reviewed and documented, the test met the pump and turbine operability requirements of TS 4.5.D.1, and quality assurance had performed surveillance of test activitie Based on the above review, the inspector determined that the licensee's conduct of the RCIC flow rate test was adequat .3 RHR System Interleakage Tests On April 10, 1986, the licensee experienced leakage from the reactor vessel past closed Residual Heat Removal (RHR) system Low Pressure Coolant Injection (LPCI) system injection containment isolation valves to the RHR system pipin The licensee declared the valves inoperable and shut down the reactor. This leakage was an NRC con-cern in Confirmatory Action Letter 86-10 issued on April 12, 198 In response to this concern, the licensee repaired the valves, per-formed local Teak rate testing prior to restart, and developed pro-cedure 8.5.2.10, Residual Heat Removal Temperature and Pressure Monitoring, to measure and evaluate valve leakage during the Power Ascension Test Program and subsequent operatio In Procedure 8.5.2.10, temperature and pressure monitoring of the RHR system is performed by taking local temperature and pressure readings in the system and comparing these to saturation conditions to determine if the potential for void formation exists.
- _ _ _ _ _ - _ _ _ _ _ _ _ - . . - _ _ _ _ _ _ _ _ _ _
!>
..
.... ,
l
!
.:
, The inspector reviewed the results of the intersystem leak checks l
'
conducted at 300 psig, 600 psig, and 930 psig per procedure 8.5.2.1 All leak checks indicated greater than 200 degrees F subcooling which
.
is well in excess of the minimum requirement of 15 degrees F subcool-l ing. The inspector had no further question .4 ADS Subsystem Testing The inspector observed pretest activities, test conduct, and test restoration for procedure 8.5.6.2, Automatic Depressurization System (ADS) Subsytem Manual Opening of Relief Valves, conducted at a reactor pressure of approximately 350 psi The operations shift conducted an adequate briefing which covered steps in the test pro-cedure and additional precautions not contained in the procedure con-cerning careful control of reactor water level, pressure and powe The shif t also performed a walkthrough of the opening of one safety relief valve, with all operators and data recording personnel on station. The conduct of this test included greater test coordinator involvement and direct supervision by the Nuclear Watch Engineer (NWE) than previous testing and operations observe The test consisted of the following major steps: (1) One loop of RHR was placed in Suppression Pool Cooling (to remove anticipated heat load), (2) one (of three) turbine bypass valves was opened about 30%
using the Manual Pressure Regulator (so that it 'would shut as each relief valve was opened, thus reducing the magnitude of steam load change placed on the reactor), (3) each of the 4 Safety Relief Valves (SRVs) was opened, data taken, and the valve shut, and (4) the RHR loop was removed from Suppression Pool cooling when torus water tem-peratures were reduced to normal about one half hour following con-clusion of the tes The inspector noted two items of interest during the test perform-ance. When the first SRV (38) was tested, the valve was left open for approximately 15 seconds as permitted by the test procedure to allow time for completion of data recording. Prior to closing the valve, reactor vessel level had swelled to approximately 43 inches which approached the Group 1 Isolation setpoint of 44 inches. Prior to proceeding with the test, the NWE instructed data recording per-sonnel to complete their tasks more quickly and cautioned control board operators to shut the SRVs if level swell again approached a Group 1 Isolatio The remaining three SRVs were then tested with opening times of between 5 and 10 seconds, and avoided further approaches to isolation setpoints. In addition, about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after completion of the test, the 3A valve tailpipe temperature had only i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ - _ - _ _ _ _ _ _ _ _ - . _ _ . _ - - _ _ - _ _ _ - _ . - - - - - _ _ _ - - _ - - - - - _ - _ _ _ _ _ _ . _ - - - - - _ - - - _ - - - - - - - - -- - - - - -
- _ - _ _ - _ _ _ _ - _ - - - - _- - - -
..>
. .
.
.
.,J 1 1 15 cooled to 220 degrees F, while the other three tailpipes had cooled
~m to about 100 degrees F. The~ 3A valve was cycled in an attempt t reduce the apparent seat / disc steam " weep". The cycling was success-ful in stopping the weep . and reactor pressure. was increased to approximately 950 psig. On February 18, 1989, following the comple-tion of testing at 950 psig, the licensee decided to enter a shor outag During the reactor shutdown and cooldown for this outage, the 3A SRV began weeping as indicated by an increase -in tailpipe
. temperature to approximately 225 degrees F, when again reactor pressure was reduced below 400 psig. During subsequent plant start-up, no weeping was evident on the 3A SRV.
'
In summary, the operating shift adequately prepared and performed the test even though precautions about power, pressure, and level effects were not contained in the procedur The shifts actions were prompt and appropriate to control testing when the Group I isolation set-E points were approached. The inspector discussed the lack of proced-ural precautions with the licensee who stated that the procedure would be revised to include appropriate precautions. The inspector had no further question .5 APRM Setdown Functional Checks ,
j Technical Specifications require Average Power Range Monitoring sys- ;
tem (APRM) downscale protective functions and surveillance test '
Procedure 8.M.1-3.1 APRM Setdown Functional Test, is performed to verify these protective functions by monitoring the change in con-tinuity across the APRM downscale trip unit output contact in the reactor protection system (RPS) circuity, in response to a simulated APRM-downscale condition. The inspector reviewed the completed test and results, and discussed them with cognizant licensee personne The inspector noted that this procedure checked the APRM rod blocks and reactor scram functions. The setpoints for these functions were found-to be conservative. The inspector noted that the test was per-formed in accordance with approved procedures which met the require-ments of TS Tables 3.1.1 and 4.1.1 and the test results were ade-quately reviewed and documente The inspector had no further l question .6 MSIV Opening Test On February 11, 1989, Temporary Procedure (TP)87-219, MSIV Opening Test was satisfactorily performed as discussed in section 2.3.2 of l this repor The test involved individually opening MSIVs against approximately 100 psid to prove operability. This test was conducted pursuant to licensee corrective action commitments made in connection with Confirmatory Action Letter 86-1 )
l i
_ -- -_ _ - _ --.____ _-_ _ -- _- - _ . -. _ _ J
__ _ - __ _ _ _ _ . _ _ _ . _
. _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ - _ - _ - _ - _ _ - _ - _ - _ _ _ _ _ _ _ _ - _ _ _ _
.
.: .
.
-16 4.0 Surveillance 4.1 Routine Surveillance Tests The inspectors observed the following surveillance tests:
8.M.1-1A Intermediate Range Monitor Functional / Calibration 8.M.2- Source Range Monitor Functional 8.M.1- APRM Setdown Functional 8.M.1-12 Main Steam Line High Radiation 8.M.1-3 APRM Functional 8.M.1-3 Analog Trip System - Trip Unit Calibration - Cabinet C229-B1 8.M.1-29 Anticipated Transient Without Scram Functional and
'
Trip Unit Calibration
'8.7. MSIV Trip 8.7. Exercising Main Steam Isolation Valves 8. Standby Liquid Control Pump Operation and Flow Rate Test Based on observations of test performance and discussions with the licensee, the inspectors determined that implementation of surveil-lance tests was generally well planned and controlled, Licensee com-munications were generally good. When the licensee identified un-satisfactory equipment performance, it took appropriate corrective measure The licensee also corrected procedure deficiencies as identifie The inspector noted that on one occasion the licensee placed check-marks in a procedure step where double verification initials were require The licensee investigated this concern and determined that it was an isolated cas The inspector independently reviewed approximately 20 completed surveillance procedures and found no
]
similar discrepancie The inspector had no further question .0 Maintenance and Modifications
,
5.1 MSIV Repair Work
.During an MSIV opening test per TP 87-219, "B" outboard MSIV failed to meet the acceptance criteria of the test. Repeated attempts to open the valve resulted in it opening with a time delay of about 20 seconds. The licensee disassembled the 4-way solenoid valve assembly for the "B" outboard MSIV for inspection and found the internals gummed with an oily substance, with the non porting piston very hard to remove. The 4-way valves for all MSIVs had been inspected by the licensee in April,1986 during an investigation of the failure of the outboard MSIVs to open upon deman :
.. _ _ - - _ _ _ _ _ _ - _ _
,
. .
-
The licensee disassembled and inspected each 4-way solenoid valve assembly for the "A", "C" and "D" outboard MSIV's and found no prob-lems. During disassembly, the licensee inspected all valve ports and 0-rings to ensure that no foreign material was present. The 4-way valve for "B" outboard MSIV was rebuilt and installe During further testing of the "B" MSIV, the licensee also identified that the top tee on the dashpot metering valve piping for the-air actuator was oriented in such a way that re-filling the dashpot was impos-sible. The licensee subsequently reoriented the piping to correct the problem. No similar problems were noted with the other MSIV During the February 18-22, 1989 outage, the 4-way solenoid valve assemblies for all four inboard MSIV's were disassembled and inspec-ted by the licensee. No discrepancies were noted for "A", "B" and
"D" valves. For the "C" valve, the licensee found a small amount of a green verdigris type material in the solenoid valve assembly. The 4-way valve for "C" inboard MSIV was subsequently rebuilt and in-stalled. No foreign material was observed in the close ports of the valves, therefore only the open function of the MSIV's was affecte The licensee's root cause evaluation for observed foreign material intrusion into the 4-way valves is ongoing. This item is unresolved (50-293/89-01-01) pending completion of the licensee's evaluation and development of an appropriate inspection schedule for the 4-way valve .2 Emergency Diesel Generator "A" Troubleshooting and Repair During shutdown of Emergency Diesel Generator "A" (EDG "A") af ter offsite power was restored on February 21, 1989, a plant operator reported unusual noise near the EDG "A" generator outboard bearin The licensee subsequently initiated troubleshooting and repair of the problem. The inspector observed prework activities, disassembly of the generator bearing, and postwork testing. It was noted that pre-work briefs, equipment isolation and test equipment calibration were adequately performed. During disassembly, components were properly segregated and controlle Inspection of the bearing and lubricant did not reveal any damage or lubricant contamination. The licensee flushed, relubricated and reinstalled the bearin EDG "A" was started and loaded per procedure 8. A.1, Manual Start and Load D/G, for postwork testing, whereupon it tripped on reverse power as the j output breaker was close The inspector determined that this j anontaly was previously identified and ascertained that Maintenance i Requests (MR 89-61-18 and 89-61-19) and Engineering Service Requests )
(ESR 89-151) had previously been generated to recalibrates the direc-tional control (reverse power) relays. The inspector noted that this relay would not affect EDG operation during a loss of power since the i EDG's would power a deenergized bus. The inspector had no further !
question !
J *~
.
l
-_ ___ _ - _ - - _ _ . _ _ ._
_ - _ _ _ _ _ _ , - . _ _ ,_- _ _ _ _ _ _ _ . -. _ _ _ _ _ _ _ _ -_. _ _ - - - - - _ _ _ .
.
..- ..
h
5.3 Replacement of the Startup Transformer Cables On February 21, 1989, a partial loss of offsite power occurred due to a fault in a ' cable associated with' the startup transformer. Repair involved replacement of approximately 100.ft of 1250 MCM (millicir-cular mil) cable with an equivalent substitute of a 500 MCM and a 750 MCM cable connected in parallel. The substitution was made due to the unavailability of 1250 MCM_ cable. The inspector reviewed plant-design change (PDC)89-012, observed replacement activities' and reviewed the post installation test data. The inspector noted that the work was appropriately classified non-Q (i .e. , not requiring special nuclear related quality requirements) and that the . replace-ment was performed in accordance with the licensee's transmission and distribution department procedures. The inspector verified that the -
licensee had conducted and documented appropriate ' engineering and safety evaluations as a part of the PDC. The inspector reviewed the post' installation test data and determined that the _ test criteria were adequate and-that the testing acceptance criteria were satis-fied. The inspector had no further question .4 - HPCI Outboard Steam Isolation Valve Repair Work During the February 18-27, 1989 outage, the licensee's maintenance department disassembled the HPCI outboard steam isolation valve (MO-2301-5) to repair a steam cut on the pressure seal seating surface of the valve body. M0-2301-5 is an 8-inch gate valve manufactured by the Velan valve company. An ISI valve internal examination revealed a steam cut of 0.006 - 0.014 inches in depth. The licen-see's repair plan included machining-the inside surfaces of the valve bore to eliminate the steam cut location and replacing the pressure seal rin The inspector reviewed the Maintenance Request (MR 89-23-1) package and Nonconformance Report (NCR 89-026) for proper disposition. The licensee's engineering department specified minimum wall thickness of 1.410 inches (total dimension of 10.033 inches) for pressure reten- )
'
tion and structural integrity of the valve bod The maintenance work plan and associated procedures reviewed were adequate. Material removal during machining was well controlled. A liquid penetrant .j test following the initial machining work revealed five rounded indi- J cations which exceeded the base material acceptance criteria. The licensee revised the work plan to remove the indications by grind-ing and weld overlay. The inspector reviewed General Welding Proced-ure 3.M.4-15 and welder qualifications; no discrepancies were note The indications were successfully removed as confirmed by liquid penetrant testing. In accordance with ASME Section XI, the integrity j of the repair was verified at system pressures during subsequent j operation. Good coordination between the engineering department and the station maintenance section was noted during the repair wor J The inspector had no further question l I
_ _ - _ - - - - - - _ _ - - _ _ - - -- - - _ - - _ - - _ - - - - 1
-__ _ _ _ _ _ - - _ - . _ -
o s
.: ..
- =
_
19 q j l l
l l
5.5 Resolution of HPCI Outboard Steam Isolation Valve (M0-2301-5)
l ' Seismic Design Concerns While. performing the _ HPCI outboard steam isolation valve '(M0-2301-5)
repair work discussed above, discrepancies between the valve refer-ence drawing (M-131-1-7) and the as-found valve configuration were z noted. The discrepancies were: (1) the drawing showed a single
'
pressure seal backing ring, whereas the. actual valve contained. a double. backing ring, (2) the drawing showed a 10 inch diameter valve, whereas the installed. valve had an 8 inch gate and 10 inch inlet /
outlet, and (3) while the drawing did not specify the valve. stem diameter, it was noti' that a 2.5 inch diameter stem characteristic of a 10 inch valve .s installed. The above listed discrepancies include those either verbally communicated to NRC inspectors, or documented in a licensee Potential Condition Affecting Quality report (PCAQ-89- 018). The PCAQ focused on the discrep'ancies between the
,
drawing and the as-found valve and expressed concern that additional valves may have similar discrepancies. The NRC inspector raised an additional concern over the potential for the apparently oversized Limitorque operator, bonnet, stem and yoke assemblies to affect the seismic analysis for the HPCI steam inlet pipin Resolution of the PCAQ concerns over differences between drawings and installed valves will be addressed in a licensee Engineering Service Request (ESR) which was scheduled to be completed by about March 22, 198 The ESR should encompass identification of similar valve drawing discrepancies and the revision of affected drawings to reflect as-found valve configurations. The seismic analysis concern raised by the NRC inspector was satisfactorily resolved by a thorough licensee review of valve requisition documents, drawings, seismic analysis data, and a final verification of valve nameplate data. The inspector will review the licensee's resolution of the drawing dis-crepancy PCAQ at the completion of the licensee's effor .6 Abandoned In Place Equipment During a routine walkdown of the control room panels the inspector observed numerous electrical cables that were not properly termin-ated. A review of the licensee's lifted lead and jumper log (see inspection report 50-293/88-37) did not list the cables in question as being lifted under any in place control system. The licensee has reviewed the inspectors concerns and has determined that the cables in question are cables that had been abandoned in place during plant life. The licensee is developing a program to either remove or iden-tify all abandoned in place cabling as well as other abandoned equip-ment. The licensee currently projects completion of this effort dur-ing the next refueling outage. Current licensee procedures require
- _ - - - _ - - - _ _ _ _ _ _ _ _ -__
- _- __ _______ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ _ _ _ - _ _ - _ . __ __ - _ _ _ . _ _ _ _ _ _
.
'
. ,
,
'
e that abandoned or spared cables be labeled with the 'date of removal from service and the documents that authorized removal from servic Pist station practice in this area did not require labeling of aban-doned or spared cables. Licensee progress toward completion of this project will be reviewed during routine resident inspection activitie .0 Security
<
Two security specialist inspectors reviewed the licensee's security pro-gram to assess its effectiveness and the licensee's compliance with the commitments in the NRC approved security plan and its implementing proced-ures. The inspectors interviewed members of the security organization and security engir ' ring support section, observed security related activ-ities, reviewed the plan and its implementing procedures and reviewed two plant modifications that had security consideration The inspectors reviewed the plan and its implementing procedures and determined that the procedures adequately adhered to the plan commitment The inspectors interviews of security personnel determined that they were familiar with the requirements of the implementing procedure The inspector noted that management support for the security program has con-tinued as evidenced by the allotment of resources for staffing, mainten- ,
ance of equipment and ongoing program upgrade '
The inspectors noted that the licensee's proprietary security organization was adequately staffed to provide the appropriate oversight of the con-tractor security organization. The inspectors' review also disclosed that the contractor security organization is adequately staffed to minimize the need for overtim The inspectors' review of the maintenance support program for security equipment disclosed that maintenance on security equipment continues to be performed in a timely manner, minimizing the necessity for the use of compensatory measure Modifications to two safety-related systems recently made by the licensee were reviewed by the inspector. For the first modification, the inspector reviewed the licensee's analysis and rationale for not considering certain of the newly installed equipment as vital . The inspectors' review dis-closed that the licensee's analysis was sound and appropriate. For the second modification, the inspectors reviewed the licensee's analysis and rationale for the protection afforded to that modificatio The inspec-tors noted a potential security weakness in a portion of the modificatio The licensee agreed to toke action to address the potential weaknes _ _ . ._. _ _-_ _ _ _ _ _ _ _ __ ___--- _ _ _ ____ - _ - _ -
. _ - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
.
+ .
.
21 In conclusion, the licensee continues to implement a significantly improved security program over that which existed when the station was shutdown in April, 1986. Management continues to be supportive of the
..rcurity program as evidenced by the allocation of resources to implement a program that goes beyond minimum compliance with NRC requirement '7.0 Fire Protection Review 7.1 Fire Garrier Penetration Tagging System The fire protection group stated that the current fire _ barrier tag-ging system is beiag phased out and is being replaced with a new type of tag which can be securely fastened to components or attached per-manently to an adjacent wal At this time all fire barrier penetrations in the plant have been identified and entered into a computerized drawing file with detailed information provided on barrier penetration size, location, shape and ID numbe Each fire barrier wall represented in this manner has been incorporated into individual Station Instructions (SI) in order to enhance the efficiency and completeness of barrier penetration inspections and surveillanc Individual fire barrier surveillance instructions have data sheets with information on each penetration identifying the ' penetration number, type, whether Technical Specifications are involved, and inspection entries for both sides of the penetratio .2 Fire Brigade Training The inspector observed a sample of classroom lectures conducted as required refresher training for security force and plant operations personnel who are designated fire brigade members. Each lecture was followed by a written test on the lecture subject matte The inspector noted that this training was conducted by an experienced and knowledgeable instructor and that several training aids were used (video presentations, fire fighting equipment, etc.) to increase the effectiveness of trainin No unsatisfactory conditions were noted in this are .3 System Walkdowns Inspections The inspector performed fire protection system and equipment walkdown inspections to observe the general condition and operability of sys-tems, and to assess general fire safety conditions, e.g. combustible material control, throughout the plant. All fire systems inspected (sprinkler, cardox, halon, etc.) were observed to be operable as indicated by annunciator panels, equipment configuration, etc., and generally appeared to be in very good conditio ,
___ _ __ - - - - - ~ _
. _-
..
. .
,
.
. .The fire protection group stated that fire extinguishers on site are currently bebg inventoried and entered into a computerized data base which will track individual fire extinguisher and other equipment for required periodic inspection requirements. When implemented, this tracking system will greatly enhance the licensee's fire protection equipment inspection progra The inspector also noted that combustible material throughout the plant is well controlled and that adequate storage space is provide Housekeeping is generally well maintained and loose debris in the plant was minima .4 Fire Watches A review of Technical Specification (TS) related fire watch postings throughout the plant was conducted to verify that specific inspection requirements were in accordance with procedural requirements, and to verify that roving fire watches were being performed on the required schedul The inspector noted that licensee performance in posting and perform-ing required TS fire watches was good. However, the inspector did identify a missed hourly fire watch in 4160 KV switchgear room "A".
Although the licensee correctly followed up on this instance, there appeared to be some confusion among the fire watch contractor manage-ment personnel as to the proper method of reporting and documenting missed fire watches. The inspector discussed this concern with the licensee fire protection manager who committed to revise the fire watch procedure to include reporting and documentation requirements for missed fire watches. These revisions were completed and they c1carly delinfated the procedure for reporting and documenting missed TS required fire watc The inspector also reviewed the licensee's mechanism for determining the deportability of missed TS fire watche If a fire watch misses a required location during his tour the licensee reviews security records to determine if any individual has entered the area during the time the fire watch was missed. If any individual has been in i the area in question the licensee does not report the missed fire I watc The inspector did not consider the chance overlap of security rounds to constitute completion of fire watches. The inspector ques-tioned the licensee regarding whether the intent of the reporting requirements is being met in the application of this polic The licensee is currently reviewing this policy and further NRC action in this area will be tracked as Unresolved Item (50-293/89-01-02).
I
_ _ _ - - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _
.
. .
,
!
-
i
~
23 l 7.5 Quality Assurance (QA) Oversight of the Fire Protection Program
The inspector reviewed the licensee's QA audits and surveillance reports pertaining to the Fir Protection and Prevention activitie Included in the QA audits reviewed were an annual fire protection audit conducted by QA and engineering personnel; a triennial fire protection audit conducted by an independent consulting firm and a special audit conducted by the licensee audit group which verified the adequacy of design, modifications and implementation of alternate shutdown capability from outside the control room during a fire. The audits had identified several deficiencies ah ng with numerous recom-mendation The plant fire protection giaup had provided timely response to these audit findings and implemented corrective actions as require The fire protection department and the engineering department had reviewed these recommendations and had committed to implement the ruuired actions but the final disposition remained protracted. The inspector discussed the matter with QA and fire pro-tection department representatives. The tire protection department representative stated that these outstanding audit recommendations were currently being reviewed by the cognizant individuals at the site and at the corporate office. These issues will be resolved sub-sequent to the completion of the Pilgrim Nuclear Power Station restart activitie The inspector reviewed the QA surveillance and inspection reports of the facility's fire protection activities, including smoke detection system, halon system, combustible loading, emergency lighting, fire retardant coating, fire brigade training, fire protection maintenance and fire protection equipment. These activities were performed sat-isfactoril A walkdown was also conducted to verify the condition and adequacy of fire equipment, including self contained breathing apparatus (SCBA), radios, emergency flash lights, hats, boots, and gloves. The equipment was well maintained and properly store Based on the above review and discussion with the licensee represen-tatives, the inspector determined that QA oversight of the licensee's l fire protection activities is adequat .0 Radiological Controls 8.1 Transportation and Solid Radwaste The inspector reviewed the licensee's program for quality assurance of vendor programs for materials and services and the licensee's ability to properly prepare, package and ship licensed radioactive materials for transport and disposal . The inspector also reviewed
,
training requirements for waste management and health physics technicians.
l l
_
_ _ _ _ - _ _ _ _ _ _ - - _ _ - - . _ _ - . _ _ _ _ _ . _ _ _ - _ _ _ - _
- - _ . . _ _ . _ __
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _
,
o
. ..
- .
l
'
r - 24
L 8. Quality' Assurance / Quality Control
'The licensee has elected to utilize its 10 CFR 50, Appendix
.B Quality Assurance program in the area of transportation y and radwaste. The NRC has issued to the licensee a Quality Assurance Program Approval for Radioactive Material Package The licensee's Quality Assurance (QA).-Department conducts:
!
regular audits of those . vendors providing materials and services which directly impact its transportation and solid radwaste program. The licensee also participates in a con -
sortium of utility QA ' programs for vendor audits. The inspector examined the following audit reports:
WPPSS Audit * 07-395, dated March 12, 1987, Vendor: Nuclear-Packaging WPPSS Audit # 88-429, dated April 12, 1988, Vendor: Nuclear Packaging Audit # 88-28, dated August 17, 1988, Vendor: Chem Nuclear Systems, In The inspector noted that audits were conducted by personnel possessing the appropriate ' expertise to evaluate the vendor. The audits were comprehensive in - scop These audits were conducted using a predetermined audit plan, which required the auditors to examine certain key areas, but allowed sufficient time for the auditors to perform in-depth analyses of areas of interest as they developed dur-ing the audit. All findings were followed up promptly, and vendor responses were tracked through to completion. The QA Department also conducts annual audits _of the licensee's i transportation and waste management program. Audit # 88-05 was reviewed in its entirety and found to be comprehensiv Currently, Audit # 89-02 is being completed; the inspector was able to review the audit plan and checklist which were found to be adequat Procurement of supplies and services for the transportation and radwaste program is conducted by the licensee's pur-chasing departmen Specifications have been written for the procurement of high integrity containers (HIC), liners, shipping casks and waste processing services. These spec -
ifications, which have been reviewed and approved by the QA
- . . . . ,.
_-_____._._-__-_:___- - _ _ _ - i
- _ _ _ _ _ _ . . _ ______ . _ _ _ _ _ _ _ - __
.
T' . .
.
)
!
department, are used to order supplies and services from approved vendors. Supplies are inspected upon receipt by Quality Control (QC) for conformance to the licensee's specifications, and for the presence of appropriate docu-mentation, including certificates of compliance (C0C) where applicabl All procedures which are a part of the licensee's Process Control Plan are subject to hold points for periodic mon-itoring by Q All liners and HICs are tracked by the licensee from acceptance test upon receipt until loading and transportation offsit QC conducts a program of surveillance of all shipment.s of radioactive material, together with the preparation of waste packages in accordance with the licensee's Process Control Plan. Additionally, the QA Group conducts periodic surveillance of transportation and waste management activities independent of the QC progra .1.2 Transportation and Solid Radwaste Process Review The licensee's program for packaging and transportation of radioactive material and radwaste is conducted by the Waste Management Group. As part of the inspection the following procedures related to packaging and transportation were examined:
NOP 87RC1 " Processing, Packaging and Shipping of Radio-active Material" 2 .117 " Transferring Spent Resins to Shipping Con-tainers" " Receiving and Handling of Un-Irrad ated Fuel Assemblies" 6.9-060 " Receipt of Radioactive Material" 6.9-160 " Shipment of radioactive Material" 6.9-174 " Packaging Dry Radioactive Waste" 6.9-178 "High Integrity Container (HIC) Lid Closure Device Procedure" 6.9-179 " Radioactive Waste Press"
_ _ _ _ _ _ _ _ _ _ l
r e
. 4 .
'
l ,i
, . -
6.9-185 " Handling and . Loading Procedure PAS-1 Shipping.
p Cask" 6.9-186 "High Integrity Containers" 6.9-188 " Dewatering Bead Resin / Activated Carbon in 14-215 or Smaller Liners" 6.9-190 " Dewatering 14-215 or Smaller Liners Containing Powdex Resin, Precoat Material or D.E."
6.9-193 " Classification of Radwaste" 6.9-194 " Loading Transport Vehicle for Radioactive Ship-ments" 6.9-195 " Completion of' Radioactive Waste Shipping Records" 6.9-197 " Operation and Control of Radioactive Material Storage Areas" 6.9-200 "00T Classification of Radioactive Material" 6.9-201 " Completion of - Radioactive Shipping Records" 6.9-211 "10 CFR 61 Sampling" 6.9-212 " Handling and Loading Type 'A' Shipping Casks" 6.9-213 " Handling and Loading Procedure for Type 'B'
Shipping Casks" SI-RP.2705 " Monitoring Green Bags of Waste for Release" SI-RP.2800 " Radioactive Material Segregation Process" The inspector noted that the above procedures were tho-rough, with appropriate supervi sory and QC revie The-inspector reviewed the records of .27. shipments of radio-active materia The licensee continues to perform hand 1 calculations for transportation and waste classification, although it has done certain limited tests of computer codes for this purpose. Hand calculations are reviewed by the Waste Management supervisory personnel and QC prior to shipping any materia .
--- . __ _ _ -__ .
_ _ - _ _ _ _
- 6 A
, .. .
.
Review of the records for the seventeen contaminated laun-
. dry shipmeats made during 1988 and the first 6 weeks of 1989 showed that the licensee failed to identify the presence of Irco-55 on the shipping papers. This isotope constitutes approximately 30% of the total activity of these shipments. This is an apparent violation (50-293/
89-01-03) of 49 'CFR 172.203 and 172.204 which require that y
, each shipment of-hazardous material be accompanied by ship-r ping papers which accurately reflect the shipped material contents, and requires that~ the shipper certify that the material has been properly described. The Iron-55 quantity
_
is not directly measured but must be inferred from other dat The licensee had previously corrected their quan-tification methods in other radwaste areas, but laundry shipments, which are under a separate program, had not been similarly update Scaling factors are determined by ~ the Chemistry Department through the use of a vendor laboratory. Composite samples
.of specific waste streams were submitted to a vendor labor-atory for isotopic analysis, with the results provided to the Waste Management group. The . licensee has not sent samples to the vendor laboratory since late 1986, due to the extended shutdow In the interim, the Chemistry Department ~has taken monthly samples of the reactor. coolant and performed analysis for Cobalt-60 and Manganese-54 con-ten These parameters have not significantly changed since the shutdow With the exception of the above noted apparent violation, which seems to be an omission limited to one type of ship-ment the licensee's controls were considered adequat . Training 'I The licensee has developed a formal training program for' i waste management and health physics technicians, and main- 1 tenance and chemistry personnel who work in the transporta- l tion and solid radwaste program, as required by NRC IE Bulletin 79-19. Training for waste management . technicians is divided into two phases, an initial qualification pro-gram, and a periodic retraining program, both of which are two weeks in lengt Health physics technicians receive two day training, while maintenance and chemistry personnel J receive four hour trainin The licensee's training pro- f gram is considered adequat j i
- _-_ . _ - . o
_ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ - _ _ -
.
. 4 i
.
28 !
9.0 Cracking in Residual Heat Removal (RHR) System Drain Line As a result of the second failure (June 1987 and February 1989) of a fil-let weld in the 3/4 inch diameter drain line adjacent to the M0-1001-29A valve in the "A" valve room the inspector observed a penetrant examination of the failed weld, observed the location of the line in the "A" valve room and held discussions with licensee personnel concerning the cause of the failures and planned corrective actions. As a result of 12 similar failures during the life of the plant, two in the core spray system and ten in the RHR system the licensee initiated an investigation to determine the root cause of the failures. This investigation was completed prior to the February 1989 failure. As a result of this investigation the licensee concluded that the root causes of the failures were water hammer and excessive vibration caused by the throttling of valves in the system to adjust the flow rate, resulting in fatigue failure of the line I The licensee has installed vent lines at the high points of the RHR system to allow complete filling of this line prior to operation and replaced the valves with ones designed for throttling the flow to eliminate the root causes of these failures. In addition the licensee designed supports for these lines and has installed these supports on vent and drain lines inside the containment that were determined to be susceptible to this type of failur Based on the above the inspector had no further question .0 Review of NRC Temporary Instructions 10.1 Handling of EDG Fuel Oil (TI 2515/100]
The purpose of this inspection was to assess the licensee's program to maintain adequate quality of emergency diesel generator (EDG) fuel oil on site. The licensee has a sampling program to ensure adequate quality of the EDG fuel oil itself and a preventive maintenance pro-gram to ensure that fuel oil can be succe5sfully transferred from the fuel oil storage tanks to the EDG engine The licensee's Technical Specification (TS) 4.9. A.1.e requires that once a month a sample of diesel fuel be checked for quality in ac-cordance with American Society for Testing and Materials (ASTM)
Standard 04057-81 or 04177. The quality is required to be within the limits specified in ASTM-D975-81. The licensee's chemistry depart-ment samples the two fuel storage tanks each month and analyzes the,n in accordance with Station Procedure No. 7.1.3.6 " Diesel Generators Fuel Oil Sampling and Quality Analysis." The analysis includes test-ing for accumulated wate The licensee does not regularly sample the EDG day tanks nor are they tested for water accumulation, how-ever, during each calendar quarter the day tanks are drained of any accumulated water in accordance with station procedure 3.M.4-36, EDG ,
Preventative Maintenanc I
!
!
. _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l
_ _ _ _ _ _ _ _ _ _ _ _ - _ -
.
. .
'
~,
The licensee samples and analyzes new fuel oil brought on site prior to it being pumped into the storage tanks to prevent contaminating the contents of the fuel storage tank Depending on the time of year the licensee uses a fuel additive to minimize oxidation and bacterial growt The licensee has never drained and cleaned the fuel storage tanks, however, they intend to do so during their next refueling outage. Station procedures i? quire immediate notification of the Watch Engineer if any water is found or if the fuel oil quality is not within specificatio In the EDG fuel oil transfer system there are three components which have the potential to restrict the flow of fuel oil to the EDG engine There is a strainer at the suction of each fuel oil trans-fer pump and there are primary and secondary duplex filter / strainers in the fuel line between each day tank and their associated EDG. The latter two are monitored for differential pressure (dp). If the dp becomes excessive a local Hi dp alarm initiates which in turn results in a "EDG Trouble" alarm in the main control room. All three of these components are periodically cleaned and/or replaced in accord-ance with Station Procedure 3.M.4-3 Based on the above, the inspector determined that the licensee's pro-gram is adequate to ensure proper handling of EDG fuel oil and meets or exceeds the regulatory requirement .0 Review of Licensee Self Assessment Activities The inspectors routinely monitored the licensee's inplace programs to assess facility and personnel performance. The licensee has implemented a formal peer evaluation program for routine personnel performance mon-itorin The individuals selected for the peer evaluator program are selected from the onsite organization, receive training on performance monitoring techniques and are assigned to monitor specific activitie The peer evaluator program provided twenty-four hour operations monitoring during all periods when the facility was critical, as well as routine audits of other areas of facility activitie The peer evaluators held regular debriefings with audited organizations to discuss identified strengths and weaknesses. NRC inspectors who attended these debriefing sessions observed that the findings, both positive and negative were dis-cussed in a frank open atmospher The audited organizations have generally been receptive to this process and the resolution and closecut of findings has been timely and thoroug The inspector also noted increased presence of management in the plant throughout this period. Routine presence of middle and senior level man-agement in the control room and in the plant was note Management over-sight and control of routine and abnormal activities showed clearly that the licensee has set high performance standard ,
,
. - - _ - - . _ _ _ _ _ _ . . , _ _ _ .
_ _ _ - _ _ _ __ .-. - - _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.
. -
t 30 l The licensee's quality assurance organization has also developed a special audit program for the duration of the power ascension plan. The inspec-tors noted an increased presence of quality assurance and quality control personnel throughout the inspection perio Management efforts in assuring high standards of facility and personnel performance were evident throughout this inspection period. The licensee was highly self-critical in this self assessment period and overall man-agement performance was goo .0 Management Meetings An NRC Restart Assessment Panel meeting was held on February 17, 1989, at Pilgrim Station. NRC management from Region I and headquarters were on-site for the meeting and Region I staff participated via teleconferenc The assessment panel received a presentation from the licent,ee on their assessment of the results of the 0-5% Power Ascension Program. The licen-see handout for the presentation is included as Attachment II to this repor At periodic intervals during the inspection period, meetings were held by the restart inspection staff with senior facility management to discuss the inspection scope and preliminary findings of the inspectors. A final exit interview was conducted on March 29, 198 No written material was given to the licensee that was not previously available to the public.
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _
_ _ _ . _ _ _ _ - _ _ _ _
+ za
. !
ATTACHMENT Persons Contacted R. Bird, Senior Vice President - Nuclear .
K. Highfill, Site Director !
R. Anderson, Plant Manager D. Eng, Outage and Planning Manager E. Kraft, Training Department Manager D. Swanson, Nuclear Engineering Department Manager D. Long, Plant Support Department Manager J. Alexander, Operations Section Manager J. Jens, Radiological Section Manager J. Seery, Technical Section Manager ,
R. Sherry, Maintenance Section Manager L. Olivier, Chief Operating Engineer J. Neal, Security Division Manager W. Clancy, Systems Engineering Division Manager F. Wozniak, Fire Protection Division Manager
Senior licensee manager present at the exit interview
)
l i
l
I
!
, . ATTACHMENT II PILGRIM STRTION I POWER RSCENSION PROGRRM PILGRIM STRTION HAS SATISFACTORILY COMPLETED THE POLDER RSCENSION PROGRAM THROUGH THE 5% POLDER LEVEL TO THE NRC HOLD POIN THE LINE ORG ANIZATION H AS PERFORMED EFFECTIVELY. THE PLANT AND j PEOPLE ARE READY TO PROCEED TO 25%
POLDER FOR SCHEDULED TESTING.
SLIDE 1
_ - - - - -
, l
.
!
.
.
FINDINGS ARE FORMALLY DOCUMENTED AND DISPOSITIONED l
-
REQUEST FOR INUESTIGHTION RECOMMENDATION FOR IMPROVEMENT (RFI)
i
,
-
MAINTENANCE REQUESTS (MRs)
FRILURE AND MALFUNCTION REPORTS
-
(F&MRs) (INCLUDES ROOT CRUSE ANALYSES)
-
PEER EURLURTOR SUMMARIES TO NUCLEAR 111HTCH ENGINEERS (NLUEs)
SLIDE 2
!
-
.,
ODERSIGifT AND ASSESSMENT
' DECISION PROCESS RECOMMENDATION TO NRC
- L l
DECISION d L I
SENIOR UICE PRESIDENT - NUCLEAR l (MO&RT CHRIRMAN)
s i RECOMMENDATION
-
t L MANAGEMENT DUERSIGHT AND MD&AT INDIVIDUAL
+ INPUTS ASSESSMENT TEAM (MO&RT)
PEER EUALURTOR QA LINE MANAGEMENT ASSESSMENTS ASSESSMENTS REC OM MEND ATI ONS SLIDE 3
\
' * *
. .
'
SCOPE OF ODERSIGHT
THE OVERSIGHT PROGRAM HAS PROVIDED EHTENSIDE FORMAL COVERAGE OF THE POWER ASCENSION PROGRAM
,
'
-
PEER EVALUATIONS
-
MO & AT WATCHES
- LINE MANAGEMENT W ATCHES QA SURVEILLANCE
-
I
!
\ l SLIDE 4 l
. . . . .
..
'. '
.
?
r POLDER ASCENSION PROJECT (PEER EUALURTOR)
ASSESSMENT CONCLUSION: ORSERVED PERFORMANCE SUPPORT PROCEEDING WITH TEST PROGRAM TO 25% POLDE DISCIPLINES EURLURTED o GPER ATIONS o M A INTEN ANCE MECHANICAL ELECTRICAL I&C o RRD10 LOGICAL PROTECTION O CHEM I STRY I o SECURITY o FIRE PROTECTION
-
PEER EURLURTOR SUMMARIES FOR MO&RT
-
STRENGTHS DBSERVED ARERS TRRGETED FOR RDDITIONRL
-
IMPR0 DEMENTS
-
TRENDS SLIDE 5
.
.. .. ----
l
.
QUALITY ASSURANCE
DEPARTMENT ASSESSMENT l .
J CONCLUSION:0BSERVED PERFORMANCE SUPPORTS PROCEEDING [UITH THE '
TEST PROGRAM TO 25% POLDE SUMMARY OF QR FINDINGS o STRENGTHS o ARERS TARGETED FOR RDDITIONRL IMPROVEMENT o RECOMMEND ATIONS SLIDE 6
- - - - - - - - - - - - - - - _ - - - - - _
, :
~
.
I.INE M AN AGEMENT RECOMMEND ATI ONS CONCLUSION: PERFORMANCE OF PLANT RND PERSONNEL SUPPORTS PROCEEDING TO THE 25% P01UER LEVEL PORTION OF THE TEST PROGRR TEST PROGRAM RESULTS
-
OPERATIONS PERFORMANCE
-
MRTERI AL CONDITION
-
INTER-0RG ANIZ ATION SUPPORT i
l SLIDE 7
_ _ . _ . . . _ . )
. 1
- .
.. .
l l
RECOMMENDATION l
BOSTON EDISDN RECOMMENDS NRC APPROVE l PROCEEDING WITH THE POWER RSCENSION PROGRAM TO THE 25% POWER LEVEL RECOMMENDATION BASED UPON SEPARRTE ASSESSMENTS OF STATION PERFORM ANCEE INDICATING READINESS TO PROCEED BY:
'
-
SENIOR M ANAGEMENT (MO&RT)
STATION LINE MANAGEMENT
-
-
PEER-EUALURTORS
-
QUALITY RSSUR ANCE THE PLRNT AND PERSONNEL RRE PERFORMING j WELL. WE ARE FINDING THE THINGS THAT l NEED TO BE ADDRESSED 9ND ARE TRKING l RPPROPRIRTE ACTIONS TO RESOLVE THE IDE RRE RERDY FOR THE NEXT STEP SLIDE 8 i
_ .-. __ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - -
__-__ . _ __ _ _ __
.
"'
ql , l
-
.r l
I Status of Pilgrim Emergency Planning Issues
' As Of February 16, 1989 Boston Edison Company This report is being submitted on behalf of Boston Edison Company in response to a request from the NRC Staff. It does not necessarily represent the views or opinions of the Commonwealth of Massachusetts or any of the local ;
-
governments around Pilgrim Statio i
,
I l .
l
_ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
..
____ _ _ _ _ . . ._ - ..
'* ,
.. .
. .-
.
STATUS OF EMERGENCY
PLANNING ISSUES Bridaewater Issue: EOC Renovations / Facility Equipment Placement Proaress:
EOC building renovations have been completed at Bridgewate E0C equipment (including installation and testing, as appropriate) is complete except for the provision of:
- 1 map
- photocopier
- miscellaneous office supplies l'
Issue: Training Proaress:
Training of local. officials in Bridgewater is ongoing.:
)
1
.
l l
,.
Bridgewater Page 1 of 4 02/15/89 l
. _ _ - - _ _ _ _ _ _ _ _ _ _ _
.
.
. ,
'
.
STATUS OF EMERGENCY i
PLANNING ISSUES Bridaewater Issue: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - complete as of 1/25/89 Proaress:
19 operational staff positions required for initial respons operational staff positions filled as of 9 January 198 operational. staff positions required for extended respons extended operational staff positions filled as of 25 January 198 administrative support staff positions identified for initial respons administrative support staff positions filled for initial i respons administrative support staff positions identified for extended respons ' administrative support staff positions filled for extended respons Issue: Plans & Procedures l
Proaress:
Revised draft emergency plan and initial draft implementing procedures were forwarded to MCDA and subsequently forwarded to FEMA on September 21, 1988. Results of the FEMA technical review were received on-2/10/8 Comments are being studied for incorporation in the next revisio Bridgewater Page 2 of 4 02/15/89
-
,
..
', r,
-
.'
STATUS OF EMERGENCY PLANNING ISSUES Bridgewater
.
Issue: Equipment Proaress:
- Traffic Control - Initial shipment of Equipment by Boston Edison was delivered February 3,198 *. Communications - Initial * equipment has been identified, ordered and received. Most initial equipment has been place Subsequent ** equipment has been identified; most has been ordered; and, some has been receive '
- Initial equipment is comprised of equipment that was based upon the fiFSt ~
draft of implementing procedure ** Subsequent equipment is comprised of equipment that was identified after review and revision of the implementing procedures by agency head Issue: Public Information Brochure Proaress:
The wording of the initial Draft of the entire Public Information Brochure (PIB) was accepted by the. Commonwealth on December 7, 1988. On January 4, 1989, MCDA called for an additional Town and State review. Currently, the Towns and State are in the process of again reviewing the PIB Draf Comments were due back to the State by January 18, 1989. BECo final copy ,
review sheet s by Bridgewater on 12/21/88. Brochure will not be I until .iten Authorization received from MCDA per meeting of l
.,
!
Bridgewater Page 3 of 4 02/15/89
- _ _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _- ___-________-_ _
. _ _ _ _ _ . . _ _ _ _ _ _ _
l .
.
.
STATUS OF EMERGENCY j PLANNING ISSUES Bridaewater J
Reception Center Renovations / Equipment Placement
<
Issue:
Proaress:
Reception Center Renovations: l Currently the Bridgewater State College Gymnasium serves as the Reception Center location. Discussions with Bridgewater State '
College about Reception Center enhancements to the building have been
. ongoing, but proceeding with the enhancements is not scheduled to
-
commence until the Board of Trustees meets on February 23, 1989 to discuss and concur on the enhancements. Implementation of improvements will be coordinated with Bridgewater State College, 1 Massachusetts Civil Defense Agency, and the Division of Capital j Planning Offic t Equipment:
- Monitoring & Decontamination - M/D Equipment delivered to town
- Registration - in town
- Dosimetry - in town
-
Bridgewater Page 4 of 4 02/15/89
- _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - _ - _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l ", .-
l *
..
STATUS OF EMERGENCY-PLANNING ISSUES
Carver Issue: EOC Renovations / Facility Equipment Placement i
Proaress: EOC building renovations have been completed at Carve EOC l equipment (including installation and testing, as appropriate) is complete with the exception of:
- Provision of office supplies, paper, pencils, paper clips, et * Provision of a few additional chair * Completion of minor telephone system adjustment .
Installation of TD0 Lines; EOC and 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> dispatch poin ; ENMO Renovations will not occur until early spring when building becomes availabl Issue: Training Proaress:
Training is continuing in Carver. Six sessions have been conducted since 12/8/88. Training sessions were conducted on 12/13/88, 1/7/89, 1/14/89, 1/18/89, 2/9/89 and 2/11/8 l'
Carver Page 1 of 3 02/15/89
!
_ - _ _ _ _ - - _ _ _ _ _ _ _ _ _ _
.
-
. .
.o STATUS OF EMERGENCY PLANNING ISSUES Carver liing: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> EI29I.111:
23 operational staff positions required for initial respons operational staff positions filled as of 9 January 198 operational staff positions required for extended respons extended operational staff positions filled as of 9 January 198 administrative support staff positions identified for initial respons .
4 administrative support staff positions filled for initial respons administrative support staff positions identified for extended respons administrative support staff positions filled for extended respons i litus: Plans & Procedures Proaress: 1
'
Revised draft emergency plan and initial draft implementing procedures were fertsrded to ICDA and subsequently forwarded to FEMA on October 12, 1988." Its of the FEMA technical review were received on 2/10/8 C are being studied for incorporation in the next revisio f i
I Carver 02/15/89 j
_ _ _ _ _ _ _ _ _
'
.
t e
'e
STATUS OF EMERGENCY PLANNING ISSUES Carver Issue: Equipment Proaress:
- EHMOS - Equipment delivered 1/30/8 * Traffic Control - C-van in plac Equipment delivered 2/2/8 * Communications - Initial * equipment has been identified, ordered, and received. Most initial equipment has been place Subsequent ** equipment has been identified; most has been ordered; and, some has been receive * Dosimetry - Equipment has been identified, ordered, and received by l Boston Edison. Delivered to town 1/18/8 * Initial equipment is comprised of equipment that was based upon the first draft of implementing procedure ** Subsequent equipment is comprised of equipment that was identified after I review and revision of the implementing procedures by agency head All equipoent has been delivered to Carver Fire Dept. as of 1/24/8 .
!
li1MA: Foblit Information Brochure !
Proaress:
The wording of the initial Draft of the entire Public Information Brochuts (PIB) was accepted by the Commonwealth on December 7, 1988. On January , NCDA called for an additional Town and State review. Currently, the Towns;and $ tate are in the process of again reviewing the PIB Draf Comments were due back to the State by January 18, 1989. Carver final revisuLef BECo draft signed on 12/20/88. Brochure cannot be printed and distributed until written authorization is received from MCDA per meeting with MCDA/BECo on 12/12/8 Carver Page 3 of 3 02/15/89
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
-. __ _ -__ __ _ .__ _ __ _ -.
,
.
o
.
-
. c
- '
STATUS OF EMERGENCY
]
PLANNING ISSUES Duxbury
,
Issue: EOC Renovations / Facility Equipment Placement
.
Proaress: ]
EOC building renovations have been complete EOC equipment (including installation and testing, as appropriate) is complete {
except for the provi: ion of:
- Maps - All maps have been delivered and mounte * Support equipment VCR, misc, et * TD0's delivered; awaiting installation
.
Issue: Training Proaress:
Training is continuing in Duxbury. Eight sessions have been conducted since 12/8/88. One session for the Council on Aging, must be reschedule ,
Duxbury Page 1 of 3 02/15/89
-
,g,. .. :.%'
- s 1 , 4 .;
.
l~
STATUS OF EMERGENCY K PLANNING ISSUES i
Duxbury Issue: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
- . Proaress:
20... operational staff-positions required for initial respons operational staff positions filled as of 9 January 198 ..
.
40 operational staff positions required for extended respons extended operational staff' positions filled as of 9 January 198 administrative support staff positions identified for initial respons O' administrative support staff positions filled for initial respons administrative support staff positions identified for extended respons O administrative support staff positions filled for extended respons Issue:- Plans & Procedures Progress:
e Initial draft emergency plan previously provided to MCDA/ FEM c.Cauments received have been incorporate /43 procedures reviewed by agency head Agency head procedure review committee has completed a review of 39/43 procedures and forwarded them to the RERP Committee l Chairma The RERP Committee is scheduled to review all IP's and then forward them to the Selectmen for revie Duxbury Page 2 of 3 l 02/15/89
_ _ _ _ _ - _ _ - _ _ _ _
,
..
.
.'
.
-
- .- ,
STATUS OF EMERGENCY PLANNING ISSUES Duxbury Issue: Equipment i
I Proaress:
- EINDS - Equipment was delivered to town 1/24/89 by Boston Ediso * Traffic Control - Equipment has been identified, ordered and received by Boston Edison. C-van delivered 1/25/8 Equipment was delivered 1/29/8 * Communications - Initial * equipment has been identified, ordered and received. Most initial equipment has been place Subsequent ** equipment has been ordered, and some has been receive * Dosimetry - Equipment was delivered to tow's on 1/18/89, by Boston Ediso * Initial equipment is comprised of equipment that was based upon the first draft of implementing procedure ** Subsequent equipment is comprised of equipment that was identified after I
review and revision of the implementing procedures by agency head Issue: Public Information 6rochure Proaress:
The tording'of the initial Draft of the entire Public Information Brochure (PIB) was accepted by the Commonwealth on December 7, 1988. On January 4, 1989, called fbr an additional Town and State review. Comments sent back State on 1/16/89 - State review copy was missing several sections and . School dismissal issue not resolved in Duxbury. Brochure will not ted until written authorization is received from MCOA per 12/12/98 meeting.
!
Duxbury Page 3 of 3 02/15/89
,
t
< ,
. .
.
"
STATUS OF EMERGENCY PLANNING ISSUES Kinoston 11 gut: EOC Renovations / Facility Equipment Placement Proaress:
EOC building renovations have been completed in Kingsto EOC equipment (including installation and testing, as appropriate) is complete with the exception of:
- Provision of T.V. antenna (cable installed)
- Provision of Sign-in board a Provision of Table for facsimile machine e TD0 in the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> dispatch poin Illui: Training Proaress:
Training is continuing in Kingsto Six sessions have been conducted since 12/8/8 Training for Sacred Heart Schools has been scheduled for March 10 and 15. A training session for Growth Un. limited Preschool has been scheduled for 2/27/89. A training session for siren activation is scheduled for 3/2/89. The town has approved 41 of 56 lesson plan Kingston Page 1 of 3 02/15/89
- _ - _ _ . .
l .
r
,-.
STATUS OF EMERGENCY PLANNING ISSUES Kinaston
Issue: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i
!
Proaress:
22 operational staff positions required for initial respons operational staff positions filled as of 9 January 198 operational staff positions required for extended respons extended operational staff positions filled as of 9 January 198 administrative support staff positions identified for initial respons administrative support staff positions' filled for initial respons administrative support staff positions identified for extended respons administrative support staff positions filled for extended respor.s Issue: Plans & Procedures Proaress: l Revised draft emergency plan and initial draft implementing res were forwarded to MCDA, and subsequently forwarded to
- on 10/12/88. Kingston received FEMA comments from the State i aftd89. Comments are being studied for incorporation in the next J revisio l l
Kingston Page 2 of 3 02/15/89
_ _ __ ____-____ _ - _
~
. .
. ..
.
STATUS OF EMERGENCY PLANNING ISSUES Kingston 111ut: Equipment Proaress:
- ENMDS - Equipment was delivered 1/25 by Boston Ediso * Traffic Control - Equipment was delivered 2/1/89 by Poston Ediso C-Van was delivered 2/7/8 * Communications - Initial * equipment has been identified, ordered and received. Most initial equipment has been place Subsequent ** eqgipment has been ordered, and some has been receive A pager (Pilgrim CANS) was provided by Boston Edison to the Civil Defense Director and programmed 2/1/8 * Dosimetry - Equipment was delivered 1/19 by Boston Ediso * In'itial equipment is comprised of equipment that was based upon the first draft of implementing procedure ** Subsequent equipment is comprised of equipment that was identified after review and revision of the implementing procedures by agency head Issue: Public Information Brochure Progress:
mording of the initial draft of the entire Public Information (PIB).was accepted by the Commonwealth on December 7, 198 (h Januart 4.'1989, MCDA called for additional Town and State review. The Town has reviewed and approved the current PIB draf Brochure eill not be printed until written authorization is received from MCD4 ,,er 12/12/88 meetin Kingston Page 3 of 3 02/15/89
!
L- - - - - -
- . . . . . .
. _ _ . . _ _ _ _ _ _ _
.
.
.
o
-
. .
_
.- <
STATUS OF EMERGENCY ,
PLANNING ISSUES MArshfield Issue: EOC Renovations / Facility Equipment Placement ,
Proaress:
EOC building renovations are nearing completion in Marshfiel EOC equipment has been identified, ordered and received by Boston Ediso Delivery, installation, and testing of equipment is underway. Open house is scheduled for 2/18/8 Issue: Training Proaress: 1
'
Training is underway in Marshfiel Four sessions have been conducted since 12/8/8 <
- Polics/Harbormaster training has been rescheduled until after the Marshfield EOC is complet (0 pen house is 2/18/89.)
t i
7'
1 Marshfield Page 1 of 3 02/15/89
_ _ _ _ - _ _ _ _ _ _ _ - _ _ - -
s.
,
~
+
.
..
.'
STATUS OF EMERGENCY PLANNING ISSUES Marshfield lign: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Proaress:
19 operational staff positions required for initial respons operational staff positions filled as of 9 January 198 operational staff positions required for extended respons extended operational staff positions filled as of 9 January 198 administrative support staff positions identified for initial respons O administrative support staff positions filled for initial respons administrative support staff positions identified for extended respons O administrative support staff positions filled for extended respons gn: Plans & Procedures Proaress:
Initial draft emergency plan and initial draft implementing edures were forwarded to MCDA, and subsequently forwarded to
, on 8/8/88. FEMA technical review was received on 2/10/8 mts are being studied for incorporation in the next revisio Marshfield Page 2 of 3 02/15/89
\
- - - _ _ _ _ _ _ - _ _ _ _ _ . _
-
. .
,
l
.
<
STATUS OF EMERGENCY
,
PLANNING ISSUES Marshfield
>
Issue: Equipment
.:
i Proaress:
- EHMDS - Equipment was delivered to towns 1/24/89 by Boston Ediso * Traffic Control - Equipment was delivered to town 2/1/89 by i
'
Boston Ediso * Communications - Initial * equipment has been identified, ordered and received. Most initial equipment has been place Subsequent ** equipment has been identified; most has been ordered; and, some has been receive * Dosimetry - Equipment was delivered 1/18/89 by Boston Ediso * Initial equipment is comprised of equipment that was based upon the first
~
draft of implementing procedure ** Subsequent equipment is comprised of equipment that was identified after review and revision of the implementing procedures by agency head ,
Issue: Public Information Brochure Proaress:
MewordingeltheinitialdraftoftheentirePublicInformation W echsre (PIB) was accepted by the Commonwealth on December 7, 198 $ h ry 4. 1989, MCDA called for an additional Town and State Selew. Currently, the Towns and State are in the process of again !
reviewing the PIB draft. Comments were due back to the State by l January 18, 1989. Brochure will not be printed until written authorization is received from MCDA par 12/12/88 meetin !
Marshfield Page 3 of 3 02/15/89
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ ___ _ __ ._ __
__
- - _ _ _ _ _ _ _ _
.
,
. ,
.
STATUS OF EMERGENCY i PLANNING ISSUES P1vnouth
!
l Issue: EOC Renovations / Facility Equipment Placement J Proaress:
EOC renovations are complete in Plymouth. All EOC equipment is in ]
plac j Issue: Training
,
i Proaress:
Training is continuing in Plymouth. Twenty-eight sessions have been conducted since 12/8/88. Additional training is scheduled for 2/21/89, 2/22/89, 2/28/89, 3/7/89, and 3/14/8 I d
i i
!
!
l
)
!
!
l i
i
!
I Plymouth Page 1 of 3 1 02/15/89 l
l l
'
..
..
. .
STATUS OF EMERGENCY PLANNING ISSUES Plymouth 1 Issue: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Proaress: j
!
22 operational staff positions required for initial respons ,
i 17 operational staff positions filled as of 9 January 198 operational staff positions required for extended respons j l
32 extended operational staff positions filled as of 9 January 1989. j 4 administrative support stafi positions identified for initia)
respons administrative support staff positions filled for initial respons administrative support staff positions identified for extended respons administrative support staff positions filled for extended respons Issue: Plans & Procedures Proaress:
- Initial draft emergency plan previously provided to MCDA/ FEMA l
~
for Informal Technical Review. Comments have been incorporated )
into the Emergency Pla l
- 18/19 procedures reviewed by agency head * One additional special facility procedure (Jordan Hospital) I I
remains to be reviewe Plymouth l Page 2 of 3 02/15/89
- _ _ _ _ _ ___ __ - __
- ,
.
.
.
.-
.
..
)
,
STATUS OF EMERGENCY l
PLANNING' ISSUES f Plymouth Issue: Equipment J
l
.Proaress: !
- EMMDS - Equipment was delivered 1/25
- Traffic Control - Equipment was delivered 2/1/89 by. Boston Edison
. * Communications - Initial * equipment has been identified, ordered and !
received. Most initial equipment has been place i Subsequent **' equipment has been identified; most has been ordered' and, some has been receive * Dosimetry - Equipment was delivered 1/20 ]
l I
Initial equipment is comprised of equipment that was based upon the first draft of implementing procedure ** Subsequent equipment is comprised of equipment that was identified after review and revision of the implementing procedures by agency head Issue: Public Information Brochure
'
Proaress:
.,
uprding of the initial draft of the entire Public Information (PIB) was accepted by the Commonwealth on December 7, 198 ry 4, 1989, MCDA called for an additional Town and State er. Currently, the Towns and State are in the process of again reviewing the PIB draft. Comments were due back to the State
,
by .lanuary 18, 1989. Plymouth sign-off on BECo final copy of December 1988 was completed on 12/20/88. Procedure will not be printed until written authorization is received from MCDA per I 12/12/8 .
i l
Plymouth Page 3 of 3 02/15/89 ;
I
__ ..
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
,.
i 'o
- .
.
,
STATUS OF EMERGENCY PLANNING ISSUES Taunton l
liing: EOC Renovations / Facility Equipment Placement Proaress:
EOC building renovations have been completed at the Taunton EO Equipment is complete except for the provision of:
- 1 Map Issue: Training Proaress:
Training is continuing in Taunton. The Fire Department received training on survey meter / portal monitor operations; 2 sessions per day on 2/14/89, 2/16/89, and 2/17/8 l l
Taunton Page 1 of 4 02/15/89
- - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _
.___ -
.
- n
.,
.
l STATUS OF EMERGENCY PLANNING ISSUES
'
Taunton i
Issue: EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Proaress:
20 operational staff positions required for initial respons ]
i 20 operational staff positions filled as of 9 January 198 ]
40 operational staff positions required for extended respons extended operational staff positions filled as of.9 January 198 l 5 administrative support staff positions identified for initial I respons administrative support staff positions filled for initial respons administrative support staff positions identified for extended respons administrative support staff positions filled for extended respons Issue: Plans & Procedures Proaress:
Resised draft emergency plan and initial draft implementing pesadures were forwarded to MCDA and subsequently forwarded to FEMA e.5#5/88. The results of the FEMA technical review were received on Comments are being studied for incorporation in the next '
revisio ,
l Taunton Page 2 of 4 02/15/89
. _ _ - - _ . . . . .
_ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _
.- 1
.: ,. .
.'
STATUS OF EMERGENCY PLANNING ISSUES- )
l
Taunton Issue: Equipment f I
Proaress: l
- Traffic Control - Equipment was delivered February 3,1989 to Taunton i DPH by Boston Ediso l
- Communications - Initial equipment has been identified, ordered and l received. Most initial equipment has been place Subsequent ** equipment has been identified; most has been ordered; and, some has been receive Issue: Public Information Brochure Proaress:
The wording of the initial Draft of the entire Public Information Brochure (PIB) was accepted by the Commonwealth on December 7, 1988. On January 4, 1989, MCDA called for an additional Town and State review. Currently, the i Towns and State are in the process of again reviewing the PIB Draf Comments were due back to the State by January 18, 1989. Taunton signed review sheet of BECo final copy dated December,1988 on 12/21/8 Brochure will not be printed until written authorization is received from MCDA per meeting of 12/12/8 i Taunton Page 3 of 4 02/15/89
.l
_ _ - _ _ _ _ _ _ _ _ _ _ _ -
.-
,
. , ,-
,
,
e STATUS OF EMERGENCY PLANNING ISSUES Taunton l Issue: Reception Center P novation/ Equipment Placement l
l Proaress:
Reception Center Renovations:
Taunton State Hospital is designated as the reception cente Currently, the Cain Building is serving as the interim facility to be used for registrations, monitoring, and decontamination. Layouts for the building have been provided to Hospital Administrators, MCDA, and Taunton Civil Defense. The building has been cleaned and organized Portable shower facilities and a portable generator are in plac Supplies and equipment necessary to register and monitor evacuees and-their vehicles are in place. Proposed final measures to establish a long term facility involve construction of a new building on hospital grounds. Discussions are underway with Hospital administrators to define building parameter Equipment: Portal monitors delivered to Taunton State Hospital as of 1/3 Monitoring & Decontamination - delivered to Cain Building January 26 and 2 Registration - delivered to Cain Building January 26 and 2 Dosimetry - in town, delivered during this perio .
Taunton Page 4 of 4 02/15/89
,_ _ - . - ___
-
.
.
,
..
.'
STATUS OF EMERGENCY
!
PLANNING ISSUES i
State l
Issue: Area II Improvements / Equipment Placement
)
.Proaress:
Currently, the Area II EOC is operational, however, Boston Edison has f entered into discussions with MCDA concerning improvements to the facility and its equipmen ,. Issue: State Agency Training
,
Proaress:
Training is continuing with the State Agencies and related support group Eight sessions have been conducted since 12/8/88. One additional :ession is schedule ..
l
.
- q W I
i i
t'
State 02/15/89
_
P~1 . ,
l
,
r,
-
'
..
l .
,
STATUS OF EMERGENCY PLANNING ISSUES l
State i
Issue: Area II EOC Staffing for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> l Proaress:
i
! 20* operational staff positions required for initial respons * operational staff positions filled as of 9 January 198 * operational staff positions required for extended respons i 40* extended operational staff positions filled as of 9 January 198 administrative support staff positions identified for initial respons administrative support staff positions filled for initial respons administrative support staff positions identified for extended respons administrative support staff positions filled for extended respons *MCDA Framingham has committed to providing support to fill all position Issue: Plans & Procedures Proare11:
- The results of Informal Technical Review of the Area II Plan by FEMA were received on 2/8/89. Comments are being studied for incorporation in the next ravisio j
- Area II Implementing Procedures have been drafted and submitted ,
for submission to FEMA for an informal technical review on i February 10, 198 State Pago 2 of 5
-
-
r .
<'
..
,
.
4 .
I STATUS OF EMERGENCY ~
PLANNING ISSUES State l Issue: Equipment
l'
! Procress:
- Traffic Control - Equipment has' heen identified and is in the process of being ordered
- Monitoring /Decon - Equipment has been identified and is in the l process of being ordere ,
- Dosimetry - Equipment has been identified, ordered and received by Boston Ediso :
Issue: Public Information Brochure Proaress:
The wording of the initial Draft of the entire Public Information Brochure (PIB) was accepted by the Commonwealth on December 7, 1988. On January 4, 1989, MCDA called for an additional Town and State review. Currently, the Towns and State are in the process of again reviewing the PIB Draf Coments were due back to the State by January 18, 1989. When all comments are returned and State authorization to print and distribute is given, comments will be incorporated and printing and distribution will be undertake !
State Page 3 of 5 02/15/89 l l
kl-.
. 3:
.
.
l
,e STATUS OF ENERGENCY >
PLANNING ISSUES
,
State 111Mg: Reception Center Renovations / Equipment Placemen Proaress:
Reception Center Renovations:
Long term enhancements to the Hellesley DPH garage are currently being finalized with DPH and MCDA representative Equipment:
o Monitoring & Decontamination - M/D Equipment delivered to facility 2/13/8 >
o Registration - Delivered 2/13/8 o Dosimetry - Delivered 2/13/8 >
l l
i State Page 4 of 5 02/15/89 i
.
. . . - - _ _ _ _ _ - _ _ _ _ _ _
- '
. i 4-
!
STATUS OF EMERGENCY
, PLANNING ISSUES i
'
State Issue: Transportation Provider LOA j i
Proaress: ]
All Transportation Providor resource commitment and response time data was reformatted in accordance with directions from the State, and compiled into updated letters of commitment. The letters of j commitment have been signed by the Transportation Providers and are >
currently in the custody of MCD Issue: Transportation Provider Trainin ,
i l
Proares1: .
Transportation provider training is continuin Seven sessions have been conducted since 12/8/8 l l
l
,
-
State Page 5 of 5 02/15/89
,
. .
.
ii i 'il i
'il
-
'il 'il 'il 'l 'l li i i oll l '
i
'l
'1 l
'l '1 l 'l 'l ji[j l
i I
'il 'il '1 l
'l 'l 11 l- 11 if!!!ll ii!!!ll !!b;
.. ,i , i , ,i ,, ,i ,i
.! l ili dilii lli sill'n a j lli i!Il ill 1lIll
!!Ilo illiin 1111 11I!!l'lii iilin
4!! fli fli fl) l))I I !
n i,ii < i,ii > >
5 g
a!!
!.! !.!!.!! <!.III i.iInl !.!!.!! !.! !.! .
!.!I!
I il
- L lj Ljin -la4 ll 1 IL i;>
l i4 1 i44 in i54 i44
!! ll l !!!! .!! .i !!
! ' ii ni , ,ir a ii ii . i
- Ji> i
- .!!4!! o!.!!!Lilg4!i .h . li4 ;!!> 1L l
- , y . i
.
. ..
l l 3 1 I ] I g ) 31
_ - _ - _ _ _