ML16342D889
| ML16342D889 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/04/1997 |
| From: | Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| 50-275-97-14, 50-323-97-14, EA-97-369, NUDOCS 9712080185 | |
| Download: ML16342D889 (32) | |
See also: IR 05000275/1997014
Text
CLTEGORY 2--
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9712080185
. DOC-DATE: 97/12/04
NOTARIZED: NO
DOCKET
FACIL:50-275 Diablo Canyon Nuclear Power Plant, Unit 1, Pacific
Ga
05000275
50-323 Diablo Canyon Nuclear Power Plant, Unit 2, Pacific
Ga
05000323
VTB . NAME
AUTHOR AFFILIATION
, T.P.
Region
4 (Post
820201)
RECIP.NAME
RECIPIENT AFFILIATION
RUEGER,G.M.
Pacific Gas
& Electric Co.
SUBJECT: Ack receipt of 971105 ltr informing,NRC of steps
taken to
correct violations noted in insp repts 50-275/97-14
Ec
50-323/97-14.
DISTRIBUTION CODE: IE01D
COPIES
RECEIVED:LTR-
ENCL
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SIZE:
TITLE: General
(50 Dkt)-Insp Rept/Notice of Violation Response
NOTES:
RECIPIENT
ID CODE/NAME
PD4-2
INTERNAL: ACRS
ILE CENTER
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NRR/DRPM/PERB
OE DIR
RGN4
FILE
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ID CODE/NAME
BLOOM,S
AEOD/SPD/RAB
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NRR/DRPM/PECB
NUDOCS-ABSTRACT
OGC/HDS3
NOAC
NUDOCS FULLTEXT
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NOTE TO ALL "RZDS" RECIPIENTS:
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p,~ REGIIC
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+**<<+
UNITEDSTATES
NUCLEAR REGULATORY COMMISSION
REGION IV
611 RYAN PLAZA DRIVE, SUITE 400
ARLINGTON,TEXAS 76011 8064
XC -4 l997
EA 97-369
Gregory M. Rueger, Senior Vice President
and General Manager
Nuclear Power Generation Bus. Unit
Pacific Gas and Electric Company
Nuclear Power Generation, B14A
77 Beale Street, Room 1451
P.O. Box 770000
San Francisco, California 94177
SUBJECT:
NRC INSPECTION REPORT 50-275/97-14; 50-323/97-14
Thank you for your letter of November 5, 1997, in response to our letter and Notice
of Violation dated October 6, 1997.
We have reviewed your reply and find it responsive to
the concerns raised in our Notice of Violation. We will review the implementation of your
corrective actions during a future inspection to determine that full compliance has been
achieved and will be maintained.
Sincerely,
Thomas P. Gwynn, Dir
tor
Division of Reactor Pr
ect
Docket Nos.:
50-275
.50-323
License Nos.:
DPR-82
~
CC:
Dr. Richard Ferguson
Energy Chair
1100 lith Street, Suite 311
Sacramento,
California 95814
iknJ~A Pi
97XV080X85 97aa04
ADQCK 05000275
8
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Pacific Gas and Electric Company
-2-
Ms. Nancy Culver
San Luis Obispo Mothers for Peace
P.O. Box 164
Pismo Beach, California'3448
Chairman
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San Luis Obispo County Board of
Supervisors
Room 370--: .,
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County Government. Center
San Luis Obispo, California 93408
\\
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Mr. Truman Burns>Mr. Robert Kinosian
California Public Utilities Commission
505 Van'ess,
Rm. 4'1 02
~
San Francisco, California 94102
Robert R. Wellington, Esq.
Legal Counsel
Diablo Can'yon Independent Safety Committee
857 Cass Street, Suite D
Monterey, California 93940
Mr. Steve Hsu
Radiologic Health Branch
State Department of Health Services
P.O. Box 942732
Sacramento,
California 94234
Christopher J. Warner, Esq.
Pacific Gas and Electric Company
P.O. Box 7442
San Francisco, California 94120
Robert P. Powers, Vice President
and Plant Manager
Diablo Canyon Power Plant
P.O. Box 56
Avila Beach, California 93424
Managing Editor
Telegram-Tribune
1321 Johnson Avenue
P.O. Box 112
San Luis Obispo, California 93406
0
Pacific Gas and Electric Company
r
bcc to DCD IE01
-3-
DEC -4 l99T
bcc distrib. by RIV:
Regional Administrator
DRP Director
Branch Chief (DRP/E, WCFO)
Senior Project Inspector (DRP/E, WCFO)
Branch Chief (DRP/TSS)
WCFO File
.
Resident Inspector
DRS-PSB
MIS System
RIV File
M. Hammond (PAO, WCFO)
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DOCUMENT NAME: R:$ DC>DC714AKA+RhfWO7
To receive copy of document, indicate in box: "C" = Copy without enctosures
"E"-"Copy with enctosures "N"= No copy
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HJWong:jb
11/26/97
GF
12/
/97
TPGwynn
12/
/97
OFFICIAL
ECORD COPY
- previously concurred
Pacific Gas and Electric Company
-3-
DEC -4
)997
bcc to DCD IE01
bcc distrib. by RIV:
Regional Administrator
DRP Director
Branch Chief (DRP/E, WC')
Senior Proje'ct Ins'pector (DRP/E, WC
Branch Chief
(DRP/TSS)'CFO
File
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receive copy of document, indicate in box: "C" = Copy without enciosures
"E" = Copy with enciosures "N"= No copy
RIV:C:DRP/E
C
D:DRP
HJWong:jb
1 1/26/97
GF
12/
/97
TPGwynn
12/
/97
OFFICIAL
ECORD COPY
- previously concurred
Pacific Gas and Bectrfc Company
November 5, 1997
245 Market Street. Room 937-N9B
San Francisco. CA 94105
.ilcllllll".
u/(/I%5i'ail
Code N9B
.
P.O. Box 770000
San Francisco. CA 94177
415:973-4684 Fax 415;973-2313
Gregory M. Rueger
, Senior Vice PresideaP+g
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General Manager
Wy
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Nuclear Power Generationi g'~C;.
6
PG&E Letter DCL-97-184
~ I
U.S. Nuclear Regulatory Commission
.
ATTN: Document Control Desk
Washington, DC 20555
i
~
'ocket
No. 50-275, OL-DPR-80,: -;-,.
Docket No. 50-323, OL-DPR-82
Diablo Canyon Units 1 and2
Re
I to a Notice of Violation - Ins ection Re ort Nos. 50-275/97-14 and
50-323/97-1 4
Dear Commissioners and Staff:
NRC Inspection Report (IR) Nos. 50-275/97-14 and 50-323/97-14, dated
October 6, 1997, included three Severity Level IVviolations. The three
violations are:
(1) failure to meet the requirements of 10 CFR 50.65, the
NRC's Maintenance Rule (MR), in that certain auxiliary saltwater (ASW)
system check valves were not being effectively maintained to assure they
performed their intended functions, (2) failure to consistently document
these occurrences on action requests (ARs), and (3) failure to comply
with the requirements of Technical Specification 3.0.3 when the check
valves were removed from both trains of the Unit 1 ASW system for
approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 1991.
As PG&E stated at the September 22, 1997, Predecisional Enforcement
Conference and as noted in the NRC's'IR cover letter, the root cause for
these violations was PG&E's failure, despite several opportunities, to
recognize the relationship between the functionality of the check valves
and the operability of the ASW system.
This continuing failure to
recognize the importance of the valves contributed to the failure to
document recurring problems, which prevented the valves from being
properly evaluated under the MR. PG&E is taking actions to prevent
check valve failures by increased inspection and maintenance activities,
placement of the check valves in MR goal setting, and evaluating design
changes.
0
Document Control Desk
November 5, 1997
Page 2
To address potential generic issues in light of the findings made during
the check valve investigation, PG8 E has completed a review of
preventive maintenance records to identify any similar failures to initiate
ARs and a review of sele'cted Class II equipment to identify other
" equipment or design features which support safety systems.
Additionally,
PG8 E has'initiated reviews of: (1) licensing and design basis documents
to identify other subtle design features which may be relied upon to
support safety systems or to mitigate design basis events, and (2) ARs
initiated during the last two years to ensure that MR functional failures
have been appropriately identified and evaluated.
From the reviews that have been completed to date, PGRE believes that
problems associated with ineffective maintenance are isolated to the
ASW check valves and are not indicative of programmatic deficiencies in
the maintenance of similar equipment.
PG8 E's reply to the notice of violation is enclosed.
Sincerely,
Gregory M. Rueger
cc:
Steven D. Bloom
Ellis W. Merschoff
Kenneth E. Perkins
David L. Proulx
Diablo Distribution
Enclosure
WEC/2237/N0002034
Enclosure
PG&E Letter DCL-97-184
l
REPLY TO A N'OTICE OF VIOLATION
INSPECTION REPORT NOS. 50-275/97-14 AND 50-323/97-14
On October 6, 1997, as part of NRC Inspection Report (IR) Nos. 50-275/97-14
and 50-323/97-14, NRC Region IVissued three Severity Level IVviolations to
Diablo Canyon Power Plant, Units 1 and 2. The 'statements of violation and
PG&E's reply are documented below.
STATEMENT OF VIOLATIONA
10 CFR 50.65(a)(1) states, in part, that holders ofan operating license shall
monitor the performance or condition ofstructures, systems, and componenfs
(SSCs), as defined by 10 CFR 50.65(b), against licensee-established
goals, in a
manner sufficienf to provide reasonable assurance
that such SSCs are capable
offulfillingtheirinfended functions.
When fhe performance or condition ofa SSC
does not meef esfablished goals, appropnate corrective action shall be taken.
10 CFR 50.65(a)(2) requires, in part, that monifonng as specified in 10 CFR 50.65 Section (a)(1) is not required where it has been demonstrated that fhe
performance or condition ofan SSC is being effectivel controlled through the
performance ofappropriate preventive mainfenance, such that fhe SSC remains
capable ofperforming its intended functions.
Contrary to 10 CFR 50.65(a)(2), as ofJuly 10, 1996, the pointin time thaf fhe
licensee elecfed to nof monitor the performance or condition ofauxiliary saltwater
(ASW)system pump vaulf drain line check valves against licensee-established
goals pursuant to fhe requirements of50.65(a)(1), the licensee failed to
demonstrate that the peiformance or condition ofthe check valves was being
effectively controlled through fhe performance ofappropriate preventive
maintenance,
such that they remained capable ofperforming theirintended
function. In fact, prevenfive maintenance ofthese check valves wasineffecfive
in assuring thaf they remained capable ofperforming theirintended function.
(01014)
Thisis a Severity Level IVviolation (Supplement I).
REASON FOR THE VIOLATIONA
PG&E agrees with the violation as stated in the IR.
At the September 22, 1997, Predecisional Enforcement Conference, PG8 E
presented findings from an evaluation of the ineffective maintenance practices
for the auxiliary saltwater pump (ASWP) vault drain line check valves. Actions
were first taken to implement preventive maintenance (PM) of these particular
Enclosure
PGRE Letter DCL-97-184
f
valves in 1988. Although repeated unsatisfactory inspection findings resulted in
reduction of the interval between valve inspections from 36 to 24 months, and 24
to 12 months, these actions were ineffective in preventing recurring valve
degradation.
PGRE attributes these ineffective actions to its failure to fully
understand the role of these check valves in supporting Technical Specification
(TS) operability of the auxiliary saltwater (ASW) system.
As stated at the
Predecisional Enforcement Conference, a number of events occurred prior'o"
July 10, 1996, the date of the Maintenance Rule (MR) implementation, which
contributed to this failure. These events are summarized below:
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1.
In 1991, an engineering evaluation was performed to assess
operability
for an'event in which both, Unit 1 check valves were co'ncurrently removed
for maintenance for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The"evaluation erroneously
concluded that the plant was not outside the design basis with both check
valves removed:
This event is discussed further in respons'e to
Violation C.
Due to this erroneous engineering evaluation, a 1991 nonconformance
report (NCR) which questioned the appropriateness
of the 24-hour
concurrent removal of the valves, as well as the as-found valve
conditions, was closed.
However, some of the proposed corrective
actions from the NCR were not adequately implemented.
Had the
corrective actions been adequately implemented, it is unlikely that the
continued failures of these valves during maintenance inspections would
have occurred.
3.
As discussed further in Violation B, the maintenance personnel
performing the check valve inspections were provided with unclear
problem reporting guidance.
Thus, action requests (ARs), PG8E's
routine problem reporting documents, were not written to document as-
found conditions that resulted in failed inspections.
The failure to'write
ARs contributed to PG8 E's inability to identify the failed inspections as
Maintenance Rule functional failures (MRFFs) and led to omission of the
valves in 10 CFR 50.65(a)(1) goal setting.
4.
Finally, there were several instances where ARs were written for ASW
check valve PM failures, but were not properly evaluated under the MR.
This weakness
in the MR Program was associated with the limited criteria
used by reviewing personnel to determine ifevents described in the ARs
constituted MRFFs.
CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
To assure check valve operability followingthe June and July 1997 inspections,
the ASW drain lines were flushed; the ASW rooms, drains, and lines were
Enclosure
PG&E Letter DCL-97-184
= cleaned; temporary filters were installed in the floor drains to prevent debris
entry into the valves; and frequent inspections of the floor drains were
conducted.
Filter inspections are currently performed weekly.
PG&E is conducting check valve inspections on an approximate 56 day interval.
This interval may be lengthened as corrective actions are determined to be
effective.
Since these actions have been taken, nine check valve inspections have been
performed; all with satisfactory as-found valve conditions.
I ~ 'I ( ~
II
The ASW drain check valves have been placed in MR goal setting with the goal
of no additional failures during the goal-setting period.
As discussed at the Predecisional Enforcement'Conference,
PG&E has
taken'ctions
to address potential generic problems in light of the ASW check valve
findings. These actions included a review of selected Class II equipment to
identify other equipment or design features which support safety systems.
These reviews resulted in several specific findings, including some weaknesses
in the MR implementation.
However, PG&E has concluded that in general,
Class II equipment appears to be adequately maintained and the ASW check
valve issue appears to be isolated.
PG&E believes that effective implementation
of the MR willensure effective monitoring of Class II systems.
Management expectations for ASWP vault cleanliness have been established.
CORRECTIVE ACTIONS TQ BE TAKENTO PREVENT RECURRENCE
PG&E willenhance the housekeeping controls during significant
maintenance activities within the ASWP vaults. These controls should be
more appropriate for preventing debris and dirt from entering the drain
lines than the foreign material exclusion area controls that PG&E
indicated it would implement at the Predecisional Enforcement
Conference.
2.
PG&E is evaluating a design change to decrease
susceptibility to debris.
3.
PG&E is reviewing licensing and design basis documents to identify other
subtle design features which may be relied upon to support safety
systems or to mitigate design basis events.
4.
PG&E is reviewing ARs initiated since September 1995 to ensure that
MRFFs have been appropriately identified and evaluated.
Enclosure
PGKE Letter DCL-97-184
(
DATE YVHEN FULLCOMPLlANGEWtLLBE ACHIEYED
k
PGRE is in full compliance with respect to the ASW check valves.
Housekeeping controls for the ASWP vaults willbe enhanced by January 31,
1998. The design change, ifadopted willbe implemented during the Unit 2
eighth refueling outage and.the Unit 1 ninth refueling outage.
PGRE will,
complete the design feature and AR reviews by April30, 1998.
,pi
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1
Enclosure
PG8E Letter DCL-97-184
STATEMENT OF VIOLATION8
Diablo Canyon Technical Specification 6.8.1 sfafes that written procedures shall
be established, implemenfed and maintained covering fhe applicable procedures
recommendedin Appendix A ofRegulatory Guide 1.33, Revision 2, February
19?8.
Regulatory Guide 1.33> Revision 2, February 1978, Section Q.a, states in
part that maintenance that can affecf /he performance ofsafety-related
equipment should be performed in accordance
wifh wnffen procedures.
Infer-Departmental Administrative Procedure OM?-ID1, "Problem Identification
and Resolution - Action 'Requ'ests," requires that problems be documented'on'an
Action Request (AR). Affachment 7.2 to th'e'procedure, in part, defines'p'roblem
cnteria as conditions which r'ender anitem or activity unaccepfable or
'ndeterminafe
or could'negativelyimpacf systems, strucfures or componenfsif
leff uncorrected.
Confrary to the above, as ofJu'ne 25, 1997,during the performance of
maintenance activifies toinspecf ASM/pump vault drain line check valves, Acfion
Requests were nof wnffen to document problems as required by Procedure
OM?-ID1. The inspecfions revealed thaf fhe check valve was incapable of
stopping back flowforinspections performed on August 2 and 4, and September
6 and 8, 1994.
These inspection results were condifions which rendered the
valves unacceptable and negativelyimpacted the ASWsystem.
(02014)
This is a Severity Level IYviolation (Supplement I).
REASON FOR THE VIOLATION8
PG8 E agrees with the violation as stated in the IR.
As stated at the Predecisional Enforcement Conference, the original guidance in
Maintenance Procedure (MP) M-51.14, "Check Valve Inspection Program," did
not clearly communicate management expectations that ARs be written for as-
found problems with check valves.
From 1991 to 1996, the procedure required
ARs for parts, materials, or workmanship deficiencies that could not be corrected
during the course of maintenance.
Accordingly, maintenance personnel did not
always write ARs since the as-found conditions were corrected.
MP M-51.14
was revised in February 1996 to require documentation of unsatisfactory as-
found conditions and generation of ARs. Subsequent
reviews indicate that ARs
were appropriately written followingthe procedure revision.
. Enclosure
PG&E Letter DGL-97-184
CORRECTIVE STEPS TAKENAND RESULTS ACHIEVED
IVlanagement expectations for,the generation ofARs for as-found conditions
have been reemphasized
to maintenance personnel.
To address the potential generic issue',of ARs'pot'being" written for deficiencies
and degradation, PG&E performed the following reviews:
- 1.": "~ Selected Class II equipment (diesel fuel oil transfer pump vault check'
'valves, circulating water pump trip, and the intake demusseling valves)
work order (WO) completion remarks were reviewed dating back to the
mid-1980s.
This review identified no failures to write ARs.
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2.
To determine the acceptability of current maintenance practices, a total of
450 preventive maintenance and corrective maintenance WOs covering
the last 6 months were randomly selected and reviewed. Three minor
cases (fastener issues) were identified where ARs should have been
written. 'ARs were subsequently written.
To determine the acceptability of past maintenance practices, over 200
PM WOs were randomly selected covering the past 4 years and reviewed
to identify any instances in which a problem was discovered during the
PM and not properly reported.
Only two instances were identified where
an AR should have been written, both involving ASW discharge vacuum
breaker check valves.
However, by the time of this review, the vacuum
breaker check valves had already been placed in MR goal setting. The
vacuum breaker check valve corrective maintenance histories were further
reviewed and it was determined that previous maintenance failures had
occurred without proper documentation.
The effect of these failures was
evaluated and determined to have no impact on system operability.
Because of the vacuum breaker check valve failures, approximately 100
PM WOs covering the past 9 years were randomly selected and reviewed
using MP M-51.14. Two inspections were identified where valves
apparently failed inspection and no ARs were written. One valve was a
.
screen wash pump discharge check valve which was found with
significant internal wear and refurbished in 1993, prior to the procedure
changes
in MP M-51 ~ 14. This valve is not subject to MR criteria. The
other valve was an ASWP discharge check valve for which an AR had
previously been written documenting and evaluating check valve leakage.
Therefore, the failure to document as-found conditions had no effect for
either valve.
0
0
Enclosure
PG8 E Letter DCL-97-184
I
For the above events where ARs had not been written, PG&E determined in
each case that there were no operability concerns.
From these reviews, PG8 E
concluded that problem reporting as required by the current PM Program is
adequate to allow functional failure determination under the MR. The specific
events involving failure to write ARs for the ASW check valves were due to a
procedural weakness...
CORRECTIVE ACTiONS TO BE TAKENTO PREVENT RECURRENCE
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Administrative procedure MA1 DC51, "Preventive Maintenance Program," willbe
revised to clarify conditions requiring documentation on ARs.
DATE WHEN!PULI COINPLIANCEWILLBE ACHIEVED
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i
PG&E is currently in full compliance.
Administrative procedure MA1.DC51 will
be revised by December 15, 1997.
0
Enclosure
PGBE Letter DCL-97-184
STATEIIENTOF VlOLATIONC
Technical Specifications (TS) LimitingCondition for Operation 3.7.4.1 requires
that af least two auxiliary satfwater trains be operable in Modes 1-4.
The Acfion
Statement requires that with only one auxiliarysaltwater train operable to restore
at least two trains fo an operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> orbein at least hot
standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in cold shutdown wifhin the following30
hours.
TS Section 1.21 defines "operable" as when a system is capable ofperforming
ifs specified functions.agd when all necessary attendant auxiliary equipment that
are required forthe system to perform ifs function are also capable ofperforming
their related support funcfion.
TS 3.0.3 specifies that when a limitingcondition foroperationis not met, within
one hour action shall beinrfr'afed fo place the unitin a mode in which the
specification does not apply by placingitin at least hot standby within the next 6
hours, af least hot shutdown within fhe following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least cold
shutdown within the subsequent
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, on August 9, 1991, with the reactorin Mode 1, both Unit 1
ASWtrains were made inoperable when both floordrain check valves (SW-1-
987 and SW-1-988) were removed at the same time forabout 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The
removal ofthe check valves made th'e ASWsystem susceptible to the loss of
both ASWpumps (needed forperformance ofthe ASWsystem specified
function) in the evenf offlooding ofthe intake structure.
With bofh ASWtrains
inoperable due to the floordrain check valves being removed, the licensee failed
comply with TS 3.0.3 to initiate actions within one hour to place the unitin a
mode in which the specificafion did not apply by placing the unitin at least hot
standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least hot shutdown within the following 6
hours.
(03014)
This is a Severity Level IVviolation (Supplement I).
REASON FOR THE VlOLATIONC
PG8 E agrees with the violation as stated in the IR.
The failure to implement TS 3.0.3 on August 9, 1991, was due to the failure of
maintenance personnel to recognize the relationship between the functionality
of the check valves and the operability ofthe ASW system.
Though
Operations questioned ASW operability in this configuration, and an AR and
NCR were initiated, the engineering evaluation of the event erroneously
concluded that the plant was not outside its design basis during the 24-hour
0
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~
Enclosure
PG8 E Letter DCL-97-184
~
concurrent removal period. Therefore, the failure to enter TS 3.0.3 was due to
reliance on the erroneous engineering evaluation.
As stated at the Predecision'al Enforcement Conference, PG8E now believes
that the TS action statement should have been entered when a check valve
was removed since the valves perform a supporting function for ASW train
operability. PG&E also agrees, as stated in the violation, that when the Unit 1
valves. were concurrently removed in 1991, TS 3.0.3 should have been
entered.
CORRECTIVE STEPS, TAKENAND RESULTS ACHIEVED
A shift order was issued by operations on August 19, 1997, requiring operators
to declare the associated ASWP inoperable and enter the TS action statement
whenever a vault'drain line check valve is removed.
A TS interpretation (TSI) was approved by the PSRC and issued on October 31,
1997, to formalize this requirement.
CORRECTIVE ACTIONS TO BE TAKENTO PREVENT RECURRENCE
PG8 E willsubmit a License Amendment Request (LAR) or a TS Bases change
to replace the TSI.
DATE WHEN FULLCOMPLIANCEWILLBE ACHIEVED
PG8 E is currently in full compliance.
An LAR or TS Bases change will be
submitted by May 1, 1998.