ML20133B654

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Annual 10CFR50.59 Rept 950701-960630 for Lgs,Units 1 & 2
ML20133B654
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 06/30/1996
From:
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701060064
Download: ML20133B654 (25)


Text

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Robert W.Boycs  ;

., Plant Manager l g , Lmerick Generating Staten w ,

PECO NUCLEAR esco energv companx Lrnerick Generating Station A Unit of PECO Energy PO Box 2300 t

, Sanatoga. PA 19464-0920 1 610 718 2000 l

l December 30, 1996 1

Docket Nos. 50-352 50-353 )

License Nos. NPF-39 i

NPF-85 U.S. Nuclear Regulatory Commission Attn
Document Contrel Desk i uashington, DC 20555 t

SUBJECT. Limerick Generating Station, Units 1 and 2 l Annual 10CFR50.59 and Commi; ment Revision Report  :

for the period July 1, 1995 through June 30, 1996 Attached is the Annual 10CFR50.59 Report as required by l 10CFR50.59(b), Additionally, this report provides a summary ,

of revisions to commitments previously made to the NRC as '

recommended in the NEI Commitment Management Guideline.

i l If you have any questions or require additional information, l l please contact us.

l l

Sincere y,

  1. ve-R. W. Boyce DBN:bdd cc: H. J. Miller, Administrator Region I, USNRC N. S. Perry, USNRC Senior Resident Inspector, LGS l

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I 9701060064 960630 PDR ADOCK 05000352 R PM

PECO ENERGY PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT REVISION REPORT JULY 1,1995 THROUGH JUNE 30,1996 LIMERICK GENERATING STATION f

o

PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 ANL) 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT REVISION REPORT JULY 1,1995 THROUGH JUNE 30,1996 This report provides a brief description of changes to the facility and procedures as described in the Safety Analysis Report, tests, and experiments that were implemented between July 1,1995 and June 30,1996. A summary of the safety evaluation for each item concluded that an unreviewed safety question, as defined in 10CFR50.59(a)(2), was not involved. Summaries of revised commitments to the NRC are being included as recommended in the NEI Commitment Management Guideline.

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PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT REVISION REPORT JULY 1,1995 THROUGII JUNE 30,1996 TABLE OF CONTENTS

PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 REPORT TABLE OF CONTENTS Modifications Page ECR 95-00164 1 ECR 95-01110 1 ECR 95-01775 1 ECR 95-02335 and ECR 95-02336 2 ECR 95-02946 2 ECR 95-03168 2 ECR 95-03610 and ECR 95-03611 2 ECR 95-03820 3 ECR 9544281 3 ECR 95-05017 3 ECR E00722 and ECR %01595 3 ECR 96-00821 4 ECR 96-01157 4 ECR % 01236 4 P00020, P00097, and P00165 5 P00096 5 P00097 5 IN 5 P00165 6 P00279 6 P00289 6 P00290 6 P00372 6 P00391 7 P00573 7 Unit 1 Cycle 6 Core Redesign 7 Nonconformance Reports NCR 93-00300 7 NCR 95-00142 8 NCR %00417 8 NCR %00845 8 NCR %00856 8 Temporary Plant Alterations ECR 96-00745 9

TABLE OF CONTENTS Procedures. Tests. or Exneriments Pagg GP-5, Rev. 51 9

GP-5, Rev. 53 9

M-041-200 and M-041-400 10 MAT P00167-1 10 MAT P00168 10 SP-147 10 SP-160 11 SP-161-1 11 SP-163 11 SP-165 11 SP-S-081-1 12 T-225, T-250, S51.2.A, S51.8.A. S51.8.1, SE-1, SE-8-1, SE-8-2, SE-8-3, 12 SE-8-4, and SE-6 UFSAR Channes l

ECR 93-01941 12 ECR 93-03116 13 ECR 93-03510 13 ECR 95-00544 13 ECR 95-02073 13 ECR 95-02894 13 ECR 95-05284 13 ECR 95-05313 14 ECR 95-05558 and Technical Requirements Manual Rev. 0 14 ECR %-01073 14 ECR 96-01833 14 ECR %-02491 15 L00733 and ECR 94-05389 15

_Q1hgr Technical Requirements Manual, Rev. I 15 Technical Requirements Manual, Rev. 2 16 Commitment Revisions Cavity Seal Replacement 16 Health Physics Training Revision 16 Radioactive Material Control 17 Undervoltage Relay Testing 17 Emergency Bus Driver Program Staffing Reduction 17 l

l

PECO ENERGY COMPANY LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 ANNUAL 10CFR50.59 AND COMMITMENT REVISION REPORT JULY 1,1995 TIIROUGH JUNE 30,1996 SAFETY EVALUATION SUMMARIES i

i

M' LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 95-00164 Unit 1_ Unit 2_ Common x This modification involved rerating the reactor enclosure crane's Maximum Critical Load (MCL) rating from 110 tons to 125 tons. This crane is used for refueling floor activities for both Unit 1 and Unit 2. The reactor enclosure crane was originally designed for 125 tons Design Rated Load. The MCL of the crane was later established to be 110 tons in order to comply with NUREG-0554 which recommends an additional 15% design margin on components subject to degradation due to wear and exposure. The reevaluation was performed in accordance with NUREG-0554 and CMAA-70 and confirms that no physical change to the crane is required. Increasing the MCL to 125 tons does not affect the vahdity of the original load test. This change affected a section of the UFSAR and is an overall enhancement to 9 maintenance.

1 MOD ECR 05-01110 Unit 1 x Unit 2_ Common _

This modification installed a bypass disconnect switch across the twe series Reactor Protection System (RPS) breakers in panel 1A-C248 and 1B-C248. The bypass switch is used during surveillance testing of the breakers to prevent loss of power to the RPS/UPS 120V AC distri'ation panels 1A-Y160 and IB-Y160. This ECR is safety related since the RPS breakers are designed to fail open on under-voltage, under-frequency, and over-voltage conditions. The disconnect switch is safety related and seismically qualified and mounted. No new failure modes were added to the system. When the bypass disconnect switch is closed during test, the system is declared inoperable per procedure control. The switch, when not in test, will be locked open and controlled per procedure A-8 (control of locked valve and devices). All cables installed were non-Q and are in conduits designed for II/I seismic considerations. No unresolved safety issues were identified. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 95-01775 Unit 1 x Unit 2 Common.

This modification added permanent 480vac and 120vac power in the drywell. The power feed is from an offsite supply, via the Site Support Building 480vac Load Center and will only be energized during an outage. Added in the drywell were 480vac welding receptacles and 120vac GFI duplex receptacles. This installation supports outage activities in the drywell by precluding the future necessity of pulling temporary power cables into the drywell and setting up power packs in the drywell. This installation will result in a significant time, cost and radiation exposure savings. This change affected a section of the UFSAR and is an overall enhancement to maintenance.

1

LIMERICK GENERATING. STATION

  • UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 95-02335 and ECR 95-02336 Unit 13 Unit 2. Common _

This modification drilled a small hole in the high pressure side of the wedge on High Pressure Coolant Injection (HPCI) Pump Discharge Injection valves HV-055-1F006, to loop 'B' Core Spray, and HV-055-1F105, to loop 'A' Feedwater, to eliminate the potential for pressure locking of the valve disc. Numerous industry and regulatory documents identify the problem of flexible wedge gate valves which have failed to open from " pressure locking." This hole provides a continuous vent path from the valve bonnet area to the upstream side of the valve disc. This continuous venting prevents pressure build-up inside of the valve bonnet area resulting in the mitigation of the pressure locking phenomena. This change has no adverse impact on the safety related functions of these valves. This modification affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 95-02946 Unit 1_ Unit 2_ Common x  ;

This modification made the toilet facility installed on elevation 239' of the Turbine Building ,

permanent. The area of installation was previously occupied by the Health Physics Issue Cage which was removed under SM ECR LG 94-10875. A toilet trailer was installed in support of j Refueling Outage 2R03 and remained in place under a Temporary Plant Alteration (TPA). The '

objective of this small mod is to provide for the proper evaluation and documentation of the trailer to allow for its long term use. The fire suppression equipment and combustible loading of this area were revised. This modification affected a section of the UFSAR and is an overall enhancement to maintenance.

MOD ECR 95-03168 Unit 1 x Unit 2 3 Common _

This ECR revised Specification M-171 to increase the HPCI maximum normal room temperature  !

from 115 F to 120*F. This change has no effect on the post Loss of Coolant Accident (LOCA) maximum room temperature or the qualified life of the environmentally qualified equipment in the HPCI room. This change is associated with the elimination of HPCI room cooling to support HPCI system operability. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 95-03610 and ECR 95-03611 Unit 1 x Unit 2 x Common .

ECR 95-03610 changed the setpoint for condenser low vacuum alarms from 25.0 in. Hg to 24.2 in. Hg. ECR 95-03611 eliminated a redundant low vacuum alarm. In addition, an increase in the maximum allowable turbine exhaust pressure was changed from 5.0 in. Hga to 5.5 in. Hga at power levels above 85%. Operations at power levels less than 85% will remain unchanged. No turbine trip setpoints were affected by either ECR. The implementation of these changes enhances the ability to operate up to 100% power during extreme summer operating conditions with increased trend in back pressure. These changes affected a section of the UFSAR and are an overall enhancement to operations.

2

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 95-03820 Unit 1 x Unit 2 x Common x This modification added manual keylocked switches and relays to electrically interlock either Unit 1 or Unit 2 Reactor Enclosure Secondary Containments and the Refuel Floor Area Secondary Containment isolation control logics. This provides an isolation of the associated Reactor Enclosure and the Refuel Floor Secondary Containment any time either of the two systems receives an isolation signal when the Secondary Coatainment areas are electrically interlocked. In addition, this modification supported extending either of the Reactor Enclosure Secondary Containment zone boundary to include the Refuel Floor Area. The zone extension will be procedurally controlled. This modification affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 95-04281 Unit 1_ Unit 2_ Common x This change provided areas outside the power block but inside the Protected Area Boundary (PAB) to be used for temporary storage of containers which hold reusable materials surface contaminated with very low levels of radiation. The criteria of Generic Letter 81-38 for onsite storage of radioactive waste material was incorporated into this evaluation, where appropriate, for temporary onsite storage of contaminated reusable material. Storage of contaminated reusable material outside the power block will continue throughout the life of the plant, subject to limitations and controlled by plant procedures. This charge affected sections of the UFSAR and is an overall enhancement to mainterance and operations.

MOD ECR 95-05017 Unit 1 x Unit 2 3 Common x This modification removed the inlet and outlet valves associated with the HPCI and Reactor Core Isolation Cooling (RCIC) room coolers from the Inservice Testing (IST) Program. These valves are air operated and control the flow of Emergency Service Water (ESW) to the room coolers.

This change followed as part of Modification P00212, which justified that room cooling is not required for the HPCI and RCIC systems to perform their safety functions. The HPCI and RCIC room coolers will continue to automatically function as before and the valves will be maintained.

This change only affected the Inservice testing of these valves, an;l addresses the revision of their safety classifications. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 96-00722 and ECR 96-01595 Unit i _ Unit 2 x Common _

This modification involved the drilling of a small 1/8" diameter hole in the upstream (i.e., pump) side of the disc of valves HV-051-2F014A and B. A design analysis was performed to determme the susceptibility of safety related active gate valves to wedge binding. Of the valves evaluated, the Unit 2 Residual Heat Removal (RHR) Heat Exchanger Residual Heat Removal Service Water (RHRSW) Inlet valves, HV-051-2F014A and B, were determined to be susceptible to Thermally Induced Pressure Locking which is caused, in this case, by the heating of the trapped bonnet fluid by elevated ambient temperatures. This hole provides a continuous vent path from the valve bonnet area to the upstream side of the valve disc. This continuous venting prevents pressure build-up inside of the valve bonnet area resulting in the mitigation of the pressure locking phenomena. This change has no adverse unpact on the safety related functions of these valves.

This change affected a section of the UFSAR and is an overall enhancement to operations.

3

LIMERICK GENERATING STATION ~

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD ECR 96-00821 Unit 1 x Unit 2_ Common.

This modification installed permanent alternate feeds to multiple components. One of these feeds included an alternate 480vac power feed to the IB Fuel Pool Cooling Water Pump Motor. The Fuel Pool Cooling system is not safety related. Class IE power is provided to ensure a reliable power source. It was determined that a non-class IE feed is acceptable because, while the 'B' pump is normally fed from a safeguard load center, its immediate Motor Control Center (MCC)

)

breaker is non-class 1E. In the event of a Loss of Offsite Power (LOOP), procedural guidance '

directs the use of RHR Shutdown Cooling to be implemented to maintain Fuel Pool temperature.

The UFSAR also specifically identifies both that the 'A' & 'B' pumps are powered by a Class 1E feed. The 'C' pump is also fed from a Class 1E feed. When the temporary feed is utilized, two pumps, the 'B' and 'C', were fed from a Class 1E feed so the reliability of Class 1E power to 2 of the 3 Fuel Pool Cooling pumps was maintained. The use of the alternate feed is controlled via approved station procedures / processes and is being utilized as a temporary power source during divisional bus outages which occur during unit refuel outages. This alternate feed was evaluated for use while the unit is in OPCON 5 or refueling. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD ECR 96-01157 Unit 1 x Unit 2 Common _

This modification added a 1/2" bypass line around the Unit 1 RHR "D" pump discharge check valve 051-1F031D. This line will provide a means to bleed a small quantity of flow (no more than 1 GPM) past the check valve to the Suppression Pool to prevent RHR Low Pressure Coolant Injection (LPCI) piping line pressurization in the event of in-leakage past the LPCI injection valve. In-leakage is quantified by existing procedures. When it has been established that Tech Spec limits are not being exceeded, the bypass line installed by this ECR provides a means to bleed the in-leakage to the Suppression Pool without having to open the large (18")

full-flow return test valve. The bypass ime is designed to existing pipe and instrument requirements. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD ECR 96-01236 Unit 1 x Unit 2 Common _

This modification modified valve HV-051-1F017D, LPCI, to eliminate pressure locking. In order to resolve HV-051-1F017D leakage, inbody maintenance was performed (in conjunction with ECR LG 96-01157). The external bypass line was cut to support valve maintenance. The external bypass line was not re-installed, however, the valve was modified to eliminate pressure locking by drilling a small pressure relief hole (approx.1/8") in the high pressure side of the disc. The hole drilled in the high pressure side disc will allow venting of the bonnet back to the downstream (vessel) side pipmg. This fix has been done 3reviously. In addition, tite manual valve (051-1186D) installed to facilitate between the seat LRT testing was removed and replaced with piping. As such, the valve test / drain line piping was essentially restored to its original layout (i.e., prior to incorporation of ECR LG 94-06387). This change affected a section of the UFSAR and is an overall enhancement to operations.

4

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD P00020. P00097. and P00165 Unit.1 x Unit 2 x Common _

These modifications replaced the Plant Process Computer P-1 software with the new 3D Monicore software. The 3D Monicore system was developed by General Electric (GE) to replace existing core monitoring systems for GE Boiling Water Reactor (BWR) plants. It was developed under the GE QA plan. The main calculational module of 3D Monicore is the PANACEA code, which was approved by the NRC via Licensing Topical Report NEDO-30130-A, Steady-State Nuclear Methods. This change affected the software utilized to calculate thermal limits as re enhancement to operations. quired by the Technical Specifications and is an overall MOD P00096 Unit 15 Unit 2. Common _

This modification added new power distribution equipment in the Technical Support Center (TSC) to supply the new Plant Monitoring System (PMS) computers for Unit 1. It also revised the power distribution arrangement in the Inverter Room and Auxiliary Equipment Room supplying the new Unit 1 Data Acquisition System (DAS) cabinets and control room computer consoles. This allowed for removal of Static Inverter 10D161. Temperature and humidity indication / alarm capability was also added to areas of the TSC to allow better operator environmental control of rooms where the power and computer equipment is located. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD P00097 Unit 1 x Unit 2_ Common _

This modification replaced the existing Plant Process Computer (PPC) and the Emergency Response Facility Display System (ERFDS) with the PMS. The PMS combines the functions of the PPC and ERFDS into one integrated computer system v>hich is functionally identical to the Unit 2 PMS. The PPC and ERFDS were replaced to maintain the reliability of the plant monitoring function. This change affected a section of the UFSAR and is an overall enhancement to operations.

MOD P00099 Unit 15 Unit 2_ Common _

This modification replaced the existing PPC System Rod Worth Minimizer (RWM), with a GE Nuclear Measurement Analysis and Control (NUMAC) RWM. The NUMAC RWM is a dedicated microprocessor based system with an operator display and a continuous operating self-test feature. The RWM momtors and enforces adherence to established low power level rod insert and withdraw sequences. It is a permissive system, and cannot itself cause unacceptable rod patterns to be established. This change replaced the old RWM system with a state-of-the-art microprocessor with enhanced reliability and flexibility. This change affected sections of the UFSAR and is an overall enhancement to maintenance and operations.

5

LIMERICK GENERATING STATION -

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD P00165 Unit 1 x Unit 2 x Common &

This modification replaced and/or modified the existing Main Control Room (MCR) computer consoles for Unit 1 and Unit 2 Reactor Operators, the Chief Operator, and the Shift Supervisor.

In addition, the existing Unit 2 Plant Monitoring System Toshiba graphic display terminal hardware was replaced with Digital _ Equipment Corporation VAX workstations. This modification increased desktop work area, created space to permanently laydown Transient Response Implementation Plan (TRIP) flowcharts, and allowed the ability for a PMS monitor to  !

face the TRIP flowchart area. These changes improved the work environment of the MCR and enhanced the operator interface with the plant monitoring computer system. Temporary configurations during installation were evaluated. These changes affected a section of the UFSAR and are an overall enhancement to operations.

MOD P00279 Unit 1 x Unit 2_ Common.

This modification added Uninterruptible Power Supplies (UPS) to selected feedwater control circuits. These UPSs were installed to increase the reliability of the feedwater system. .The UPSs provide a source of power during short interruptions of AC power upon transfer of certain station buses which reduces the likelihood of a scram. This modification affected a section of the UFSAR and is an overall enhancement to operations.

MOD P00289 Unit 1 x Unit 2_ Common .

This modification deleted several recorders in the MCR and various other locations in the plant that are no longer required per the recommendations of a Recorder Reduction / Replacement Project team. The deleted recorders were non-safety related and the momtored parameters were not related to safety related systems. The recorders that were deleted were reviewed by Operations, System Managers, and various other station orgamzations. This modification affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD P00290 Unit 1 x Unit 2_ Common.

This modification replaced several existing MCR recorders with new (Westronics 2100 Series) recorders. Existing recorders were replaced because they are no longer manufactured and a reliable supply of spare parts is not available. This modification affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD P00372 Unit 1 x Unit 2_ Common .

This modification installed a more flexible disc / wedge on flexible wedge gate valves which significantly reduces the probability of a thermal binding event. In addition, a small pressure relief hole was provided in the replacement disc / wedge to elimmate the susceptibility to liquid entrapment induced pressure locking. These measures were taken due to the susceptibility of this valve to the thermal binding and pressure locking phenomena. This modification affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

6

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 MOD P00391 Unit.13 Unit 2 s Common _

This modification provides for the capability of hydrogen and oxygen injection to the feedwater system for Hydrogen Water Chemistry (HWC) control. This modification included installation of equipment modules and interconnecting piping and wiring inside the Control Structure and Turbine Enclosures, breaching walls and floors with barrier requirements, and tie-ins to existing piping systems. None of the Hydrogen Water Chemistry equipment is safety-related. This activity only included installation and pre-operational testing of the HWC system. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

MOD P00573 Unit 1 x Unit 2_ Common _

This modification replaced Reactor Water Cleanup Dump Flow Control valve HV-C-044-1F033 due to seat leakage when in the closed position. This leakage was attributed to cavitation damage that has occurred as a result of throttling this valve during the operationa! hydrostatic testing.

This modification replaced the installed Hammel-Dahl valve with a valve more suitable for the hydrostatic test service conditions (i.e., valves with anti-cavitation trim). HV-C-044-1F033 is non-nuclear safety-related but is installed in a seismic category IIA system. The affected valve and riping are ASME II, Class 3. This change affected a section of the UFSAR and is an overall enhancement maintenance and operations.

MOD Unit 1 Cycle 6 Core Redesien Unit 1 x Unit 2_ Common _

This change involved the core redesign of Unit 1 Cycle 6. The redesign of the core was performed to detect and discharge any failed fuel and to shuffle other fuel to improve cycle energy. All fuel in the redesign was resident in the Cycle 6 core with the exception of the fuel failure replacement bundle. The replacement bundle was in the Unit 1 Spent Fuel Pool. This bundle was discharged during the last refueling outage and eight bundles of the same type were in the Unit 1 Cycle 6 core. This evaluation concluded that no unreviewed safety question exists during shutdown conditions based on the design shutdown margin and the fact all fuel was currently resident in the Cycle 6 core. The replacement bundle was installed in the core during a mid-cycle outage.

NCR 93-00300 Unit 1 x Unit 2. Common _

This NCR addressed the discovery of an additional valve installed on the Instrument Air System. Because of the valve's remote location and inaccessibility and impact on other air uses, it was decided to leave the valve in place and tag it rather than remove it. The valve was most likely installed as part of the Deep Bed Demineralizer modification, but not recoded in the as-built design documentation. The valve was in service for over a year without any preolems. Design documentation was updated to reflect the addition of the valve. This change affected a section of the UFSAR and is an overall enhancement to maintenance.

7

LIMERICK GENERATING STATION UNITS 1 AND 2 -

DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 NCR 95-00142 Unit.1 x Unit 2 Common _

This NCR evalu ted the acceptability of performing refueling activities including flood-up and fuel movement with inflatable seal #4 (1D-S290) leaking. Surveillance Test ST-4-015-490-1, performed on 8/10/95, indicated excessive leakage from seal #4 upon infladon. The final NCR disposition was to " rework" the seal during the next refueling outage. The interim disposition was to " repair" the seal by maintaining sufficient air pressure on the seal to maintain it in an operable inflatable state during flood-up and refueling activities. Licensed Senior Reactor Operators are trained on procedures S53.0.A, Response to Low I.evel in Fuel Storage Pool or Reactor Well, and ON-120, Fuel Handling Problems in the event of excessive water leakage past the seal. This change affected sections of the UFSAR and is an overall enhancement to operations.

NCR  % -00417 Unit 1_ Unit 2 3 Common _

Four control blades exceeded design end of life defined as 10% loss of total reactivity worth (34% average B-10 depletion) due to the need to control thermal limits. The safety evaluation addressed the impact of the loss of reactivity on the function of the control blade such as scram reactivity and shutdown margin impact. The blades were not planned to exceed the design life in the core management plan. The safety evaluation concluded that the only impact is the need to account for the reduction with respect to the shutdown margin. Sufficient shutdown margin was verified to still be provided. All four blades will be replaced during the next refueling outage.

NCR  % -00845 Unit 1 x Unit 2_ Conunon .

This NCR evaluates a "use-as-is" disposition for up to four years, two operating cycles, for circumferential flaw / crack indications m certain welds on the Unit I core shroud. Inspections xrformed during the IR06 refueling outage identified circumferential indications in the weld leat affected zone at weld H-3. No mdications were observed with the H-4, H-5, or H-7 welds.

These exammations satisfied the commitments for Unit 1 in response to NRC Generic I.etter 94-03 regarding core shroud cracking. Using the BWR Vessel and Intervals Project guidelines, these indications were evaluated and determined that operation could continue for four more years.

NCR 96-00856 Unit 1 x Unit 2_ Conunon _

This NCR evaluated the "use-as-is" disposition for the presence of lost parts in the Reactor Vessel. During core verification, a piece of a plastic tie wrap was discovered in the core and could not be retrieved. This evaluation concluded that the existence of this item and the cumulative effects of other items previously lost in the reactor vessel would not compromise reactor integrity or reactor safety.

8

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85

-TPA ECR 96-00745 Unit.1 x Unit 2_ Common _

This temporary change involved the use of a non-class IE source as a temporary power feed for the 1A Fuel Pool Cooling Pump. The Fuel Pool Cooling system is not safety related. Class IE power is provided to ensure a reliable power source. It was determined that a non-class IE feed is acceptable because, while the 'A' pump is normally fed from a safeguard load center, its immediate MCC breaker is non-class 1E. In the event of a LOOP, procedural guidance directs the use of RHR Shutdown Cooling to be implemented to maintam pool temperature. The UFSAR also specifically identifies both that the 'A' & 'B' pumps are powered by a Class 1E feed. The 'C' pumps, the 'B' pump is also fed from a Class 1E feed. While the this change was in service, two and 'C' were fed from a Class 1E feed so the reliability of Class 1E power to 2 of the 3 Fuel Pool Cooling was maintained. The use of the alternate feed is controlled via approved station procedures / processes and is being utilized as a temporary power source during divisional bus outages which occur during unit refuel outages. This alternate feed was evaluated for use while the unit is in OPCON 5 or refueling. This chan an overall enhancement to maintenance and operations.ge affected a section of the UFSAR and is PROCEDURE GP-5. Rev. 51 Unit 1 x Unit 2 3 Common _

This procedure, " Power Operations," was revised to incorporate a methodology to clarify the control of core flow during operations. The methodology provides for a smoother core flow signal to be limited to 110 Mlbm/hr. during steady state conditions. This evaluation showed that there is no impact of instantaneous signals above 110 Mlbm/hr as defined by the methodology.

The smooth core flow signal provides digital filtering of the core flow value. This process is consistent with current measurement of feedwater flow and local power range monitor signals in the process computer. The methodology is also analogous to the process used to control reactor thermal power. This change affected a section of the UFSAR and is an overall enhancement to operations.

PROCEDURE GP-5. Rev. 53 Unit 13 Unit 2 3 Common.

This change evaluated operation at indicated core flows less than (to the left of) the approximate natural circulation line with at least one recirculation pump in operation. The Power to Flow Map changes provide the Operators with guidance should the plant reach this portion of the operating map. Operation in this region could occur due to inaccuracies associated with core flow measurements and uncertainties in defining the natural circulation line. Additionally, core plate differential pressure was added to the Power to Flow Map to allow its use as an indicator of core flow as specified in the operating procedures. Procedure GP-5, " Plant Operations," was revised to include this information. This change affected sections of the UFSAR and is an overall enhancement to operations.

9

LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 PROCEDURE M441-200 and M-041-400 Unit 15 Unit 2 s Common.

These procedore revisions incorporated enhancements and lessons learned from previous outages.

Several improvements resulted in the ability to lift the eight RPV studs with the RPV head. The use of kevlar slings in place of the original RPV strongback for lifting the mirror insulation was evaluated and concluded to be acceptable. The additional guidance for mating of the RPV N-7 nozzle flange was provided to ensure proper fit-up of the flange in response to difficulties experienced in the past. The use of the Stud Elongation Measurement System was incorporated to provide more reliability and ease of use in measuring stud elongation associated with the tensioning of the RPV head. These changes affected a section of the UFSAR and are overall enhancements to maintenance.

PROCEDURE MAT P00167-1 Unit 1 x Unit 2 Common This procedure involved the post modification testing of a portion of the ESW and RHRSW crosstie modification. During this test, manual operator actions are taken credit for in order to maintain the ESW and RHRSW systems operable. This is consistent with the guidance of Generic Letter 91-18.

PROCEDURE MAT P00168 Unit 3 Unit 2 x Common _

This procedure involved the post modification testing of the 'A' and 'B' RHRSW return header crosstie modification. This test verified that ESW and RHRSW are capable of supplying design flow to both units vital loads with the 'A' and 'B' RHRSW return headers crosstied and both systems flows returning through RHRSW 'A' or 'B' return. During this test, manual operator actions are taken credit for in order to maintain the ESW and RHRSW systems operable.

PROCEDURE SP-147 Unit 1 x Unit 2_ Common _

This procedure, " Raising Core Flow to 110 Mlb/hr.," previously titled " Raising Unit 2 Core Flow to 110 Mlb/hr.," was revised to make SP-147 generic to both units so that it can be used on Unit 1 and to clarify that it will only be necessary when entering Recirculation Pump Speeds beyond those previously experienced. The intent of SP-147 is to outline how the MG-Set gag stop will be moved as flow is increased and how noise / vibration monitoring will be conducted.

There were no significant changes to the actual process described in SP-147. This evaluation actually performed two functions. It reviewed the use of SP-147 as required by station procedures and it allowed full use of the 110 Mlb/hr flow range for Unit 1. This use is dependent on implementation of SP-147 when entering "new" (beyond previous experience)

Recirculation Pump Speeds. It does constrain top Recirculation Pump Spe:ds to 1650 RPM based on a GE report analyzing the potential for damage to Jet Pump Sensing Lines due to vibration. The top allowable Recirculation Pump Speed had previously been set to 1500 RPM in a previous 10CFR50.59 Safety Evaluation due to unknowns about the impact on the Jet Pump Sensing Lines.

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1 LIMERICK GENERATING STATION 1 UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 PROCEDURE SP-160 Unit 1_ Unit 2 x Common .

This test procedure controls the performances of thermal limit monitoring during Hydraulic Control Unit (HCU) on-line maintenance. The evaluation justified the operation of Unit 2 during Cycle 4 with the P1 program in the symmetric control rod pattern mode with up to seven control rods asymmetric by forty-eight positions (48 notches) for HCU On-Line Maintenance. This allowed for an asymmetric control rod pattern operation with the control rods undergoing HCU maintenance insened to position 00 and with their symmetric partners withdrawn to position 48.

PROCEDURE SP-161-1 Unit 1 x Unit 2 Common _

This change implemented Special Procedure SP-161 to perform voltage regulator stability testing with the generator connected to the grid. During the test a 1% voltage difference between the automatic and manual settings of the voltage regulator was established to test the stability of the automatic volta considerations.ge regulator. These activities were controlled and implemented using special test This was a test not previously described in the SAR.

PROCEDURE SP-165 Unit 1. Unit 2_ Common x This change implemented Special Procedure SP-163 which provides for testing of the Control Enclosure HVAC duct flow switches. This evaluation considered operability of the Control Room Emergency Fresh Air Supply (CREFAS) system during the test evolution and provided for manual operator actions to ensure that the CREFAS system would function in the event of a system imtiation due to radiation, chlorine or toxic gas. This is consistent with the guidance of Generic Letter 91-18. Manual operation of the CREFAS system has been demonstrated previously.

PROCEDURE SP-165 Unit 1_ Unit 2_ Common 3 This change implemented Special Procedure, SP-165, the procedure for Auxiliary Equipment Room (AER) HVAC Supply / Return fan flow switch coordination. This special procedure is intended to verify and field calibrate as necessary, the flow switches that are designed to allow for the auto start of the standby supply and/or return fans, and to develop new setpoints to facilitate the auto start capability. The automatic start of the standby fan is a design feature of the AER HVAC system as described by section 9.4.1.2.1.c and Table 9.4-3 of the UFSAR.

This evaluation considered operability of the AER HVAC system during the test evolution and provided for manual operator actions to ensure the AER HVAC system functions as required.

This is consistent with the guidance of Generic Letter 91-18.

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DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 PROCEDURE SP S-081-1 Unit 1 x Unit 2_ Common.

This special procedure involved cooling the ID Traversing In-core Probe (TIP) indexer by introducing cooled nitrogen gas into the TIP guide tube at a location outboard of the containment isolation valves with the unit at power. The ID TIP indexer was experiencing difficulty in performing its indexing function and it was concluded that cooling the indexer would have a significant potential to improve its operation. Since the cooling operation was performed at power, the containment was required to continue to perform its containment function. The TIP indexer is used in support of safety related equipment but has no safety function of its own. This change affected a section of the UFSAR and is an overall enhancement to maintenance and operations.

PROCEDURE T-225. T-250. S51.2. A. S51.8. A. S51.8.I. Unit 1 x Unit 2 x Common x SE-1. SE-8-1. SE-8-2. SE-8-3. SE-84. SE-6 This change revised the following procedures: l T-225 - Startup and Shutdown of Suppression Pool and Drywell Spray Operation T-250 - Remote Manual Primary Containment Isolations i S51.2.A - LPCI System Shutdown After Automatic or Manual Initiation S51.8.A - Suppression Pool Cooling Operation (Startup and Shutdown) and Level Control S51.8.I - Use of Dedicated LPCI Pumps for Suppression Pool Cooling Operation (Startup and Shutdown) and I2 Vel Control SE Remote Shutdown SE-8 Safe Shutdown Method A SE-8 Safe Shutdown Method B SE-8 Safe Shutdown Method C SE Safe Shutdown Method D SE Alternate Remote Shutdown These procedures were revised for shutdown of a RHR pump operating in the LPCI injection mode to facilitate closure of the associated HV-051-1(2)F017A/B/C/D LPCI Injection Valve.

Valve and motor operator data indicates that the valves may not fully close against full LPCI injection flow due to disc tolerance. When 3rocedures permit securing an operating LPCI loop, ,

the standard method was to first close the L?CI Injection Valve. As system flow decreases, the l associated RHR pumps minimize flow valve would open to prevent pump deadheading. The l RHR pump would then be secured or allowed to continue operating on minflow. The subject change allows tripping the RHR pump as required to reduce system differential pressure across the associated LPCI Injection Valve m the event the valve does not fully close on initial command under dynamic conditions. The reduced differential pressure facilitates valve closure.

UFSAR CHANGE ECR 93-01941 Unit 1 x Unit 2 x Common _

This UFSAR change updated the UFSAR description of the "first-out" annunciator features for the Emergency Diesel Generators (EDG) to reflect the as-built condition shown on the design drawings. The UFSAR was updated to remove an exception that was taken to NRC Regulatory Guide 1.108. Design drawings confirm that the "first-out" feature is included in the annunciator design. No material change to the facility was made.

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LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE ECR 93-03116 Unit 1 x Unit 2 x Common .

This UFSAR change updated the UFSAR text and figures to agree with plant conditions and vendor design and documentation. Two thermocouples, PT13 and PT14 on the EDG exhaust manifold, were shown on the wrong line. The P&ID and UFSAR Figure incorrectly showed the thermocouples on the EDG combustion air outlet line from that turbocharger. This change did not result m any physical changes to any structure, systems, or components.

UFSAR CHANGE ECR 93-03510 Unit 1 x Unit 2 3 Common .

This UFSAR change updated the UFSAR description of the lube oil sump level control feature for the EDGs to reflect the as-built plant condition. The ECR identified discrepancies which existed between the as-built plant and P&ID. No material change to the facility was made. The lube oil sump level control is manually controlled rather than automatically controlled as previously indicated.

UFSAR CHANGE ECR 95-00544 Unit 1 x Unit 2 x Common _

This UFSAR change incorporated the de voltage load adjustments resulting from the revision of the Class 1E battery calculation, LE-0052. Calculation LE-0052 was revised to allocate allowance for growth (" margin") to the batteries, de buses, and some plant inverters.

UFSAR CHANGE ECR 95-02073 Unit 1_ Unit 2_ Common x This UFSAR change revised section 11.3.3 to list the gaseous release points listed in the Offsite Dose Calculation Manual (ODCM). The four points are as follows: North Stack, South Stack, Maintenance Hot Shop, and Auxiliary Boiler. This change made the release points identified consistent between the ODCM and UFSAR by adding the Auxiliary Boiler. The Auxiliary Boiler was previously added as a release point during revision 16 of the ODCM.

UFSAR CHANGE ECR 95-02894 Unit 1 x Unit 2_ Common .

This UFSAR change annotated UFSAR Section 10.2.3.6.a to document the deferral of the Unit I low pressure main turbine rotor inspections beyond the six-year interval as committed to in the In-Service Inspection Plan for prevention of turbine missiles. The deferral is supported by probability data provided by GE using a methodology accepted by the NRC and documented in the UFSAR as the basis for determination of future inspection intervals.

UFSAR CHANGE ECR 95-05284 Unit 1_ Unit 2_ Common x This UFSAR change revised the UFSAR description of the facility to reflect that automatic is not the normal mode of operating the Perkiomen Make-Up Pumps. The automatic mode is not preferred because there would be no limitation on ti. : frequency of pump motor starts to protect the motor windings insulation from overheating. Furthermore, each time a pump started or stopped, the operator would have to respond by making adjustments to cooling tower make-up valve positions in order to stabilize the system since the make-up flow control system is manual.

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UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE ECR 95-05313 Unit.1_ Unit 2_ Common x This UFSAR change removed the overly conservative assumption, made during the original post fire safe shutdown analysis, of a LOOP occurring concurrently with a fire. A review of Regulatory Requirements was performed and there is no requirement to assume more than a fire-induced LOOP or a LOOP when an alternate or dedicated shutdown method is assumed.

UFSAR CHANGE ECR 95-05558 and Technical Requirements Manual Rev. 0 Unit 1 x Unit 2 x Common x This change incorporated a Technical Requirements Manual (TRM) into Chapter 13.5 " Plant i Procedures" of the UFSAR and implemented the TRM document. The TRM contains the technical requirements and/or supporting information (i.e., tables, and component lists) which were once contained in the Technical Specifications (TS) (i.e., Appendix A of the operating license). The TRM is intended to provide operational guidance and requirements for various plant conditions, actions, and testing similar to TS, however, these requirements are in accordance with licensing commitments. The TS Sections related to Fire Protection and the list l

of Secondary Containment Isolation valves were relocated to the TRM with Revision 0. A separate TRM will contain the commitments for each unit.

UFSAR CHANGE ECR 96-01073 Unit 1_ Unit 2_ Common a This UFSAR change revised the UFSAR discussions of the Control Room Heating HVAC System (CRHVS) standby fan automatic start feature. The UFSAR was revised to describe a CRHVS operating mode that uses a manual start of the standby air supply or return fan (s) in conjunction with specific compensatory measures. Consequently, the handswitches for the CRHVS air supply and/or return fan (s) can be placed in "Off" and this manual mode can be used in lieu of the automatic start feature. This is consistent with the guidance of Generic Letter 91-

18. l UFSAR CHANGE ECR 96-01833 Unit 1 x Unit 2 x Common .

This change evaluated the use of nuclear fuel channels from discharged initial core fuel assemblies from Units 1 and 2 on ex-Shoreham fuel bundles. These " reused" channels will be utilized on unchanneled ex-Shoreham fuel bundles over the next several cycles at Units 1 and

2. 260 unchanneled enriched ex-Shoreham fuel bundles remain in the spent fuel pool. The first application of reused fuel channels will be for Unit 2 Cycle 5 (approximate startup date March,1997). The impact of reused fuel channels on channel-control blade interaction, thermal limits and the safety limit Minimum Critical Power Ratio (MCPR) have been evaluated.

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l LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 UFSAR CHANGE ECR 96-02491 Unit 1 x Unit 2 3 Common x This UFSAR change involved conducting one of the four quarterly fire drills at an offsite training facility. The offsite training facility simulates plant physical conditions and requires the use of similar fire fighting strategy and tactics per plant fire procedures. By conducting a fire drill at the training facility, one entire shift brigade is able to practice together as a team, drill scenarios are expanded and the entire shift benefits from observing co-members and exchanging ideas and critiquing the overall effectiveness of the brigade and drill execution.

The Fire Protection Program will continue to be maintained as described in the UFSAR in regards to its effectiveness.

UFSAR CHANGE L00733 and ECR 94-05389 Unit 1 x Unit 2_ Conunon _

This ECR and associated UFSAR change revised the IST Boundary for the Spray Pond from valve 12-0031 to valve 12-1011 and revised the Q-classification for valve 12-1011 from non-Q to Q-Active. These changes were made to provide better shutoff capability to prevent siphoning of the Spray Pond in the event of a pump trip caused by a LOOP while making up to the Spray Pond from the Schuylkill River. This change reduces maintenance and IST testing to the Spray Pond and the amount of operator time required for making up water.

Technical Reauirements Manual. Rev.1 Unit 1_ Unit 2_ Common x This activity involved changing the TRM Diesel Driven Fire Pump battery specific gravity (s.g.)

minimum setpoint from 1.260 to 1.225. The setpoint of 1.260 represented a full charged battery specific gravity reading. Although the Diesel Drive Fire Pump batteries may reach a value of 1.260 when fully charged, a s.g. value as low as 1.225 is considered normal. The battery vendor indicated that a s.g. limit of 1.225 provides a limit for which the battery would function normally without requiring overcharging which causes premature aging of the batteries. Revising the required s.g. limit from 1.260 to 1.225 maintains the starting capability of the Diesel Driven Fire Pump, and increases the reliability of the batteries by extending battery life.

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LIMERICK GENERATING STATION '

UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 Technical Reauirements Manual. Rev. 2 Unit 1 x Unit 2 x Common x This revision involved the addition of interval extension (i.e. 25% time extension) to the time limits specified in recurring TRM ACTION requirements. The TRM BASES states that the 25% grace provision is not to be used repeatedly as a convenience to extend the interval.

Rather the extension facilitates scheduling of the recurring ACTION and allows for consideration of plant operating conditions that may not be suitable for conducting the

, recurring ACTION (e.g., local radiological conditions). Since the extension is short in duration relative to the interval length, the 25% extension does not significantly degrade the reliability of plant equipment that results from performing the ACTION at the specified interval. The extension does not apply to the initial performance of the ACTION since such an action usually verifies that no loss of function has occurred by checking the status of redundant .

or diverse components or accomplishes the function of the inoperable equipment in an alternative manner. This initial performance is considered to be a single action with a single com letion time and a time extension is not appropriate. Subsequent performances continue to veri that the initial verification is unchanged.

COMMITMENT REVIS' ION Cavity Seal Replacement Unit 13 Unit 2 3 Common _

T02829 This commitment required that the #3 and #4 reactor cavity seals be inflated prior to removal of the shield plugs. The commitment was intended to prevent a pressure differential from spreading contamination through the cavity when the shield plugs were removed. Equipment deficiencies have been corrected which will prevent the spread of contamination and the conunitment has been deleted. The original commitment was documented in LER 1-92-004.

COMMITMENT REVISION Health Physics Trainine Revision Unit 1_ Unit 2_ Common x T03047 This commitment revision relocated the commitment to establish a retraining program for l Health Physics (HP) personnel from procedure HP-100 to Nuclear Training Section (NTS) course plan 9300 for HP. HP-100 was canceled and training and qualification for HP was included in NTS and HP position guides respectively. The origiaal commitment was '

documented in NRC Inspection Report 50-352/86-13.

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LIMERICK GENERATING STATION UNITS 1 AND 2

' DOCKET NOS. 50-352 AND 50-353 LICENSE NOS. NPF-39 AND NPF-85 COMMITMENT REVISION Radioactive Material Control Unit 1. Unit 2_ Common a

_ T02838 This commitment revision involved allowing station personnel to release personal items from the Radiologically Controlled Area (RCA) using the Small Article Monitor (SAM). This i

revision also allows for qualified Advanced Radiation Workers (ARW) to release approved

} material such as Green is Clean trash frm. the RCA using the SAM or Bag Monitor. New instrumentation and training were i lemented after this commitment was issued. The original commitment required workers to fris personal items and for HP personnel to release all other items. Based on the plant's Isotopic Mix, the SAM is a better instrument for detecting contamination. In addition, it is also easier to use and more reliable than a frisker. Only select individuals that are specifically trained to use the Bag Monitor and SAM are qualified to j release material other than personal items from the RCA. The original commitment was documented in NRC Inspection Report 50-352/92-23.

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CON.MIDfENT REVISION

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Undervoltace Relav Testine Unit 1 x Unit 2 3 Common _

T03588 This commitment revision decreased the frequency of 4ky safeguard bus undervoltage relay testing from a six week cycle to a six month cycle. To ensure long term operability of relays, it was determined that an enhanced six month frequency test along with periodic replacement of the relays would reduce / eliminate relay failure. Frequent testing of the relays would not guarantee their operability. The original commitment was documented in a letter to the NRC

, dated April 12,1995 regarding failures of 4kV safeguard bus relays.

COMMITMENT REVISION Emercency Bus 3E in r Procram Unit I _ Unit 2_ Common a Staffine Reduction This commitment revision reduced the bus driver staffing necessary for local scrols in case of ar, e.nergency. The Emergency Bus Driver Program was re-evaluated based e. tne needs of the two (2) affected school districts. Both affected school districts were surveyed to determine their anticipated unmet needs for bus drivers. Based on the results of the surveys, the combined unmet needs for both districts is approximrtely 76 drivers which allowed for a c reduction in the number of bus drivers in PECO's Emergency Bus Driver Program from 200 to

( -g 100. This reduction still provides more than enough drivers to provide "reawnable assurance" that adequate protective actions can and will be taken for the affected school districts in the event of a radiological emergency at the plant. The original commitment was

~ made during licensing proceedings and was documented in the Emergency Bus Driver Program.

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