ML19305B947
| ML19305B947 | |
| Person / Time | |
|---|---|
| Site: | Crane, Beaver Valley |
| Issue date: | 02/14/1980 |
| From: | Ahearne J NRC COMMISSION (OCM) |
| To: | Thornburgh R PENNSYLVANIA, COMMONWEALTH OF |
| References | |
| NUDOCS 8003250378 | |
| Download: ML19305B947 (2) | |
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o UNITED STATES g
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WASHINGTON, D. C. 20565
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February 14, 1980 CHAIRMAN l
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i The Honorable Richard Thornburgh Governor of Pennsylvania Harrisburg, Pennsylvania 17120 f S Q
Dear Governor Th.ornburgh:
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S*iL As'~promisid in D'r. Hendrie's letter to you dat'd May 25, 1979, enclosed are s
e Inspection Reports relating to Beaver Valley and Three Mile Island Unit 1.
As you know, the NRC conducted inspections of reactors in Pennsylvania, other than Three Mile Island Unit 2, in April 1979.
These were conducted to provide
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a prompt assessment of facility operation in light of the events at Three Mile Island Unit 2.
Although I am not providing these reports as promptly as originally intended, the Three Mile Island Unit 1 report was transmitted to the Bureau of Radiological Health of the Commonwealth of Pennsylvania, Depart-ment of Environmental Resources, on June 29, 1979 and the Beaver Valley report on October 1,1979.
As a matter of general interest, I am also including copies of reports and related correspondence regarding inspections at Beaver Valley in July and August 1979.
The inspectors concluded that at the time of the inspections these facilities were in compliance with NRC safety requirements. Although items of noncompli-ance were found at Beaver Valley, these were not of direct safety concern and either have been or will be corrected by the licensee with corrective action verified by the NRC. More recently, on November 27, 1979, it was discovered that Beaver Valley Unit 1 was operated for about two hours in a condition in which part of the emergency core cooling system (ECCS) was unavailable for automatic start and injection of coolant into the reactor coolant system if the need had occurred concurrent with the loss of offsite power. As a result of this event, on December 5, 1979, the Commission issued an Order Modifying License and a Notice of Proposed Imposition of Civil Penalties.
We have i
received a reply to our letter which the staff is presently evaluating. A copy of our correspondence and the reply from Duquesne Light are enclosed.
Beaver Valley now'has a resident insnector and Peach Bottom had a resident
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' inspector at the time of Dr. Hendr':.'s May 25, 1979 letter to you.
Sincerely, 7
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'M ohn F. Ahearne
Enclosures:
(See'nextpage)
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Enclosures:
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Inspection Report 50-289/79-11 B
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April 1979)
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Inspection Report 50-334/79-09 e
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50-337/79-16; 4
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rsi3 TInspection Report E:e QI MMP @'and related correspondence W.
77e:A. (Beav'er ValTe~y'insp~ection in i
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Inspection Report 50-334/79-17
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Letter fm V. Stello to Duquesne Light
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Letter fm C. Dunn to NRC dated 1/10/80 with enclosures e
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Docket No. 50-289 Metropolitan Edison Company ATTN:
Mr. J. G. Herbein Vice President - Generation P. O. Box 542 Reading, Pennsylvania 19640 Gentlemen:
Subject:
Inspection 50-289/79-11 This refers to the inspection conducted by Mr. D. Haverkamp of this office on April 19-21, 1979 at Three Mile Island Nuclear Station, Unit 1, Middletown, Pennsylvania of activities authorized by NRC License No. DPR-50 and to the discussions of our findings held by Mr. Haverkamp with Mr. J. Seelinger of your staff on April 23, 1979 at the conclusion of the inspection.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed.with this letter. Within these areas, the inspection consisted of selective a-4nntions of procedures and representative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, no items of noncompliance were observed.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Locument Room.
If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the information, which identifies the document or part sought to be withheld, and which cone =4na a
l statement of reasons which addresses with specificity the items which will be considered by the Commission as listed in subparagraph (b) (4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in I
this regard within the specified period, the report will be placed in the Public Document Room.
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MAY 31 IS73 Metropolitan Edison Company 2
No reply to this letter is required; however, if you should have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely.
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J. Brunner, Chief Rd tor Operations and Nuclear S pport Branch
Enclosure:
Office of Inspection and Enforcement Inspection Raport Number 50-289/79-11 cc w/ enc 1:
E. G. Wallace, Licensing Manager J. J. Barton, Project Manager L. L. Lawyer, Manager - Generating Operations G. P. Miller, Manager - Generating Station - Nuclear J. L. Sealinger, Unit 1 Superintendent W. E. Potts, Unit 1 Superintendent - Technical Support I. R. Finfrock, Jr.
Mr. R. Conrad G. F. Trowbridge. Esquire Miss Mary V. Sot:uard, Chairman, Citizens for a Safe Environment (Without Report) 4
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U.S. NUCLEAR REGULATORY ColeilSSION OFFICE OF INSPECTION AND ENTORCDfENT REGION I Report No. 50-289/79-11 Docket No. 50-289 License No. DPR-50 Priority -
Category C Licensee: Metropolitan Edison Company Post Office Box 542 Reading, Pennsylvania 19640 Facility Name: Three Mile Island Nuclear Station, Unit 1 Inspection At: Middletown, Pennsylvania Inspection Conducted:
April 19 and 21, 1979 Inspector:
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D.'R vihr@p, Reactor Inffector Date Signed Approved By:
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3d[? 7 R.'R. p g,(jhief, Reactor O Data Signed Projects Section No. 1, RO&NS Branch Inspection Summarv:
Inspection on April 19 and 21, 1979 (Repor: No. 50-289/79-11)
Areas Inspected:
Routine, unannounced inspection of plant operations I
in a cold shutdown condition, including observation of control room activities and review of selected operating logs and records.
The inspection
- involved 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> onsite by one NRC regional based inspector.
Results:
No items of noncompliance were identified.
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DETAILS 1.
Persons Contacted Metropolitan Edison Company Mr. M. Beers, Shift Supervisor Mr. J. Masters, Control Room Operator
.Mr. D. P11 sitz, Shift Foreman Mr. W. Ream, ISI Coordinator Mr. M. Ross, Unit 1 Supervisor of Operations
- Mr. J. Seelinger, Unit 1 Superintendent Mr. H. Shipman, Operations Engineer / Shift Supervisor The inspector also interviewed other licensee employees during the inspection including plant operators and. general office personnel.
- Denotes those present at the exit interview on April 23, 1979.
2.
Review of Plant Operations in Cold Shutdown a.
Background
On March 28, 1979, Unit I was in hot shutdown in preparation for startup following refueling, when a reactor incident.
occurred at Unit 2.
Due to the uncertainties associated with the Unit 2 event, its impact upon Unit 1 operation, and the reduction of Unit 1 personnel. resources to support Unit 2 incident operations, plant management directed that Unit 1 be taken to cold shutdown.
The plant cool down was completed during March 29-30, 1979.
The purpose of this inspection was to verify compliance with Technical Specif1-cation requirements for cold shutdown and to determine the ability to maintain Unit 1 in a stable condition based on satisfactory completion of applicable surveillance testing.
b.
Shift Logs and Operating Records The inspector reviewed the following logs and records.
Shift Foreman Log and Control Room Log Book; dated March 28 - April 19, 1979.
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Shift and Daily Checks; dated March 28 - April 10, 1979. '
OP 1102-11. "Plent Cooldown," Revision 19, dated March 22, 1979; completed during March 29-30, 1979.
0F 1104-2, " Decay Heat Removal System," Revision 22, dated February 14, 1979 with TCNs 79-55 and-79-88; completed on March 30, 1979.
SP 1300-38 A/B, " Decay Heat Removal Ptc.p Functional
, Test and Decay Heat Removal System Valve Operability Test," Revision 8, dated January 24, 1979; completed on April 10, 1979.
SP 1300-3C, " Decay Heat Closed Cooling Water Pumps Functional Test - Recirculation Mode," Revision 0, dated September 23, 1977; completed on April 3, 1979.
SP 1300-3D, " Decay Heat River Water Pump Functional Test and Decay Heat River Valve Operability Test,"
Revision 2, dated February 6,1979 with TCN 79-92; completed on April 17, 1979.
The logs and records were reviewed to verify the following items.
The plant was taken to cold shutdown as described in paragraph 2.a.
Systems required to maintain the plant in a crable condition while in cold shutdown were demonstrated operable, based on satisfactory completion of appli-
. cable surveillance testing.
Acceptance criteria for the above review included inspector judgment and requirements of applicable Technical Specifi-l cations and facility procedures.
No items of noncompliance were identified.
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Plant Tour l
l At various times during April 19 and 21, 1979, the inspector conducted tours of the following accessible plant areas.
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Control and Service Building Turbine Building
'Centrol Room Swit'chgear Rooms Inverter and Battery Rooms The following observations and determinations were made.
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Control Room monitoring instrumentation for various components and parameters was observed on April 19, 1979, including safety and regulating group rods (fuglyinserted),decayheatremovaltemperagure (93 F), "A" DH Cooler outlet temperature (93 F),
j pressurizer temperature (85 F), pressurizer level i
l (377 inches), and reactor building pressure (14.2 Psia).
l The indicated positions of electrical power supply breakers and selected control board equipment start switches and remote-operated valves were observed.
"h1 April 19,1979, the 1A DH River Pump, DH Closed Cooling Pump, and DH Removal Pump were operating.
s The Control Board was observed for annunciators that normally should not be lighted during the existing plant conditions.
The reasons for the annunciators were discussed with control room operators.
Control Room manning was observed on several occasions during the inspection.
The shift turnover at 3:00 p.m.
March 19, 1979 was observed.
l Acceptance criteria for the above items included inspector judgment and requirements of 10 CFR 50.54(k), Regulatory l
Guide 1.114, and applicable Technical Specifications and facility procedures.
No items of noncompliance were idantified.
3.
Exit Interviev l
l The it.spector met with the licensee representative (denoted in paragraph 1) after the conclusion of the inspection on April 23, 1979.
The inspector sumuarized the purpose and scope of the inspection and the findings.
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M UNITED STATES 8
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Docket No. 50-334 SEP.2 4 197S Duquesne Light Ccmpany ATTN: Mr. C. N. Dunn Vice President Operations Division 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Gentlemen:
Subject:
Inspection 50-334/79-09 This refers to your letter dated September S,1979, in response to our letter dated August 10, 1979.
Thank you for informi.ng us of the corrective and preventive actions documented in your letter.
These actions will be examined during a subsequent inspection c1 your licensed program.
Your cooperation with us is appreciated.
Sincerely,
-~
. Brunner, Chief R ctor Operati.ons and Nuclear upport Brancit cc:
F. Bissert, Technical Assistant Nuclear R. Washabaugh, QA Manager J. Werling, Station Superintendent G. Moore, General Superintendent, Power Stations Department J. J. Carey, Nuclear Technical Assistant g
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l 'Af M Him m -sooo - e.-. Pa, September 5, 1979 United States Nuclear Regulatory Comission Attention: Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Region I 631 Park Avenue King of Prussia, Pennsylvanin 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspection Report No. 79-09
Dear Mr. Brunner:
1 ( In response to your letter of August 10, 1979 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was i included as Appendix A of the referenced Inspection Repert. The noted violation was the failure to perform a surveillance test for the Supplementary Leak Collection and Release (SCLRS) Filter Banks. If you have any questions concerning this response, please contact my office. Very truly yours, /b _ = u - C. N. Dunn Vice President, Operations Attachment i e -^f .. f ,I ?' ,[ }
,3 '.* i,i. DUQUESNE LIGHT COMPANY ~ Beavsr Valley Powcr Statica Unic No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 79-09 Letter Dated August 10, 1979 Description of Infraction (79-09-05) Technical Specification 4.7.8.1.c states, in part, "Each Supplementary Leak Collection and Release System exhaust air filter train shall be demonstrated OPERABLE:... c. At least cuce per eighteen months by:
- 2. Verifying that the air flow distribution to each REPA filter and charcoal absorber is within i 20% of the averaged flow per unit.
Technical Specification 6.8.1.c states, in part, "Writran procedures shall be established implemented and maintained covering... c. Surveillance and test activities of safety related equipment. Contrary to the above, the verification required by' Technical Specification 4.7.8.1.c.2 has not been performed since August 1975 and procedures to perform that verification have not been established or maintained as part of the licensee's surveillance test program. Corrective Action The immediate corrective action to resolve the subject noncompliance was to test the SLCRS exhaust air filter train in accordance with the technical specification requirement. This was completed on May 15, 1979. Action Taken To Prevent Recurrence The station is currently reviewing this technical specification requirement for a potential change to the eighteen (18) month performance period. Basis for this change is the ANSI N510 requirement for Airflow Capacity, Distribution and Residence Time Tests, i.e. " acceptance tests are to be made after completion of initial construction and after any major system repair or modification". Until this change is initiated, approved and incorporated into the technical specifications, air flow distribution tests will continue to be performed in compliance with the eighteen (18) month interval. This test will be added to the station Technical Specification Surveillance Procedure Scheduling List. Date On Which Full Compliance Will Be Achieved Full compliance has been achieved at this time. l l l r w w - -e -,. -,,, -, -, -,,-,,,, -w--ee-< -,, -, _ ,--,--,,,--,.-,--a-- e- , - - -.. - - -,,,,--e,--.--,~we,
h nee (. UNITE] STATES l 'o NUCLEAR REGULATORY COMMisslON ( 8 o RE! ION I g 831 PARK AVENUE I f KING OF PRUSSIA. PENNSYLVANIA 19444 k,?..@..%.o! (O M Docket No. 50-334 l Duquesne Light Company ATTN: Mr. C. N. Dunn Vice President l Operations Division 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Gentlemen:
Subject:
Inspection 50-334/79-09 This refers to the inspection conducted by Mr. D. A. Beckman of this office on April 16-24, 1979, at the Beaver Valley Power Station Unit 1, Shippingport, Pennsylvania, of activities authorized by NRC License No. DPR-66 and to the discussions of our findings held by Mr. Beckman with Messrs. J. Werling and H. Williams of your staff at the conclusion of the inspection. ~ Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance has been categorized into the levels as described in our correspondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," l Part 2. Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this (1) corrective notice, a written statement or explanation in reply including (:2) corrective steps which have been taken by you and the results achieved; steps which will be taken to avoid further items of noncompliance; and (3) the date when full _ compliance will be achieved. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor) believe to be proprietary, it bus ch / 7 / O O 7 C7 C C ~
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AUG 101979 Duquesne Light Company 2 is necessary that you make a written application within 20 days to this office to withhold such information from public disclo ure. Any such application must be accompanied by an affidavit executed by the owner of the infonnation, which identifies the document.or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Comission as listed in subparagraph (b)(4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. l Sincerely, l a t Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch
Enclosures:
1. Appendix A Notice of Violation 2. Office of Inspection and Enforcement Inspection Report Number 50-334/79-09 cc w/encls: l F. Bissert, Technical Assistant Nuclear R. Washabaugh, QA Manager J. Werling, Station Superintendent G. Moore, General Superintendent, Power Stations Department 1 J. J. Carey, Nuclear Technical Assistant 1
APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 Based on the results of an NRC inspection conducted on April 16-24, 1979, it appears that one of your activities was not conducted in full complianc6 with the conditions of your NRC License No. DPR-66 as discussed below. This item is an infraction. Technical Specification 4.7.8.1.c states, in part, "Each Supplementary Leak Collection and Release System exhaust air filter train shall bs demonstrated OPERABLE:... c. At least once per eighteen months by:
- 2. Verifying that the air flow distribution to each HEPA filter and charcoal absorber is within + 20% of the averaged flew per unit.
Technical Specification 6.8.1.c states, in part, " Written procedures shall be established, implemented and maintained covering... c. Sur-veillance and test activities of safety related equipment. Contrary to the 'above, the verification required by Technical Speci-fication 4.7 8.1.c.2 has not been performed since August 1975 and procedures to perform that verification have not been established or maintained as part of the licensee's surveillance test program. bo h / 3 / co yc75 4 v
U.S. NUCLEAR REGULATORY COMMISSION. OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-334/79-09 Docket No. 50-334 License No. DPR-66 Priority: Category: C Licensee: Duquesne Light Company 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 1 Facility Name: Beaver Valley Power Station, Unit 1 Inspection at: Shippingport, Pennsylvania j Inspection condu l: pri 1,-24, 1979 Inspectors: bi. f-G~~}9 or it x s n 'Df' A4 3eckma'n, Reactor Inspector date signed s As%Ad e-r-- n l R. S. Markowski, Reactor Inspector date signed 10-- 7-V-M C. d. Co~ gin 1, Reactor Inspector date signed Approved by: 8 k i . R.' Keim Reactor Pr'W Ihief dpesiigned ets S. ion No. 1, RO&NS Branch Inspection Summary: l Inspection on April 16-24,1979 (Recort Mo'. 50-334/79-09 Areas Inspected: Routine announced inspection by regional based inspectors of actions taken by the 11 l Three Mile Island; to veri ations for the existing plant cond ing to the incident at Three Mi DUPLICATE DOCUMENT Power Station, Unit 1. The ee regional based inspectors. Entire document previously entered into system under: r. fM $$7ff O O nuo No. of pages: O
UNITED STATES p
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[ cEGION i g d _,, g S3I PARK AVENUE v y2 MING OF PRUS58A. PENNSYLVANIA 19444 k'C%/ g OCT 2 a 575 ' Jocket No. 50-334 Duquesne Light Company ATTN: Mr. C. N. Dunn Vice President Operations Division 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Gentlemen:
Subject:
Inspection 50-334/79-16 This refers to your letter dated October 10, 1979, in response to our letter dated September 18, 1979. Thank you for infoming us of the corrective and preventive actions documented in your letter. These actions will be examined during a subsequent inspection of your licensed program. Your cooperation with us is appreciated. Sincerely, El o U. Brunner, Chief Re etor Operations and Nuclear S'upport Branch cc: F. Bissert, Technical Assistant Nuclear R. Washabaugh, QA Manager J. Werling, Station Superintendent i G. Moore, General Superintendent, Power Stations Department l J. J. Carey, Nuclear Technical Assistant R. Martin, Nuclear Engineer l los ef~ 7 7 / /A a a / R c 1
9 y 'Af M p m m.sooo T~ October' 10, 1979 United States Nuclear Regulatory Commission Attention: Mr. Eldon J. Brunner, Chief Reactor Operations and Nuclear Support Branch Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspection Report No. 79-16
Dear Mr. Brunner:
In response to your letter of September 18, 1979 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A of the referenced Inspection Report. The noted violation was the failure to properly implement procedures for jumper and lifted lead control. If you have any questions concerning this response, please contact my office. .Very truly yours, h:~ Vice President, Operations Attachment J b !J O t,
u,, i DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 REPLY TO NOTICE OF VIOLATION Inspection No. 79-16 Letter Dated September 18, 1979 Description of Deficiency (79-16-01) Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below:
- a. The applicable procedures recomu nded in Appendix A of Regulatory Guide 1.33, November 1972..." Regulatory Guide 1.33, Appendix A, identifies the following as a typical safety re',ated activity which should be covered by written procedures:
"A.10 Bypass of Safety Functions and Jumper Control". The BVPS Operating Manual, Section 1.48.5.D.2.b, requires, in part, that each entry in the Jumper and Lifted Lead log include the fellowing: "(3) Elementary Control Schematic number where the jumper or lifted lead effact on the cor. trol circuit can be seen. (5) The reason jumper placed or lead lifted with sufficient information to clearly identify location on the schematic. ... (7) The location of jumper or lead (breaker compartment / panel board)..." 1 l l Contrary to the above, on July 11, the following active Jumper and Lifted Land log entries, listed by Tag Number, did not comply with one or more of the above requirements of the BVPS Oparating Manual: Tag Numbers 1519-1520, 1792-1793, 1834-1837, 1863-1865, 1965-1967, 2065-2069, 2080-2087, 2106-2118, 21:?6-2137, and 2158-2170. Discussion Of Deficiency It is agreed that in some cases the tags did not contain all the information required by the BVPS Operating Manual. However, it was demonstrated to the auditor at the time of the inspection that sufficient information was available, when utilized with indexes and drawings available to the shift supervisor, that all tags were adequately described as to not constitute an unsafe condition. Since accountability was provided the intent of the log was fulfilled. Corrective Action A review of the Jumper and Lifted Lead Log was initiated to verify compliance with Chapter 48 of the BVPS Operating Manual. Action Taken To Prevent Recurrence The administrative requirements concerning the maintenance of this log will be reassessed and Chapter 48 of the BVPS Operating Manual will be revised accordingly. Dace On Which Full Compliance Will Be Achieved Full compliance will be achieved by October 15, 1979. l
UNITED STATES f NUCLEAR RESULATORY CcMMisslON y naanon a g j M1 PARK AVENUE je u nine or poussia.esansvi.vania suos \\,..ov/ Docket No. 50-334 SEP 18 1979 Duquesne Light Company ATTN: Mr. C. N. Dunn Vice President Operations Division 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 Gentlemen:
Subject:
Inspection 50-334/79-16 This refers to the inspection conducted by Mr. D. Beckman of this office on July 2-6 and 10-13,1979, at Beaver Vallay Power Station Unit 1, Shippingport, Pennsylvania, of activities authorized by NRC License No. DPR-66 and to the discussions of our findings held by Mr. Beckman with Mr. J. Werling and others of your staff at the conclusion of the inspection. Areas examined during this inspection are described in the Office of ~ Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. l Based on the results of this inspection, it appears that one of your activities l was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. This item of noncompliance has been categorized into the levels as described in our correspondence to you dated December 31, 1974. This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2. Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office, within twenty (20) days of your receipt of this l notice, a written statement or explanation in reply including (:(1) corrective steps which have been taken by you and the results achieved;
- 2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures will be placed in the NRC's Public Document Room. If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this F ,Qu p of _/ f / / ( 7 0 / V / I
Duq0esne Light Company 2 office to withhold such information from public disclosure. Any such application must be accompanied by an affidavit executed by the owner of the informtion, which identifies the document or part sought to be withheld, and which contains a statement of reasons which addresses with specificity the items which will be considered by the Comission as listed in subparagraph (b)(4) of Section 2.790. The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Roem, Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, f3 1 n . Brunner, Chief Re tar Operations and Nuclear Support Branch
Enclosures:
1. Appendix A. Notice of Violation 2. Cffice of Inspection and Enforcement Inspection Report Number 50-334/79-16 cc w/encis: F. Bissert, Technical Assistant Nuclear R. Washabaugh, QA Manager J. Werling, Station Superintendent G. Moore, General Superintendent, Power Stations Department J. J. Carey, Nuclear Technical Assistant i i
APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 Based on the results of an NRC inspection conducted on July 2-13, 1979, it appears that one of your activities was not conducted in full compliance with the conditions of your NRC License No. DPR-66 as discussed below. This item is a deficiency. Technical Specification 6.8.1 states, in part, " Written procedures l shall be established, implemented and maintained covering the activities referenced below:
- a. The applicable procedures recormnended in Appendix A of Regulatory Guide 1.33, November 1972..."
Regulatory Guide 1.33, Appendix A, identifies the following as a typical safety related activity which should be covered by written procedures: "A.10 Bypass of Safety Functions and Jumper Control". The BVPS Operating Manual, Section 1.48.5.D.2.b, requires, in part, that each entry in the Jumper and Lifted Lead 1og include the following: "(3) Elementary Control Schematic number where the jumper or lifted lead effect on the control circuit can be seen. ... (5) The reason jumper placed or lead lifted with sufficient infonnation to clearly identify location on the schematic. ... (7) The location of junper or lead (breaker compartment / panel board)... Contrary to the above, on July 11, the following active Jumper and Lifted Lead Log entries, listed by Tag Number, did not comply with one or more of the above requirements of the BVPS Operating Manual: Tag Numbers 1519-1520, 1792-1793, 1834-1837, 1863-1865, 1965-1967, 2065-2069, 2080-2087, 2106-2118, 2136-2137, and 2158-2170, i l l l p j l m M
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Rep 3rt No. 50-334/79-16 Docket No. 50-334 License No. DPR-66 Priority ' Category C Licensee: Duquesne Light Company 435 6th Avenue Pittsburgh, Pennsylvania 15219 Facility Name: Beaver Valley Power Station Unit 1 Inspection at: Shippingport, Pennsylvania Inspection conducted: July 2-6 and' 10-13,1979 bS. ddc./&i 2l74 7 Inspectors: l D. A. Beclanan, Reactor Inspector date signed date signed Approved by f/ <R'.R.Kei5iigNhief,ReactorProjects / date sig'ned Sution No.1, RO&NS Branch Insoection Summary: Inspection on July 2-6, ~anc 10-13, 1979 (Recort No. 50-334/79-16) Areas Inspected: Routine, unannounced inspection,.beginning on a backshifti 'of licensee action on previous inspection findings, followup on licensee event reports, review of licensee periodic reports, action in response to IE Bulletins and Circulars, review of plant operations, followup on loss of RHR flow events, review of administrative controls, and review of a 10 CFR 21 report. The inspection involved 78 hours onsite by one NRC regional based inspector. Results: Of the eight areas inspected, no items of noncompliance were identified in sevsn areas. One item of noncompliance was to maintain Jumper and Lifted Lead Log, par DUPLICATE DOCUMENT n l(,f, 1-6f Entire document previously ~ / / entered / !! ystem under: nto s f-ANO Region I Form 12 No. of pages: .(Rev. April 77)
9e UNITED STATES / NUCLEAR RE2ULATORY COMMiss12N neosos i g E $31 PARK AVENUE
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"%f.. fit,/ NOV s1979 Docket No. 50-334 Ouquesne Light Company ATTN: Mr. C. N. Dunn Vice President Operations Division 43S Sixth Avenue Pittsburgh, Pennsylvania 15219 Gentlemen:
Subject:
Inspection 50-334/79-17 This refers to your letter dated October 29, 1979, in response to our letter dated October 1, 1979. Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a subsequent inspection of your licensed program. Your cooperation with us is appreciated. Sincerely, C =w W. l Boyce H. Grier rector cc: F. Bissert, Technical Assistant Nuclear R. Washabaugh, QA Manager J. Werling, Station Superintendent G. Moore, General Superintendent, Power Stations Department J. J. Carey, Nuclear Technical Assistant R. Martin, Nuclear Engineer 3 I' ,) [ N
NOV 6 1979 Duquesne Light Company 2 bec: IE Mail & Files (For Appropriate Distribution) Central Files Public Document Room (PDR) Local Public Document Room (LPDR) (NSIC) Nuclest Safety Infonnation Center Technical Information Center (TIC) REG:I Reading Room Connonwealth of Pennsylvania l i
l M4 'Af M p m 4s64000 436 Semm Avenue $2 October 29, 1979 United States Nuclear Regulatory Commission Attention: Boyce H. Grier, Director Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR-66 IE Inspection Report No. 79-17
Dear Mr. Grier:
In response to your letter of October 1, 1979 and in accordance with l 10 CFR 2.201, the attached reply addresses the Notice of Violation which was i l included as Appendix 4 of the referenced Inspection Report. The noted violations included: (1) the failure to implement procedures, (2) the perfermance of operating and maintenance activities without a properly approved procedure, and (3) the use of measuring and test equipment which has passed its calibration date. ) Duquesne Light Company shares your concerns about the implenentation of the 1 management control systems that permitted these violations to occur. In addition to the actions noted in the attached reply, a letter has been issued to the l plant staff expressing management's concern about the occurrance and handling of situations which have resulted in recent noncompliances. If you have any questions concerning this response, please contact my office. Very truly yours, ...h l .m. t C. N. Dunn Vice President, Operations l Attachment DUPLICATE DOCUMENT p Entire document previously -L_ entered into system under: ANO h/MMM No. of pages:
' APPENDIX A ' NOTICE OF~ VIOLATION Duquesne Light Company Docket No. 50-334 Based on the results of an NRC inspection conducted August 20-24, 1979, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Facility License No. DPR-66, as indicated below. l These items are infractions. A. Technical Specification 6.8.1 states, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below: (a) The. applicable procedures recommended in Appendix "A" of Regu-latory Guide 1.33, November,1972...," and "(c) Surveillance and test activities of safety related equipment..." Regulatory Guide 1.33, Ouality Assurance Requirements (Operation}, November,1972, recomends that the following typical safety related activities be covered by written proce-l dures: ...A.3 Equipment Control (e.g. locking and tagging)... B.2 Nuclear Startup to Minimum Load..." The BVPS Operating Manual, Section 1.50.3, Startup Checklist D, Revision 7, requires, in ;: art, verification that "...(3) An estimated critical position and boron concentration has been calculated in accordance with Procedure F, " Estimated Critical Position Calculations" of this chapter and associated data sheets..." The BVPS Operating Manual, Section 1.55A.1, Periodic Checks - Operating Surveillance, Subsection 1, Revision 3, states, in part, "...The Shift Supervisor will, within 24 hours, review the test for proper perfonnance and documentation and record any evaluation required..." The BVPS Operating Manual Section 1.48.5.C.2, Use of Padlocks on Operating Equipment, Revision 3, states, in part, "...(b) BVPS Operations Padlocks may be used to lock valves... that are infrequently operated or, if impro-perly operated could cause equipment damage or upset which might require considerable time and expense to recover from... These padlocks will only be removed by permission of the Station Operating Foreman or Shift Super-visor..." The Operating Valve Lists of the BVPS Operation Manual, Sections 1.7.3, Revision 7; 1.24.3, Revision 6; and,1.30.3, Revision 5, require that valves 1-CH-26,1-RW-98, and 1-FW-57 be locked as part of the nonnal l system alignment. The official Padlock Log also lists these valves as being locked open. Contrary to the above requirements: The estimated critical p and 19,1979, were not p DUPLICATE DOCUMENT Entire document previously entered into system under: M/D ANO I No. of pages: hT
o UNITED STATES 8 '. NUCLEAR REGULATORY COMMISSION o g WASMNGTON, D. C. 20555 7, l v DEC 0 51929 Docket No. 50-334 l Duquesne Light Company ATTH: Mr. Stanley G. Schaeffer President i 435 Sixth Avenue Pittsburgh, Pennsylvania 15219 1 Gentlemen: On Novembe'r 27, 1979, the Beaver Vr' ley Power Station, Unit 1, was operated for about two (2) hours in a condition which exceeded the Limiting Condition for Operation. This matter was brought to the attention of our inspector at your facility in a tithely fashion, and your subsequent action to correct the condition was expeditious. Nevertheless, this condition rendered a part of the emergency core cooling system (ECCS) unavailable for automatic start and injection of coolant into the reactor coolant system (RCS) if the need had occurred concurrent with the loss of offsite power (the design basis). This unavail-ability of ECCS constitutes a serious matter which reveals an apparent weakness in your control of maintenance and essential equipment. Therefore, we propose to impose a civil penalty for the item of noncompliance set forth in Appendix A to this letter in the amount of $5,000. Appendix B is a Hotice of Proposed Imposition of Civil Penalties. You are required to respond to this letter and in preparing your response, you should follow the instructions in Appendices A and B. In addition to the civil penalty, we are issuing the enclosed Order (Appendix l C) effective immediately. This Order requires that your administrative control of licensed activities involving operating and maintenance of safety equipment verifies availability of all required equipment when a counterpart is removed from an operable status. This Order further requires that you formally review and report your actions to prevent recurrence. It also requires that you meet publicly on January 25, 1980, with the Director, Office of Inspection and Enforcement, at a location near the Beaver Valley Power Station, to discuss your evaluation of this condition and your corrective actions to prevent l recurrence. We will infonn you of the location and time of the meeting. In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures i s
- f.,
a u; ac j y/ g g' o o c, I x m. b V
DEC 0 5 C9 Duqu:sne Light Company - will be placed in the Comission's Public Document Room. Sincerely, ) td S 1 o, r/ Director Office of Inspection and Enforcement
Enclosures:
1. Appendix A, Notice of Violation 2. Appendix B, Notice of Proposed Imposition of Civil Penalties 3. Appendix C, Order Modifying License. cc: C. N. Dunn, Vice Dresident, Operations Division F. Bissert, Techu' cal Assistant Nuclear R. Washabaugh, Q Manager J. Werling, Stat.on Superintendent G. Moore, General Superintendent J. J.. Carr;y, Nuclear Technical Assistant R. Ma.-tin, Nuclear Engineer l L j m m
DEC 0 51979 APPENDIX A NOTICE OF VIOLATION Duquesne Light Company Docket No. 50-334 ) Pittsburgh, Pennsylvania 15219 License No. DPR-66 This refers to the inspection conducted by the NRC Resident Inspector at the Beaver Valley Power Station, Unit 1, of activities authorized by NRC License No. DPR-66. During the inspection conducted on November 27, 1979, the following item of noncompliance was identified. Technical Specification 3.5 2 states that with the plant in Mode 1 (Power Operation), two separate and independent ECCS subsystems shall be operable, l and further states in section 3.5.2.c that each subsystem shall include an operable flow path capable of taking suction from the refueling water storage 1 tank upon initiation of a safety injection signal. Technical Specification 1.6 defines " operable" to include the assumption that all necessary attendant instrumentation, controls, electric power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component or device to perform its function (s) are also capable of performing their related safety function (s). Contrary to the above, on November 27, 1979, from approximately 8:30 a.m. to 10:30 a.m., maintenance activities rendered both ECCS subsystems inoperable in that a) refueling water storage tank isolation valve MOV-CH-ll5D was closed and incapable of automatic opening in response to a safety injection signal, and b) refueling water storage tank isolation valve MOV-CH-ll58, in the redundant subsystem, was closed, had no emergency power available, and thus was incapable of automatic opening in response to a safety injection signal if there had been a condition of loss of offsite power. This violation had the potential for causing or contributing to an occurrence related to health and safety (Civil Penalty $5,000). l m l of 7 r O c./ m s ,;,-) e-ao f y s I =
DEC 0 51979
- APPENDIX B NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Duquesne Light Coc:pany Docket No. 50-334 Pittsburgh, Pena:,ylvania 15219 License No. DPR-66 This office has considered the enforcement options.available to the NRC including administrative actions in the fom of written notices of viola-tion, civil monetary per.alties, and orders pertaining to the modification, suspensica or revocation of a license.
Based on these considerations, we propose to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as anended, (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount of Five Thousand Dollars ($5,000) fo the specific items of noncompliance set forth in Appendix A to the cover letter. In proposing to impose. civil penalties, the factors identified in the Statements of Consideration published in the Federal Register with the rule-making action which adopted 10 CFR 2.205 (36 FR 16894) August 26, 1971, and the " Criteria for Deter:aining Enfercecent Action", which was sent to NRC licensees on December 31, 1974, have been taken into account. Duqueshe Light Cocpany cay, within twenty (20) days of the receipt of this notice pay the civil penalties in the cumulative amount of Five Thousand Dollars (55,000) or may protest the imposition of the civil penalties in whole or in part by a written answer. Should Duquesne Light Company fail to answer within the tice specified, this office will issue an order imposing the civil penalties in the amount proposed above. Should Duquesne Light i Company elect to file an answer protesting the civil penalties, such an answer may (a) deny the itecs of noncompliance listed in the Notice of Violation in whole or in part, (b) demonstrate extenuating circumstances, (c) show error in the Notice of Violation, (d) show other reasons why the penalties should not be imposed. In addition to protesting the civil penal-ties in whole or in part, such answer may request remission or mitigation of the penalties. Any written answer in accordance with 10 CFR 2.205 should be set forth separately frem the statement or explanati-in reply pursuant to 2.201, but may incorporate by specific reference W.g., giving page and paragraph numbers) to avoid repetition. Duquesne Light Cocpany's attention is directed to the other provisions.of, l 10 CFR 2.205 recarding, in particular, failure to answer and ensuing orders; answer, consideraticn by this office, and ensuing orders; requests for hearings, hearings and ensuing orders; compromose, and collection. Upon failure to pay any civil penalty due which has been subsequently deter-mined in accordance with the applicable provisions of 10 CFR 2.205, the matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or c:itigated, may be collected by civil action pursuant to Section 234.c of the Atomic Energy Act of 1954, as amended (42~ USC 2282). L l [ e
APPENDIX C UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION In the_ Matter of ) ) DUQUESNE LIGHT COMPANY ) Docket No. 50-334 (Beaver Valley Power Station, Unit 1) ) ORDER MODIFYING LICENSE EFFECTIVE IMMEDIATELY I The Duquesne Light Company (the " licensee") is the holder of Operating License DPR-66 (the " license") which authorizes operation of the Beaver Valley Power Station, Unit 1, at steady tate reactor core power levels not in excess of 2652 megawatts thermal (rated power). The license was issued on January 30, 1975. 'The facility consists of a pressurized light water moderated and cooled rea: tor (PWR), located at the licensee's site in Beaver County, Pennsylvania, on the southern shore of the Ohio River. II On November 27, 1979, from about 6:30 AM to 1:20 PM while the reactor was operating at about 30% of rated power, Emergency Diesel Generator (EDG) I was out of service for routine caintenance. This EDG supplies emergency power to suction valve, MOV-CH-1158, in the line from the refueling water storage tank (RWST) to the High Pressure Safety Injection System (HPSIS) pemps. In addition to the EDG be'ng out of service, resulting in loss of one Emergency Core Cooling System (ECCS) flow path, as described above, the redundant suction valve, MOV-CH-1150, was removed from service for maintenance which resulted in loss of the redundant ECCS flow path from the RWST from 8:30 a.m. to 10 30 a.m. During this time the facility was operated in noncompliance with the Li nitiri Condition for Operation specified in Technical Specification 3.5.2.c. TM: condition resulted from inadequate control of maintenance activities and its ap d '7 y /2 O c 6 G 7 L.
Appendix C '. occurrence suggests that the licensee has not adopted appropriate controls to assure that maintenance activities do not defeat required safety features. ' This in turn undermines the basis for determining that there is reasonable assurance that redundant safety features will function under design basis conditions. In view of the significance to safety of adequate controls to assure that maintenance activities do not defeat required safety features, I have deter-mined that the public health, safety, or interest requires, effective immediately, modification of License No. DPR-66 as stated in Part III of this Order. III-Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50, License DPR-66 is modified as follows: (1) Administrative Procedures shall be adopted and implemented to require redundant independent verification of the operability of the remaining engineered safety fe;tures whenever any safety system, or subpart thereof, is intentionally removed from service. (2) A detailed review of existing procedures and controls shall be performed to assure that limiting conditions for operation are not defr '.ed by maintenance or other activities. (3) A report of the administrative procedures required by paragraph (1) above and the detailed review required by paragraph (2) above shall be submitted by January 11, 1980, to the Director of NRC's Region I office. l s
Appendix C * (4) The licensee shall meet. with the Director, Office of Inspection and Enforcement, on or before January 25, 1980, in a meeting open to the public in the vicinity of the Beaver Valley site to describe how the above requirements will be implemented. The Director, Region I, will inform the licensee at least one week in advance of the specific time and location of the meeting. IV The licensee, or any other person who has an interest affected by this Order, may, within twenty-five days of the date of this Order, request a hearing. A reques,t for a hearing shall be addressed to the Director, Office of Inspection and Enforcement, U.S.N.R. C., Washington, D. C. 20555. If a hearing is requested by the licensee or an interested person, the Commission will issue an Order designating the time and place of hearing. Such a request for hearing SHALL NOT STAY THE IMMEDIATE EFFECTIVENESS OF THIS ORDER. Resumption of operation on terms consistent with this Order is not stayed by the pendency of any proceeding on this Order. In the event that a need for further enforcement action becomes apparent, either in the course of any proceeding on this Order or at any other time, the Director will take appro-priate action. V In the event the licensee or any other interested person requests a hearing as provided above and a hearing is held, the issues to be considered at such a hearing shall be: 1 s' V
\\ Appendix C - (1) whether the facts set forth in Part II of this Order are correct;
- and, (2) whether this Order should be sustained.
FOR THE NUCLEAR REGULATORY COMMISSION Victor Stell V r. Director Office of Inspection nd Enforcement Dated at Bethesda,bber,1979. Maryland this 33P5 day of i O e
4 l Tf A (412) 456-6000 435 Sixth Avenue Pittsburgh, Pennsylvania is2is January 10, 1980 United States Nuclear Regulatory Commission Attention: Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement Washington, D.C. 20555 Re'ference: Beaver Valley Power Station, Unit No.1 Docket No. 50-334 Response to December 5,1979 Order Modifying License
Dear Mr. Stello:
The attached report is submitted in accordance with the Order which accompanied your letter of December 5,1979 to Mr. S. G. Schaffer relating to the exceeding of a Limiting Condition for Operation which occurred on November 27, 1979. Pursuant to Section III, paragraph (3) of the Order Modifying License forwarded as Appendix C to the aforementioned NRC letter, a report describing 1) the new administrative procedures which have been adopted to require redundant, independent verification of the operability of the remaining engineered safety features whenever any safety system, or subpart thereof, required by the Limiting Conditions for Operation is intentionally removed from service, and 2) the review of existing procedures which has been performed to assure that Limiting Conditions for Operation are not defeated by maintenance or other activities, is forwarded herewith. This report also describes other actions taken by Duquesne Light Company to prevent recurrence of this or any similar incident. Very truly yours, bO- / C. N. Dunn Vice President, Operations Attachment D. P x s Q Q .J O a( DUPLICATE DOCUMENT Entire document previously entered into system under: ^No. FACGt02/go.. i ( No. of pages: h i
l-l. DUQUESNE LIGHT COMPANY Power Stations Department l l l -~ b O db c i REPORT ON THE REVIEW NO ESTABLISHMENT OF ADMINIST nTIVE PROCEDURES TO PROVIDE REDUNDANT, INDEPENDENT VERIFICATION OF OPERABILITY OF l l ENGINEERED SAFETY FEATURES i Prepared By: V DUPLICATE DOCUMENT e Entire document previously entered into system under: ANO h / No. of pages: [ - -. - - -}}