ML17157A303
| ML17157A303 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna |
| Issue date: | 08/20/1990 |
| From: | Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 9009100266 | |
| Download: ML17157A303 (16) | |
Text
Docket Nos.
50-387 50-388 AUG 20 1990'ennsylvania Power 8 Light Company ATTN:
Mr. Harold W. Keiser Senior Vice President - Nuclear 2 North Ninth Street Al 1 entown, Pennsyl vania 18101 Gentlemen:
Subject:
Maintenance Program Team Inspection This letter is to inform you that the NRC intends to perform a team inspection of your maintenance program at the Susquehanna Steam Electric Station (SSES),
in Salem Township, Pennsylvania on October 9-19, 1990 and to request your assistance in accomplishing this task.
The inspection will focus on the performance of maintenance and'hether components, systems and structures of your plant are adequately maintained and properly repaired so that they are available to perform their intended safety function.
In order'for us to properly prepare for the inspection and maximize the onsite time spent in observation of maintenance in progress, we request that you furnish the reference material identified in Enclosure 1 to this letters To assist you in the gathering of the requested reference material, we have enclosed a Maintenance Inspection Tree (Enclosure
- 2) which is used by the team as guidance during the inspection.
The team leader will be contacting a
member of your staff shortly regarding the information that will be needed prior to the start of the inspection and to arrange a suitable date for a meeting to explain the inspection and assessment methodology.
A copy of the NRC Temporary Instruction 2515/97, "Maintenance Inspection,"
Revision 1 is enclosed for your information and to aid in the preparation for the inspection (Enclosure 3).
Thank you for your cooperation in this matter.
It you have any questions regarding this matter, please contact Donald Caphton, Team Leader, at (215) 337-5287 or David Bessette at (215) 337-5199 or myself at (215) 337-5291 Sincerely, priginal Signed Bys ROBERT M GALLP
'Robert M. Gallo, Chief Operations Branch Division of Reactor Safety O, j ~~
OFFICIAL RECORD COPY 9009100266 y00~20 PDR ADOCK 05000=87 9
I-'DC BUD - 0001.0.0 08/16/90
Pennsylvania Power 8 Light Co.
Enclosures:
- 1. Request for Material
- 2. Maintenance Inspection Tree 3.
NRC Temporary Instruction 2515/97 Maintenance Inspection cc w/encl:
A.
R. Sabol,
- Manager, Nuclear Quality Assurance J.
M. Kenny, Licensing Group Supervisor G. Stanley, Superintendent of Plant-SSES S.
B. Ungerer, Manager, Joint Generation Projects Department J.
DE Decker, Nuclear Services
- Manager, General Electric Co.
B. A. Snapp, Esquire, Assistant Corporate Councel H.
D. Moodeshick, Special Office of the President J.
C. Tilton, III, Allegheny Electrical Cooperative, Inc.
Public Document Room (PDR)
Local Public Document Room ( LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspecto~
Commonwealth of Pennsylvania bcc w/encl:
Region I Docket Room (with concur rences)
Management Assistant, DRMA (w/o encl)
R. Bellamy, DRSS P. Swetland, DRP K. Abraham, PAO (20)
SALP Report and (2) All Inspection Reports J. Caldwell, EDO M. Thadani, NRR S. Barber, SR.'usquehanna R. Gallo, DRS N. Blumberg, DRS D. Caphton, DRS DRS Files (5)
RI: DRS Caphton 8/
/90 p6 RI:DRS Bessette 8/'~ /90 RRRIS Gal lo 8/
90 OFFICIAL RECORD COPY BUD 0002.0.0 08/14/90
ENCLOSURE 1
Please provide three sets of the requested documents.
The team leader will contact a member of your staff regarding the best method of transmitting the documents to us.
We request that you provide pertinent documen'ts covering each element of the Maintenance Inspection Tree (Enclosure 2), including your management and administrative controls, procedures, instructions and guides.
Experience has shown that providing the requested information makes preparation for the inspection easier for both yourself and the team.
If you do not have a docu-ment for specific item within an element, you need not generate it to comply with this request.
The blocks on this tree identified as 1.0, 2.0, etc.
do not require information from you.
Some documents may be applicable to a number of elements.
For these, provide the document and list the elements for which it applies.
Also, to aid in planning the onsite inspection, provide the appro-priate contact for each element.
In addition to information provided for the inspection tree, we also request
.that you include the following information.
Documents covering any of the following that were already provided, for the tree elements need only be listed.
Description of methods by which maintenance performance is measured.
Are performance indicators used?
What are they?
Who is informed of the reports used to assess maintenance performance.
Description of process for communications with vendors for technical services and latest technical information on equipment and systems installed at the plant, and interfaces with equipment and NSSS vendors for=
training, modifications, and equipment replacement.
Documents which describe the preventive maintenance and predictive main-tenance programs.
Which equipment is included?
How is maintenance frequency determined?
What is done with results of these maintenance action's?
The number of craft personnel for electrical, mechanical, and 18C main-tenance organizations.
Please include foremen and the foremen to craft ratio.
The average years of experience for each individual and the turnover rate.
Enclosure 1
Description of shift work and work assignments.
How do'licensee super-visors decide on which craft or contractor is to perform what type to work?
Identify significant equipment failures which occurred during the last two years, include those identified during the last refueling'Provide for both units).
Describe the maintenance and testing of diesel generators and class 1E electrical equipment..
Provide the following Maintenance Work Orders (MWOs) status.
Current total listing and status of MWOs, number in planning, number in final sign-off, number on hold for lack of parts, number on hold for engineering assistance, number available to be worked on.
Projected number of corrective MWOs to be outstanding at the Unit 1
start-up by priority.
Rate of completion of corrective MWOs in terms of number completed per month and manhours expended (by craft) per month for the past 12 months.
Current number of preventive MWOs for the past 12 months.
Rate of completion of preventive MWOs for the past 12 months.
Estimated manhours required to complete current preventive maintenance MWOs. (Provide for both units)
Number MWOs requiring rework over the past six months.
(Provide for both units)
Provide five cor recti ve maintenance procedures for wor k that i s scheduled for the outage (e.g.,
- MOVs, PRVs, Solenoid Operated Valves, Safety/Relief
- Valves, ECS Pumps, Batteries, Switchgear, etc.).
Provide five preventive maintenance procedures that are scheduled prior to your next scheduled outage.
Provide your overall maintenance schedule for the outage.
enclosure 3
gR lipC~
~Co 0
~ 9
() ~. (l UNITED STATES NUCI EAR REGULATORY COMMISSION WASHINGTON, O. C. 20555 NRC fNSPECTlON MANUAL TEt'>PORARY INSTRUCTIOH 2515/97 REVISION I PQEB MAINTENANCE INSPECTICN 2515/97-01 PURPOSE This temporary instruction (TI} provides guidance for conducting a perfor-mance-based inspection of an established and implemented maintenance process at all operating nuclear power stations.
2515/97-02 08 JECTI YES The primary obiective of this TI is to determine whether all components,
- systems, and structures of nuclear power plants are adequately maintained so that they can be relied upon to perform their intended functions.
R Additiona 1 ly, thi s TI should determine whether the maintenance pr ocess provides for the prompt repair of plant components,
- systems, and structures, as appropriate to their prescribed functions.
2515/97-C3 BACKGROUND NRC has examined their nuclear power plant maintenance programs and has found a wide variation in their effectiveness.
Inadequate maintenance has been a
significant contributor to plant and system reliability problems and, thus, is a safety concern.
Analysis of operational events has shown that 'nuclear power plant components are rot being maintained at a level of reliability R
commensurate with their importance to safety.
This TI was developed tc inspect. ard assess the effectiveness of maintenance at selected nuclear power plant sites'.
A Maintenance Inspection Tree (tree}
will be used as auidance during these inspections to collate and present inspection findings.
The tree is intended to provide a systematic approach to the performance of the inspections and to ensure a level of consistency.
2515/97-04 CONDUCTING TEAM INSPECTIOHS The maintenance team inspections will be announced when the team leader prepares for the pre-inspection visit. (Section 04.01} to the site.
The full-scope inspection cycle wi11 generally be of a 6-week duration, with the team leader possibly taking an additional 2
weeks to initially coordinate the inspection, gather information, and issue the final inspection report.
Issue Date:
09/22/Bg
- h" 6 w~e.'s o<
team eQr t should gereraily consist of Week of preparation, week uf i u-c f'fice inspection, 2 weeks of ons i te inspection
~ and 2 weeks of document ta;ion.
The sequence of the inspection effort wil> be deterrrined b
he I Pniona 1
ot fice.
For example, the 2 weeks of onsite inspection may be consecu;ivy or separct.ed hy 1 week, of in-office inspection.
Generally, the inspection team wil> he composed of the following six members:
one team leader (region) two reactor/project engineers (region) one radiation specialist (region) two engineers (HO)
The team composition and/or the extent of effort for individual members may he adjusted by the region.
For example, the extent of involvement of the radiation specialist may be less than 6 full weeks, as determined by the regional office.
In addition, the regions may include involvement of the resident inspector (RI) to the extent that is normally covered by IP-62703 monthly examinatiors.
The RI should be provided training in the use of the logic tree by the appropriate team leader for this purpose.
The project manager (PH) will be generally involved with each inspection to the following extent:
be available to the team leader to facilitate contacts with the licensee attend I to 2 days of the team preparation attend fina1 pre-exit team meeting attend exit meetings The team wi 11 determine what failures of significant equipment (probabilistic R
risk assessment (PRA)-identified, safety-related, or balance of plant (BOP) that affects safety-related and special interest items) have occurred and wi11 inspect the licensee's trending and maintenance activities to schedule, P.
- repair, and prevent further failure of that equipment.
Other selective examinations of equipment failures attributed to maintenance will be examined to determine the adequacy of licensee corrective actions and root-cause determinations of the failures.
The inspection should be performed following reviev of the elements of the thintenance Inspection Tree (tree) and the additional inspection quidance provided in the Naintenance Inspection Guid-ance Volumes I
and II (separately distr ibuted).
This guidance should be used as an aid in determining adequacy and implementation of maintenance activities and to evaluate them.
The tree is also used as a tool to provide a
level of uniformity in inspection structure and in the preliminary recording of'he inspection results.
It is important to stress that the tree does riot drive the inspection, but it does represent guidance in the areas of inspection to be considered in planning the scope of the inspection, with R
inspection results recorded on the tree to the extent completed.
The tree consists of'hree major sections:
('.)
Overall Plant Performance,
{2) t'management Support. nf Naintenance, and (3)
$1aintenance Implementation.
The inspection requirements for Haintenance Implementation, which focus on th e plant.
- systems, components, test and surveillance
- data, and related activities, will receive the major portion (at least 80 percent, including di rect observations of maintenance heino performed) of the inspection effort.
'ssue Oate:
09/22/89 251<~9".
1 <
5 '".<<0
~e rec~i "ed
<hat.
inspect>on resu>,~ror the Nointenance Inlp1E'n~0nta t i o<<
=.r ca~ 1 a 1 sc provide input to the P%f ageme P%
g en..,<<pport area.
I z i s exnec ted that por t.ions o
the management, Support of Yaintenance sections 0<
the
- tree, c spec ia 1 1y th<
management Comtni tment and Hanaqement Organizatior sections,-
could be conducted by a
sing1e team menber in a
relatively short,:in@.
The amount of inspection effort devoted to the individual subsections of the tree will be determined by the regional
- office, taking into account recent inspection
- findings, time and staf
. limitations, and future inspec-tions planned to cover specific areas.
The inspection is to determine the effectiveness of the total integrated maintenance process of the power reactor licensees.
Therefore th t
e earn p ction may be directed into areas for which explicit regulatory require-ments may not exist.
- Thus, the inspection is oriented toward analyzing the performance o.
maintenance activities rather than toward the identifi-cation of violations.
A specific example of an area not subiect to explicit requirements is the licensee's participation with the Institute of Nuclear Power Operations
( INPO).
Review of licensee resolution of IHPO activities shall be conducted in accordance with established policy and, thus, observa-tions in this
- area, when warranted, should be treated as indicators of strengths or weaknesses.
Although the inspection may result in the identif'ication of'nadequacies that are not covered by explicit regulatory requirements, there is no intent to "ratchet" licensees.
Individual findings that licensees are not following published NRC guides and industry guidelineq..do not necessarily indicate that program or area is inadequate.
The goal of the inspection effort is to emphasize the use of plant experience,
- test, reliability and surveillance
- data, component failures, PRA irsights (available to the licensee or provided to the team by the Risk Applications Branch),
and items of interest in evaluating the licensee's maintenance process in terms of capabilities and performance, and to identify maj or strengths and weaknesses as they are related to safety significance.
04.0l Team Leader Preparation.
A meeting should be held with the licensee to describe the scope of the inspection and to obtain preliminary review materials, such as the licensee's procedures for planning, conducting and assessing maintenance, as we11 as organizational
- charts, work schedules, equipment lists, component failure and trending
- data, completed work orders, and related quality control (QC) inspection procedures.
The material obtained by the team leader from the licensee should be distributed to the team members for their review.
Following completio>> of the in-office review o
the licensee's maintenance
- process, the team leader will discuss the results of these reviews with the team members and factor them into the plan for the onsite inspection.
64.02 Inspection Preparation.
In preparation for site inspections, the inspection team shou d review the elements of the Maintenance Inspection Tree to determine which areas may have received recent inspections, which areas may not be applicable, and which areas will be reviewed at the plant site.
The three major parts of maintenance (i.e.,
overall plant performance, management support of maintenance, and maintenance implementation) should be inspected to the degree required to provide a valid conclusion regarding the effectiveness oi the 1icensee's maintenance program..
?515/97 Issue Gate:
09/22/89
P<<par on
- phase, the team shou]d s
t 1
and r
y U
s~ t severd components an /or systems for detailed ir spection either thrnvi;h n
d i
e r. i
- insights, licensing trendino
- data, component
<ailure R
in safety-related or BOP systems that affect safety, or se1ected equi n n<
f heiehtened in r
~
interest to the Commission, such as chec'k valves, motor-operated b
Ya1 ves, solenoid-opera i.ed valves.
and air sysi.eo s Th PRP e
used to select components or activities whose potential failures are predicted to contribute most to the risk at that plant.
At 1
t ys em s ould be included to verify that all performance-re1ated maintenance has been accomplished, including preventive maintenance.
Equip-R ment failures provide a vehicle for review of various aspects of maintenance, including root-cause analysis and
- trending, equipment history, corrective R
- actions, and past maintenance (preventive or corrective).
Inspection of failed equipment repairs or work packages will provide the opportunity tn examine the adequacy of the interaction of all licensee functions supporting maintenance, including engineerinq analyses arid trending.
Review of performance indicator
- data, systematic assessment f li erformance
(
A P~
en o 'censee p
e (SAL,
- reports, previous inspection
- findings, licersee event reports (LERs),
maintenance radiation
~ exposure
- history, and other direct measures may identify potential weak areas at that plant for which more etai ed inspection may be required.
Figure 1
(Inspection Flowchart) depicts the initiators that may be selected to enter the tree.
Dul ing the preparation
- phase, program strengths and weaknesses in certain areas may be recorded on the Naintenance Inspection Tree (working tree).
If there are sufficient data to provide an evaluation rating during the prepara-
- ion, e
e ements should be rated in accordance with the Maintenance Inspection Guidance.
However, selected items and, in particular, identified weaknesses should be verified auring the onsite inspection, even if an evaluation rating is assigned during the preparation.
04.03 Qnsite Inspection.
An entrance meeting shall be held with the liceni-see tc Cetai the scope and schedule of the inspection, introduce the team
- members, and establish the licensee's contacts for the inspection.
The team should obtain from the licensee the status of ongoing work applicable to the inspection or that may affect the performarce of the inspection or the irspection schedule.
Schedules and plans for the.exit meetirigs and the interim meetings between the team leader and licensee management should also be establisheo ouring the entrance meeting.
Team members sha11 perform a Cetailed walkdown inspection of the plant on the first or second day on site to observe the overall plant and equipment material condition.
This walkdown inspection, in which the team should observe the condition of numerous
- valves, pump,
- motors, etc.,
'should include, but not be limited to the following:
Condition nf components Significance of tagqed equipment Housekeeping and environment Adequacy of labeling Comparisons with drawings and/or proredures Status of annunciators This walkdown inspection may provide indications of areas requiring further examination during the inspection.
!ssve Dai.e:
09/22/80 4
2515/gI
o s
Qu d
o u~
or t rr.
djrqcMbse vat il f' wur"k i t) f rogr't.ss.
includ~
the followirsc of licensee cwork wi h
enuipment, ir>-
progress (e.g.,
- teacups, procedures, wnrk
- packages, engineering suppor<,
raa<orials, ccnmunications,
- testino, approvals, quality co<hen this analysis has been completed, an overall rating can be determined in accordance with the Haintenance Inspection Guidance and Criteria.
04.05 Exit Heetin Before the final days of inspection, issues and findings s
ou d
be reduced to definitive writing and then used to highlight the presentatiorr version of the Hiaintenance Inspection Tree (the Presentation Tree) and to complete the rating roll-up.
The exit meeting should include a
brief discussicn of the preliminary inspection findings using the Presenta-tion Tree to depict inspection results in a
surreary fashion;
- however, the licensee should be irformed that the findings are preliminary until they are reviewed by regional management and the inspection report is issued.
04.06 Report Preparation.
Because of the broad extent of the inspection, documentation of inspecticn activities should begin early in the process tn minimize the time, required to complete the final report.
The final report should document the assumptions
- used, the elements inspected, the elemerrts that were not applicable, licensee strengths and weaknesses, and overall conclusions consister;t with IHC-0610.
The report should address elements of the tree to at least the depth of the tier with eight areas (e.g.,
Direct
- Heasures, Hanagement Commitment and Involvement, etc.',.
a r
04.0?
Follovr Up.
Any unresolved findings identified during the inspection will be appropriateiy tracked ard resolved by the regior.al office.
2515/97 Issue Date:
09/22/09
I
t
,. 515/97-05 I f ESP ECT i0" 0 i AEl'.EhTS Than inspection shall include selective examinations of the aspects o< main-tenance listed in Sections 05.0i through C5.03, including each o
the areas and related elements of licer see activities identified under the sections.
To the extent possible, selective examinations should be based on observation of maintenance and equipment work activities ir. progress, review of lic'ensee implementation of maintenance procedures and controls, results of review of selected documents
(..uch as work packages, equipment test results, and engi-neering evaluations),
and interviews with personnel).
05.01 Overall Plant Performance Related to Maintenance a.
Direct Measures.
The team shall cor:duct appropriate examinations of i'I bi condition that can be directly related to the effective implementa-tion of a maintenance process.
Before conducting the inspection of plant performance, the inspector should review available plant information on (1) availability, (2) operability, and (3) reliability.
Information on these items can be obtained from the plant's.
operatirg history.
Other sources for obtaining the information are SALP
- reports, Performance Indicator
- Data, AEOD-Scr am
- Studies, ESF Actuation
- Studies, Safety System Unavailability
- Studies, Technical Specification Violations, Monthly Operating Peport
- Data, and Capacity Factors from NUREG-0020.
Data collection should be directed to those measures related to safety significant aspects of the maintenance process.
In addition, the inspector should conduct a detailed walkdown inspection of the overall plant material condition to assess the effectiveness of the licensee's maintenance process to the extent that it is reflected in plant housekeeping and in the external condition of equipment.
The scope of the inspection should include examination of direct measures by using information gleaned from plant and equipment for the following:
Historical data Material condition 05.02 Mana ement Support of Maintenance a.
Mana ement Commitment and Involvement.
The examination of management e
ect>veness concerning maintenance should be directed to deter-mining the extent of corporate and plant management awareness and support of the maintenance and resolution of maintenance problems and should include examination of:
The application of industry initiatives.
Extent of management direct participation in maintenance and in corrective actions (management vigor and examplel.
b.
Mana ement Or anization and Administration.
The inspection of management organization and administration controls should be directed to determining how the organization supports maintenance activities, what.maintenance activity plan has been established, how the maintenance activity plan has been implemented, corrected, and controlled.
and the control o
resources.
The inspection should include examination of:
Issue Date:
09/22/89 2515/97
Pi ogram covei e for mai>>te>>ance Policy
- coals, and objectives for maintenance Allocation of resources Oefini io>> of maintenance requirements Perfurn.a>>ce measurement Oocume>>t Control System for maintenance Maintenance decision process c.
Technical Support.
The areas that are to be selectively examined for follows:
O Internal and/or corporate conaiunication channels Engineering control Licensee acknowledgement of risk significance Quality control Incorporation cf radiological controls into maintenance process Safety Review Conmittees Reaulatory documents Trending Examples of the applicable departments or organizations subject to this inspection are:
Engineering (nuclear, instrumentation ard control (IEC),
mechanical, electrical, licensing, systems, etc.)
Quality Assurance (QA)
Quality Control (QC}
Health Physics (HP)
Safety Fire Protection Operations 05.03 Maintenance Implementation a.
Work Control.
The inspection of the work control process should be directed to work order documentation, equipment history, observation of.testing in progress, planning and scheduling, and document review.
The inspection should incluae selective examination of:
Review of maintenance in prnoress Work order control Maintenance of equipment records and history Job planning Work prioritization tfaintenance work scheduling Backlog controls Maintenance procedures Post-maintenance testino Review of ccmpleted work control dccuments b.
Plant Haintenance Orqanizaticn.
The inspection of the plant mainte-nance organization s
ou e
directed to how the organization supports maintenance activities, how the maintenance activities are controlled, implemented, and corrected, how personnel are controlled, how the organization estahlishes documentation, the effectiveness of 2515/97 Issue Date:
09/22/89
the coordinate~
a>>d feedback 1 ines of coirmun
~tion t etween p1ant management ard craft personnel, and the effectiveness o< ir tei-faces With other departments
~ especiai ly operations.
The i>>spection should include selective examination of:
Control of plant maintenance activities Control of contracted maintenance Deficiency identification, control, and corrective action system htaintenance trending Support interfaces c.
Maintenance Facilities, E uipment, and htaterials Control.
The fol-Wowing are to be se ective y examined for the area of facilities, equipment, arid material
- controls, as well as for their support of the maintenance process:
Maintenance facilities and equipment Material controls htaintenance tool and equipment control Control and calibratior, of measurement and test equipment d.
Personnel Control.
The following areas of personnel control are to be se ectively
- examined, including corisideration of
- staffing, training, and qualification:
Staffing control Personnel training Test and qualification process Assessment of the current personnel control status 2515/97-06 REPORTING REOUIRENEh!TS The appropriate regional office will document the findings and the actions taken in an inspection report
- and, in addition to the normal distribution, will forward one copy to the Director, Division of Licensee Performance and Ouality Evaluation, Office of NRR, and one copy to the Director, Division of Reactor Safety, in each of the other regional offices.
A copy of the
'R Maintenance Inspection Tree colored to reflect the inspection results for P,
each inspection conducted should be sent to the Chief of PLEB at mail stop R
10-A-19.
R 2515/97-07 COMPLETION SCHEDlJLE Inspections should he scheduled so that they are completed prior to April, P.
1991.
2515/97-08 EXPIRATION This temporary instruction shall remain in effect until April 1991 or R
until the in pectiors I ave been completed.
issue Date:
09/22/89 2515/97
?515/97-09 NRR i!TACT Any questions regarding this temporary instruction should he addressed A. T. Gody (301-492-1117) 2515/97-10 STATISTICAL OATA REPQRT ING Record the actual time spent to perform this inspection against inspectior.
procedure number "5597 for the 766 system and 2515/097 for RITS.
2515/97 1 1 ORIGINATING ORGANIZATION INFORMATION 11.01 Or anization Responsibilities.
The Performance ard Quality Evaluation Branch of NRR wi provide support and overall guidance for these inspec-tions.
11.02 Estimated Resources.
Each inspection is plarined for 6 weeks for 6 persons with 2
o the 6
weeks being direct onsite inspection (12 staff weeks) and 1
week in-office inspection, with expected additional effort by the team leader (a total of 38 staff weeks).
This total includes prepara-tion, inspection and report writing.
11.03 Parallel Inspection Procedures The inspection procedures that this TI may satisfy totally or in part are listed below.
Where credit is taken, the inspection report should note the inspection procedure number per IYiC-0610.
'The region should make final determinations based on the scope arid documentation of the inspectior.
37701 37702 37828 CIP 38701 30702 41400 567QO 61700 6i?25 62700 62702 62703 CIP 62704 62705 72701 83000 series 92700 CIP 92701 2515/97 Issue Date:
09/2"/89