ML18029A851

From kanterella
Jump to navigation Jump to search
Insp Repts 50-259/85-39,50-260/85-39 & 50-296/85-39 on 850727-0819.Violation & Deviation Noted:Failure to Have Adequate Procedure to Cover Operation of Standby Gas Treatment Sys Charcoal Bed Heaters
ML18029A851
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 08/30/1985
From: Brooks C, Cantrell F, Patterson C, Paulk G, Petterson C, Stadler S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18029A848 List:
References
TASK-2.K.3.28, TASK-TM 50-259-85-39, 50-260-85-39, 50-296-85-39, NUDOCS 8509160153
Download: ML18029A851 (18)


See also: IR 05000259/1985039

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323

Report Nos.:

50-259/85-39,

50-260/85-39

and 50-296/85-39

Licensee:

Tennessee

Valley Authority

500A Chestnut Street

Tower II

Chattanooga,

Tennessee

37401

Docket Nos.:

50-259,

50-260

8 50-296

License Nos.:

DPR-33,

DPR-52

8

DPR-68

Facility Name:

Browns Ferry 1, 2,

and

3

Inspection

Conducted:

July 27 - August 19,

1985

Inspectors:

G.

L.

Pa

k, Senior

R

id

o

ate

Signed

C. A.

Pa

erson,

Resi

en

C.

R. Bro

s,

eside

3

S.

D. Sta ler,

Inspec

or

Approved by:

F.

. Cantrell,

Sec

ip'n

ef

Division of Reactor

Prospects

ate

igned

o

D te

igned

D te

igned

8" 9g

q

Date

igned

SUMMARY

Scope:

This routine

inspection

involved

150

resident

inspector-hours

in the

areas

of operational

safety,

maintenance

observation,

reportable

occurrences,

surveillance

observation,

TMI action

item,

licensee

action

on previous

enforce-

ment items,

and unresolved

items.

Results:

One Violation - Technical Specification 6.3.A. 1 for failure to have

an

adequate

procedure

to cover operation of the Standby

Gas Treatment

(SBGT) System

charcoal

bed

heaters

and failure to

use

an

updated

procedure

which covered

operation of the heaters.

One Deviation - Final

Safety Analysis Report,

section

5.3.3.7 for not having

a

low temperature

alarm on the

SBGT system charcoal

bed heaters.

0

8509160153

850904

PDR

ADOCK 05000259

8

PDR

REPORT DETAILS

1.

Persons

Contacted

Licensee

Employees

J.

A. Coffey, Site Director

R.

L. Lewis, Plant Manager (Acting)

J.

E. Swindell, Superintendent

- Operations/Engineering

T.

0

~ Cosby,

Superintendent

- Maintenance

J.

H. Rinne, Modifications Manager

J.

D. Carlson, guality Engineering

Supervisor

D.

C. Nims, Engineering

Group Supervisor

R.

McKeon, Operations

Group Supervisor

C.

G. Wages,

Mechanical

Maintenance

Supervisor

J.

C. Crowell, Electrical Maintenance

Supervisor (Acting)

R.

E. Burns,

Instrument Maintenance

Supervisor

A.

W. Sorrell, Health Physics

Supervisor

R.

E. Jackson,

Chief Public Safety

T.

L. Chinn, Senior Shift Manager

T.

F. Ziegler, Site Services

Manager

J.

R. Clark, Chemical Unit Supervisor

B.

C. Morris, Plant Compliance Supervisor

A. L. Burnette, Assistant Operations 'Group Supervisor

R.

R. Smallwood, Assistant Operations

Group Supervisor

S.

R. Maehr,

Planning/Scheduling

Supervisor

G.

R. Hall, Design Services

Manager

W.

C. Thomison,

Engineering

Section Supervisor

A. L. Clement,

Radwaste

Group Controller

2.

Other

licensee

employees

contacted

included

licensed

reactor

operators,

auxiliary operators,

craftsmen,

technicians,

public safety officers, guality

Assurance,

Design

and engineering

personnel.

Exit Interview

(30703)

The inspection

scope

and findings were

summarized

on August

2 and

19,

1985,

with the Plant Manager and/or Assistant Plant Managers

and other members of

his staff.

3.

The licensee

acknowledged

the findings and took no exceptions.

The licensee

did not identify as proprietary

any of the materials

provided to or reviewed

by the inspectors

during this inspection.

Licensee Action on Previous

Enforcement Matters (92702)

0

(Closed)

Unresolved

(259/260/296/85-36-03)

The charcoal

bed heaters

are the

subject of the violation and deviation in this report.

This item is closed.

5.

Unresolved

Items" (92701)

There are

two unresolved

items covered

in paragraph

five and eleven.

Operational

Safety

(71707,

71710)

The

inspectors

were

kept

informed

on

a daily basis

of the overall plant

status

and

any significant

safety

matters

related

to plant

operations.

Oaily discussions

were held each

morning with plant

management

and various

members of the plant operating staff.

The inspectors

made frequent visits to the control

rooms

such that each

was

visited at least daily when

an inspector

was

on site.

Observations

included

instrument

readings,

setpoints

and recordings;

status of operating

systems;

status

and

alignments

of emergency

standby

systems;

onsite

and offsite

emergency

power

sources

available

for automatic

operation;

purpose

of

temporary tags

on equipment controls

and switches;

annunciator

alarm status;

adherence

to procedures;

adherence

to limiting conditions for operations;

nuclear

instruments

operable;

temporary

alterations

in effect;

.daily

journals

and logs;

stack monitor recorder traces;

and control

room manning.

This inspection activity also

included

numerous

informal discussions

with

operators

and their supervisors.

General

plant tours were conducted

on at least

a weekly basis.

Portions

of'he

turbipe building, each reactor building and outside

areas

were visited.

Observations

included

valve positions

and

system

alignment;

snubber

and

hanger

conditions;

containment

isolation

alignments;

instrument

readings;

housekeeping;

proper

power

supply

and

breaker

alignments;

radiation

area

controls;

tag controls

on equipment;

work activities in progress;

radiation

protection

controls

adequate;

vital

area

controls;

personnel

search

and

escort;

and vehicle search

and escort.

Informal discussions

were

held with

selected

plant

personnel

in their

functional

areas

during

these

tours.

Weekly verifications of system

status

which included major flow path

valve

alignment, instrument

alignment,

and

switch

position

alignments

were

performed

on the source

range monitors

and

SBGT systems.

A complete

walkdown of the

accessible

portions

of the

SBGT

system

was

conducted to verify system operability.

Typical of the items checked during

the walkdown were:

lineup procedures

match plant drawings

and

the as-built

configuration,

hangars

and

supports

operable,

housekeeping

adequate,

electrical

panel interior conditions, calibration dates

appropriate,

system

instrumentation

on-line, valve position alignment correct,

valves

locked

as

appropriate

and

system indicators functioning properly.

"An Unresolved

Item is

a matter

about which more information is required to

determine

whether it is acceptable

or may involve a violation or deviation.

Cy

All three

units

remained

shutdown

during

this period.

Unit

One

fuel

off-load commenced

on August 16,

1985.

Reactor

Building Flooding

During

a routine tour of the unit

one reactor building torus area

on

July 31,

1985,

the inspector

observed

several

inches

of water

on the

floor of the northwest

corner

room.

Matet

was spraying

down from the

next higher elevation

from the control

rod drive

(CRD)

pumps.

Access

to the corner

room was not restricted

in any

manner.

One of the

CRD

pumps

was running and was observed

to have

a severe

packing leak.

The

CRD

pump

was being

used

to adjust water levels prior to removing the

refueling gate.

The unit operator

was contacted

who stated

personnel

were being dispatched

to the afea.

Later, it was

learned

that

the flood level

switch located

six inches

off the floor had alarmed in the control

room.

This is one of the

same

flood level

switches for,which

a deviation

was given for the switches

not being fully operable

nor seismically mounted.

(Report 85-36).

The

inspector

notified the

plant

manager

of his concerns

and corrective

action

was promptly taken.

b.

SBGT Charcoal

Bed Heater

Problems

The inspector

continues

to track concerns

over the

apparent

lack of

understanding

of

how the

Standby

Gas

Treatment

(SBGT) System charcoal

bed heaters

operate

and

general

preventive

maintenance

of

them.

As

discussed

in Licensee

Event

Report

( LER) 259/85-29, it was previously

not known that the

SBGT charcoal

bed heaters

needed

to

be reset after

the

SBGT

system

was

secured.

However, this information was available

on Final

Safety Analysis Figure 5.3-9,

note

six which describes

the

manual

reset.

This is

a violation of Technical Specification 6.3.A. 1

in that plant procedures

did not address

the

manual

reset

to insure

heater operation.

This violation was discussed

in an exit meeting with

plant management

on August 19,

1985.

(259,

260, 296/85-39-01).

After plant procedures

were revised

as discussed

in

LER 259/85-29,

an

operator

was questioned if the heaters

had been reset or were operating

properly.

This could not

be determined

as

no log readings

are

taken

nor is the

SBGT room routinely checked

on the operator

rounds

sheet.

Each train of heaters

is thermostatically controlled at

125 degrees

F.

If the

temperature

reaches

150

degrees

F.,

a

temperature

switch

interrupts

power

to

the

heater

and

alarms

in control

room.

The

temperature

switch must

be locally reset

in the

SBGT

room.

Train

C

only has

an additional

safety switch set at 450 degrees

F. which must

be locally reset.

No temperature

indication is provided directly for

the charcoal

beds.

Local

and

remote temperature

indication is provided

at the outlet of the bed eighteen

inches

away from the bed.

The inspector

reviewed Final Safety Analysis Report

(FSAR) page 5.3-21

and

found that it stated

the charcoal

bed temperature

is thermostati-

cally controlled with high

and

low temperature

alarms

in the

Main

Control

Room.

A review of the control circuit with plant personnel

found no low temperature

alarm.

A low alarm would have

indicated

the

system

was

not operating.

This is

a deviation

from

FSAR section

5.3.3.7,

Standby

Gas

Treatment

System

for

failure

to

have

a

low

temperature

alarm for the charcoal

bed temperature.

This deviation

was

discussed

in

an

exit

meeting

on

August

19,

1985.

(259,

260,

296/85-39-02).

In

an attempt

to determine

the status of the charcoal

bed heaters

the

following problems

were identified:

Train C-

( 1)

On August 2, 1985, four of six,

750 watt heater s were found burned

out.

Temperature

switch

TS-65-63B

(450

deg.)

had

one

set

of

contacts

which

are

in line with the

heater

power

were

welded

closed.

The annunciator

in the control

room was alarming but the

red

run light was still indicating the

heaters

were

energized.

This led to the heater

burnout.

(2)

Temperature

switch

TS-65-63B

had

previously

been

replaced

on "

July 6,

1985

as indicated

in

LER 259/85-28.

Closer evaluation

of

the

heaters

indicated

the

design

was

wrong.

The iheaters

are

located in a pipe at the bottom of, the filter bank. (Train A and

B

heaters

are distributed

throughout

the charcoal

bed.)

The sensor

for TC-65-63 (125 deg.)

and

TS-65=63A (150 deg.)

are

located

on

the opposite

side of the charcoal

beds

and

near

the

top of the

filter bank.

The

TS-65-63B

sensor

was

located directly

on

the

heater

pipe.

Apparently the heaters

would come

on and due to the

location,

the

450 deg.

switch would be tripped prior to the other

controller or switch sensing

heat

from the heaters.

Prior to the

contacts

being welded shut the only way to have the heaters

remain

operable

was to locally reset

the heaters

after

the

temperature

reached

450 degrees

F.

This fact was not

common

knowledge at the

plant.

The local reset

is inside

a cabinet in the

SBGT room and

is not labeled

on the outside of the cabinet.

The heater controls

could not be

made to function correctly.

Train B-

The temperature

control bulb ( 125 deg.)

was found not securely

mounted

and dangling next to the charcoal

bed.

The response

of the controller

was believed to be erratic depending

on the position of the bulb.

Train A-

During performance

of surveillance

instruction

on August 4,

1985,

TS

65-14 (150 deg.)

was found inoperable.

The licensee

delayed fuel off-load of unit one until problems with the

heaters

were

resolved.

On

August

8,

1985,

a

licensee

evaluation

determined that operation of the

SBGT system with the relative humidity

heaters

on for ten

hours

a month

ensures

no moisture

buildup in the

charcoal

beds.

This operation

is discussed

in

NRC Regulatory

Guide

1.52

and plant surveillance instruction

SI 4.7.B-10 implements this.

The evaluation

stated that similar charcoal

bed heaters

at Sequoyah

and

Watts

Bar nuclear plants

had

been

deenergized

because

of a potential

for

a malfunction of the heaters

causing

a fire in the absorber

bed.

This information had not been

relayed

to Browns Ferry.

The inspector

requested

from plant

management

when the information was

known at the

other

TVA facilities.

This will remain

an unresolved

item for further

review and evalution.

(259,

260, 296/85-39-03).

6.

Maintenance

Observation

(62703)

Plant

maintenance activities of selected

safety-related

systems

and compon-

ents

were

observed/reviewed

to

ascertain

that

they

were

conducted

in

accordance

with requirements.

The following items

were considered

=during

this review:

the limiting conditions for operations

were

met; activities

were

accomplished

using

approved

procedures;

functional

testing

and/or

calibrations

were

performed prior to returning

components

or

system

to

service;

quality control

records

were maintained;

activities

were

accom'-

plished

by qualified personnel;

parts

and materials

used

were

properly

certified;

proper

tagout

clearance

procedures

were

adhered

to; Technical

Specification

adherence;

and

radiological

controls

were

implemented

as

required.

Maintenance

requests

were

reviewed to determine

status of outstanding

jobs

and

to

assure

that priority was

assigned

to

safety-related

equipment

maintenance

which might affect plant safety.

The inspectors

observed

the

below listed maintenance activities during this report period:

a.

SBGT Charcoal

bed heater repair.

b.

Rework

of various

hangers

and

supports

incorrectly

designed

under

bulletins 79-02

and 79-14.

c.

Refuel activities.

d.

Cable spreading

room support inspections.

There were

no violations or deviations

in this area.

7.

Survei1

1 ance Testing

Obser vation

(61726)

The

inspectors

observed

and/or

reviewed

the

below listed

surveillance

procedures.

The inspection

consisted

of

a

review of the

procedures

for

technical

adequacy,

conformance

to technical

specifications,

verification

of test

instrument calibration,

observation

on

the

conduct

of the test,

,6

removal

from service

and return to service of the system,

a review of test

data,

limiting condition

for

operation

met,

testing

accomplished

by

qualified. personnel,

and that the surveillance

was completed at the required

frequency.

a.

SI 4.7.B-10 -

SBGT System Train Operation With Heater

On

b.

SI 4.7.B-2 - SBGT Humidity Control Capacity Test

c.

SI 4.7.B-4 - SBGT High Efficiency Particulate Activity Test

d.

SI 4.7.B-5 - SBGT Charcoal

Halogenated

Hydrocarbon Testing

e.

SI 4.7.B-6 - Iodine

Removal Efficiency

f.

SIL-40 - Operation

Section Instruction Letter, Surveillance Instruction

g.

SI 4.7.B-1

-

SBGT Operability Test (see

below)

Ouring

a routine tour of the control

room

on July 30,

1985,

the inspector

found

a surveillance

procedure

being

used

which did not contain

a recent

change

concerning

the charcoal

bed

heaters.

Surveillance

Instruction

SI

4.7.B-l,

Standby

Gas

Treatment Operability

Test,

was being

used

which did

not contain

a

change

dated July 7, -1985,

which required

the

charcoal

bed--

heaters

to

be

reset

after

system

shutdown.

The controlled

copy of the

instruction

in the

control

room contained

the

change

but

copies

of the

- instruction in

a file drawer

did not.

Operations

personnel

are instructed

by operations

section Instruction Letter SIL-40 to compare

page

by page the

file drawer

copy to the controlled

copy

to. ensure

the latest revision is

being

used.

However,

no signature verification or otherwise is required

to

indicate this has

been

accomplished.

A review of completed

SI 4.7.B-l

procedures

since

the

change

of July 7,

1985,

revealed

three out of ten

times

no

change

had

been

entered

into the

procedure.

The dates

of performance

are listed below:

7-07-85;

7-07-85;

7-08-85;

7-09"85;

7-09-85

7-11-85;

7-12-85;

7-13-85;

7-25"85;

7-25-85;

Changed

Changed

Changed

Changed

Changed

No Change

Changed

Changed

No Change

No Change

This is the

second

example of the violation against Technical Specification 6.3.A.1

(259,

260, 296/85-39-01).

In

an exit meeting

on August

19,

1985,

plant management

was informed of the violation.

8.

Reportable

Occurrences

(90712,

92700)

The

below listed licensee

events

reports

( LERs) were reviewed to determine

if the

information

provided

met

NRC

requirements.

The

determination

included:

adequacy

of event description,

verification of compliance

with

technical

specifications

and

regulatory

requirements,

corrective

action

taken,

existence

of potential

generic

problems,

reporting

requirements

satisfied,

and

the relative safety

significance of each event.

Additional

in-plant reviews

and discussion

with plant personnel,

as appropriate,

were

conducted

for

those

reports

indicated

by

an

asterisk.

The

following

licensee

event reports

are closed:

LER NO.

Date

Event

"259/85-37

7-18-85

"259/85-35

7-10-85

Containment Isolation Because

of a Blown Fuse

Secondary

Containment Isolation from a High

Radiation Alarm.

"259/85-29

6-28-85

Procedural

Deficiency - Controls Necessary

to

Ensure

Operability

of the

Standby

Gas

Treatment

System

Charcoal

Heaters

"259/85-28

7-06"85

Loss of Standby

Gas Treatment

System

The inspectors

reviewed

LER 259/85-28

and

noted

the

problem with the

'C'rain

charcoal

bed heater

high temperature

cutout switch (450 deg.

F.)

was

more

than

a

switch drift.

The

design

problem with the 'C'rain is

discussed

in paragraph five.

9.

TMI Action Items

The following action

item was

reviewed

by the inspector during this report

period:

II.K.3.28, gualification of Accumulators

on Automatic Depressurization

System

(ADS) Valves.

This item requires

the

licensee

to address

two

separate

concerns

on short-term

and long-term operability

requirements

for the

ADS valves

and accumulators.

In

a letter

from

NRR to

TVA on

July 24,

1985,

on this item,

NRC found that the modifications committed

to be comiPleted

on the

ADS system is satisfactory.

This item will be

inspected

for

long-term

operability

modifications

during

future

inspections'0.

Licensee Action on Previous

Enforcement Matters

The inspector

reviewed

a

number of open

items from Inspection

Report 84-52

regarding failures of Limitorque valve operator failures.

The licensee's

corrective actions

were detailed

in commitments

at the exit interview,

a

Response

Letter to violation 50-259,

260, 296/84-52 dated

February

13,

1985

and

a

Supplemental

Response

Letter dated

June

20,

1985 'he

licensee

has

substantially

upgraded

the maintenance

and electrical

procedures

applicable

to Limitorque operators

to ensure

proper installation of the motor pinion

gears;

and require

inspection

of these

gears

during preventative

mainten-

ance.

In addition,

a

comprehensive

three-day

Limitorque Valve Actuator

Course

has

been established

at the site for maintenance

personnel.

As part

of this

course,

Limitorque operators

are

utilized to

provide

hands-on

training

in maintenance,

repair,

and

inspection.

At the

time of this

inspection,

approximately

80 percent

of the

maintenance

personnel

respon-

sible for Limitorques

had completed this training course.

The licensee

has

also

completed

a

100 percent

inspection

of Limitorque operators

on safety

related

valves

to ensure

proper pinion gear orientation

and pinon gear set

screw tightness.

(Closed)

Violation

259,

260,

296/84-52-01:

The

licensee

has

revised

procedures

and

increased

training fo help control

assembly

of Limitorque

operators

and

has

inspected all safety related

Limitorque valve operators.

(Closed)

Inspector

Followup

Item

259,

260,

296/84-52-02:

Independent

verification

and

sign off for correct installation of the Limitorque valve

operator

motor pinion gear

has

been

added to Maintenance

Procedure

M/I-87.

(Closed)

Inspector

Followup Item 259,

260, 296/84-52-03:

Inspection of the

Limitorque motor side gearbox

and pinion gear

has

been

added to the preven-

tive maintenance

section of Maintenance

Procedure

MMI-87.

(Closed)

Inspector

Followup Item 259,

260, 296/84-52-04:

The direct current

(D.C.) Limitorque operators

for primary containment

isolation valves

have

been

added to the Outage

Shunt Field Inspection

Program.

General Electric Reports

The inspector

reviewed

a

number

of reports written

on

Browns Ferry safety

related

systems.

These reports

were generated

as

a result of a TVA initia-

tive to have General

Electric (GE) perform detailed engineering

analysis of

these

systems

and the applicable

operating

and surveillance

procedures.

Included within the

scope of these

reviews were the following:

a.

Vendor manuals

b.

FSAR

c.

GEK's

d.

Technical Specifications

e.

Design specifications

f.

System walkdowns

g.

System Information Letters (SILs) and Product Experience

Reports

(PERs)

h.

Operating

procedures

correct equipment operation

agreement

with design intent

agreement

with references

changes

that the Operations

Department

would like to make

- controlling parameters

i .

Surveillance

procedures

- review only procedures

performed

by operations

- review for operational

correctness

and conformance with

design

and technical

specifications

intent

j .

Reactor

Protection

System

(RPS) trip hi story review and analysis

Excluded

from the

scope

of these

GE systems

evaluations

were the following

areas:

a.

Abnormal operation

procedures

b.

Commitment compliance

c.

Procedure

setpoint verification--

d.

INPO SOERs

and

NRC Information Notices

and Bulletins

e.

Identification of changes

required to other procedures

or

a result of

GE recommendations

f.

Compliance of recommended

changes

to administrative

requirements

g.

Identification of training required or

a result of GE -recommendations

The inspector's

review of these

GE

system

and

procedure

reports

indicated

that they were well done

and very comprehensive.

Each report is subdivided

into several

sections

including

recommended

procedure

revisions,

walkdown

results,

operator

comments,

SIL and

PER status,

FSAR change

recommendations,

and

an overall

summary

of major

recommendations.

The

procedure

change

recommendations

were

numerous

for most

systems,

including procedural

steps

that would noi. work as written,

and

the

addition

of entire

sections

to

surveillance

procedures.

Although

not specifically required within the

scope of the

TVA-GE contact,

several

of the

engineers

also

conducted

very

detailed

walkdown of their assigned

systems.

A number of deficiencies

were

noted

on these

walkdowns, particularly

on the offgas

system.

Examples

of

the

deficiencies

included

broken

instruments,

pegged

high differential

indicators,

missing valve handles,

improper equipment installation,

missing

or improper labeling,

personnel

safety

hazards,

and burned

out indicating

lamps.

The inspectors

expressed

a concern for the status of safety related

systems

which were not walked

down to the extent the offgas

system.

J

)

10

The

inspector

encountered

substantial

difficulty in determining

who

was

coordinating

the overall resolution

to

GE

recommendations

and identified

deficiencies,

the status

of each

item,

how the

numerous

deficiencies

and

recommendations

were

being

tracked

and

how

these

results

were

being

integrated

into the

many

on-going

Browns

Ferry

programs

including

RPIP,

Operational

Readiness

Assessment,

Configuration

Management,

the

Backwork

Taskforce,

etc.

To

help

ensure

that

each

GE identified

concern

or

recommendation

receives

adequate

consideration,

whether

incorporated

or

rejected, it would

seem

beneficial

to

assign

a

unique

identifier,

a

responsible

individual,

and

a

due date for

each

item.

This

would allow

tracking and is of particular importance

where safety issues

are invalid, or

where the item is considered

necessary

for Unit 2 restart.

Another area

of

concern

was the massive

procedure

changes

recommended

by

GE including 63 on

the

HPCI operating

procedure.

With this

number of changes,

the procedures

may require testing

and additional

operator training prior to restart

of

Unit 2.

The inspector

was also concerned that since

a large

number of plant

groups

and individuals are apparently

responsible

for determining

whether

these

GE recommendations

are incorporated,

therefore,

the safety

considera-

tion for recommendations

not utilized should

be considered

and reviewed

by

plant management.

Because

these

systems

involved in the

GE study are safety related,

and there

are potential

procedural,

technical

specification,

and

equipment deficien-

cies noted,

the resolution of these

reports will be carried

as

an unresolved

item 259,

269, 296/85-39-04.

The licensee, stated

at the exit interview that

a coordinator for the

GE systems

and

procedure

reports

had

been

appointed.

The licensee

also

committed to conduct

a

PORC review of all

GE recommenda-

tions not adopted.