IR 05000397/1987022
| ML17279A543 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/13/1987 |
| From: | Caldwell C, Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17279A542 | List: |
| References | |
| 50-397-87-22-MM, CAL, NUDOCS 8709020372 | |
| Download: ML17279A543 (37) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report No.
.
50-397/87-22 Docket No.
50-397 License No.
NPF-21 Licensee:
Washington Public Power Supply System P.
O. Box 968 Richland, Washington 99352 Facility Name:
Washington Nuclear Project No,
(WNP-2)
Meeting at:
Region V Office Meeting Conducted:
July 20, 1987 Prepared by:
C.
W. Caldwell, Projec Inspector Date Signed Approved by:
P.
H. Johnson, Chic Reactor Projects Section
ate Signed
~Summar A Management Meeting was held on July 20, 1987, to discuss the Supply System's actions in accordance with the Confirmation of Action Letter (CAL) dated July 6, 1987.
70g0203j2 8j0818 pDR ADDCH, 050003>~Rj
DETAILS 1.
Mana ement Meetin Partici ants NRC Partici ants J.
B. Martin, Regional Administrator J. L. Crews, Senior Reactor Engineer D. F. Kirsch, Division Director R. P.
Zimmerman, Chief, Reactor Projects Branch R. B. Samworth, Licensing Project Manager P.
H. Johnson, Chief, Reactor Projects Section
C.
W. Caldwell, Project Inspector WPPSS Partici ants D.
W. Mazur, Managing Director A. L; Oxsen, Assistant Managing Director for Operations C. H. McGilton, Manager of Operational Assurance L. T. Harrold, Manager of Generation Engineering C.
M. Powers, WNP-2 Plant Manager Bonneville Power Administration D. L. Williams, Nuclear Engineer State of Washin ton W. Miller, Chairman, Compliance Committee, EFSEC A. Mohseni, Nuclear Engineer, State Office of Radiation Protection 2.
Mana ement Meetin On July 20, 1987, a management meeting was held at the Region V Office with the individuals identified in paragraph 1 in attendance.
The purpose of the meeting was to discuss the Supply System's findings from the actions described in the Confirmation of Action I.etter (CAL) that was issued on July 6, 1987.
The meeting convened at 9:15 a.m.
On July 6, 1987, a
CAL was issued by Region V to document licensee actions initiated in response to a number of events that occurred at the site upon return to service after the second refueling outage.
Included in these events were five recent reactor trips.
The CAL confirmed Supply System management's intent to accomplish the following actions prior to restart:
A.
Perform an evaluation of the effectiveness of the post-trip review and root cause assessment programs with particular emphasis on the Supply System staff's apparent willingness to proceed with plant operation without fully understanding the cause of problems encountere B.
Reevaluate the root cause of problems encountered during the startup program, including but not limited to those identified in the enclosure to the CAL.
C.
Perform an assessment of major work items accomplished during the recent refueling outage to assure the readiness of plant components, particularly electrical systems, for continued plant operation.
D.
Review the implementation of the root cause analysis program, particularly including the steps to be taken following equipment failures to ensure that that potential cause factors are not disturbed before the cause of the failure is clearly determined.
Mr. Mazur opened with a summary of the events that lead to the plant shutdown, the reviews that the Supply System performed, and the corrective actions that were implemented as a result.
After introductory remarks, Supply System representatives made presentations on the following subjects in response to the CAL:
Timeline of Recent Events Principal Items in the Confirmation of Action Letter Readiness for Restart Program Principal Elements Assessment of Plant Readiness for Restart Electrical Work Review Activity Major Outage Work Review Present Operational Readiness Review Post Trip Process Root Cause Process Assessment of Restart Decisions Overview of Other Startup Problems Summary A copy of slides used during the licensee's presentations are enclosed with this report.
In closing, Mr Hartin acknowledged the Supply System's efforts with regards to the CAL.
He emphasized the continuing need to maintain a
self-critical attitude, especially with regards to root cause assessment of events.
Mr. Martin suggested that the Supply System further question the adequacy of system designs and the need for increased Engineering review of quality/reliability of equipment and system Mr. Mazur expressed confidence that the plant was ready for operation.
He stated that the present plan was for a slow, gradual return to power operation.
The meeting adjourned at 12:30 p.m.
Enclosure:
Selected slides from the licensee's presentations
ENCLOSURE
.
SLIDES USED DURING THE LICENSEE'S PRESENTATION
R E
A D
I N
E S
S F
R R
E S
T A
R T
E Y
A l.U A
T I
N J
U l'Y.
Q.,
9
7
T I
N E
L I
N E
APRIL 10, 1987 JUNE 19, 1987 JuNE 26, 1987 JuNE 27, 1987 JUNE 28.
1987 JuLY 2, 1987 START OUTAGE REACTOR CRITICAL 1500 HRs, - ScRAM 87-02 (TRN-1)
1933 HRs
-
SGRAM 87-04 (EPA/DEH)
1216 HRS, -
SCRAM 87-05 (NG/TRANSFER SNITCH)
JULY 6, '1987 JuLY 6, 1987 0506 HRs
" SGRAM 87-06. (Nl-2)
SUPPLY SYSTEM DECISION TO REMAIN SHUTDOHN CONFIRMATORY ACT ION LETTER
P R
I N
C I
P L
E I
T E
N S
I C
N F
I R
N A
T
R Y
A C
T I
N L
E T
T E
R j.)
A)
EFFECT I VENESS OF POST-TRIP/ROOT CAUSE PROGRAM B)
QUALITY OF SCRAM RESTART DECI S IONS
'
2)
REEVALUATION OF OTHER (NON-SCRAM)
STARTUP PROBLEMS GENERIC CAUSES 3)
ASSESSMENT OF MAJOR OUTAGE ACTIVITIES TO REAFFIRM READINESS FOR RESTART/CONTINUED OPERATION (ESPECIAL LY ELECTRICAL)
11)
PROTECTION OF CAUSAL FACTORS TO ENSURE EFFECTIVE ROOT CAUSE ANALYSIS
l
SELF-CRITICAL EVALUATION BY PLANT STAFF
INDEPENDENT EVALUATION OF PLANT ACTIVITIES BY SENIOR SUPPLY SYSTEM NANAGERS IiRPO EVALUATION OF POST-TRIP/ROOT CAUSE PROGRAM I'
OVERVIEW OF PROCESS BY ASSISTANT NANAGING DIRECTOR FOR OPERATIONS
FORMAL PRESENTATION TO NANAGING DIRECTOR
FORMAL PRESENTATION TO NRC-REGION Y O
REFLECTION ON PROCESS/PROGRAMS BY OUTSIDE SENIOR INDUSTRY EXPERTS
MAJOR ELECTRICAL WORK REVIENED FOR ADEQUACY/INPACT NAJOR OUTAGE WORK REVIENED FOR PROPER EQUIPMENT RETURN-TO-SERV ICE ACTIONS
PRESENT OPERATIONAL READINESS REVIEWED'"lMR REVI EN NCR REVIEN PLANT OPERATIONS DEPARTMENT INPUT PLANT TECHNICAL STAFF INPUT e
CONCLUSIONS; RESTART REVIEW PROCESS REAFFIRMED/IMPROVEMENTS IDENTIFIED I
C PLANT IS READY TO RUN
1800 PM TASKs 4600 MAN-HOURS 350 I'IRS EXECUTED ADEQUACY OF THE PM PROGRAM Hl 9UALITY OF CORRECTIVE MAINTENANCE/MODI F ICATION WORK SKILL LEVEL OF THE CRAFT TRAINING OF TEMPORARY ELECTRICIANS ON ASS IGNED TASKS PM PROGRAM IDENTIFIED 30 POTENTIAL PROBLEMS CORRECTIVE MAINTENANCE REQUIRED 18 REVISITS PROBLEMS UNCOVERED BY'MT PROCESS) f~M TO DECLARATION OF OPERABIL'ITY
e'9 MAJOR CORRECTIVE MAINTENANCE l%RS e,
5 f MAJOR PLANT MODIFICATION PACKAGES CRITERIA DEVELOPED TO SELECT ACTIVITIES WHICH CHALLENGE OUR EQUIPMENT RETURN TO SERVICE.PROCESS 9/A INDEPENDENTLY REVIEWED SELECTION CRITERIA AND PACKAGES IDENTIFIED CROSS-SECTION IN COMPLEXITY OF MAINTENANCE ACTIVITIES SELECTED
HEFENSE IN DEPTH APPROACH TO WORK CONTROL PRACTICES CONFIRMED EQUIPMENT OPERABILITY IMPROVEMENTS INDENTIFIED IN CONSISTENCE OF TEST SPECIFICATIONS AND DOCUMENTATION OF RESULTS
509 OPEN iNCRS REVIEWED j.70 OPEN NHRS ON PLANT EQUIPMENT REVIEWED POTENTIAL IMPACT ON THE FOLLOWING SELECTED FOR FURTHER EVALUATION PLANT SAFETY OPERABILITY OF COMPONENT RELIABILITY OPERATOR CONVENIENCE
IMPACT
~
~
+
~
NO PLANT SAFETY OR OPERABILITY IMPACTS IDENTIFIED SEVERAL REL IABI LITY/OPERATOR CONVENIENCE PACKAGES WORKED
BASED ON INDUSTRY'PPO, AND OUR OWN EXPERIENCE l
LIVING PROCESS -- RECENT 'CHANGES INCLUDE l CREW DEBRIEFING WITH PLANT OPERATIONS NANAGER EXPANDED POST TRIP PARTICIPATION (NSASJ GA)
YiORE FORMAL DOCUMENTATION
LESSONS LEARNED'MPROVE THE QUALITY OF INFORMATION NORE RIGOR IN THE DOCUMENTATION
CORRECTIVE ACTIONS:
FOLLOWUP REVIEW COMMITTEE PRIOR TO RESTART "-
IMPROVE QUALITY PEER REVIEW COMMITTEE FOR PERSONNEL PERFORMANCE NORE RIGOR IN DOCUMENTATIONl
TEST FOR GENERIC ISSUES
YER IFY DATA 8EW PROCESS HAS BEEN COMMUNICATED TO KEY ELEMENTS OF THE STAFF
CURRENTLY EXISTS IN POST-TRIP, LERi AND HPES PROGRAMS LESSONS LEARNED NO FORMAL SYSTEMATIC PROCESS CORRECTIVE ACTION l EVALUATE INPOUR SNIJBp AND TROJAN S
800T CAUSE PROGRAMS
DEVELOP FORMAL PROGRAM NITH IMPLEMENTATION PROCEDURES
\\
TRAIN EVER-EXPANDING NUCLEUS OF INDIVIDUALS IMPLEMENT PROGRAM AT A HIGH LEVEL (SCRAM/LER/
HPES)
AND EVENTUALLY EXPAND TO NCRSi AWRSg PERFORMANCE MON ITOR I NG p ETC )
~
S
SCRAM 87-03.(TRN-2)
COULD HAVE BEEN PREVENTED BY A MORE DETAILED EVALUATION OF SCRAM 87-02 (TRN-1)
O NO COMMON CAUSE BETWEEN SCRAMS 87 03 (TRN 2)p 87-00.(EPA/DEH), 87-05 (NG/swITCH),
AND 87-06 (N1'-Z)
I
NO COMMON CAUSE ROOTED IN OUTAGE SCOPES PERFORM-ANCES OR PROGRAM CONTROLS LESSONS LEARNED:
COMMON CAUSE IN ATTENTION TO DETAIL--
LOWER D ISCRIMINATER FOR ROOT CAUSE PROGRAM SCRAM 87-02 AND 87-03 TEST SWITCH/BPA INTERFACE; OI L SAMPLE RESULTS SCRAM 87-04 -- REPLACEMENT OF DEH SNITCH DUR I NG RF87A
e RE-EXAMINED CORRECTIVE ACTIONS FOR EACH CITED PROBLEM EXPANDED REVIEW TO OTHER EVENTS AND DIFF I CULTI ES EXPERIENCED DURING RESTART e
NSAG REVIEW OF SHIFT, NANAGER S
LOG FOR PROBLEM
,RESOLUTION o
CONCLUSIONS:
APPLY OUR ROOT CAUSE PROCESS TO A
LOWER LEVEL OF PROBLEMS TO IDENTIFY AND RESOLVE PRECURSOR EVENTS AGGRESIVELY FOLLOW-THROUGH ON IDENTIFIED CORRECTIVE ACTIONS TEST FOR GENERIC IMPLICATIONS STRENGTHEN INTERFACE WITH OUTSIDE SUPPORT ORGANIZATIONS
06/20/87
. INSTRUMENT YALVES ISOLATED 06/29/87 AND (VALVES NOT LABELED)
LABEL VALYES 0 LIST YALYE NUMBERS N
PROCEDURE
MPROVE INDEPENDENT VERIFICATION "
.
9 100lo REVER IF ICAT ION OF INSTRUMENT YALVES 06/25/87 TIP".INDEXER ( I NTERNAL MIS-ALIGNMENT)
REALIGN SPARE INDEXER 07/01/87 STEAM LEAK IN/STOP "(.IMPROPER
REPLACE GASKETS TOR-TORQUE METHOD i I ) E i
~
TORQUE/
QUEi AND 'CHECK FOR NOT COMPRESS ION)
COMPRESSION 9 YERIFY S IMILAR FLANGES P'OR PROPER COMPRESSION
UPGRADE TORQUING PRO-CEDURE 07/04/87 LP TURBINE RUPTURE DISC (PROCEDURAL GUIDANCE)
REPLACE RUPTURE DISC
UPGRADE PROCEDURES O
IMPROYE BOILER OPERA-TION
~
~
PROV IDE OYER-PRESSURE ALARM 07/05/87 GENERATOR ANTI-NONITOR I NG (NH FEEDBACK LOOP)
500 KY BREAKER FAILURE.
(RE) AY OPERATION/BREAKER)
ALIGNMENT)
0 SHORT-TERN'ELECT HIGHER LOAD REFERENCE AND RATE O
IMPROYE YIN FEEDBACK CIRCUITRY 0 BASED ON ABOVE'P-GRADE PROCEDURE READJUST BREAKER/
RELAY 6 TEST C.IRCUITRY e
LONG-TERM; IMPROVE SECONDARY GENERATOR PROTECTION
n,
06/06/87 RRC-P-1A CAsING LEAK (INCORRECT VENDOR MANUAL)
O REPLACE GASKET
UPGRADE VENDOR flANUAL UPGRADE BILL OF HATER IAL
INDEPENDENT INVESTI-GATION r
06/21/87 RCIC EGR (EGR FAILURE/
REPLAGE EGR AND TAPE IN COIL)
CALIBRATE (06/24/87)
DUE TO DI'FFICULTY IN NULLINGp REPLACE AND RECAL I BRATE (07/16/87)
06/21/87
.
RRC-Y-23A LEAK ( IN-PROPER TORQUING
RETORQUE TO ENSURE GASKET COMPRESSION 06/22/87 CIA-Y-39A/8 (DEsIGN/
APPLICATION)
CLEAN AND INSPECT O
REPLACEMENT IN THIRD REFUELING OUTAGE
CAUSAL FACTORS HERE GENERALLY MAINTAINED FOR ALL SCRAM INVESTIGATIONS
'NO FORMAL PROGRAM TO ENSURE PROTECTION OF CAUSAL
~i I
I
~
FACTORS EXI'STED
..
PPNS 1 3 5r REACTOR TRIP AND RECOVERED AND 1,3,42, TROUBLESHOOTING PLANT SYSTEMS AND EQUIPMENT>
HAVE BEEN MODIFIED TO PROVIDE PROTECTION
8EH PROGRAM HAS BEEN COMMUN.ICATED TO KEY ELEMENT OF THE STAFF
NE BELIEVE EVERY SCRAM CAN BE PREVENTED HE ARE PURSUING AGGRESSIVE PROACTIVE RELIABILITY IMPROVEMENTS
PN PROGRAM ADJUSTMENTS BASED UPON EQUIPMENT HISTORY PERFORMANCE MONITORING PROGRAM TO ANTICIPATE UNACCEPTABLE IMPACTS TO PLANT RELIABILITY
CAPITAL IMPROVEMENT PROGRAM DIRECTED AT RELIABILITY ISSUES
.
HIDER APPLICATION OF ROOT CAUSE ANALYSIS PROGRAM
'I E
I NORE COMPLETE PURSUIT OF GENERIC IMPLICATIONS OF FAILURES HE WILL NOT ACCEPT THAT FIVE (5)
SCRAMS"IN TEN (10)
~ DAYS IS SIMPLY UNAVOIDABLE EQUIPMENT FAILURE
~
i
~
OUR PROGRAMS AND -PERFORMANCE WILL BE STRONGER AS A
RESULT OF OUR LAST TWO (2)
WEEKS OF SELF-CRITICAL REFLECT IONg NAMELYl POST-TRIP REVIEW PROCESS ROOT CAUSE PROGRAM O
IMPROVED TORQUING PROGRAM IMPROVED, INTERORGAN I ZATIONS CONTROL
IMPROVE RESTART REVIEW PROCESS NE ARE"COMFORTABLE THAT OUR RESTART EVALUATION PROCESS-WAS EFFECTIVE AND THE PLANT IS READY FOR SAFE AND RELIABLE OPERATION
COMMITTEE PROCESS
~ wi )
---"-CHARTER:
'
PA PROVIDE INDEPENDENT EVALUATION OF THE POST-TRIP REVIEH AND ROOT CAUSE ASSESSMENT PROGRAM EVALUATE THE RESTART DECISIONS ASSOCIATED HITH SCRAMs 87-02, 03, 00, AND 05 FOR ADEQUATE ROOT CAUSE AND CORRECTIVE ACTION, EVALUATE THE COMPLETENESS OF PLANNED ACTIONS PRIOR TO RESTART,
o COf'IMITTEE INTERVIEl'LED 14 PLANT PERSONNEL
ON 1, o
ASSIGNED INDIVIDUALSCRAMs TO COMMITTEE MEMBERS,'
REVIE!r(ED SCRAM DOCUMENTATION o
REVIEWED PLANT PROCEDURES GOVERNING RESTART, o
REVIEMED PLANT CORRECTIVE ACTION PLAN.
o REVIEWED EQUIPMENT HISTORY.
o REVIEWED PLANT LOGS.
o IDENTIFIED PROBLEMS FROM PLANT LOGS FOR PERIOD 5/12
'7/7 TO ENSURE CLOSURE BY NCR..
MHR OR MHETHER OR NOT IT HAS CLOSED, o
COMMITTEE MEMBERS DELEGATED ALL RESPONSIBILITIES AND HAVE BEFN MOBILIZED SINCE Jul Y 6.
o flFET DAILY WITH PLAflT MANAGER AND ASSISTANT DIRECTOR FOR NUCLEAR OPERATIONS TO PROVIDE STATUS, o
COMMITTEE EVALUATION VtILL BE DOCUMENTED IN A REPORT TO THE PLANT MANAGER,
EVALUATION OF RESTART DECISION o
INITIAL CAUSE IDENTIFIED AT RESTART t<AS INCORRECT
DECISION HAS BASED UPON OIL SAMPLES o
TRANSFORNER TENPERATURE DATA OVERLOOKED o
POPPET VALVE OVERLOOKED o
OPERATOR LOG DATA NOT SCRUTINIZED
EVALUATION OF RESTART DECISION 87-05 o
DECISION TO RESTART l'NS BASED ON REMOVAL OF POPPET VALVES CORRECT DECISION, 0 'RANSFORMER TEMPERATURE DATA OVER-LOOKED, o
OPERATOR LOG DATA NOT SCRUTINIZED,
EVALUATION OF RESTART DECISION 87-OQ
'a
~4 o
IDENTIFICATION OF EPA BREAKER NISALI~nN-l'1ENT AS CAUSE IS STILL NOT CERTAIN, o
BASED UPON VENDORS JANUARY RECO.'l,'lENDATIONS,
,
SWITCHES SHOULD HAVE BEEN REPLACED AT EARLIEST OPPORTUNITY, o
PERFORMANCE OF LOGIC CARD IS CURRENTLY BEING EVALUATED HY GE,
EVALUATION OF RESTART DECISION 87-05 o
INITIAL CAUSE CORRECT o
THE DECISION TO RESTART tNS CORRECT 87-06 o
THE INITIAL CAUSE OF THE SCRAN IS CORRECT, o
CORRECTIVE ACTION CORRECT TO SUPPORT RESTART,
EVALUATION OF POST-TRIP REVIEM
.AND ROOT CAUSE ASSESSMENT PROCESS o
IMPROVEMENT-NEEDED CONVENE TEAM OF EXPERTS PROMPTLY FOLLOWING SCRAM STEPS TO PRESERVE EVIDENCE UNTIL PLAN ESTABLISHED o
.
IMPROVE DOCUMENTATION OF EVALUATIONS PROCEDURALIZE THE ROOT CAUSE DETERMINATION PROCESS o
PROVIDE TRAINING IN ROOT CAUSE EVALUATION TECHNIQUES
'
EVALUATION OF ROOT CAUSE PROCESS o,:
~
DEFINED IN PPM 1.3.5,
"REACTOR TRIP AiND RECOVERY,"
o PERFORMED BY SCRAM FOLLOH-UP COMMITTEE IF ROOT CAUSE NOT IMMEDIATELYDETERMINED FOLLO'AING THE SCRAM, ROOT CAUSE DETERMINATION PROCESS IS NOT STRUC-TURED TO ENSURE COMPREHENSIVE AND CONSISTENT
~. EXECUTION, o
l1ORE COMPLETE DOCVMENTATIOil IS REO(.IIRED.
o MAJOR PORTION OF ROOT CAUSE DETERMINATION PRO-CESS SHOULD PRECEED RESTART DECISION TO STRENGTHEN THE BASIS,
GENESES OF SCRA."lS 87-02/
87-03
~
~ ~
LACK OF CONF IGURATION COi ASTROL 87-04 o
FAILURE TO REPLACE PRESSURE SHITCHES FOLLOWING DECENBER LI, 1986 FAILURE 87-05 o
UNPREDICTABLE EQUIP LENT FAILURE, 87-06 o
NOT FULLY RECOGNIZING THE CONSEQUENCES OF FINGER NISALIGNNENT ON NORNAL BREAKER OPERATION
COMMITTEE RECOMMENDATIONS NEAR TERM o
ESTABLISH REQUIREMENT THAT FOR ALL FUTURE SCRAMS, A COMMITTEE OF EXPERTS HILL BE FORMED TO ASSESS ROOT CAUSE AND INPUT INTO THE RESTART DECISION, o
RESOLVE EPA ISSUES, o
REPLACE RPS DEH PRESSURE SHITCHES
COMMITTEE RECOMMENDATION (CONT INUED)
LONGER TERM
.
o REVISE PPM 1,3,5,
"REACTOR TRIP AND RECOVERY":
~,.0 PROVISIONS FOR SCRAM COMMITTEE OF EXPERTS TO INVESTIGATE ROOT CAUSE AND INPUT TO RESTART DECISION; PROVISIONS FOR PRESERVATION OF P/IDENCE, ESTABLISH A FORMAL ROOT CAUSE EVALUATION PROCESS.
INSTALL NEW IMPROVED LIFE DEH PRESSURE ShITCHES IN R-3, o
DEVELOP GUIDANCE FOR INTENTIONALLYENTERING A HALF-SCRAI'1, CLARIFY THE BPA/SUPPLY SYSTEM INTERFACE AND RES-PONSIBILITIES, r
EXPAND THE RESTART REVIEH PROCESS FOLLOWING MAJOR OUTAGES TO INCLUDE AN ASSESSMENT OF THE PLANT'S CONDITION TO TRANSITION TO AND SUPPORT FULL POWER OPERATION:
IDENTIFY AND ASSESS MAR"INALLY PERFORMING EQUIPMENT; EVALUATE AGGREGATE EFFECT OF ALL KNO'L'IN EQUIP-MENT CONDITIONS,
REVIB< OF PLANT'S READINESS FOR RESTART PROGRAM o
COMMITTEE CONCLUDED THE PLANT'S PLAN WS COMPREHENS IVE AND COMPLETE o
RECOMMENDED THE FOLLOHING ADDITIONS TO THE PLAN:
EVALUATION OF THE ADEQUACY OF TORQUING REQUIRB1ENTS DEFINITION OF BPA AND SUPPLY SYSTEM RESPONSIBILITIES
,CHECKPOINT ON THOROUGHNESS REVIG'tED CONTROL ROOM LOGS MAY 12, 1987 TO JULY 7 1987 TO IDENTIFY THOROUGHNESS OF PROBLEM RESOLU-TION:
o TOTAL OF 73.PROBLEMS LOGGED IN TIME PERIOD
MERE EASILY DETERMINED TRACEABLE TO MIMIR OR NCR/PDR REMAINING 18 TURNED OVER TO PLANT FOR FOLLOW-UP RESOLUTION CONCLUSION ALL MERE BEING SATISFACTORILY TRACKED TO)'lARD D I SPOS ITION