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Category:ABNORMAL OCCURRENCE REPORTS (SEE ALSO LER & RO)
MONTHYEARML20085F6511976-04-12012 April 1976 Update to AO AO-75-15 Re Containment Air Cooler Temp Control Valve Body Failure.Spare Valve Procurement Requirement Changed from ASME Section III Stds to ANSI B31.1 Stds. Sys Built to B31.1 Std ML20085E7841975-11-14014 November 1975 Telecopy Message Ao:On 751113,CB Exhaust Valves Leaked in Excess of Total Allowable Rate Back Through Inside Valve. Valves to Be Tagged Shut Until Repaired During Next Plant Shutdown ML20085E7971975-10-30030 October 1975 Telecopy Message Ao:On 751029,interchanged W Prime Curves Resulted in Nonconservative Heat Rate Calculation for Core Limiting Assemblies.Caused by Improper Conversion of Flux to Power by Inca Power Distribution on 730619 ML20085E8231975-10-24024 October 1975 AO 75-024:on 751015,thermal Discharge of Blowdown from closed-cycle Cooling Sys Found Above Permissible Temp Limit. Caused by Shutoff Dilution Pumps During Installation of New Thermal Discharge Monitoring Equipment.Procedure Revised ML20085E8081975-10-15015 October 1975 Telecopy Message Ao:On 751015 Discharge Water Temp Exceeded Tech Spec Limits by 5 Degrees During Temp Monitoring Equipment Installation ML20085F7071975-09-19019 September 1975 Updated AO AO-74-11 Revising Analysis of Occurrence.Loss of Dc Control Power to Bus 1D Feeder Breaker 72-203 Results in Breaker Not Being Able to Operate If Equipment Malfunctions ML20085E8721975-09-18018 September 1975 Telecopy Message AOs 75-022 & 75-021:boron Concentration Found Below Tech Spec Limits & HPSI Safety Injection Valve Found W/Apparent Disc Separation.Valve MOV-3007 to Be Disassembled & Evaluated.Investigation Continues ML20085E8811975-09-15015 September 1975 Telecopy Message Aos:Safety Tank Boric Acid Concentration Found Below Tech Spec Limits & HPSI Valve MOV-3007 Failed. Further Info Will Be Submitted ML20085F7201975-09-0909 September 1975 AO 75-019:on 750830,control Rod 11 Dropped Into Core.Caused by Shorted Clutch Coil.Clutch Replaced ML20085F6891975-09-0808 September 1975 Telecopy Message of AO 75-020:on 750905,control Rod 16 Dropped.Flux Tilt & Ejected Rod Worth Resulting from Dropped Rod within Tech Spec Limits.Clutch Coil Replaced ML20085F7491975-08-28028 August 1975 AO 75-018:on 760817,control Rod 19 Dropped Into Core.Caused by Shorted Clutch Coil.Clutch Replaced.Preventive Maint,To Include Insulation & Component Resistance Measurements on Control Rod Drive Mechanisms,To Be Evaluated ML20085F7671975-08-18018 August 1975 Telecopy AO 75-018:on 750817,control Rod 19 Dropped Into Core.Caused by Shorted Clutch Coil in Control Rod Drive Mechanism ML20085F7961975-08-12012 August 1975 AO 75-016:on 750722,radwaste Batch 75-021 R Discharge Rate Exceeded.Caused by Inaccurate Flow Control Due to Water Loss in One Leg of Flow Controller FIC 1050.Radwaste Release Procedures Revised ML20085F7721975-08-12012 August 1975 AO 75-017:between 750718-28,waste Gas Decay Tank T 101C Lost Pressure.Probably Caused by Small Valve Leak.Tank Will Be Monitored During Next Period of Use Since Tests Did Not Determine Pressure Drop Cause ML20085F8731975-07-25025 July 1975 Telecopy Ao:On 750716,util Water Storage Tank T-91 Removed from Svc to Replace Liner Coating ML20085F8041975-07-24024 July 1975 Telecopy AO 75-016:radwaste Batch Discharge Rate Exceeded During Release of Radwaste Batch 75-021-R.Caused by Malfunctioning Flow Controller FIC 1050 ML20085F8631975-07-22022 July 1975 Telecopy Ao:On 750719,MOV-3011 Functioned Improperly During QO-1 Test.Caused by Failure of Spring Return Switch,Ge Type CR 2940 ML20085F3581975-07-11011 July 1975 AOs AO-75-6,AO-75-7 & AO-75-13 Have Been Canceled.Tech Specs Re Heated Discharge Do Not Apply to Svc Water Sys or Other Discharge ML20085F9101975-07-0808 July 1975 AO 75-014:on 750630,bus 1D Failed to Transfer from Station Power to Startup Power.Caused by Failure of Incoming Breaker 152-202 to Close Automatically Due to Diesel Generator Breaker 152.213 Interlock.Synchrocheck Circuitry Repaired ML20085F9271975-07-0202 July 1975 AO 75-014 & RO 75-004:on 750701,bus 1D Failed to Fast Transfer from Station to Startup Power & Control Rod 38 Deviated by 9 Inches,Respectively.Ao Caused by Faulty Auxiliary Contact.Ro Caused by Shorted Capacitor ML20085F9151975-07-0202 July 1975 Telecopy Message AO 75-014:on 750701,bus 1D Failed to Transfer from Station Power to Startup Power.Caused by Faulty Auxiliary Contact on Incoming Bus Breaker.Ro 75-004, on 750701,control Rod 38 Deviated Due to Capacitator Short ML20085F9501975-06-30030 June 1975 AO 75-013:on 750619,plant Discharge Water Temp & Heat Rate Exceeded Tech Spec Limits.Caused by Changing Lower Basin Level.Addl Operating Procedures to Be Formulated for Raising & Lowering Cooling Tower Basin Levels ML20085F9601975-06-23023 June 1975 Telecopy AO 75-013:on 750619,mixing Basin Outfall Exceeded Lake Temp Differential While Adjusting Cooling Tower Makeup to Allow Evaporation Changes.Details Will Follow ML20085F5821975-06-18018 June 1975 Updated AOs AO-21-74,AO-6-75 & AO-7-75,in Response to 750512 Request for Addl Info.Cause of Failure of Diesel Generator 1-1 Air Start Motor Not Determined ML20085F9761975-06-13013 June 1975 AO 75-012:on 750603,required Measurements & Observations Re Closed Cycle Condenser Cooling Sys Chlorination Treatment Not Performed.Caused by Incorrectly Conceived Tech Specs ML20085F9961975-06-0606 June 1975 Telecopy Message AO 75-012:on 750606,difficulty Encountered in Adhering to Tech Spec Section 3.9.7-3.9.9 Re Cooling Tower Chlorination Limits ML20085F9991975-05-30030 May 1975 Telecopy AO 75-011:on 750529,overpower Trip Setpoint on NI005 Found Out of Spec During Surveillance Test MO1 ML20085F3251975-04-28028 April 1975 AO AO-75-9:on 741223,three Reactor Trip Pressure Switches, PS-1801,PS-1802 & PS-1803 Found Out of Calibr.Caused by Use of Incorrect Procedure for Switch Calibr.Instrument Index Revised to Ref Proper Tech Spec Section ML20085F3221975-04-23023 April 1975 AO AO-10-75:on 750413,in-core Readings on Primary Data Logger Failed to Update.Caused by Deficient Software Program.Program Being Analyzed to Find & Correct Deficiency ML20085F3341975-04-18018 April 1975 Telecopy AO AO-75-8:three Containment High Pressure Switches Found Out of Calibr ML20085F3281975-04-17017 April 1975 AO AO-75-8 Has Been Canceled.Review of Temp Measuring Techniques Disclosed Temp Measurements in Error.Revised Measurements Show Discharge Temp within Allowable Limits ML20085F3771975-04-16016 April 1975 AO AO-75-7:on 750406,plant Discharge Effluent Heat Rate & Discharge Temp Increase Found Greater than Tech Spec Limits. Apparently Caused by Plant Procedure Problems & Beginning Operation of Newly Installed Closed Cycle Cooling Sys ML20085F3981975-04-14014 April 1975 AO AO-75-6:on 750404,plant Discharge Effluent Heat Rate Exceeded Tech Specs.Apparently Caused by Plant Procedure Problems & Beginning Operation of Newly Installed Closed Cycle Cooling Sys ML20085F4201975-04-11011 April 1975 AO AO-75-5:on 750411 Unsampled South Filtered Waste Tank W/Laundry Waste Released.Caused by Use of Wrong Batch Card. Tank Release Terminated Until Appropriate Analysis Could Be Made ML20085F3441975-04-0808 April 1975 AO AO-75-8:from 750406-07,indicated Temp of Mixing Basin Discharge More than 5 F Above Indicated Temp of Plant Intake Water.Caused by Excess Amount of Water Going Over Cooling Tower Pump Makeup Basin Overflow ML20085F4271975-04-0707 April 1975 Telecopy AO AO-75-5:on 750401,unsampled Liquid Waste Tank of Laundry Waste Released.Caused by Two Tank Analyses on Same Tank.Tank Release Stopped & Analysis of Tank Contents Made. Tank Released on 750403 ML20085F3881975-04-0606 April 1975 Telecopy AO AO-75-7:on 750406,plant Discharge Effluent from Mixing Basin Exceeded Tech Spec Limit.Caused by Cracking Open of Condenser Inlet Valve MOV-5301 to Reduce Hotwell Temp to Avoid Thermal Shocking Condenser Tubes ML20085F4081975-04-0404 April 1975 Telecopy AO AO-75-6:on 750404,plant Discharge Effluent Heat Rate Exceeded Tech Specs.Caused by Diversion of Dilution Water Through Unused Side of Condenser.Personnel Unaware of Difference in Temp Between Inlet Water & Basin Outfall ML20085F4511975-03-27027 March 1975 Update to AO AO-4-75,revising Analysisi of Occurrence.Util Discovered 102 restraints,12 Restraint Replacements & 74 Restraint Mods Required or Added for Addl Conservatism. Sys Studied Listed ML20085F4561975-03-17017 March 1975 AO AO-4-75:on 750307,util Determined Certain Seismic Class I Piping Sys Restraints Do Not Comply W/Fsar Design Criteria. Investigation Into Cause Underway.Sys Studied Listed ML20085F5181975-02-0404 February 1975 AO AO-2-75:on 750126,vol Control Tank Gas Lost to Auxiliary Bldg.Caused by Bank Pressure Due to Venting of Vol Control Tank Which Blew Loop Seal on Evaporator Vacuum Pump Air Water Separator ML20085F5091975-02-0404 February 1975 AO AO-3-75:on 750122,leak in Component Cooling Water to Svc Water Header Discovered.Cause Not Stated.Leak Developed 750116.Leaking Tube Plugged ML20085F5231975-01-31031 January 1975 AO AO-75-1:on 741206,allowable Leak Rate Exceeded on Purge Air Supply Valve CV-1808 During Test.Caused by Lack of Sufficient Lubricant Aggravated by Unusual Svc Condition. Packing Properly Greased & Leakage Reduced ML20085F5151975-01-28028 January 1975 AO Telecopy 75-2:on 750126,vol Control Tank Gas Lost to Auxiliary Bldg.Caused by Discharge of Orificed Recirculation Line from Vacuum Pump Back to Evaporator,Causing Erratic Evaporator Operation ML20085F5061975-01-26026 January 1975 AO 75-3:on 750122,leak Suspected in One Component Cooling Water Hx.Component Cooling Water a Isolated.Leak Developed on 750116.Caused by Leaking Tube.Tube Plugged ML20085F5361974-12-26026 December 1974 AO AO-28-74:on 741215,north Filtered Waste Tank of Laundry Waste Released W/O Prior Sampling.Caused by Technician Error.Wrong Tank Identification Wrote on Batch Card When Transposing Data ML20085F5391974-12-17017 December 1974 Telecopy AO AO-74-28:on 741215,north Filtered Waste Tank of Laundry Waste Released W/O Prior Sampling.Caused by Technician Error.Technician Wrote Down Incorrect Tank Identification on Batch Card ML20085F5471974-12-12012 December 1974 AO AO-27-74:on 741130,released to Plant Vent Stack from Waste Gas Surge Tank.Caused by Waste Gas Surge Tank Leakage, Due to Leaky Relief Valve.Valve Repaired & Pressure Tested ML20085F5521974-12-0202 December 1974 AO AO-74-27:on 741130,waste Gas Surge Tank Vented to Plant Stack.Continuous Stack Monitor Alarmed.Caused by Malfunction of Waste Gas Surge Tank Pressure Relief Valve.Total of 40 Mci Released in 3 Cubic Meters Radioactive Gases ML20085F5291974-11-18018 November 1974 Updated AO AO-24-74 Re Greater than Allowed Ph Difference Between Lake Inlet & Outlet Water.Caused by Cooling Tower Acid Injection Sys Continuing to Operate After Pump Shut Off Due to Incorrect Relocation of Sample Probe 1976-04-12
[Table view] Category:TEXT-SAFETY REPORT
MONTHYEARML18066A6901999-11-0101 November 1999 Rev 5 to Palisades Nuclear Plant Colr. ML18066A6761999-09-30030 September 1999 Monthly Operating Rept for Sept 1999 for Palisades Nuclear Plant ML18066A6271999-09-0202 September 1999 LER 98-011-01:on 981217,inadequate Lube Oil Collection Sys for Primary Coolant Pumps Was Noted.Caused by Design Change Not Containing Appropriate Level of Rigor.Exemption from 10CFR50,App R Was Requested.With 990902 Ltr ML18066A6351999-08-31031 August 1999 Monthly Operating Rept for Aug 1999 for Palisades Nuclear Plant ML18066A6771999-08-31031 August 1999 Operating Data Rept Page of MOR for Aug 1999 for Palisades Nuclear Plant ML18066A6221999-08-20020 August 1999 LER 99-002-00:on 990722,TS Surveillance Was Not Completed within Specified Frequency.Caused by Failure to Incorporate Revised Frequency Into Surveillance Schedule in Timely Manner.Verified Implementation.With 990820 Ltr ML18066A6061999-07-31031 July 1999 Monthly Operating Rept for July 1999 for Palisades Nuclear Plant.With 990803 Ltr ML18066A5201999-06-30030 June 1999 Monthly Operating Rept for June 1999 for Palisades Nuclear Plant.With 990702 Ltr ML18066A4841999-05-31031 May 1999 Monthly Operating Rept for May 1999 for Palisades Nuclear Plant.With 990603 Ltr ML18066A6371999-04-30030 April 1999 Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18068A5941999-04-30030 April 1999 Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant.With 990503 Ltr ML18066A4161999-04-0101 April 1999 Rev 4 to COLR, for Palisades Nuclear Plant ML18066A4501999-03-31031 March 1999 Monthly Operating Rept for Mar 1999 for Palisades Nuclear Plant.With 990402 Ltr ML18066A4671999-03-31031 March 1999 Rev 0 to SIR-99-032, Flaw Tolerance & Leakage Evaluation Spent Fuel Pool Heat Exchanger E-53B Nozzle Palisades Nuclear Plant. ML18068A5351999-02-28028 February 1999 Monthly Operating Rept for Feb 1999 for Palisades Nuclear Plant.With 990302 Ltr ML18066A3931999-01-31031 January 1999 Monthly Operating Rept for Jan 1999 for Palisades Nuclear Plant.With 990202 Ltr ML18066A3781999-01-20020 January 1999 LER 98-013-00:on 981222,safeguards Transfer Tap Changer Failure Caused Inadvertant DG Start.Caused by Failed Motor Contactor.Contactor Was Replaced.With 990120 Ltr ML20206F6131998-12-31031 December 1998 1998 Consumers Energy Co Annual Rept. with ML18066A3651998-12-31031 December 1998 Monthly Operating Rept for Dec 1998 for Palisades Nuclear Plant.With 990105 Ltr ML18066A3421998-11-30030 November 1998 Monthly Operating Rept for Nov 1998 for Palisades Nuclear Plant.With 981202 Ltr ML18066A3301998-11-11011 November 1998 Part 21 Rept Re Potential Safety Hazard Associated with Wrist Pin Assemblies for FM-Alco 251 Engines at Palisades Nuclear Power Plant.Caused by Insufficient Friction Fit Between Pin & Sleeve.Supplier of Pin Will No Longer Be Used ML18068A4921998-10-31031 October 1998 Monthly Operating Rept for Oct 1998 for Palisades Nuclear Plant.With 981103 Ltr ML18068A4851998-10-29029 October 1998 LER 97-011-01:on 971012,starting of Primary Coolant Pump with SG Temps Greater than Cold Leg Temps Occurred.Caused by Inadequate Procedures & Operator Decision.Sop Used for Starting Primary Coolant Pump Enhanced ML18066A3181998-09-30030 September 1998 Monthly Operating Rept for Sept 1998 for Palisades Nuclear Plant ML18066A2901998-08-31031 August 1998 Monthly Operating Rept for Aug 1998 for Palisades Nuclear Power Plant.With 980903 Ltr ML18066A3191998-08-31031 August 1998 Revised Monthly Operating Rept Data for Aug 1998 for Palisades Nuclear Plant ML18066A2831998-08-18018 August 1998 LER 98-010-00:on 980721,reactor Manually Tripped.Caused by Failure of Coupling Which Drives Feedwater Pump Main Lube Oil Pump.Main Lube Oil Pump Coupling & Associated Components Replaced & Satisfactorily Tested ML18066A2771998-08-13013 August 1998 Part 21 Rept Re Deficiency in CE Current Screening Methodology for Determining Limiting Fuel Assembly for Detailed PWR thermal-hydraulic Sa.Evaluations Were Performed for Affected Plants to Determine Effect of Deficiency ML20237E0301998-07-31031 July 1998 ISI Rept 3-3 ML18066A2701998-07-31031 July 1998 Monthly Operating Rept for July 1998 for Palisades Nuclear Plant.W/980803 Ltr ML18066A2311998-06-30030 June 1998 Monthly Operating Rept for June 1998 for Palisades Nuclear Plant ML18066A2261998-06-30030 June 1998 LER 98-009-00:on 980531,small Pinhole Leak Found on One of Welds,During Leak Test Following Replacement of Pcs Sample Isolation Valves.Caused by Welder Error.Leaking Welds Repaired ML18066A3061998-06-18018 June 1998 SG Tube Inservice Insp. ML20249C4951998-06-17017 June 1998 Rev 1 to EA-GEJ-98-01, Palisades Cycle 14 Disposition of Events Review ML18066A1781998-06-0909 June 1998 LER 98-008-00:on 980511,noted That Procedure Did Not Fully Satisfy Requirement to Test High Startup Rate Trip Function. Caused by Misunderstanding of Testing Requirements.Revised TS Surveillance Test Procedure & Reviewed Other Procedures ML18066A1711998-06-0101 June 1998 Part 21 Rept Re Impact of RELAP4 Excessive Variability on Palisades Large Break LOCA ECCS Results.Change in PCT Between Cycle 13 & Cycle 14 Does Not Constitute Significant Change Per 10CFR50.46 ML18066A1741998-05-31031 May 1998 Monthly Operating Rept for May 1998 for Palisades Nuclear Plant.W/980601 Ltr ML18066A2321998-05-31031 May 1998 Revised MOR for May 1998 for Palisades Nuclear Plant ML18068A4701998-05-31031 May 1998 Annual Rept of Changes in ECCS Models Per 10CFR50.46. ML18065B2451998-05-13013 May 1998 LER 98-007-00:on 980413,HPIS Sys Was Noted Inoperable During TS Surveillance Test.Caused by Performance of Flawed Procedure.Operators & Engineers Will Be Trained to Improve Operational Decision Making Through Resources & Knowledge ML18066A2331998-04-30030 April 1998 Revised MOR for Apr 1998 for Palisades Nuclear Plant ML18068A3461998-04-30030 April 1998 Monthly Operating Rept for Apr 1998 for Palisades Nuclear Plant.W/980501 Ltr ML18066A3411998-04-22022 April 1998 Rev 0 to EMF-98-013, Palisades Cycle 14:Disposition & Analysis of SRP Chapter 15 Events. ML18065B2071998-03-31031 March 1998 Monthly Operating Rept for Mar 1998 for Palisades Nuclear Plant.W/980403 Ltr ML20217C2741998-03-31031 March 1998 Independent Review - Is Consumers Energy Method (W Method) of Determining Palisades Nuclear Plant Best Estimate Fluence by Combining Transport Calculation & Dosimetry Measurements Technically Sound & Does It Meet Intent of Pts ML18066A2341998-03-31031 March 1998 Revised MOR for Mar 1998 for Palisades Nuclear Plant ML18068A3041998-02-28028 February 1998 Monthly Operating Rept for Feb 1998 for Palisades Nuclear Plant.W/980302 Ltr ML18066A2351998-02-28028 February 1998 Revised MOR for Feb 1998 for Palisades Nuclear Plant ML18065B1641998-02-0505 February 1998 Rev 0 to Regression Analysis for Containment Prestressing Sys at 25th Year Surveillance. ML18067A8211998-01-31031 January 1998 Monthly Operating Rept for Jan 1998 for Palisades Nuclear Plant.W/980203 Ltr 1999-09-30
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Directorate of Licensing Re: Docket 50-255 US Nuclear Regulatory Commission License DPR-20 Washington, DC 20555 Palisades Plant - A0-12-75 Gentlemen:
Attached is Abnormal Occurrence Report AO-12-75 which des-cribes deficiencies associated with chlorination treatment of the closed cycle condenser cooling system. There were no safety implica-tions associated with this occurrence.
Yours very truly, Ralph B. Sewell (Signed)
DAD /ds Ralph B. Sewell Nuclear I,1 censing Administrator CC: JGKeppler, URNRC
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ABNORMAL OCCURRENCE REPORT Palisades Plant
- 1. Report No: A0-12-75, rocket 50-255
- 2. a. Report Date: June 13,1975
- b. Occurrence Date: June 3, 1975 (Designated as Abnormal Occurrence) 3 Facility: Palisades Plant, Covert, Michigan
- 4. Identification of Occurrence: Failure to perform required measurements and observationa associated with chlorination treatment of the closed cycle condenser cooling system.
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5 Conditions Prior to Occurrence: Plant was eperating at steady-state power.
- 6. Description of Occurrence: A review of our chlorination treatment of the closed cycle condenser cooling system showed that the following require-ments of Technical Specifications 3 9.6 through 3 910 were not consistently met and that in a few cases appropriate measurements or observations were
, never taken. These requirements are:
- \ l '
a. Chlorine discharge into Lake Michigan shall not exceed 0.02 ppm (T.S. 3 9.6).
b.
Records of the following quantities for each treatment shall be kept (T.S. 3 9.8).
(1) Total quantity of chlorine compound used.
(2) The cooling tower blowdown rate.
(3) The dilution blow rate.
(4) Time of holdup of blowdown to allow chemical decomposition.
- c. Sampling of the blowdown water for chlorine prior to dilution (T.S. 3 9 9).
- d. Observation of detrimental effects due to chlorine on aquatic life (T.S. 3 9.10).
7 Designation of the Apparent Cause of Occurrence: When the present Technical Specifications were conceived, chlorine discharge to the lake was considered to be that blowdown which occurred through the " blowdown piping." This path can be controlled and terminated if desired. Recently, it has been deternined that some cooling tower water is mixing or diffusing from the pump basin into the makeup basin and, consequently, discharged over the weir into the mixing basin and lake. Originally, this discharge was
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! , considered to be service water but measurements now indicate that the LJ
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makeup discharge is a combination of both excess service water and cool-ing tower water. I Because this path for discharging chlorine was not originally recognized, measurements of the discharge were not made. Measurements now indicate 1 that the lake discharge average was about 0.01 ppm (total Cl) which is within 0.02 ppm limit for total chlorine. However, the maximum could have reached as much as 0.06 ppm (total Cl). This limit is still significantly below the NPDES permit limit of 0.5 mg/1.
Failure to meet other requirements associated with chlorination treatment of the closed cycle condenser cooling system appear to be associated with plant procedure problems and the beginning operation of our newly in-stalled closed cycle cooling system.
- 8. Analysis of Occurrence: There were no safety implications associated with this occurrence.
9 Corrective Action: Procedures are being formulated and will be instituted to insure that the Technical Specifications Requirements of 3 9.6 through 3 9.10 vill be met during the chlorination treatment of the closed cycle cooling system. While (as a part of tnis review) it was also found that certain flow and other measurements are inadequate (this topic will be the
,-~s subject of a special letter report to follow), we vill insure that the
( chloride discharge limits to the lake vill not exceed the limit of 0.02
\-' ') ppm by making appropriate conservative assumptions of the various flow rates. In addition, we are considering Technical Specifications changes which would revise the current chlorine limit to directly correspond with the NPDES permit requirement.
- 10. Failure Data: See also lear to follow discussing deficiencies relatea to the environmental monitoring program.
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