IR 05000413/1996018
| ML20133L252 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/30/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133L222 | List: |
| References | |
| 50-413-96-18, 50-414-96-18, NUDOCS 9701210540 | |
| Download: ML20133L252 (27) | |
Text
_ . . - _ . _ . _ _ _ _ . _ . - . _ _ . . _ _ _ . . _ . _ . . _ . _ . . _ . _ _ . . _ . _ _ _ _ _ _ . _ . .
i
..
.
l U. S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos: 50-413, 50-414
. Licensee: Duke Power Company i
l Facility: Catawba Nuclear Station. Units 1 and 2 Location: 422 South Church Street Charlotte. NC 28242 Dates: October 20 - November 30, 1996 Inspectors: R. J. Freudenberger. Senior Resident Inspector P. A. Balmain. Resident Inspector l R. L. Franovich Resident Inspector R. S. Baldwin Chief Examiner. DRS Approved by: L. D. Wert. Acting Chief Reactor Projects Branch 1 Division of Reactor Projects
!
I l
l
!
j
I ENCLOSURE 9701210540 961230 PDR ADOCK 05000413 G PDR
,
.
EXECUTIVE SUMMARY Catawba Nuclear Station. Units 1 & 2 NRC Inspection Report 50-413/96-18. 50-414/96-18 This integrated inspection included aspects of licensee operation maintenance, engineering, and plant support. The report covers a 6-week period of resident ins)ection: in addition it includes the results of announced inspections Jy regional reactor safety and reactor projects inspector Doerations
. The licensee's efforts to im]lement a cold weather protection program were not commensurate with t1e significance of and frequency with which equipment problems have been encountered during previous winter seasons -
(Section 02.1). l
. Progress toward drafting both corporate and station guidance in the development of a structured cold weather protection program has been narrow in scope and not timely (Section 02.1).
. Corporate and site assessments of the cold weather protection program have effectively revealed problem areas, and ensuing recommendations have been thorough and broad in scope (Section 02.1).
. The licensee's licensed operator requalification program evaluators administered JPMs effectively and consistently (Section 05.1).
- During Requalification Program simulator scenarios crew communications were satisfactory; however, improvements could be made concerning plant announcements. announcing changes to major plant equipment, and repeat back of specific plant parameters (Section 05.2).
. Simulator scenarios used for operator requalification were acceptabl The scenarios could have been enhanced to capture specific plant equipment interactions that would have provided additional competency evaluation for the examination team (Section 05.3).
. The examination documentation remedial training, and retesting programs were satisfactory (Section 05.4).
- Operations Management has committsJ to participate in annual requalification examinations. The inspector viewed this as a good practice (Section 05.5).
. Operations Management has aggressively pursued the identification and correction of problems with the Employee Training and Qualification Syste Since licensee corrective actions were not complete additional inspector review of corrective actions was necessary. Specific operator qualifications will be checked as part of Inspector Follow-up Item 50-413.414/96-18-01 (Section 05.6).
ENCLOSURE
'
.
.
Maintenance
. Preventive Maintenance Thermography of switchyard connections i effectively identified the degrading condition of a bolted connectio l The connection was able to be removed from service for a planned repair prior to failure (Summary of Plant Status).
.
Maintenance activities following the failure of the Unit 1 standby makeup pump pulsation dampener were well coordinated and execute Extensive modification inspection, and testing of the pump were completed prior to the expiration of a TS action statement that would have required a unit shutdown (Section M1.1).
. The licensee's investigation of a Unit 1 main transformer cooler failure was effective in identifying the cause of the failure and initiating actions to prevent future fan failures. Subsequent actions to reduce power deenergize the 1A main transformer, and degas the transformer oil system were appropriate (Section M1.2).
. Warehouse storage conditions were goo The licensee took appro)riate corrective actions to review motor storage practices following t1e identification of an improperly stored motor (Section M2.1).
. Two Non Cited Violations were identified regarding missed offsite power availability surveillances. The inspector reviewed the circumstances of both cases and concluded that the root causes were differen Therefore, corrective actions for a December 1995 issue would not have been expected to have prevented a recent occurrence (Sections M3.1 and M8.1).
Enaineerina
. Engineering support in the form of an evaluation of standby makeup pump operation with an incorrect cylinder cover and implementation of a minor modification for the replacement of the standby makeup pump discharge dampener was appropriate (Section M1.1).
. The licensee's efforts to mechanically contain a FWST heater leak were appropriate. However. pending additional review of inclusion of a wind velocity factor in a calculation for heat losses through the FWST roof while the heater capacity was reduced. Inspector Followup Item 50-413.414/96-18-04 was opened (Section E2.1).
ENCLOSURE
_ - . _
.
'
l I
,
Plant Suonort
- An annual unannounced after-hours augmentation drill demonstrated that required Emergency Operations Facility positions could be staffed with post-game stadium traffic in the vicinity of the Emergency Operations Facilit Additionally, the resident inspectors participated in a semi- I annual emergency drill. Performance during the drill and critique was appropriate (Sections P2.1 and P2.2).
l l
ENCLOSURE
_ . . . - _ _ __ _ _ ___ _ _ ..
.
.
,
Report Details Summary of Plant Status Unit 1 operated at or around 100% power until October 27, when reactor power
,
was reduced to 50% and then 47% to support re) airs to and degassing of the A main transformer following an oil cooler fan ) lade failure. The transformer was returned to service on October 31. and power ascension to 100% commence , On November 2 the unit reached 100% power and remained at 100% for the rest of the inspection report perio Unit 2 oPrated at or around 100% power until November 14. By use of
- thermogrep .y for preventive maintenance, high temperatures were identified at a bolted ccnnection in the switchyard. Reactor power was reduced to 47% and the A train of main power was removed from service. The high temperature was attributed to resistance caused by corrosion. The connection was cleaned, and a corros on-inhibiting lubricant was applied. Train A of main power was
) laced back in service and reactor power returned to 100% on November 1 Reactor power remained at 100% for the remainder of the inspection report perio ; While performing inspections discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that were related to the areas inspecte The inspectors verified that the UFSAR wording was consistent with the
>
observed plant practices, procedures, and/or parameter I. Operations 02 Operational Status of Facilities and Equipment 02.1 Cold Weather Protection Preparations a. Insoection Scooe (71714. 40500)
The inspector reviewed the licensee's plan for ensuring that plant ecuipment that is either safety-related or important to safety is acequately protected from extreme cold weathe The inspector reviewed the licensee's actions to implement a cold weather protection plan, interviewed the designated site Freeze Protection Coordinator, accompanied personnel in heat trace and instrument cabinet inspections, and reviewed station PIPS to determine if previously identified, cold weather induced equipment problems were addressed. The inspector also reviewed corporate office and station PIPS documenting program deficiencies to assess the adequacy of corrective actions and their timely implementatio b. Observations and Findinas The inspection effort primarily focused on the eight areas listed in NRC Inspection Procedure 71714. Cold Weather Protection. Observations and findings in each area were as follows:
ENCLOSURE
. _ _ . __ . -- - --
.
.
1. Station cold weather checklist The station assigned a freeze protection coordinator to monitor the status of preparation activities. The freeze protection coordinator generated a matrix of the work items with their associated work order numbers. The matrix included items from surveillance procedure PT/0/B/4700/38. Cold Weather Protection, approved February 7. 1994, which is performed annually in the fal Open work orders for inspection and testing of electrical heat trace, cabinet heaters, and insulation were also added to the matrix. In addition the main potential transformer control cabinet space heaters were included to ensure that their l functioning would preclude an electrical fault similar to the one that resulted in a Unit 2 loss of offsite power last winter I (documented in NRC Ins)ection Report 50-413.414/96-03). The matrix, coupled with t7e surveillance procedure, served as the cold weather protection checklis . Instrumentation calibration and testing The inspector accompanied licensee personnel during the inspection and testing of heat trace. Thermostat operation was checked; the cabinet, door gasket, cable entries, and door fasteners were inspected for material condition and pro heat trace and insulation was inspected.per functioning:
To test and pipe the heat trace, the thermostat setting was increased to energize the heat trac Amperage was then measured to ensure that sufficient heat could be generated. The inspector also reviewed a sample of task 4 completion notes associated with predefined work order 96065640-01. Preventive Maintenance of the Heat Trace System, and reviewed '
other work orders that were generated to investigate and repair identified deficiencies. At the end of the inspection report period several work orders for inspecting and repairing heat tracing, heat trace heaters and insulation were outstanding. A deficient heater associated with the refueling water system was ;
among the The licensee does not calibrate space heater thermostats: however, a co*rective action in Station PIP 0-C96-1232 has 3rompted an evaluation of the need to add area electric s) ace leater checkouts to predefined model work order 91004266 for t1e inspection and l
testing of electric heat tracing. The inspector noted that some area heaters could not be adjusted to control at a specific 1 minimum temperature; they could either be turned up (for increased heat output) or turned down (for reduced heat output). The inspector expressed concern that adequate controls for maintaining
,
room temperatures above a specified minimum were not provided.
- ' The licensee responded that discussions were in progress with the vendor to determine how a finer resolution in the controls could i
'
ENCLOSURE
.
3 be obtained. The inspector did not identify any equipment ,
3roblems that have resulted from thermostat control issue l
ieater failure has been the cause of cold weather induced l equipment failures in previous winter seasons.
i The inspector also performed a walkdown of the fire water and low l
pressure service water intake structure to evaluate the presence l and material condition of heat tracing and insulation on exposed '
l piping. New insulation had been or was being installed to enclose segments of exposed piping that had been traced with heating elements. The inspector noted that the condition of these protective devices was much improved over previous year The licensee's current freeze protection efforts are implemented through predefined model work order Work Order 91004266-01 !
provides for (1) the verification of thermostat and heater i operation in heat trace cabinets, and (2) the visual inspection of heater installation and pipe insulation. Work Order 91002154-01 provides for the verification of thermostat and heater operation for 54 mechanical instrument boxes and the visual inspection of insulation and boxes for general material condition. Work Order 95073814-01 provides for the inspection and repair of insulation at various outdoor areas potentially exposed to cold weathe These work orders are typically initiated in Septembe Identified discrepancies are ccrrected via the work request proces . Inspection of systems susceptible to cold weather effects The freeze protection coordinator, assisted by an operations staff member, performed walkdowns of plant equipment to ensure that 3rotective equipment. such as heat trace, insulation and area leaters, was in good material condition. Discrepancies were identified and work orders were initiated to correct the However, plant equipment walkdowns were still in 3rogress, and subsequent work orders remained outstanding, at t1e end of the inspection period. An enhancement to the freeze protection efforts associated with outside area instrument cabinets, electric area heaters, and heat tracing this season was to close the heater breaker and energize the heater to verify electrical continuity in the circuit as well as power availability. In previous years, only power availability was verifie . Inspection of systems subjected to maintenance in past year The licensee does not as a practice, inspect systems that have been subjected to maintenance during the previous year to verify that cold weather protective measures have been reestablishe Instead, the work control 3rocess for post maintenance restoration is relied upon to ensure tlat any cold weather protective ENCLOSURE l
. _ _ - _ - - . . _ . - - .. - . ..
.
.
i equipment disturbed during maintenance activities is restored to its normal, functional status before equipment is returned to service. The licensee does consider the plant equipment walkdown to be a check to ensure that any disturbed or damaged freeze protection equipment is identified and corrected. The inspector
did not identify equipment problems associated with this practic . Protection of areas during periods of prolonged shutdowns The licensee has identified a need to determine, during long periods of prolonged shutdowns, if areas that are no longer kept warm by normal plant operation are adequately protected from cold weather. A Nuclear Station Directive for an Equipment Freeze Protection Program was under development with the lead responsibility assigned to the Duke Power Company General Offic . Correction of cold weather non-conformances previously identified
'
The inspector evaluated the scope of the licensee's efforts to determine if cold weather non-conformances that had been identified in previous years by the NRC and the licensee were included in the current season's cold weather preparations. The inspector determined that, although some equipment vulnerabilities from the previous year (including the 22 kV potential transformer com)artment heaters and main steam pressure im]ulse lines in the tur]ine building basement) were addressed in t11s year's cold weather preparations, the items were salient; the first had contributed to a loss of offsite power event in February 1996, and the second had been a recurring proble However, other equipment problems (e.g. those affecting the auxiliary feedwater condensate storage tank level instrumentation and safe shutdown system diesel generator jacket cooling water system) that had been experienced in the previous year, were not brought to the attention of the freeze protection coordinator or evaluated to ensure that protective measures that had been taken in the previous year, would be effective in the current yea The licensee had documented cold weather-induced problems with auxiliary feedwater condensate storage tank level instrumentation as early as 1991 in PIP 0-C91-0304: the inspector noted that a problem recurrence had been documented in NRC inspection report 50-413,414/94-07. Operating experience during the winter months is a source of information that could improve the thoroughness of cold weather preparations and enhance the effectiveness of a cold weather protection program. The inspector considered the lack of this information on less salient equipment problems a missed opportunity to correct potentially persisting deficiencie ENCLOSURE
.
.
7. Freeze protection annunciator response procedures The ins)ector reviewed the F/8 annunciator response procedure,
" Trace leating Freeze Protection Outdoor Trouble," to verify that the licensee's procedures have sufficient immediate and supplementary actions to preclude freezing in the event of a failure of the freeze protection system. The procedure indicates that probable causes of the annunciator alarm are (1) loss of power supply to heat tracing panelboard 2HTP6 or (2) malfunction of a heat tracing transformer. Although no immediate actions are specified, the supplementary actions are to (1) dispatch an o)erator to determine which panelboard is alarming. (2) verify tlat power to each transformer is energized and the feeder breaker is closed, and (3) initiate a work request to have the cause of the transformer malfunction investigate A corrective action to revise the F/8 annunciator response procedure is documented in PIP 0-C96-1232. The revision will consist of the addition of two Su)plementary Actions to the procedure: (1) a step to stress tie urgency of having the problem corrected during the months of November.to March, and (2) a step prompting the operator to contact the engineering group to assist in identifying the affected equipment and to evaluate the need for-temporary backup heating. The inspector considered these supplementary actions sufficient to preclude freezing in the event of a failure of the freeze protection syste . Effects of a failure of a single train of non-safety-related freeze protection system on safety-related systems The licensee has documented a corrective action in PIP 0-C96-1232 to (1) evaluate the effects of a-failure of a single train of non safety-related freeze protection on safety-related systems, and (2) evaluate the adequacy of established compensatory measures for safety-related systems that can be adversely affected. At the end of the inspection period, this corrective action was outstandin The inspection effort also focused on the licensee's efforts to initiate a formal cold weather protection program at both the corporate and site levels to verify that programmatic controls were adequat Station PIP 0-C96-1232 documents issues that were identified during a station evaluation of the cold weather protection )rogram. The PIP included (as of May 1996) a list of 31 issues tlat needed to be evaluated. Corrective actions were developed to resolve these issues. Resolution of about half of the items listed was contingent upon feedback from system engineers on cold weather-related equipment vulnerabilities and operating experience to be incorporated into the station progra At the end of the report period, only one-third of the information had been provided to the freeze protection coordinator, and the ENCLOSURE
. - . - - . . . - . - - - - _ _ _ . --
.
.
due date for closing these corrective actions was moved from November 30 to December 30. 199 General Office PIP 0-G96-0328 documents the findings of a Cold Weather Protection Program Performance Assessment that was performed by the Duke Power Company (DPC) corporate office. The PIP documents cold weather preparation programmatic and procedural deficiencies at all three DPC nuclear sites that could result in i inadequate protection of plant equipment from freezing condition A generic. utility wide finding of the assessment was that ;
administrative controls for cold weather were not adequately proceduralized, resulting in possible inadequate protection of plant equipment and delays in preparing for cold weather: the assessment was completed in September 1996, and documented in the PIP on October 3 Station PIP 0-C96-2916 was generated to document observations from the assessment pertaining to Catawba and recommendations for managing cold weather pre)arations at Catawba during the 1996-7 winter season or until a luclear System Directive (NSD) could be finalized to delineate the scope of the program, administrative I controls and group responsibilities. The recommendations were i broad in scope and proposed thorough, detailed investigation and preparation activities. Several of the recommendations were implemented: a freeze protection coordinator was designated, some work scheduling deficiencies (activity initiation due dates and grace periods) were im) roved, and critical system vulnerabilities were selected for mont11y monitoring. However, many of the recommendations were not incorporated into a programmatic structure and were not included in the station's cold weather preparations. The inspector considered this to be a function of the timing of the assessment and subsequent lack of time available to implement the recommendations in preparation for the current cold weather seaso Duke Power Company had been drafting a NSD for cold weather l
preparations since the spring of 199 At the end of the inspection period, the NSD was still in draft form. As a result, programmatic guidance on fundamental issues (e.g. program initiation schedule and program scope to focus on equipment freezing versus broader, cold weather precautions such as moisture l condensation) as well as programmatic details was not available to the sit c. Conclusions The inspector concluded that the licensee has endeavored to identify. at the corporate and site levels, programmatic deficiencies in cold weather protection efforts. Corporate and site assessments have effectively revealed problem areas, and ensuing recommendations have been thorough
'
ENCLOSURE i
. __ _ _ _ . _ . _ _ _ . _ _ . . _ _ _ _ _ . _ _ ____ _..___
'
,
i !
i j
'
t
! I
and broad in scope. The designation of a cold weather protection' s
coordinator and adjustments to the work scheduling system constituted !
- site improvements. However, progress toward drafting both corporate and I
! station guidance in the development of a structured cold weather i protection 3rogram has been untimely and narrow in scope. The inspector 4 concluded tlat. although equipment problems attributed to cold weather i
- and freezing temperatures have been identified previously by both the !
j NRC and licensee, the licensee's efforts to implement a cold weather i protection program have not been commensurate with the significance of and frequency with which equipment problems have been encountered during i previous winter seasons. No equipment problems have resulted from j
. exposure to cold weather or freezing temperatures thus far this seaso i
l 05 Operator Training and Qualification
i 05.1 Job Performance Measure Evaluations (71001)
! a. Insoection Scooe i
During the period of October 21 - 25, 1996, the inspector reviewed the
, licensee's licensed o3erator requalification program to determine 1 compliance with 10 CFR 55.59. Requalification. The inspector used 1 Inspection Procedure 71001 to review and evaluate the licensee's operator requalification program in the area of Job Performance Measure (JPMs) evaluation I j b. Observations and Findinos !
i :
i The inspector observed the administration of JPMs to Senior Reactor
! Operators (SR0s) and Reactor Operators (R0s) on the simulator and in the
'
plant. The licensee evaluator's grading was consistent with that of the inspector's. Evaluators effectively queried the operators using follow-i up questions based upon operator performance. This allowed the
! evaluators to determine generic or individual areas needing improvement.
l There were no JPM failures observe .
! c. Conclusions i
<
The inspector concluded that the licensee's evaluators administered JPMs l 4 effectively and consistentl .2 Crew Communications and coerator Performance (71001)
l i a. Insoection Scooe
The inspector used Inspection Procedure 71001 to review and evaluate the licensee's operator requalification program in the area of crew
- communications and operator performanc !
i a
j ENCLOSURE i
l
., , - _ .:-,.,_
_ . _ . _ _ _ _.__ _ . _ _ _ _ _ _ _ _ _ _ _ _ .
l I
. )
'
b. Findinas and Observations f
The inspector observed the administration of two dynamic simulator scenarios to three crews. The crews consisted of five operators; two ;
SR0s. two R0s and one STA. The inspector observed that crews, during page announcements, did not provide informative plant status to personnel outside of the control room The inspector also noted that
,
i plant announcements concerning major plant equipment starts or stops !
during normal plant and emergency evolutions are not performe Operations Management Procedure 1-11. " Operations Communications Standards," did not have a requirement to announce the starts / stops of ,
major plant equipment. However, a safety hazard may be present to plant i l personnel.in the immediate area of the equipment. The inspector observed that R0s did not regularly report equipment auto-start ,
malfunctions to the Control Room SRO or the Operations Shift Manager 4
,
when-the equipment was able to be manually placed in service. The '
l inspector observed that operators generally met 0)erations Managements communications standards delineated in OMP-1-11.10 wever, R0s did not >
'
report specific plant status when the Control Room SR0 read a step in the emergency operating procedure. The R0s would repeat back the ste), 1 but, would not provide actual plant status. An example of this was w1en
,
the SRO asked if pressurizer level was greater than 17%. The repeat
- back was, "Yes, pressurizer level is greater than 17%." Specific plant i l status was not provided. This practice of not providing detailed plant I status can slow down the implementation of the procedures. It forces l the SR0 to request specific plant status after a step has been acknowledged. The inspector also observed operators who failed to take j l appropriate action until they obtained concurrence from the SRO and the
- Operations Shift Manager prior to taking procedurally directed actions.
l An example of this was during Steam Generator depressurization following i a tube rupture. The R0s were provided with specific plant parameters,.
I which when achieved, required stopping the depressurization. The R0s did not automatically stop the depressurization but waited to obtain concurrence from the SR0s when these plant parameters were met. This caused the parameters to be exceeded.
I c. Conclusions l
The inspector concluded that communications, in general, were !
satisfactory, however, improvements could be made. Concerning plant '
i announcements, the inspector concluded that more information concerning l plant status could be provided to personnel outside the control roo l In the area of announcing changes to major plant equipment, the i
'
inspector concluded that additional attention is necessary in this are In the area of repeating back s)ecific plant parameters, the inspector concluded that repeating back t1e actual value of the specific parameter requested would reduce confusion and increase the efficiency of l emergency operating procedure implementation. The inspector concluded '
that R0s should perform required action steps when plant parameters have been met without soliciting the concurrence of control room supervisor ENCLOSURE l I
-. . -- - - - - .
l
.
n
05.3 Simulator Scenario Evaluation (71001)
a. Insoection Scone The inspector used Inspection Procedure 71001 to review and evaluate the licensee's operator requalification program in the area of simulator scenario evaluatio b. Findinas and Observations I The inspector reviewed the dynamic simulator scenarios administered I during the inspection week. The dynamic scenarios were considered I satisfactory and met the requirements of scenario constructio The inspector reviewed the simulator scenario grading criteria. The inspector noted that the licensee used Generic Westinghouse Owners Group Critical Tasks for crew performance. Crew performance was evaluated using Crew Critical Tasks (CCTs). Individual performance was evaluated l using individual competencies. It should be noted that CCTs are not i required by regulation to evaluate crew performance. The inspector ;
determined that many CCTs were not based on specific plant 3arameter !
rather they were based on generic Westinghouse critical tascs, coupled i to procedural anchor The inspector observed the administration of simulator scenarios by the licensee's evaluators. The final facility evaluators'
grading / evaluation was consistent with the inspector's. The inspector noted that evaluators effectively used post-scenario follow-up questions concerning operator action The inspector reviewed final individual evaluation reports. The inspector noted that evaluators regularly provided comments for competency values less than "3."
c. Conclusions '
The ins)ector concluded that while the simulator scenarios were i
'
accepta)le they could have been enhanced to capture specific plant equipment interactions which would have provided additional com)etency evaluation for the examination team. The inspector concluded tlat CCTs ,
could be improved to encompass more objective performance measures that contain measurable performance indicators. Objective performance .
measures allow a common ground for evaluators to objectively evaluate I operator performance. The inspector concluded that CCTs. as writte may fail to identify less than satisfactory performance. The inspector concluded that the licensee's evaluators effectively used follow-up questions to ascertain individual and group knowledge deficiencie The inspector also concluded that documentation of competencies with less l ENCLOSURE l
j
.-
than a value of "3" was a good practice. Maintaining documentation concerning less than satisfactory performance allows trending of operator performance and determination and tracking of generic operator weaknesse .4 Documentation and Remediation of Failures (71001)
a. Insoection Scooe
~
The inspector used Inspection Procedure 71001 to review and evaluate the licensee's operator requalification program in the area of documentation and remediation of failure b. Observations and Findinas The inspector reviewed examination documentation, remedial training and retesting of two operators that failed annual requalification examination The inspector noted that adequate documentation was provided for examination failures and that remedial programs administered contained pertinent and substantive topic c. Conclusion The inspector concluded that the licensee's examination documentatio remedial training and retesting programs were satisfactor .5 Ooerations Manaaement Practices (71001)
a. Insoection Scoo_q The inspector used Inspection Procedure 71001 to review and evaluate the licensee's operator requalification program in the area of Operations Management practice b. Observations and Findinas The inspector observed a cooperative relationship between Operation erations Management. and tne Training Department. The inspector o) served that Operations Management participated in the annual requalification examinations. This 3ractice is not currently required by plant procedure. The inspector o) served that the Operations Training Manager acted as the operations representative during one simulator sessio c. Conclusions The inspector concluded that Operations Management has committed to participate in annual requalification examinations. The inspector viewed this as a good practice. However, the use of the Operations Training Manager as the Operations Representative does not necessarily
,
ENCLOSURE
. __ - -- -= - - - - . _ - _ . . .
.
.
provide an independent view of the training department's performance or crew's performance by the operations department. In addition, it may :
not provide current Operations management expectations to the cre l 05.6 Emoloyee Trainina and Qualification System (71001) ,
l a. Insoection ScoDe The inspector used Inspection Procedure 71001 to review and evaluate the licensee's operator requalification program in the area of Employee Training and Qualification Syste b. Observations and Findinas The inspector reviewed Catawba Nuclear Station Problem Investigation Process (PIP) report (0-C96-1566) concerning the Employee Training and Qualification System (ETOS). The Operations De)artment requested that the Employee Training and Qualification System Je audited by the Nuclear Assessment and Issues Department from the General Office Group because ETOS requirements for some 0]erations personnel had not been completed as required. Two of the tas(s identified required requalification to new standards because of recent plant modifications using new equipment in the areas of air compressors and a new computer. The PIP identified areas where deficiencies were found concerning operations personne The type of deficiencies identified were failure to satisfy necessary <
cualification requirements and a failure to adequately process '
cocumentation following completion of qualifications. Additionally. the PIP identified there was inadequate information available to determine if the process to notify and track expired qualifications was effective and to ensure that requalification was accomplished after notification of delinquency. The review identified at least three tasks in which significant numbers of operations personnel were not currently quali fied. The inspector discussed these areas with the Operations Superintendent and found reasonable assurance that operators qualifications were no longer of concern. When the problems with ETOS were initially identified, Operations Management instituted a corrective l action program to determine what qualifications were missing and what was necessary to qualify all personnel in their deficient qualifications. The corrective actions requalified the delinquent operators in those areas needi-ng requalification. At the end of the inspection, the inspector was unable to verify completion of all i corrective actions delineated in the PIP. The proposed corrective l actions due date for this PIP was December 23. 1996. Since all corrective actions have not been completed. this item is characterized as Inspector Follow-up Item 413.414/96-18-01: Verification of Corrective actions for Documentation of Training and Qualification.
ENCLOSURE l
i
_ __ _ - _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
i .
!
i i 12
) c. Conclusion i
'
.
The inspector concluded that Operations Management has aggressivel ,
pursued the identification and correction of problems with the Em)1oyee i Training and Qualification System. Previously. Plant Management lad not i j provided the proper amount of emphasis / attention on the Employee' !
1 Training and Qualification System. The inspector concluded that since j- the PIPS corrective actions have not been completely closed ou , additional review of corrective actions was necessary. Specific i j operator qualifications will be checked as part of this inspector i
[,
follow-up item.
j II. Maintenance l M1 Conduct of Maintenance M1.1 Standby Makeuo Pumo ReDair and Testina l
i a. Insoection Scope (62707. 61726)
, On Thursday. November 21. a discharge pressure test rig fitting failed j_ during a Standby Makeup Water Pump quarterly test. Operator actions in
response to the failed fitting resulted in damage to pump discharge
] pressure relief valve 1NV-866. Subsequent attempts to test the pump were unsuccessful. The licensee determined that air had entered the j system during maintenance of 1NV-866. and the pump discharge pulsation ;
) dampener was damaged as a result. The inspector reviewed the i
'
circumstances which lead to damage to the pump's discharge dampener, i
- observed portions of the maintenance and inspections of potentially l
! damaged components, and assessed licensee actions to prevent recurrence.
t b. Observations and Findinas k On November 21. operators were performing a Standby Makeup Water Pump
,
quarterly test when a discharge pressure test rig fitting failed and
started spraying water. An operator, located at the pump recirculation valve adjusting valve position to obtain the desired pressure for flow data acquisition, immediately throttled the recirculation valve closed
.
in an instinctive effort to stop the leak. This action caused pump discharge pressure (and flow through the failed fitting) to increase.
'
.
The operator quickly reversed the action and opened the valve to reduce
! pressure and flow through the failed fittin However, the initial
- pressurization caused relief valve 1NV-866 to open.
The relief valve incurred some damage and was repaired. On November 23 i the licensee made several attempts to complete testing and observed
, pressure fluctuations and insufficient flow rates. A Failure i Investigation Team was initiated to determine the cause of the pressure j and flow anomalies, j ENCLOSURE
.
-
_ _ - _ __ - _ _ . _ _ _ _ _ _ - - - _ . - _ _ _ - _ _ _
-
t
-
!
The licensee disassembled the Unit 1 standby makeup pump on November 25 '
to investigate the cause of low pump discharge flow and to perform inspections of the Jump internals for aossible debris or foreign material generated ay the failure of t1e pump discharge pulsation dampener bellows (MWO 96093879). The inspector observed the internals of the pump following disassembly and verified that no debris from the bellows migrated into the suction or discharge headers of the pum The inspector noticed flakes of rust were in the discharge of the number 1 cylinder. The licensee had previously identified these corrosion products during the initial disassembly and had initiated a review to determine the source. The licensee determined that the corrosion products originated from the number 1 discharge cylinder cover which had a carbon steel insert 'on the portion of the cover exposed to borated water. The remaining nine cylinder covers had stainless steel inserts which are not susceptible to boric acid corrosion. The licensee determined that the cover with the carbon steel insert was an incorrect part. This part was supplied with the original pump by the pump manufacturer during initial )lant construction. The licensee cleaned and reassembled the pump wit 1 the carbon steel cover and performed an operability evaluation to justify o)erating with the carbon steel cover until the next refueling outage. lie inspector reviewed the operability '
evaluation (PIP 1-C96-3137) and concluded that continued operation with the carbon steel insert would not impact performance of the standby i makeup pump or reactor coolant pump seal On November 26. the inspector witnessed final fill and venting of the Unit 1 standby makeup pump and performance of PT/1/A/4200/07C. Standby Makeup Pump #1 Performance Test, approved February 17, 1993. The '
inspector verified that the pump was properly filled prior to-flow verification testing. The inspector also verified that the proper test equipment and fittings were used during pump testing. Pump flows met the flow rates required by TS, and discharge piping vibration monitoring confirmed that the modified pulsation dampener functioned appropriatel ;
c. Conclusions 1 The apparent cause of the dampener damage was air entrainment in the l system during maintenance of relief valve 1NV-866. In addition, the l test rig fitting failure was attributed to the use of an inappropriate fitting and the relief valve damage was caused by the throttling of the ;
recirculation valve. Maintenance activities following the failure of the Unit 1 standby makeup pump pulsation dampener were well coordinated and executed. Extensive modification, inspection and testing of the pump were completed prior to the expiration of a TS action statement that would have required a unit shutdown. Engineering sup) ort in the form of an evaluation of standby makeup pump operation wit 1 an incorrect cylinder cover and implementation of a minor modification for the
,
replacement of the discharge dampener was appropriat ENCLOSURE
.-.
.
I
.
M1.2 Unit 1 A Main Transformer Coolina Fan Failure and Oil Leak i l
a. Insoection Scone (62707) l l
On October 27, the Unit 1 control room received a Main Transformer 1A I trouble alarm. Operators responded to the 1A transformer and investigation revealed that a gas detection alarm had actuated and a cooling fan in cooler #2 had broken from its shaft. During investigation of the source of gas in the transformer, a low transformer oil level alarm was also received. The licensee deenergized the fan l motors and oil pump associated with cooler #2 as part of the l troubleshooting. When the oil pump was deenergized a severe oil leak l began on the pump suction piping. Operations then entered Ra)id 1 Downpower procedures and reduced Unit 1 power to 50% within t1irty minutes secured the 1A main transformer and isolated the oil leak. The inspector discussed the issue with licensee personnel, reviewed PIP 1-C96-2880 which documents the failure and reviewed the results of the licensee's failure investigatio b. Observations and Findinas The source of the gas in the transformer and the oil leak both resulted from a cracked weld in the cooler #2 suction piping. Excessive vibration when the fan in cooler #2 broke from its shaft which initiated the crack. Outside air was then drawn into the transformer which initiated the transformer gas detection alarm. The severe oil leak occurred when oil was forced out of the cracked weld by pressure from l the 8 other operating transformer oil cooler pumps after the cooler #2 l pump was shutdow l The licensee subsequently performed visual examinations of all l transformer cooler fans. One fan that had a crack indication was replaced. A metallurgical examination of the failed cooler # 2 fan blade which was performed as part of the licensee *s failure investigation determined that the fan failure was not a premature failure. The fan had reached the end of its normal service life. The l licensee initiated actions to perform random nondestructive examinations l of a sample of transformer cooler fans to determine if other fans were l approaching the point of failur Transformer repair activities included removing the damaged cooler unit I and isolating and installing blank flanges to the cooler pipe 1 connections. Since oil level in the transformer did not decrease below the top of the transformer windings the licensee in conjunction with the ,
corporate transformer maintenance support personnel decided to top off l the transformer with the volume of oil that had leaked (800 gallons) and vent the small amount of air that was expected to remain after fillin The 1A transformer was then placed back in service and Unit 1 power was increased to 100%. After approximately 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, small amounts of air were still required to be vented from the transforme Venting was l ENCLOSURE l
_ _ _ __ _ _ _ _ _ _ _ _ ._ _ _ _ _ _ _
j
.
.
I
initially expected to be required for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Corporate transformer maintenance support personnel were contacted and determined i venting for this extended' period of time was an abnormal condition that may have resulted from an air pocket that remained trapped below the transformer core or air suspended in the oil since the initial cooler 1 piping weld failure. As a result a Unit 1 power reduction to 50% was .
initiated and the 1A main transformer was removed from service again to l completely drain and vacuum refill the transformer to remove all i entrained air. Degassing and vacuum refill activities were completed successfully and the. transformer was placed back inservic c. Conclusions The investigation of a Unit 1 main transformer cooler failure was effective in identifying the cause of the failure and initiating actions to prevent future fan failure Returning the 1A main transformer to service with air entrained in the oil system' occurred because of a lack of experience or knowledge with~ this type of failure. The licensee's subsequent actions to reduce power deenergize the 1A main transformer and degas the transformer oil system were appropriat M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Warehouse Storaae Condition Walkdown a. Insoection Scooe (62707)
The inspector performed a walkdown of warehouse storage conditions and reviewed corrective actions for a licensee identified problem with the storage of a spare containment spray pump motor in the contaminated warehouse (PIP 0-C96-2488).
b. Observations and Findinas Items stored in the contaminated material warehouse were appropriately packaged, boxed or wrapped to prevent the spread of contaminatio Access to the contaminated material warehouse was controlled. The licensee had initiated work requests to energize heaters in a spare containment s) ray pump motor that was found without its heaters ,
energized. T1e licensee is also reviewing overall motor storage !
practices to correct any similar motor storage deficiencies. The inspector found that storage conditions in the non-contaminated warehouses were good. The storage areas were well lit and clean. Items were neatly stored on shelves and clearly labeled. The licensee addressed minor discrepancies that the inspector identified during the ,
walkdow ENCLOSURE
,
.
. _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _ _ _
l
!
.
.
'
,
c. Conclusions-Warehouse storage conditions were found to be goo The licensee took ,
appropriate corrective actions to review motor storage practices following the identification of an improperly stored moto M3 Maintenance Procedures and Documentation M3.1 Offsite Power Verification i Insoection Scooe (71707. 61726) ;
On November 2 the control room Senior Reactor Operator identified that i Technical Specification action 3.8.1.1.a1 was not performed as required when the 2A diesel generator was cut of service for normal maintenance testing for 64 minutes. The inspector discussed the missed TS ,
i surveillance with operations personnel: reviewed the associated l maintenance )rocedure, station PIP and Licensee Event Report (LER 414/96-06). iissed Technical Specification Surveillance for AC Offsite )
Power Sources: assessed the adequacy of proposed corrective actions; and i verified that corrective actions had been completed.
j Observations and Findinas f l On November 1 the 2A diesel generator was removed from service and ,
l placed in maintenance for normal diesel generator maintenance testing ;
per PT/2/A/4350/02A, approved September 30. 1996. On November 2 the- :
control room Senior Reactor Operator discovered that the diesel was
,
inoperable the previous day from 10:13 a.m. until 11:17 a.m. , for a l l
'
total of 64 minutes and that Technical Specification action 3.8.1.1.a1 1 was not performed. The action requires operators to demonstrate the operability of the remaining required offsite circuit by performing Specification 4.8.1.1.la (verifying correct breaker alignments and i indicated power availability) within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
L The licensee speculated that a procedural discrepancy contributed to the I
missed TS surveillance. The ins)ector discussed this possibility with a I 3rocedure writer who indicated tlat two procedures had been changed:
)T/2/A/4350/02A. Diesel Generator 2A Operability Test, and OP/1(2)/A/6350/02. Diesel Generator Operation. The change incorporated a vendor recommendation to bar and air-roll the DG oefore starting i The inspector obtained a copy of the maintenance procedur PT/2/A/4350/02A approved September 30, 1996, to determine if procedural guidance for barring and rolling the diesel generator was adequat A note at the beginning of the procedure stated "Due to the short duration of the inoperability, the following considerations, which are normally performed with the inoperability of a D/G. are not required."
The performance of PT/1/A/4350/02C. Available Power Source Operabilit !
was listed as one of the considerations that was not require Step ENCLOSURE
'
-_ . . . - . _ .
..
_ - - - - - - . - - - . . _ ~ - - - - - -..
.
.
12.12'of the procedure directed operators to bar the diesel generator per Enclosure 13.7 and step 12.13 directed operators to then roll the diesel generator per Enclosure 13.6. The ins)ector determined that the procedure change to bar the diesel generator Jefore rolling it had been made without consideration of the additional time incurred by performing both tasks, the subsequent impact on duration of inoperability, and the a)propriateness of the guidance provided in the note at the beginning of t1e procedur A'second note in the procedure stated that "the inoperability of a D/G is ng1 required to be logged in the [ Technical Specification Action Item-Log] computer, but may be logged for tracking )urposes if desired." The 3ractice is for control room operators to log Xi inoperability in the Reactor Operator Logbook, but this practice is not well defined with a formal structure and clear expectations and, in this case, was not used to ensure actions were performed as required by TS The LER conclusion attributes two root causes to the missed TS surveillance: (1) management expectations for short-term inoperability items have not been well-defined, and (2) insufficient detail was 3rovided in the test procedure. Corrective actions included changes to 3T/1(2)/A/4350/02A(B) to (1) provide one enclosure for barring and rolling the DG: (2) remove guidance on short-term inoperability, and (3)
perform the available AC power source operability test before placing the DG in maintenance mode. The inspector verified that these chances were made to the procedure, which was approved November 5. An operator update was issued to communicate the procedure change, and a step was added in OP/1(2)/A/6350/02, Diesel Generator Operation. enclosures to complete the available AC power source operability test before checking for cylinder head leakage or barring a DG. An additional planned corrective action is to create a quality improvement team to improve the tracking of short-duration inoperabilitie c. Conclusions The inspector concluded that the root cause determination and corrective actions were appropriate. The inspector also reviewed a previous LER (50-414/95-006) for a missed offsite power availability surveillance and concluded that the root causes were different (see Section M8.2).
Therefore, corrective actions for that issue would not be expected to have prevented the recent occurrence. This licensee-identified and corrected violation is characterized as Non-Cited Violation 50-414/96-18-02: Inadequate Procedure Results in Missed AC Power Availability Surveillance, consistent with Section VII.B.1 of the NRC Enforcement Policy. LER 50-414/96-06 is close ,
!
L I ENCLOSURE W
.--- ,
_ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ . _ . _ _ _ _ _ . _ .
-
i
.
M8 Miscellaneous Maintenance Issues (92902)
M8.1 (Closed) LER 50-414/95-06: Missed Technical Specification Surveillance for AC Offsite Power Sources. On December 15, 1995, at 2:35 a.m. the-control room SRO identified that a verification of Unit 2 offsite power availability was not performed as required at 1:00 a.m. The licensee completed the surveillance within 25 minutes of this discovery. The i
, cause was determined to be a result of inattention to detail by the Unit l 2 operator at the controls who was involved in performing a power
. reduction maneuver prior to the time the surveillance was missed. The licensee's corrective actions included counseling the operator and discussing this event with all control room operator The inspector verified the licensee's corrective actions were complete In addition, since 1995, the licensee has implemented a detailed daily schedule of control room work activities to evenly distribute control room work activities throughout the day. The licensee also has an ongoing human performance improvement 3rogram which is intended to reduce human errors of this nature. T1e inspector concluded that the
, failure to perform the offsite power availability verification was a l violation of TS action requirement 3.8.1.lc. AC Sources. This licensee
,
identified and corrected violation is characterized as Non-Cited i i Violation 50-414/96-18-03: Personnel Error Resulting in Missed AC Power 1 Availability Surveillance. consistent with Section VII.B.1 of the NRC :
Enforcement Polic III. Enaineerina E2 Engineering Support of Facilities and Equipment l
E2.1 Refuelina Water Storaae Tank Heater Leak Insoection Scooe (37551)
On July 24, 1996, the licensee identified steam coming out of a weep hole in electrical conduit from a Unit 1 refueling water storage tank
- (FWST) heater. The licensee initiated a modification to enclose the heater to contain the leak; this rendered the heater non-functiona The licensee performed an evaluation to demonstrate that minimum tank temperature could be maintained with the three remaining heaters. The inspector discussed the modification with engineers involved and reviewed PIP 1-C96-1870. work orders associated with the modificatio and the engineering evaluation in support of the modificatio Observation and Findinas On July 24. 1996, the licensee identified steam coming out of a weep
- hole in electrical conduit from a Unit 1 refueling water storage tank l (FWST) heate To contain the leak, the licensee initiated a
- modification to enclose the heater in a flanged pipe, which would serve
! ENCLOSURE
-
. . . -. . - ..
_ ._. _ _____ ____.____._..____._-m_
l
'
.
.
19 i l
as the pressure boundary. The inspector discussed the modification plan I with the engineers involved and concluded that the approach to containing the leakage was reasonabl Per the Updated Final Safety Analysis Report (UFSAR), four immersion-type heaters are used to maintain the FWST above 70 to preclude possible damage to the containment vessel as a result of an inadvertent operation of the Containment Spray Syste i l Each heater has a 30 kW capacity, yielding a total output capacity of.
l 120 kW. Because the modification required all conduit to the affected
! heater to be disconnected, the heater would not be operable. The licensee performed an evaluation to demonstrate that minimum tank temperature could be maintained with the three remaining heaters, generating a total capacity of 90 k The inspector. reviewed calculation CNC-1249.00-00-0065 to determine if the analysis was logical and thorough. In reviewing the calculation the inspector determined that the licensee accounted for heat losses from
- the tank to the ground and to the environment through the tank walls.
l
'
which are insulated, and roof. which is not insulated. Heat losses were quantified assuming a minimum temperature of -5 F. An assumed wind velocity of 20 mph was factored into the equation for quantifying heat l loss to the environment through the tank walls; however, wind velocity l
was not factored into the calculation for heat losses from the roo The calculation illustrated that the heat losses amounted to 81.88 k which is within the 90 kW capacity of the 3 remaining heaters. Since the walls are insulated and the roof is not, the inspector questioned the validity of the calculation if a wind velocity factor is not considered in the heat loss calculation from the roof. The licensee planned to address the question in a revised analysis, Conclusions
,
The inspector considered the licensee's efforts to mechanically contain l the FWST heater leak appropriate. However, pending resolution of the wind velocity factor for calculating heat losses through the FWST roof.
'
l this issue is characterized as Inspector Followup Item 50-413.414/96-18-l 04: Quantification of FWST Heat Losses Through Tank Roof Including a Wind Velocity Factor.
,
IV. Plant Sucoort P2 Status of EP Facilities, Equipment and Resources P2.1 Annual Auomentation Drill (71750)
On October 20 the inspector observed the performance of an annual unannounced after-hours augmentation drill. Emergency Response Organization pagers were activated to announce the drill at 3:53 p.m. on ENCLOSURE l !
,_ ._ _
. _
_ _ _ _ _ . . . _ _
.
.
a Sunday to coincide with the last two minutes of a Charlotte Panthers football game. The objective of the drill was to determine if required Emergency Operations Facility positions could be staffed within a 75 minute time )eriod, as required by their Emergency Plan, with post-game l traffic in t1e vicinity of the Emergency Operations Facilit The resident inspector was present to independently verify that response was executed in accordance with NRC requirements. All required positions were manned within 52 minute i P2.2 Emeraency Drill (71750) l On November 13 the resident ins)ectors. participated in the licensee's semi-annual emergency drill. T1e drill was conducted from the training simulator, beginning at 10:00 a.m. and terminating at 1:00 Inspector participation included manning the simulator and the Technical Support Center. The licensee's critique is documented in station PIP 0-C96-3133. The inspectors reviewed sections of the PIP and determined that discrepancies and strengths identified were appropriately characterized. Corrective actions were assigned and documented in the PIP to resolve areas of concern. In general, the inspectors concluded that licensee performance during the drill was appropriat ,
V. Manaaement Meetinas j X1 Exit Meeting Summary l The inspectors presented the inspection results to members of licensee management on October 21, 1996, and at the conclusion of the inspection on December 10, 1996. The licensee acknowledged the findings presente No dissenting comments were received from the licensee management and no proprietary information was identifie i
!
l
!
,
I l
i i
i
'
ENCLOSURE ;
'
,
i i
.
.
PARTIAL LIST OF PERSONS CONTACTED Licensee Bhatnager. A. , Operations Superintendent Coy. S., Radiation Protection Manager l Forbes J., Engineering Manager l Harrall. T., IAE Maintenance Superintendent ;
Kelly C., Maintenance Manager l Kimball. D., Safety Review Group Manager Kitlan. M.. Regulatory Compliance Manager McCollum. W.. Catawba Site Vice-President Peterson. G., Station Manager Propst. R., Chemistry Manager Rogers. D., Mechanical Maintenance Manager Tower. D., Compliance Engineer l
ENCLOSURE
,
_
.
.
INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61716: Surveillance Observation IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71714: Cold Weather Operations IP 71750: Plant Support Activities IP 77001: Licensed Operator Requalification Program Evaluation IP 92902: Followu) - Maintenance IP 93702: Onsite Response to Events ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-413.414/96-18-01 IFI Verification of Corrective actions for l Documentation of Training and Qualification (Section 05.6)
50-413/96-18-04 IFI Quantification of FWST Heat Losses Through Tank Roof Including a Wind Velocity Factor (Section E2.1)
Closed 50-414/96-18-02 NCV Inadequate Procedure Results in Missed AC Power Availability Surveillance (Section M3.1)
50-414/96-18-03 NCV Personr.el Error Resulting in Missed AC Power Availability Surveillance (Section M8.1)
50-414/95-06 LER Missed Technical Specification Surveillance for AC Offsite Power Sources (Section M8.1)
50-414/96-06 LER Missed Technical Specification Surveillance for AC Offsite Power Sources (Section M3.1)
ENCLOSURE
l
.
1
Alternating Current CCT -
Crew Critical Task CFR -
Code of Federal Regulations .
DPC -
Duke Power Company l ETOS - Employee Training and Qualification System i FSAR - Final Safety Analysis Report IAE -
Instrument and Electrical IFI -
Inspector Followup Item IR -
Inspection Report i JPM -
kilovolts LER -
Licensee Event Report NCV -
Non Cited Violation NSD -
Nuclear Site Directive PIP -
Problem Investigation Process SR0 -
Senior Reactor Operator TS -
Technical Specifications !
TSAIL - Technical Specifications Action Item Log UFSAR - Updated Final Safety Analysis Report VIO -
Violation WO -
Work Order i
l l
ENCLOSURE
l
<