ML19343C634
| ML19343C634 | |
| Person / Time | |
|---|---|
| Site: | North Anna |
| Issue date: | 03/06/1981 |
| From: | Kellogg P, Tattersall A, Webster E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19343C631 | List: |
| References | |
| 50-338-80-41, 50-339-80-38, NUDOCS 8103240803 | |
| Download: ML19343C634 (11) | |
See also: IR 05000338/1980041
Text
.
p* ** Coq'o
UNITED STATES
.
l
[ y) g' g
NUCLEAR REGULATORY COMMISSION
REGION 11
~
- c;i * ;#a
o F'D
101 MARIETTA ST
N.W.. SulTE 3100
'?g ' %/
e
ATLANTA, GEORGIA 30303
'
+....
Report Nos. 50-338/80-4. and 50-339/80-38
Licensee: Virginia Electric and Power Company
P.O. Box 26666
Richmond, VA 23261
Facility Name: North Anna Units 1 and 2
Occket Nos. 50-338 and 50-339
Inspection at North Anna Site near Mineral, Virginia and Corporate Office,
Richmond,. Vi rgini a
"-
?' '-
'
N'
Inspectors:
E. H. Webste,r, Senior Resident Inspector
Date Signed
- ~
.d e, , ' r m .
- ,2
,/*.
-
-
-
.
A. P . Ta* e
1
ent Irispector
Date Signed
Approved by:
/
O&
/
'
,
P. J[ kev oVM
Chief, RONS Branen
Date Signed
$
SUMMARY.
Inspection on December 1-January 10, 1981
Unit 1 Areas Inspected
This routine inspection by che resident inspectors involved 99 inspector-hours
onsite in the areas of plant transients, .10CFR21 reports, Task Action Plan
requirements, followup of previous concerns, licensee event reports, and
l
refueling operations.
Unit 1 Findings
l
Of the six areas inspected, no violations or deviations were identified in five
areas. One violation was identified in one area (Failure to trip an inoperable
instrument within the timeframe required by the Technical Specification Action
,
Statement
paragraph 7.)
,
Unit.2 Areas Inspected
.
This routine inspection by the resident inspectors involved 113 inspector-hours
onsite in the areas of plant transients, 10CFR21 reports, Task Action Plan
requirements, followuo of previous concerns and licensee event recorts.
.
.
..
1810324 0%Q
..
_.
-
.
-
.
.
.
.
Unit 2 Findings
Of the five areas inspected, no violations or deviations were identified in four
areas. One violation was identified in one area (Failure to use procedures in
activities affecting quality
paragraph 6).
5
,
v
T4
%
%
. , - -
-
,-
,
.
.
.
'
DETAILS
1.
Persons Contacted
Licensee Employees
- W. R. Cartwright, Station Manager
- E. W. Harrell, Assistant Station Manager
D. L. Benson, Superintendent - Technical Services
"J. R. Harper, Superintendent - Maintenance
S. L. Harvey, Superintendent - Operations
J. M. Mosticone, Operations Coordinator
R. A. Bergquest, Instrument Supervisor
J. P. Smith, Engineering Supervisor
F. Terminella, Engineering Supervisor
- A. K. White, Engineer
P. Perrine, Computer Technician
M. A. Harrison, QC Engineer
C. T. Snow, Corporate Reactor Physics Engineer
Other licensee employees contacted included three technicians, four
operators, two security force members and several office personnel.
Other crganizations
P. Griffin, Lead Advisory Engineer, Stone & Webster Engineering Corp.
- Attended one or more exit interviews
2.
Exit Interview '
The inspection scope and findings were s'ummarized on December 12, 1980, and
~
January 16, 1981, with those persons indicated in Paragraph 1 above. The two
violations discussed in paragraphs 6 and 7 were discussed with and
acknowledged by plant management on December 12, 1980.
3.
Licensee Action on Previous Inspection Findings
a..- (0 pen) Infraction (338/80-29-01) Failure to place an inoperable
instrument channel in " trip" within the prescribed timeframe of the
Technical Specification " Limiting Condition for Operation".
During
followup of the licensee's corrective action, another instance of this
type was identified by the-licensee.
See Paragraph 7 for a complete
description of 'this issue.
~
(0 pen) 'Infr'ac' tion. (339/8d '28-04)~ Failiare to implement valve lineup
~
b.
procedures for instruments important to safety.
The licensee did
develop valve lineup procedures to verify transmitter isolation valve
positions and included conduct of this procedure in the plant ~startup
checklist procedure as described in his letter of September 12, 1980.
.
-
-
.
-
.
..;,
,,
.
.
.; .
.
..
.
2
h3 wever, during the Unit 2 startup of November 24-30, this procedure
was not followed. This issue is described in detail in paragraph 6.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Post Three Mile Island Task Action Plant Requirements
During this reporting period, the licensee requested relief from Unit 2
Operating License NPF-7 conditions in letter serial no. 930 dated
December 15, 1980. These conditions required task completions earlier than
allowed in NUREG 0737, " Clarification of TMI Action Plan Requirements". In
response, Amendment 2 to license NPF-7 dated December 29, 1980, changed the
required completion dates for all TMI tasks discussed in the license to
coincide with NUREG 0737 scheduling.
'
The licensee also forwarded a response to NUREG 0737, serial no. 985 dated
December 15, 1980, which establishes new commitment dates for completion of
task items for both Unit 1 and 2, to coincide with the schedule of
NUREG 0737. This report also requests completion date extensions for six
specific items, three of which were required by January 1,1981:
- Item I.C.6 program implementation - to be completed June 1,1981
'
- Item II.B.1 procedure submittal - to be completed January 1,1982
- Item II.K.3.2 report submittal - to be completed March 1,1981
The inspector verified completion of the following items due by January 1,
1981.
~
a'
Shift Technical Advisor (STA) Training Program
.
NUREG 0737 item number I.A.1.1. requires the licensee to implement an
STA training program and to have on duty STA's trained by Janaury 1,
1981. Unit .2 operating license NPF-7 condition 2.C(21)(a), further
defines the minimum requirements this training program thould meet. The
licensee further committed in their -letter, serial number 277 of
.. March 26, 1980, to a minimum STA background qi.alification of 18 months
nuclear plant experience. The inspector reviewed the background of the
six STA's who will rotate shift duties. All bJt one have engineering
degrees, and.that one has an SR0 license on be.th units. All six STA's
have greater than 18 mont.ns nuclear plant expe. ience.
.The training.progra completed December 17,1980, . involved .664 hours0.00769 days <br />0.184 hours <br />0.0011 weeks <br />2.52652e-4 months <br /> of
classroom ~ instruction in~ engineering sciences given by professors from
Virginia Polytechnic Institute; folicwed by 156 classroom hours on
North Anna systems, given by t:.e licensee training staff, and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />
'
of accident / transient analysis given by the licensee's fuel resources
division. Five days of simulater training was given at tne end of this
program and a final examination.was acministered on December 15. This
.,
-
3 .
, _
.
.
.
?
,
__
-_
. .
-
..
'
<
.
3
,
program meets the requirements of license condition 2.C.(21)(a) for
initial implementation of the STA program.
The follow-on STA training program and requalification program was
reported to the NRC in letter serial no. 1022 dated December 31, 1980.
The program described appears to be adequate, and will be reviewed in
future inspections to verify adequacy.
Followup items (338/80-38-01 and 339/80-36-01) were identified to
follow task item I. A.1.1.
In this area, the staticning and initial
training of STA's has been verified. These items remain open pending
eview of the long-term program.
b.
Performance Verification
NUREG 0737 item I.C.6 requires licensee survei' lance and maintenance
activity administrative controls be uograded :.o the requirements of
Draft 3 ANS 3.2 proposed revision to ANSI N18.7-1972 section 5.2.6. The
licensee's December 15, 1980 submittal commits to completion of this
item by June 1, 1981, and indicates that interim administrative
controls would be established by January 1,1981, to meet the intent of
this requirement.
The licensee ' established Standing Order 68 prior to January 1,1981,
which directs operations supervisors to insure redundant checks of all
safety-related equipment be performed to assure operability prior to
returning it to service after maintenance or surveillance activities.
Tne adequacy of this program as well as verification of the1 final
program, when implemented, will be completed in future inspections
under the 'already designated items (338/80-38-03 and 339/80-36-03).
6.
Protec1! ion Syst'em Transmitter' Lineups (OPEN)
Infraction 339/80-28-04_ identified an item of noncompliance where procedures
concerning the alignment of the Engineered . Safeguards (ESF) and Reactor
Protection (RPS) instrument transmitter valves had not been developed. VEPC0
letter no. 738 dated September 12, 1980, stated that 2-OP-1A "Pn Startup
Checkoff List" would be reviewed to include a requirement that the ESF and
.RPS transmitter valve lineups be completed. IMP-P-MISC-11 was developed to
implement this requirement by: (1) checking transmitters against redundant
channels when the monitored variable is on scale; or (2) verifying valve
positions for transmitters that are not on scale; or (3) verifying that the
transmitter was operating satisfactorily during previous operation and no -
maintenance had been . conducted which would affect ^the transmitter. The
VEPCO. response .further -indicated that the facility would - be in full
compliance by September 15,1980. During 'this inspection', the inspector
noted while reviewing the completed procedures covering the startup of Unit
2 during the period November 24 thru November 30, 1980, that this require-
ment had not been completed. Failure to verify the service condition of the
~
ESF. and RPS instrument transmitters.is a violation.(339/80-38-01) of 10CFR50
- Appendix B Criterion V as icylemented by-VEPCO Topical Report VEP-3-A,
-
-
. -
.,
. < . .
.
,
t
w
e
w-
--
- - -
-
-
m
A
.
.
4
" Quality Assurance Program Operations Phase" section 17.2.5 and the Nuclear
Power Station Quality Assurance Manual (NPSCAM), section
5,
in that
activities affecting quality were not accomplished in accordance with
written and approved procedures. When this matter was discussed with Station
Management, a commitment was made to complete IMP-P-MISC-11 prior to startup
from the current maintenance outage and the compleuo procedure was
subsequently reviewed.
T.S. 6.8.1.a also requires procedures to be followed.
IMP-P-MISC-11 was reviewed against station drawings to determine that all
ESF and RPS instrument transmitters were included in this verification. This
review showed that P -L'4-200 A, B, C, 0, " Containment Pressure" had not been
included.
These tiansmitters were added to the procedure by a Procedure
Deviation and included in the verification completed. The permanent change
'
to the IMP to add these transmitters will be reviewed when complete
V
(339/80-38-02).
It was also noted during this review that LT-QS-200A,B,C,0, " Refueling Water
Storage Tank" (RWST) level was not included in Technical Specification 3.3.2.1 concerning ESF instrumentation, nor were there requirements for the
automatic switchover to containment sump recirculation mode of cooling after
a Loss Of Coolant Accident in Technical Specification 3.5.2 and surveillance
requirements in 4.5.2.e(1).
This fact was discussed with the NRR Project
Manager, who is implementing a request to VEPC0 to have these Technical
Specifications modified.
This item is also applicable to Unit
1.
Completion of these changer is designated 338/80-41-01 and 339/80-38-03 and
will be' reviewed when compieted.
Procedure 2-PC-36.1 " Safety Injection
System Functional Test Breakers and Valves" conducted June 14 thru 22,1979,
did verify that the required valves did reposition to their recirculation
made upon actuation of the low low level in the RWST.
~7.
Failure to Trip llevel Bistable (OPEN)
During a previous inspection, it was determined that a protection system
channel had not been placed in a tripped condition within the specified
timeframe of being considered inoperable. This instance was identified as
an Infraction, 338/80-29-01.
VEPCO letter no. 738 dated September 12,
1980, gave the corrective action for this infraction and stated that full
compliance would be achieved by September 10,1980. During this inspection
period, the infraction and the corrective . action were being reviewed in
order to close this issue. Standing Order #1 was reviewed and it was noted
that it had been revised to emphasize the actions ts be taken when
protective channels are determined to be inoperable and that these actions
should be taken first and then an. investigation into the cause of the
fai. lure should be commenced. This revision-was the stated corrective action
for the infraction.
_
The inspector noted during the review of this item, that a recent LER No.
80-097/03LO, for Unit I reported as event similar to the initiating event
for this previvus infraction had been submitted. In the case of the event
recorted by the 'LER, the Channel I A Steam Generator (S/G) Level (LT-1474)
readinc at C200 on November it,1930,.was greater than 5% different from the
,
%
.
.
.
m
5
average of three protection system channels for A S/G level. This condition
was logged again at 0600 and 1000 on November 14, 1980. At approximately
1130 on November 14, 1980, the determination that tne channel was inoperable
was made and the protection ChannelI for S/G A level was placed in a tripped
condition. This was approximately 9h hours after the condition was first
logged, where as license NPF-4 Technical Specification 3.3.1.1.
Action
Statement 7 states that the channel must be placed in trip within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of
being determined inoperable. This sequence of events is as reported in the
LER and has been verified by review of 1-LCG-4, " Control Room Operators
Surveillance Sheets", for November 13 and November 14, and 1-LOG-11, " Action
Statement Status Log." This failure to olace the protection system channel
in trip within the specified time of being inoperable is a violation of
Technical Specification 3.3.1.1 (338/80-al-02), identified by the licensee
and this item is considered to be a repetition of the previous inTraction.
8.
Fire Doors
,
On December 15, 1980, while touring plant areas, the inspector noted that
the fire door for the 2H Emergency Diesel Generator Room did not close
automatically when released. A Maintenance Report sticker attached to the
door indicated that the door closer was broken and that a Maintenance Report
had been initiated on December 13, 1980. The inspector informed the shift
supervisor of the problem with the donc closer and that the door should be
considered inoperable and action taken as required by License NPF-7 Tech-
nical Specification 3.7.15.
The shift supervisor immediately posted a fire
watch as required and initiated a Deviation Report. In that the fire watch
was not stationed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of identifying the door as inoperable, this
is a violation of Technical Specification 3.7.15.
However, as this . item was
identified prior to the licensee's response to I.E. Report 339/80-33, this
' item is identified as another example of the . noncompliance (Infraction
'339/80-33-04) as discussed in I.E. Report 50-339/80-33.
9.
(Closed) Items (338/79-01-03 and 339/79-01-03)
Axial Power Distribution Monitoring System (APDMS) program errors - 10CFR Part 21 reports. These item numbers were previously identified to track
final resolution of two software errors identified in late 1978 and early
1979 which could result in nonconservative ' axial flux shapes existing
without detection or alarm by the on-line APDMS.
IE Report 338/79-01
~
identified corrective action steps taken by the licensee for Unit 1, which
at that time was the only operational unit at North Anna.
This inspector
reconfirmed the licensee's corrective actions for both APCMS deficiencies
for both Units 1 and 2.
.-
.
.
.
.
-
The inspector reviewed flux map traces used during the' Unit 2 startup test
program and the T(Z) calculations performed by VEPCO's Fuel Resources Group
to provide alarm setpoints .for both the APCMS and its backup "FQSURVEY"
program of the PRODAC P-250 comouter.
Fuel Resource Group crocedures for
comoutation - of the APCMS limits were reviewed and verified that limit
reduction factors of 0.985 and 0.98, respectively were applied to the
.
.
..
..
-
e
de-~
=
w
-
.
.
A
'
.
6
.
computer results to account for the APCMS two digit round-off and the
potential errors due to high background signal detected on APCMS monitoring.
The . inspector verified that the backup "FQSURVEY" program adecuately
functions to alert the operator of abnormal axial flux shapes or bad incere
data.
In a computer program checkout conducted in October 1980, the
licensee staff from the Fuel Resources Group tested the "FQSURVEY" program
on the Unit 2 computer. Their internal report, dated November 4,
1980,
verified the program functional and tested all alarm console messages. The
report verified that the "FQSURVEY" program does not round-off results, coes
subtract background signal and alarms to identify abnormally high background
signal (over 0.01) exists.
The inspector. reviewed the surveillance procedures to verify limit setpoint
inputs were properly inserted into APCMS and "FQSURVEY" program (procedure
PT-22) and verified. Further, the operator is capable of reviewing FQSURVEY
and APCMS limits at any time, to insure they are correct.
The inspector was not able to confirm licensee administrative controls of
the incore detector background levels during tnis inspection. Coen Items
(338/79-01-03 and 339/79-01-03) remains open pending review of surveillance
controls affecting incere detector performance.
10. Containment Supplementary Shielding (Closed)
On May 5, 1978, LER 78-33/0IT-0, reported that there were higher than
expected neutron dose rates being experienced at North Anna Power Station
Unit I due to streaming from the vicinity of the reactor cavity. This same
concern was identified for Unit 2 by VEPC0 letter no. 300 dated May 25,
1978, submitted in accordance with 10CFR50.55(e). Subsequently, modift-
cations were made to Unit 1 by Design Change 78-507 and to Unit 2 by
Engineering and Design-Coordination Reports (E&DCR) P-2502, 2530 thru 25300,
25778, 25779, 25785,' 40189, 40191 thru 401918 and 40195. Installation of
the hardware modifications was previously inspected as reported in IE Report
338/79-52 paragraph 5.b for Unit I and IE Report 339/79-44 paragraph 6.a for
Unit 2.
Items 338/78-14-04 and 339/78-12-02, were left open pending a
review of the radiation surveys conducted after installation of the
thielding.
During .this inspection, the following data was reviewed to
determine the adequacy of the shielding:
a.
1-SU-8, " Containment Shielding and Radiation Survey" Unit 1, dated
5/14/78, conducted at 100% power prior to shielding modifications.
b.
1-SU-8, Unit 1, dated February 7,1980, conducted at 100% power after
the shielding modifications.
'
c.
2-SU-8, Unit 2, dated October 15, 1980, conducted'at 100% after the
~
~
shielding modifications.
The results of these surveys indicate that a significant reduction in
neutron dose rates was achieved. The' insoector had no further questions
concerning this subject anc items .338/78-14-04 and 339/78-12-02 are closed.
-
.
. .
.- .
.
.
.
.
j
l
.
.
..
.
7
11.
Engineered Safeguards Logic Testing (CLOSED)
During a previous inspection, it was determined that 2-PT-36.1 " Reactor
Protection and ESF Logic Test" did not adequately record all possible
results of the testing. This item was identified as 339/80-28-08.
During
this inspection 1-PT-36.1 Revision 11 dated 7/23/80, and 2-PT-36.1 Revision
5, dated 7/23/80 were reviewed. The inspector noted that step 4.7 in botn
procedures had been modified so as to record the results of the logic test
while the Blocking Function Test Switch was in both positions of Inhibit
'
Blocks (IB) and Blocks Not Inhibit (BNI).
The inspector had no further
questions concerning this subject and item 339/80-28-08 is closed.
12. Tolerance on Test Inputs (Closed)
Items 338/80-30-04 and 339/80-29-10 identified an inspector concurn with the
failure to indicate a tolerance for test inputs in instrument functional
tests. During this inspection, Instrument Department Memorandum No. 23,
dated November 6, 1980, was reviewed. This memorandum states that test
inputs must be achieved with no tolerance. If the input can not be achieved
as stated, the test is to be suspended and the problem resolved with the
technician's supervisor. The inspector had no further questions on this
subject and items 338/80-30-04 and 339/80-29-10 are closed.
13. Qualification Records for Instrument Technicians (Closed)
During a previous inspection, the fact that contract instrument technicians
did not have qualification records was identified and designated as
inspector followup items 338/80-30-05 and 339/80-29-11.
During this
inspection, selected qualification records for contract instrument techni-
cians and VEPCO personnel were reviewed. Additionally, Instrument Depart-
ment Memorandum No. 14,. dated November 6, 1980, was reviewed. It was noted
that these records appear to be up to date and to indicate the qualification
~
of instrument personnel, a status of qualification printout is also required
and is utilized by supervisory personnel in job assignments. The inspector
had no further questions on this subject and items 338/80-30-05 and
339/80-29-11 are closed.
14. Reactor Trip and Safety Injection (CLOSED)
Licensee Event Report (LER) 80-47/0IT-0 covered the react 9r trip and safety
injection event that occurred at North Anna Power Station Unit 1 on May 23,
1980. Item 338/80-19-03 stated that further review of the
initiating
event would be conducted at a later date.
.The initiating event for this occurrence was determined to be the starting
of a Reactor Coolant Pump (RCP) on ' Unit 2 that was being powered from the
same preferred offsite power supply as an emergency bus on Unit 1.
Additionally, the IJ Emergency Diesel Generator (D/G) was paralleled to the
emergency bus undergoing testing to determine acerability. The current
,
surge. due to the starting of the RCP and the resulting voltage deco caused
the breaker to the emergency bus from tne offsite power source to trip on
z
.,.
.
.~
.
-
. .
.
a
..
.
8
reverse current. This removed a significant load from the 0/G and caused
the voltage on the emergency bus to spike high. Due to this voltage spike,
the power supply fuses to 1-VB-I-03, inverter for vital bus III, opened and
Vital Bus III de-energized. The resultant sequence is described in the LER.
This event has been reviewed by the resident inspectors and was the suoject
of a discussion on July 24, 1980, between IE Headquarters, VEPC0 corporate
engineering, Station Management and this inspector.
Based upon these
discussions and reviews, the inspectee had no further questions concerning
the initiating event and item 338/80-19-23 is closed.
Corrective action outlined in LER 80-47 was reviewed for adequacy and to
determine the state of implementation. Procedure I-0P-5.2, dated 6/25/80,
was reviewed and the cautions added concerning starting Reactor Coolant
Pumps on Reserve Station Service power were noted. Standing Order NO. 52,
which discusses starting large electrical loads when an Emergency Diesel
Generator is paralleled to the bus, Maintenance Reports NI-50-0605-2031,
2032, 2033, 2034, 2035, which replaced the control and power fuses in the
four vital AC inverters and computer inverter; and Preventative Maintenance
M-20-0/R-6 which requires replacement of the D/G governors every five years
with rebuilt governors supplied by the vendor; were reviewed. The inspector
had no further questions concerning the corrective action required by LER
80-47.
15. Record Retention
In order to- determine the calibration history of the
T/TAVG protection.
channels, it was necessary for the inspector to review the results of
1-PT-31.2.1, " Reactor Coolant System Temperature Instrumentation Calibra-
tion" (T-412) Channel
I, 1-PT-31.2.2 (T-422) Protection Channel II and
1-PT-31.2.3 (T-432) Protection Channel III. When retrieval of these PT's
was requested,_it was determined that the PT's were not in Station Records
as required. The instrumen't calibration procedures ICP-P-1-T-412, 422, 423,
which are initiated by the respective periodic test (PT) were also requested
from Station Records, but only ICP-P-1-T412 was in the vault. Discussion
with the engineer responsible for logging completion of the PT's indicated
that his records showed only 1-PT-31.2.1 and 31.2.2 as being completed.
These calibrations were required to have been done during the last Unit I
refueling outage in the fall of 1979. Continued review showed that copies
of the completed instrument calibrations were available from the Instrument
Shop. Although not the formal record, these were sufficient to show the
calibration of the protection loops had been conducted as required. The
- problems 'with retrieving the completed periodic test proceduros, the
completed instrument calibration procedures and the record of completed
periodic tests maintained by Engineering is designated as inspector followup
item (338/80-41-03).
,
, .
-
.
.
=
-
..
.
9
.
16.
Plant Tours
Tours of various plant areas were conducted during the inspection period in
conjunction with other inspection activities.
The following i tems, as
available, were observed:
a.
Fire Equipment
Operability and evidence of periodic inspection of fire suppression
equipment.
b.
Houseke'eping
Minimal accumulations of debris of maintenance of required cleanliness
'
levels in systems following testing. Cbservations regarding certain
areas were given to station management who acknowledged the inspector's
comments.
c.
Equipment Preservation
Maintenance of special preservative measures for installed equipment as
applicable.
d.
Component Tagging
Implementation and observance of - equipment tagging for - safety. or
equipment protection.
e.
Communication
Effectiveness of public system in all areas toured.
f.
Equipment Controls
Effectiveness of jurisdictional controls in precluding unauthorized
work or systems turned over for initial operations or preoperational
testing.
g. - Foreign Material Exclusion-
Maintenance of controls to assure systems which have been cleaned and
flushed are not reopened to admit foreign material.
h.
Security
lfmplementation of' security provisions for both Units.
Within the above areas, 'no violations or deviations were observed when
compared to the acolicable station program and procedures.
.
+
,;
-
.
-
,
.rV
- . we
ai
-
_
,y
'