ML20198L821
| ML20198L821 | |
| Person / Time | |
|---|---|
| Site: | Fermi, 05000000 |
| Issue date: | 06/04/1985 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19264F027 | List: |
| References | |
| FOIA-86-278 NUDOCS 8606040400 | |
| Download: ML20198L821 (57) | |
Text
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. 301 492 7921 p l/86 12:14 tRC-MLM-tNBB to.003 012 -
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,.$ , %, UNITED STATES NUCLEA' -
$ "g R REGULATORY COMMisslON
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MEGION lla
- 1. 79s moostvtLT poAo .
' ..... sten cu.ves. stue.ons sein June 4, 1985
- MEMORANDUM FOR
- Harold R. Denton, Director, Office of Nuclear Reactor Regulation .-
, FRON:
-James G. Keppler, Regional Administrator, RIII
SUBJECT:
FERMI UNIT 2 QA REPORT s
The enclosed report is for inclusion in the Commissicn b'riefing .
4 A.A ~ .
ldJamesG.Keppler Regional Administrator A
Enclosure:
Bases for the Staff's
- 7 Confidence in the Quality of ~
Construction of Fermi 2
! cc w/ enclosure: "
W. J. Dircks, E00 ~
'. D. Eisenhut, NRR
s J. Tay1or, 1E
' e60604o400 8606o2 .
h seSb 278 PDR 0 3-
3TET1 492 7F21 05/0146 12:14 tEC-MSM-Mt4BB t40. 003 011 FERMI UNIT 2 QA REPORT Bases for the Staff's Confidence in the Quality of Construction at the Fermi 2 Plant The staff is confident that the quality of construction at the Fermi 2 facility is adequate. The bases for this confidence is as follows: .
- 1. Region III has expended over 28,000 man-hours c.' "section time at the Fermi 2 facility. The number of inspections ano .. ociated man-hours are summarized as follows:
Number of Year Inspections Man-Hours 1970 5
- 1971 3
- 1972 4 .
1973 10
- l 1974 8
- 1975 4 62 1976 6 g(. 249 .
1977 3
347 .
1978 20 896 1979 -
26 1,193 1980 23 1,214 1981 20 1,736 1982 21 2,359 1983 32 4,910
- 1984 68 11,377 1985 (As of May) 24 4,242' 70TAL ~2R 21G5115
- Man-hours were not specifically tracked prior to 1975.
- 2. During the construction and preoperational testing phases, there were no Severity Level III or above . items of noncompliance, NRC Orders, or Civil Penalties issued. All problems which have been ictentified have been subsequently resolved or are currently being reviiwed for resolution.
- 3. . Region III conducted a special Mini-Construction Assessment Team (CAT)
- inspection in June-July,.1982. The purpose of this inspection was to assess construction activities and the QA program to determine if
- construction problems existed or had the potential to exist at Fermi
, _. , . - - , , , , -<,w- , - - - - - - - - - - - "
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301 492 7921 0,5/01/86 12:13 IRC-M&M-m BB NO.003
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4 that were similar to problems identified at Zimmer and team consisted of six inspectors (including the other plants.
Seriier R The I who spent 481 hours0.00557 days <br />0.134 hours <br />7.953042e-4 weeks <br />1.830205e-4 months <br /> onsite conducting the inspection esident Inspector) ,
l that the overall Quality Assurance Program was being implThe tea factority.
emented satis-any significant hardware deficiencies, and the pl i 4.
constructed substantially in accordance with applicable requirem . -
From the beginning of site to the end of 1976, Detroit Edison maintained a Field QA construction a halt up activ [
with first line inspection responsibilities for organization some of the c '
others. onstruction activities and surveillance and overinspect contracted as Construction Mana s staff QA and QC organizations. ger for all site activities and also to !
responsibility for the auditing of contractor activitiesThe DIC-QA .o inspection of work performed by certain contractors , first line and th i and overinspection of work inspected by others.
organization onsite to overview e surveillance i
DIC and contractors' activities., through audits and surveillances, thi r were integrated with the Edison site rganizations QA organi i Project QAis (PQA) construction organization now complete under Edison supervision m the PQA, because !
g ,!
Assurance (NQA) organization,which will eventually contis evolvi activities for Fermi. rol all QA 5
i
- a. !
From late in 1976 through March of 1985, Edison
, DIC QA, andQA PQA performed a total of 399 site audits resulting in 2 224 findings. }
'During thisresulting 12,356 surveillances same period, in 2,496these findin organizations,perfo rmed were designed to compliment the audit program.gs. The surveillances I Tables 1 and 2 NRC staff has reviewed the licensee's it acceptable.
as found
. Theaudit pr
- b. !
Since the su organizations beginning of tne project, Edison offsite QA and Q and inspections.pported the construction of Fermi 2 through audits ,
vendors, 2,052 sourceAs ofinspections May 1985 there were 346 audits of 31 audits of A/E's and 45 i principal A/E for the proaudits of Edison's Projecte Enginee, ring:
construction activities. ject) which were conducted in support of i I
- c. ,
the authority to stop work.Throughout the lifeaveofhadthe project, th! I orders had been issued. Through March of 1985, 47 stop work 1 i
the latter years of the-project there was lessInneed r the foTable the initiative to take prompt corrective c encies actions were identified, organizations. instead of waiting for escalated action by
i 05/01/86 12:12 iRC-FEM-MNBB NO.003 009 i l d.
- In addition to the above efforts, site contractors' QA and QC organizations have performed many audits of their own activities
! and produced many thousands of inspection and examination reports.
The NRC reviewed selected audits of contractors during the CAT inspection and found them to be acceptable.
5.
During the shutdown of construction, Detroit Edison undertook a compre- '
! hensive long-tens maintenance and preservation program to maintain the
' quality of equipment and materials.
Before equipment was made operational i
at the completion of installation, a refurbishment program was implemented, including overhaul of major components, when required.
inspections by the NRC staff of preoperational testin The extensive effectivness of the licensee',s refurbishment program. g, affirmed the 6.
i, Immediately after the TMI accident, the Chairman of the Board for DECO directed that a Safety Review Task Force be established to conduct a comprehensive review of the plant design to confirm compliance with i design criteria and to analyze the response of plant systems in transient i
of the operator in these events.and accident situations, including multiple
'i including design. engineers, operations personnel and consultants;T 12,500 manhours of effort were involved.
The Task Force concluded that, criteria of 10 CFR 50althoughAppendix A the basic design of Fermi 2 was sound and m l
operator training, eme,rgency proce,dures and system'ty reimprovements in sa P (-
could be d ' (b A11 were accepted and acted upon.achievedthroughtheimple .
g 7.
ggw In late 1979, Detroit Edison "i'tM the Analysis Company to perform a. management contracted with the Management och b e ., s n extensive audit of the Feraf 2 Project covering program. all important areas of project activities including the QA $6h Results of the audit led to some changes within the project bility for some key site functions including QA and QC. org Late in 1982, a Vice President was assigned full' time at t!
l manage the completion of the plant. -
'~ I 8.
In 1980, Detroit Edison began a quality Concerns program which permitted site and to personnel to cosununicate receive prompt responses. anonymously any quality concerns they had and investigated. Approximately 85 concerns were received This program was followed, in 1983, by the current SAFETSAM program onsite and upon exiting which has involved the interview of plant personnel while the site.
upon' final. exiting. Craft personnel are also interviewed.
4 L about any perceived quality problems.This permits personnel to express their c
' concerns had been received of which 734 were safety related.As of May 1985 tions of all but three of these concerns have been completed to date.Investiga-of the investigation of their concerns.Each of those who expressed i
( The NRC reviews all concerns I
301 492 7921 g gi tE41#HUBB **
ments.
received by the SAFETEAN andrequire-more in-de their appl questions.pth inspection accomplished when the inspector a had furt that had notBoth programs have been useful in correcting deficien been previously identified. !
9.
In late with Cygna 1982, Ener Detroit Edison, at the request of the NRC
, contracted
{
i program (10VP) gy Services to perfom an independent design veri -
~
Feraf 2 design forand thethe purpose of assessing design control process the overall adequacy of I design verification on a selected scope ofk.wor.by performing a detailed !
involved the Division II Residual, Heat Removat The area chosen by Cygna !
down path suction line and portions of the assoc (RNR) System primary System (
including the "8" RHR Cooling Tower iated RHR Service Water j Cygna co(ncluded that the ilesign dequate.
program was)a. As a i
)
of the program included in the scopeincluded for the IDVP. a field walkdown An of addedthe systems a'nd feature mponents design were found during the walkdown.No significant deviations from the-
- 10. i In early 1984 ..
Company to per, form an extensive review a ed with of QA rec 1 construction sufficient documenof Fermi 2 for the purpose of determining ere was if th of the QA program. tary evidence attesting to an effective implementat
.( ,
was in place adversely the demonstrated there'were no Jocumentation deficiencies on,the quality quality of the plant. of the hardware, and ey QA record
- 11. ~
At NRC's Edison, in Junerequest, 1984 due to the unavailability of the NRC CAT team, Detroit 3 nical Services group,to furnish a team of qualified o perform personn !
i an assessment of a representative sample of safety ures, related strui systems and of construction at Femi 2. components to provide additional assurance as to t i The scope and plan of the assessment weree qual.ity patterned after the NRC Construction AppraisalonTeam (CAT) ((
module.
Ouke The assessment team was given close oversight by the NRC st ofexpended approximately 4,000 manhours in assessm ,
and reporting results. . The in support of the effort. Detroit Edison devoted more ent activities (eficiencies than 14,000 manhours!
but none The considered Duke assessment identified a number of adversely on,the qualitywere of construction. to be significant enough ect to refl significantly fermi 2. to additional assurance of the The Duke quality effort contributed of const ruction at
- 12. In 1984 urations, and the design in the electrical and in (correct field installation not accurately reflected i ems Thesimilar fled construction problems assessment performed by n wiring Duke rty also identi-Power Comp diagrams).
on a broad scale were;not effective,however, licensee actions to correct t Deco performed an analysis of the e
a
001 492 7921 05/01/86 12:11 GHC-f1&i1-f1t(BB NO.003 007
[
safety significance and presented a program for corrective actions.
Subsequent NRC inspections were performed e.
rrec-tive actions were being implemented in an adequateupport load. manner to s have been adequately addressed.All required actions .
tofuel support iss 10 CFR 2.206 request which was subsequently denied , NRR.
by the Dir O
e
301 492 7921
,01/85 12:11 tRC-tC1-ti4BB to.003 E '
TABLE 1 Quality Assurance Audits
- Number of Number of
- Year Audits Findinos
~
1976 '
2 .
9 1977 ~ ~
34
' 293 1978 33 301 1979 35
~
235
- p. 1980 17
~2'13 '
1981 66 140 1982 59 291 ' .
1983 72 290 1984 .
68
- 405 ~
1985 (thru May 1) 13 47 TOTAL 399 2,224
.s 88y Daniel (DIC), Project QA (PQA), Nulcear QA (NQA), and Offsite Engineering (Troy Engineering Group)
O a
j
__ , , - - - - - . - - - ,w * ' ~ ~ ~ ~ ' _ . _ _ _ _ _ _ _ _ _ _ _ _ . - - - - - - - - - - - - - - - - - - - - - ' - ~ - ' ~ ~ ~
~
301 492 7921 05/01/S6 12:10 NRC-Mp HilBB NO.003 005 -
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i
. TABLE 2 QA Surve111ances Performed
- i Number'of Number of Year
_Surveillances Findinos
, 1977 724' , 88 1978 1,266
~
394 1979 1,735 747 1980 406 168 1981 1,155 '
123 2( 1982 3,178 354 1983 2,764 387-1904 913 . 176 1985 (thru May 1) 215 '
59 TOTAL 12,356 2,496
- 8y Daniel (DIC), Project QA (PQA), Nulcear QA (NQA), and Offsite Engineering (Troy Engineering Group)
/
\'.
n Date issued O
Issued To Reason for Stop Work-11-8-77 W8Ji* ' Date Lifted 11-9-77 Control of welding materials fn Turbine House C.E.I. & S.E. 11-8-77 Unapproved welding procedures h, 12-2-77 .
RICO 12-1-77 12-8-77 Use of drawing not issued by Doc. Control ly-W&B 12-2-77 Missed hold points E3 12-13-77 oA W88 12-15-77 12-14-77 Improper installation of concrete anchors *i8 LKC 12-15-77 Hanger installation deviations .
Q{
12-21-77 Nooter 12-14-77 t4
~
Unapproved welding procedures _
12-28-77 RCI 12-21-77 1-5-78 Weld rod control and welding deviations LKC 1-13-78 G 2-3-78 Violation of material controis f Nooter 1-5-78 $
Impr,oper NDE technfques 3-22 W&B 2-10-78 Welding materfal controls 3-30-78 W8J!
3-23-78 Lack of traveler system procedure 1-31-79 PPP* 4-18-78 Welding materials control 2-20-79 PPP* 2-1-79 j5 Unacceptable welding practices 2-28-79 LKC 2-26-79 No QC witness of 80P cable pulls 5-23-79 Rico 3-2-79 QC Inspector not on site t-7-79 LKC 5-23-79 Lack of timely cobrective action
'-4-80 PPP* 9-18-79 Use.of incorrect weld rods , $ 80 English Electric
- 2-18-80 Failure to follow nonconformance procedure 9-26-86 9
4
. .- . . = . . . '
.C R .
G TABLE 3 'g.*
6 STOP WRK ORDERS ISSUED AT FEAMI 2 h,
Data Issued Contractor Reason for Stop Work Date Lifted 8 10-11-76 NISCO g-Material control deficiencies 10-12-76 b k, 1-14-77 LKC r, Inadequate training and document control 1-25-77 2-1-77 _j E.G. Smith Improper installation of stding fasteners m 3-15-77 tj 4-21-77 NISCO Arc strfkes on RPV' 4-25-77 k 5-10-77 Walcon 4 Use of noncon/orming saterial 6-10-77 '
S 5-13-77 Utley-James $
Inadequate work procedures 6-3-77 g
6-13-77 Kuhlman Lack of certs for cement 6-17-77 7-18-77 LKC Welder cartiffcations 8-4-77 8-16-77 RIC0 hkider certifications 8-22-77 8-23-77 WACD Welding deficienefes 8-24-77 8-26-77 LKC g
use of unapproved procedures 8-26-77 9-21-77 W&8 Grouting not to procedure 9-23-77 9-22-77 A.E. Dafley* Welding procedures deffcieneies 9-22-77 10-12-77 w&B control of weldfrig materials 10-13-77 g 10-18-77 -
WAC0 Conerete placeaent devIatiens 10-22-77 Bo-27-77 A.E. Dalley* Control of welding materfats 10-31-77
]1-2-77 LKC Working without approved documents 11-11-77 b
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. . : ...., a .: _.e.. a _.... m .4..o.t :. ... .e : s _
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Dato Issued Issued To Reason for Stop Work .g .
12-8-80 . -Date Lifted b LKC Cable pulling procedure violations t 3-10-81 12-11-80 -
8 WACo*
Lack of p' ec,cedure for work on cooling tower 6-19-81 DIC Document control problems 3-16-81 $
6-24-81 [ G~
5-26-82 W88, T&8, ACI a
Snubber installation problems w sc 10-21-82 I 8-10-82 LKC i'J Conduit installation deviations 7-9-82 j v 7-2-82 LKC 'o Cable tray supports problems t0 9-13-82 9-28-82 -
LEC Cable pulling procedure violations R 5-16 9-29-82 '
g Deco and a71 site contractors Training of craftsmen in use of Raychem products 5-19-84 l. b 11-1-84 Nuclear 63 to procurement Movement of material without processing through QA 1-23-85 All site organizations Non safety-related components being installed without adequate procedures 2-11-85 Nuclear proouction Two engineering documents improperly revised 2-21-85 g
- 8 c1ved non safety-related work; graded QA program u tirements appiicable to 80p.
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Daniel International Corporation >
i n LKC -
General Electrie Installation and Service Engineering NISCO -
L. K. Coastock g'
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PPP .- Nuclear Installation Services Co. (A RCI -
Power Process Pfpfag 'I' AICO Reactor Controls Incorp.
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'- Robert Irsay Company , ', @^
i Townsend & Bottum.
g 'A WACO Id83 -
Walbridge-Aldinger Company ~
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Wisser & 8ecker .
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COMMISSIONBRIEFING FERMI-2 JULY 10,1985
(
=
FUIL POWEE OPERATING IJCENSE i
i CONTACT:
M. D. LYNCH
\ **0 (m s N ,
SIlDE 1 C/
(
BR::EFING OUTLINE LICENSEES / BACKGROUND -
SELECTED ISSUES
/
- STAFFING /0PERATING EXPERIENCE CONSTRUCTION ASSESSMENT / ALLEGATIONS OPERATIONAL READINESS CONCLUSION i
SLIDE 2 l
( LICENSEES / BACKGROUND
- IJCENSEES
- DETROIT EDISON COMPANY WOLVERINE POWER SUPPLY COOPERATIVE, INCORPORATED
- PLANT REACTOR - GE BWR/4, WK 'I, 3292 WWI,1093 WWE '
,, ARCHITECT / ENGINEER - DETR0li EDISON AND SARGENT & LUNDY CONSTRUCTOR - DANIEL INTERNATIONAL CORPORATION
- SITE LOCATED IN SOUTH EASTERN WICHIGAN NEAREST TOWN - MONROE, MICHIGAN DISTANCE 8 WILES :
t POPULATION - 23,000 [/S80) .
POPULATION CENTER - DETROIT, MICH10AN '
DISTANCE 30 MILES 1 POPULATION - 1.2 MILLION (/S80) l l
OFFSITE EMERGENCY PLANNING t
- TWO SUCCESSFUL FULL-PARTICIPATION EXERCISES (02/01/82 & 06/26/84) ;
FEMA EVALVATION Of WAY 3,1985, CONCLUDES THAT l OffSITE PLAN IS ADE0VATE -
EXEMPTION REQUESTED FROM ONE YEAR REQV!REMElff FOR '
FULL-PARiiCIPATION EXERCISE (AFF. E,10 Cr# 50)
A=e b
SLIDE 3
[
b
. i SEmECT3D ISSUES FIRE PROTECTION PROGRAM PROGRAM APPROVED IN SSER NO. 2-(JfNvAET 1981)
- APPENDIX R INSPECTION IN MAY 1'984 -
MEETINGS (NEE, #III, BECo)REGARDING FIRE PROTECTION IN JUNE, JULY, SEPTEMBER, OCTOBER 1984 REVISED PROGRAM INCLUDING INTERIM PROCEDURES PROPOSED IN OCTOBER 1984 EVALUATED IN SSER NO. 5 [#MCN /SSS)
FAIRBANKS-MORSE DIESELS ENVIRONMENTAL QUALIFICATION LOW-LEVEL WASTE STORAGE .
4 SLIDE 4 ;
C STMnfG/0PERATIIG EXPERIEXCE STAFFING 40 UCENSES IN OPERATING DEPARTMENT ~ -
(21 SRO/19 Rb W/HIOUTPREVIOUS 5 SHIFT ADVISORS (EACH HOLDS A FERMI-2 SRO i
- PLANT-SPECIFIC SIMULATOR IN USE SINCE OCTOBER 8,1984 6 SHIFT OPERATION / SHIFT COMPOSITION
- 2 SENIOR REACTOR OPERATORS
- 2 REACTOR OPERATORS l
- 1 SHIFT TECHNICAL ADVISOR !
- 1 SHlfT OPERATING ADYlSOR !
b St.lDE 5 1 -
.( CONSTRUCTION ASSESSMENT / ALLEGATIONS NRC
- OVERALL INSPECTION EFFORT - 9297 MANHOURS
- REGIONAL CAT INSPECTION IN JUNE 1982
- TECHNICAL SPECIFICATION /FSAR COMPARISON INSPECTI0ff lN MARCH 1985
,. N0 ESCALATED ENFORCEMENT ACTIONS LICENSEE THIRD PARTY AUDITS
- MAJOR AREAS OF PROJECT ACTIVITIES BY MAC (/S79)
- QA PROGRAM ASSESSMENT BY MAC (EEB#l/A#r/AF#//1984)
- FINAL CONSTRUCTION ASSESSMENT BY DUKE POWER COMPANY (JUNE / JULY 1984) .
POST-TMI REVIEW OF PIANT DESIGN AND TRANSIENT RESPONS SLIDE 6
ALLEGATI0XS 50 ALLEGATIONS RECEIVED AND ALL HAVE BEEN RESOLVED SAFETEAM (DECO INITIATED) _
1859 CONCERNS RECElVED (734 WERE SAFETY-RELATE
[ NRC REVIEWED ALL CONCERNS AND THEIR DISPOSITION c
SELECTED ISSUES .
ELECTRICAL DRAWING DISCREPANCIES FIRE PROTECTION INSPECTION
. SLIDE 7 P
~
( PREOPERATIONAL TESTING /STARTUP NXPERIENCE PRE 0PERATIONAL TESTING ;
- REGION HI DIRECT INSPECTION - 13,513 MANHOURS l'
' EARLY PROBLEMS RESOLVED
- PROGRESSIVE IMPROVEMENT l
.. \
OPERATIONAL HISTORY t
'
- LERs a
- UNPLANNED SCRAMS DURING STARTUP ,
- PERSONNEL ERRORS !
.( !
SALP 6 (PERIOD 10/01/84 TO 06/30/85) i
'0PERATIONAL READINESS
- TEAM INSPECTION CONDUCTED l
SUDE 8 !
m c
\
NWBER OF LERS SEXT TO REGIOX III Colloway 06/11/84-10/18/84; Byron 1 10/31/84-02/15/85 LaSalle 104/17/82-06/21/82; fermi 218 = Presenf 70 **I 61 60 -
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I BYRON 1 CALLAWAY LaSALLE 1 FERMI 2 SLIDE 9
( PERS0XXEL ERRORS /I3R RE? ORTS Low Power Issuance to full Power Issuance 70 e
o e i"
- No. LERs 60 -
E g g b Errors .
- 2 50 E E e
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LaSALLE 1
,- CALLAWAY FERMI 2 L
SUDE 10 t
SALP5 SALP6 FUNCTIONAL AREAS RATING RATING
- 1. Operations NR 2
- 2. Radiological Controls 2 -
2
- 3. Maintenance NR 2
- 4. Surveillance NR 2 5.
6.
Fire Prhtection Emergency Preparedness -
3 1
h' 1
- 7. Security -
2 2
(
- 8. Fueling NR 1
- 9. Piping Systems & Supports 2 2
- 10. Bectrical Power Supply 3 2
& Distribution /Instrui mentation & Control Systems .
- 11. Preoperational and Startup 2 1 Phase Testing
- 12. Quality Programs and 2 2 Administrative Controls..
- 13. Licensing Activities -
2 2
( -
SLIDE 11
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- - . .s_._ , . . . . . - _ . - _ . . ..-_..._.-.,,_-.-mm.-.__..m,, y,.,e.~w, _ e m y ,., y,um,r., _ , . - - -
- 4 m
CONCLUSION STAFF CONCLUDES THE LICENSEES SATISFY ALL THE
. REQUlHEMENTS FOR ISSUANCE OF A FULL POWER LICENSE SUDE 12
% 4 LICENSING STATUS FOR PERRY 1 Perry 1 is a BWR/6, Mark III containment designed plant in the final stages of the licensing review process. The Cleveland Electric 111uminating Company (CEI) tendered an application for an Operating License (0L) on January 31, 1981.
The FES was issued in August 1982. The SER was issued in May 1982 with the latest supplement (No. 8) issued in January 1986. CEI is working to a fuel load date of early March,1986. They are awaiting the completion of the staff's assessment of the earthquake impact on the Perry design (which occurred on January 31,1986).
FSAR Review The staff's FSAR review is essentially complete. All outstanding SER items have been resolved and documented in SSER No. 8 issued in January 1986. A separate SER supplement will be issued prior to licensing addressing the impact of the January 31, 1986 earthquake on the Perry plant seismic design. Licensing of Perry 1 has been delayed pending completion of the staff's assessment of this event.
The Technical Specifications were issued to the applicant for certification on November 19, 1985. Additional changes including deletion of fire protection were issued for certification by CEI.
Hearings The ASLB hearings were initiated in May 1983, during which time the QA Con-U struction issue was litigated. A favorable initial Board decisicn was issued on December 2,1983, and was appealed by the intervenor (Sunflower Alliance).
The Licensing Board's QA decision was affirmed by the Appeal Board (ALAB-802).
Hearings were completed on the emergency plans and TDI diesel generator reliability issues on April 12, 1985. Hearings on the remaining issue (hydrogen control for degraded core accidents) were concluded on May 3, 1985. The ASLB issued a concluding Partial Initial Decision (PID) on emergency planning, hydrogen control and diesel generators on September 3, 1985. This decision specifies several issues to be resolved by the applicant: emergency planning - 4 items; TDI diesels - 1 item; and hydrogen control - 2 items. Both intervenors (Ohio Citizens for Responsible Energy and Sunflower Alliance) have appealed the ASLB PID as well as several other prior decisions. A motion for a stay of the PID was denied by the Appeal Board on October 24, 1985. A motion to reopen the record and admit six new contentions involving fire protection requirements and single loop operation was filed by Intervenor OCRE on December 12, 1985. A motion to admit a new contention relative to the earth-quake impact on the Perry seismic design was also filed by OCRE.
2.206 Petition A Petitien.was filed by Susan Hiatt of the Ohio Citizens for Responsible Energy (OCRE) on February 3, 1986. This Petition requests that the NRC not permit fuel loading or any facility operation pending inspection and testing of the facility, an examination of site seismicity, and hearings on OCRE's seismic design contention (if it is admitted by the Appeal Board).
~
Gr
8 LICENSING STATUS FOR PERRY 1 By letter dated February 4,1986, to the Commission, Donald L. Schlemmer, on behalf of the Western Reserve Alliance, requested that immediate action be taken with regard to the Perry plant, Units 1 and 2. Specifically, Mr.
Schlemmer requested that the Comission: (1) suspend the construction of the Perry plants, (2) require an independent design and construction verification program to assess the integrity and implementation of the Perry quality assurance (QA) programs, and (3) review and require an audit of an application by Centerior Energy Corporation (CEC) seeking the approval of the Securities and Exchange Commission (SEC) to acquire all outstanding shares of Cleveland Electric Illuminating Company (CEI) and Toledo Edison and of mergers by which this will be effectuated.
The staff is currently reviewing these petitions.
Construction Appraisal Team (CAT) Inspection A CAT inspecti.on was conducted by the Office of Inspection and Enforcement on August 22-September 2 and September 12-23, 1983 at Perry Units 1 and 2. The inspection Report (50-440/83-31; 50-441/83-30) issued on November 7, 1983 noted no pervasive failure to meet construction requirements but did identify nine potential enforcement actions. A Notice of Violation containing three viola-
, tions was issued to the applicant. These matters have been reviewed by the Region and subsequently closed.
Integrated Design Inspection (IDI)
The NRC's Office of Inspection and Enforcement conducted an IDI at Perry and related facilities during the period of August 6 to October 12, 1984. The inspection report (50-440/84-29) was issued December 12, 1984. The applicant responded to the inspection report on January 24, 1985. IE letter dated February 25, 1985 comments on the applicant's January 24 response and a followup inspection team visit to the Perry Architect Engineer was conducted during the week of February 25, 1985. IE's followup inspection report dated March 26, 1985 indicated that 13 cpen items remain to be settled, primarily in the electrical design area. A further audit was conducted in May 1985, during which these remaining 13 open items were closed, with some followup required in the electrical system area by the regional staff to verify implementation. The IDI inspection is considered to be closed with all items satisfactorily resolved.
Region III Inspections There are about six matters requiring resolution by the applicant. These include: open items, violations, construction deficiency reports (10 CFR 50.55(e)), and responses to circulars and bulletins.
There are also a number of normal inspection items that remain to be completed (percent completion for each item is included):
witnessing of preop tests (96%)*
,. n- -
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Y LICENSING STATUS FOR PERRY 1
- evaluation of test results (94%)*
verification that test results are reviewed by the licensee (98%)*
- These inspection items will remain open beyond fuel load due to deferred test.
There are a number of other open inspection items. These are:
- 1. Construction and Preoperational Testing Preoperational test phase is approximately 95% complete. The overall status of the test program is listed below. NOTE: Included in the status below are tests which the applicant has identified as not required prior to fuel load.
Test Results Test Results No. Approved Verified Tests ,CEI By NRC Preoperational Tests 106 102 85*
Acceptance Tests . 118 115 83*
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The region held a management meeting on June 3, 1985 with the licensee to discuss preoperational test program deficiencies in the area of test pro-cedure adequacy, test conduct. and commitment implementation. The licensee committed to extensive corrective actions which Region III has followed and evaluated. Although these corrective actions were slower than expected in manifesting themselves in actual program conduct, more recent inspections show that they appear to have been effective. Therefore, problems with the preoperational test program are no longer of major concern.
- The NRC review of pre-fuel load required test results is complete.
- 2. Radiation Protection and Radwaste No significant RP or RW problems that might impact on the licensing process are being carried as regional open items. Several matters including use of silicone sealant on ventilation duct work and licensee requests for deviation from NUREG 0737 items are being considered by NRR.
- 3. Emergency Preparedness An Emergency Preparedness Implementation Appraisal (EPIA) was conducted in March 1985, and follow-up inspections were conducted in July, September, and November 1985. All appraisal items were closed, except for two items required to be completed before criticality. In addition, one bulletin item remains to be resolved prior to criticality, and a plant first aid facility must be completed before removing the construction crew medical office.
LICENSING STATUS FOR PERRY I A full participation exercise which is required to be conducted within one year and prior to exceeding 5% power was conducted in November 1984. A partial participation exercise was conducted in November 1985. An exemption request has been submitted to the Commission in the event the plant is ready to exceed 5% power before the next full participation exercise, which is scheduled for April 1986.
By ;etter dated February 4,1986, FEMA has confirmed that two Board conditions have been completed satisfactorily. This confirmation will be provided in a future supplement to the SER prior to authorization to exceed 5% of rated power.
4.. Security The last security inspection was conducted the week of December 2,1985, which closed all remaining modules. No violations were identified and all previous violations have been satisfactorily addressed and are considered closed. There are no known security issues which would preclude issuance of a license.
- 5. Fire Protection In December 1985, Region III completed its pre-licensing inspection activi-ties. All pre-licensing issues have been resolved. A few minor hardware items are being processed by the licensee on an acceptable schedule. The g licensee has been requested to evaluate the need to wrap safety related cable tray supports prior to exceeding 5% power.
- 6. Earthquake Damage Review An earthquake occurred on January 31, 1986, at an epicenter 10 miles south of the Perry site. the earthquake had a magnitude of approximately five on the Richter scale. An Augmented Inspection Team (AIT) war dispatched to the site on February 1,1986, to gather facts and to make a general assessment of the damage. This effort was subsequently supplemented with a team of Regional Specialists during the week of February 3,1986. These team inspections identified no significant damage to the plant as a result of the earthquake.
On February 12, 1986, CEI provided an assessment of the earthquake and it's impact on the plant. That report concluded that the impact of the earthquake would not alter any of the design or licensing basis. That report with its conclusions is currently being evaluated by NRR for any design basis impact.
Allegations There are currently seven allegation files on Perry being pursued by the staff, and are expected to be closed in the next few weeks.
i One of the allegation files consists of 48 allegations received as part of the February 4, 1986, 2.206 petition from Western Reserve Alliance (WRA).
An initial inspection was conducted during the week of February 16 and February 23, 1986.
I LICENSING STATUS FOR PERRY 1 All of these allegations, including WRA 2.206 allegations, have been reviewed in some detail and no significant problems have been identified, which would preclude issuance of a low power license.
01 Investigations The Office of Investigations has three investigations underway regarding Perry.
These items are being pursued and are not expected to impact fuel load. !
Operating Shift Experience By letter dated February 6, 1985, the applicant updated experience tables (initially provided in March 1984) reflecting nuclear power plant experience for operating shift positions at Perry. The tables reflect current and projected staffing experience levels at the time of Perry 1 fuel load. ,
At this time, no impact on licensing and availability of qualified operators is expected. Additional operator examinations were conducted during the week i of December 9, 1985. Fifteen additional licenses were issued.
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NA:'.R OF FACILITY DATE MAILED 3 REPORT NUMBERS
.DPRP
_ - = DISTRIBUTION
- - - = _
NUMBER OF REPORTS TO BE REPRODUCED LETTER W/ CONCURRENCES W/ REPORT LETTER W/0 CONCURRENCES W/ REPORT REPORT ONLY
_ NUMBER OF THANK YOU LETTERS TO BE REPRODUCED LETTERW/CONCURRENCESW/RESPONSEFkOMLICENSEE LETTER W/O CONCURRENCES W/ RESPONSE FROM LICENSEE LETTER ONLY U/O CONCURRENCE COPIES WITH CONCURRENCES DM3/DOCLYJ.NT CONTROL DESK (RIDS)
REGION III FILES DPRP DIVISION FILES ~
( RESIDENT INSPECTOR
- MIS /L. SUCHARSKI DEP D?JiSP KEPPLER/ DAVIS COPIES WITHOUT CONCURRENCES
_ P. ANDERSON K. CRAESSER T. MURRAY L. BECK J. CUDAC R. CALLEN J. PARKYN D. HOFFMAN M. CHERRY T. QUAKA )
D. HINTZ R. QUERIO D. CHEVEZ T. HOUVENAGLE R. QUILLAN
_ R. COSARO N. KALIVIANKIS V. SCHLOSSER T. DATTILLO J. KODNER J. SCHOTT
_ C. DIEDERICH H. KOHN D. SCOTT K. DREY LeBOUEF. IAMB, J. DUTIY L. SHAMBLIN LEIBY f MACRAE W. SPAMLA H. EVANS W. MARSHALL D. FARRAR M. SINCLAIR D. MARTIN C. SORENSEN J. FERMAN E. MARTIN R. FLUECCE J. SPENCER M. MILLER B. STAMIRIS S. CADLER D. MINECK l J. CALLCL'AY B. STEPHENSON l R. MONTROSS H. VOICHT OVER *
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J. VENNDIANN E. WATZL V. WEBER D. WELLS D. WILT C. WRIGHT
- J. WALDRON M. VETTERHAHN [\
- s. YORK E. BORCSTADT W. SMITH EIS COORDINATOR, USEPA (D. C. COOK REPORTS ONLY)
J. FLYNN .
CARE (CITIZENS ACAINST A RADIOACTIVE ENV.)
T. APPLEGATE .
G. HUMMEL J. WILLIAMS R. HOLYOAK .
D. VANDEWALLE -
C. BECHHOEFER J. HARSOUR F.COWAN R. DECKER W. PATON S. MILTENBERCER J. ZACH
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LICENSING STATUS FOR PERRY 1
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Perry 1 is a BWR/6, Mark III containment designed plant in the final stages
'of the licensing review process. The Cleveland Electric Illuminating Company (CEI) tendered an application for Operating License (0L) on January 31, 1981.
The FES was issued in August 1982. The SER was issued in May 1982 with the latest supplement (No. 5) issued in February 1985. The current fuel load date in the Bevill Schedule (12/85) was predicated on a Caseload Forecast Team visit to the site in March 1984. (The Team report ~ Es Ts'sheH~on Augus I28," ~
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1984). CEI is working to a fuel load date schedule which targets Perry 1 licensing for July 1985. Progress being made in the pre-operational / acceptance tests and other factors suggest a reasonable possibility of CEI attaining a a
license in July 1985. CEI has voluntarily committed to provide monthly progress reports on test activities to ensure appropriate NRR management attention to scheduling resources accordingly.
FSAR Review i .
The staff's FSAR review is essentially complete. Of t'he. outstanding.it'ess . .
reported in the latest SER supplement (No. 4) the following remain unresolved and are considered significant:
~
(1). Mark III containment system design (Humphrey issues) - of the allegations made by J. Humphrey, a former GE employee, regarding the adequacy of the Mark III design, two have been found to warrant investigation; mainly: (a) the effect-of encroachments over the
( suppression pool might have on pool swell and structural impact loads; and (b) loads to the RHR' system piping due to steam condensation in the " Steam Cooling Mode". -
(2) Mark III containment pool dynamic loads due to a LOCA event ' analysis i required of the phenomena affe.cting suppression pool equipment i loadings. ~ '
(3) Hydrogen control for degraded core accidents - implementation of the new rule (12/11/84); CEI proposing a hydrogen ignition system design similar to Grand Gulf and River Bend designs; tests to be performed by the Owners Group to verify adequacy of the design schedule for April 1985. '.
l (4) TDI diesel generator reliability - requalification must be performed to verify reliability of the D/G's to perform intended function in the '
event of loss-of-offsite power; work proceeding in the disassembly /
reassembly and test of the Perry D/G's which.is to be completed '
in March 1985.
(5) Technical Specification - CEI proposed Technical Specification submitted i for staff review on July 31, 1984. Expect to issue proof & review copy in April 1985 to support CEI projected July 1985 fuel load date.
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, LICENSING STATUS FOR PERRY 1 t.
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-Hearings -
The ASLB hearings were initiated in May 1983, during which time the QA Construction issue was litigated. A favorable initial Board decision was issued on 12/12/83, and has been appealed by the intervenors (Sunflower Alliance and Ohio Citizens for Responsible Energy or OCRE). The appeal has not yet been ruled on by the ASLAB. The ASLB decision is not expected to be overturned.
M m _.,._.." issues' remain to be ruled upon by the ASLB. Resumption of the hearings
~
to address the remaining issues has been scheduled for April 9, 1985. " wcscr, OC: nos sitco .... t # c : '. _ ry d* p :; t :o.. uf mi' #--"^- The issues are:
(1) Emergency plans - FEMA interim findings on State / County plans
~- received 3/8/84; a full participation exercise was successful.ly' performed on 11/28/84. The Board admitted 18. specific, issues in January 198 Anuna lau.t .dwnvn dahpttGhin
' Ais-mittaf 9m &n A S M /985 (2). Hydrogen c ntrol for degraded core accidents. Ctuff filmd i..si.un
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,-g u pf.c _ p_ - ,.7 s;eper: tier ',; 7 Lcc. pr:p::;d t; ti -.d. Ctcf f _ il' '": -"pp^-t'.g rc:p - c-3 (f) AReBaloufHy of TDr Agi4ef ge+sfpm, Psci;cL;ii L, vf TO: dic::. ge e-ste-c.
? t ' ' ic ccaev..;c in appe.t of CE: .etiva su r s u..u..u. s J i ;p c ; i ti e s.
CAT Inspection A CAT inspection was conducted in August-September 1983. The team noted no pervasive failure to meet construction requirements in the samples of installed hardware inspected. The followup of deficiencies are included in the Region III tracking for resolution.
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1 LICENSING STATUS FOR PERRY 1 .
Integrated Design Inspection The NRC's Office of Inspection and Enforcement conducted an Integrated Design Inspection at Perry and related facilities during the period of August 6 to October 12, 1984. The inspection report (50-440/84-29) was issued December 12, 1984. Several significant technical areas were found to have systematic weaknesses. In addition, approximately 170 deficiency and seven unresolved items were identified and require applicant response. The inspection report concluded that "none of the identified deficiencies, either collectively or individually, are such that the overall adequacy of the Perry plant design is called into question." The applicant responded to the inspection report on January 24, 1985. IE letter dated February 25, 1985 comments on the appli-cant's January 24 response and a followup inspection team visit to the Perry Architect Engineer is being conducted during th,e week of February 25,<1985.
Region III In'spections
-There are about 181 matters requiring resolution by the applicant. These include: open items, noncompliances, construction deficiency reports (10 CFR 50.~55(e)), and responses to circulars and bulletins.
There are also a number of normal inspection items ~ that remain to be completed (percent completion for each items is included): - ,
construction piping (95%)
pipe supports (30%) r i
electrical (60%)
instrument (30%) __
- s as-built verification (0%)
safety committee inspection (0%)
plant procedures inspection (0%)
operating procedures (0%)
maintenance procedures (Q%)
cmergency procedures (0%)
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LICENSING STATUS FOR PERRY 1 .
' review ~ of preop te'sf.' proc'bdures'(0%) * ' ' '
performance of preop tests (5%)
evaluation of test results (0%)
verification that test results are reviewed by the licensee (0%)
fire protection (0%) ~ .
containment leak rate test results review (0%) ~
, testing of pipe supports and restraints (0%)
radiation protection (40%)
. . . . Y k}. i, raffwaste (0%) - - -
radiochemis'try (50%)
- ~ ^
. environmental monitoring (50%) '
emergency planning (20%) ,
- ' security (0%)
4 review of startup test procedures (0%). -- , ,
There ar.e. a number of other ope'n inspectko' n items. These are:
- 1. Construction and Preoperational Testing .
One significant item requiring resolution is to qualify the Delaval Diesel Generators. A number of construction deficiency reports have been reported on these units.
One deficiency identified by the CAT team requires review by NRR.
During construction, a large number of concrete expansion anchor bolts were installed through the drywell liner into the concrete.
Licensee's preliminary review indicates there is not a problem.
Significant preoperational testing has commenced and major system testing (i.e. , ESF, RPS, ECCS, etc.) is expected to be we11' underway in early 1985. '
No significant problems have been identified which could impact on the licensing process. _
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LICENSING STATUS FOR PERRY 1 ., .. .
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1
- 2. Radiation Protection and Radwaste Three radiation protection (RP) inspections have been performed; no radwaste (RW) inspections have been performed.
It is too soon to anticipate / determine whether significant RP or RW problems might exist that could impact on the licensing process.
None have been identified during the three RP inspections.
- 3. Emergency Preparedness A full participation exercise was conducted in November 1984 that provided an integrated test of the Emergency Plans and response capa-bilities of the applicant, State of Ohio, Ashtabula, Geauga and L'ake.
Counties in.0hio, and the State of Pennsylvania. The' appl-icant's p'er-
, formance during this exercise was sufficient to qualify for issuance of the operating license. An Emergency Preparedness Imp'ementation Appraisal .
by NRC (IE and Region III) to determine if adequate protective measures .
can and will be taken in the event a radiological emergency is scheduled
~ for March 1985. A successful Appraisal is necessary before an operating license can be issued.
- 4. Security -
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One security inspection has been conducted to date. The applicant will be required to have their security plan fully implemented prior to fuel load. Monitoring of the applicant's progress towards full implementation has begun and will continue until c,ompletion of the security program.
Allegations In addition to the above issues, there are currently eight allegation files on Perry being pursued by the staff and are expected to be closed in the next several months. These allegations can generally be divided into the following areas:
work package control inadequate electrical documentation inadequate electrical problems not corrected in a timely manner ;
questionable pipe support qualification of QC inspectors '
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LICENSING STATUS FOR PERRY 1 ' ' " ' '
improp'er firing of QC inspector
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improper weld rod control Come of_these $ssues_have been-reported-in local newspapers. Most of these allegations have been reviewed in some detail but additional inspections are required _to determine if any 1ssues have an impact on safety. These issues are expected to be resolved prior to fuel load.
OI Investigations -
~-
The' Office 'o~f Investigations has'several investigations underway regarding the Perry site. - These items are being pursued and should not impact fuel load.
- , . i
~.r Operating Shift Experience -
4 (i,I.
By letter dated February 6,1985, the applicant ~ updated exper~ience tables (initially provided in March 1984) reflecting nuclear power plant experience for operating shift positions at Perry. The tables reflect current and projected staffing experience levels at the time of Perry 1 fuel load
- (currently targeted by the applicant for June '1985).
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( LICENSING STATUS OF FERMI-2 Fermi-2 is in the final stages of the licensing review. Detroit Edison tendered ~
its application for an Operating License (OL) on October 24, 1974. The FES was issued August 1981. The SER was issued July 1981, with the latest SER Supplement issued in September 1984. The letter from ACRS supporting issuance of an OL was dated August 11, 1981. The hearings were-completed in- April--1982--The applicant - ~
has informed us of a further delay to mid-March 1985 from the earlier announced fuel load date of December 16, 1984. Region III believes that the second week of March 1985 is a realistic estimate of the fuel load date.
FSAR Review The staff review of FSAR matters is essentially complete; almost all matters remaining are either resolved or will be shortly. Two relatively new issues are presently under review, i.e., the lubricating problem in the emergency diesel generators and the portable li, quid radwaste sys, tem. The app,licant,'has
~
provided initial res~p onses on both these matters'. Two of the foor emergency ,
diesel generators were severely damaged; all four should be operational by March 8, 1985. A representative of NRR visited the site on March 1, 1985 to discuss the resolution of the diesel issue.
The' applicant submitted on February 13, 1985 additional deviation requests on fire protection. We have rejected some of these and sent a statement of our
( .
positions to the applicant.
Hearings Hearings on the limited contested issues were held March 31 through April 2, 1982. The ASLB Initial Decision, issued October 29, 1982, was favorable to licensing on all issues and was affirrmediby the Appeal Board on June 2,1983 (ALAB-730). The Commission declined review and the Initial Decision became final agency action (ending the hearing phase of the proceeding) on October 17, 1983.
Offsite Emergency Preparedness FEMA has provided findings on offsite emergency plans which indicate that an adequate state of preparedness exists. The NRC staff requested supplemental findings from FEMA on the revised emergency plan developed by Monroe County, Michigan, and a separate plan developed for Brownstown Township in Wayne County, Michigan. In its letter dated May 14, 1984, FEMA found both plans acceptable. The Monroe County plan has now been formally approved by the County Board of Commissioners.
As the revised county plan was submitted subsequent to FEMA's revicw, the staff has requested confirmation from FEMA that the revised plan continues to support FEMA's favorable finding.
- A full scale participation exercise was conducted with the State of Michigan and Wayne and Monroe Counties on June 25-27, 1984. Both the NRC and FEMA
(, issued reports on this e'xercise; no def.iciencies affecting public health and safety were identifi
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LICENSING STATUS FOR FERMI-2 .
i On-Site Emergency Preparedness Review and evaluation of onsite plans are complete. All outstanding EP-related SER and Region III open items have been resolved.
Independent Construction Verification A CAT inspection was previously scheduled for Fermi-2 but was cancelled. The applicant subsequently arranged to have Duke Power perform a construction verification inspection. The implementation of this program began on June 11, 198" and was completed in mid-July 1984.
Duke Power presented its findings to the applicant and staff on July 31, 1984.
. Duke generated 199 potential finding reports, which resulted in 24 recommenda-
. - tions; these were presented at the meeting and documented in-the report entitled,
" Fermi-2 Final Assessment of Construction" which was-transmitted to the staff by Detroit Edison on August 1, 1984. It was Duke Power's opinion that, pending resolution of the findings and implementation of the recommendations, there-will be reasonable assurance that no significant deviations from the final
. design disclosure documents exist.
A DECO report was issued on September 20, 1984, /espondidg to the Duke assessment, including Duke's 24 recommendations. Region III has reviewed the DECO report and provided comments during a meeting at the site on October 31, 1984. Deco has provided a supplemental response dated December 28, 1984. Region III is
?
conducting inspections to verify DECO's response and to resolve open and unresolved items from the staff's report. ,It is not currently anticipated that activitiesassociatedwiththeassessment[followupwillimpactfuelload.
Region III Inspection There are about 60 matters requiring resolution by the applicant prior to fuel l load. These include: open items, noncompliances, Section 50.55(e) reports (i.e., design and construction deficiencies), and responses to circulars and bulletins. Due to the large number of these matters, a detailed list has not been provided. It should be noted that substantial progress has been made in reducing the total number of open items. Currently, 38 of the 60 items require action by the applicant prior to NRC review. An additional person has been assigned to Fermi-2 to aid in closing outstanding items. There are also a number of normal inspection items which remain to be completed (percent completion for each. item is included):
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LICENSING STATUS FOR FERMI-2 .
as-built verification (65%)
evaluation of test results (90%)*
verification that test results _are reviewed by the licensee (70%)*
containment leak rate test results review (0%)**
. testing of pipe support: and restraints (50%)***
At the present time, the staff is evaluating resource needs. Inspections will be' conducted on a schedule consistent with the plant's readiness in these areas.
as e One, inspection matter of current s,ignificance pertains, to : fire protect'iondat- -
the Firmi-2 site. The principal conchrn is that a. fire in the control room divisional panels cannot be limited to a single ' panel, thus limiting or pre-venting reactor shutdown. A fire in the relay room would have the same effect and the' remote shutdown panel was not independent of the control and .
relay ro6ms. Th'e applicant met with the staff on June 5, July 11, September 13, November 1 and November 2, 1984 to discuss the staff's concerns. To address the staff's concerns, the applicant proposed the use of electric auxiliary
' ~feedwater pumps, which are powered by an onsite power source, and that all controls ~ required to achieve cold shutdown be totally independent of the control and relay rooms. The staff has accepted this proposed solution. The
' applicant is proceeding with final design and procurement activities and will implement the titernate shutdown by the first fuel outage but no later than December 31, 1986. !
/
' Awaiting applicant action (i.e. , procedure preparation and completion of .
construction / testing activities). -
- The containment leak rate test was successfully completed on December 2, 1984; the test results have not been completely reviewed by the applicant.
(Note: This will not be a fuel load requirement.)
- This program cannot be 100% complete until after fuel load.
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LICENSING STATUS FOR FERMI-2 -
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i Radiation Protection Radwaste Open items remaining to be closed prior to fuel load involve: completion of the analysis of the standby gas treatment system (SGTF); noble gas detector l range overlap; procedure revision to include calculated sample line loss [
correction factors for the SGTS; development of procedures to determine quanti-tative release of radiciodine and particulates for the SGTS pertaining to draining and venting contaminated systems, and completion of associated training; correc- '
tion of Emergency Plan Implementing' Procedure EP-540 to reflect the correct SGTS :
effluent monitoring system and completion of associated training; and demonstra- !
tion by testing that the carbon absorber has not significantly degraded for both t the Control Center and the Technical Support Center.
Electrical Power Supply and Plant Instrumentation -
, f Ouring recent Region III inspections where plant electrical power supply and '
instrumentation systems were compared to the current design documents, many errors, inconsistencies, and omissions were found. A management meeting with ;
the applicant was held in Region III on December 31, 1984 to dinuss these findings. The applicant committed to provide a comprehensive program which ,
will ensure ~ that necessary design documentation is correct and available prior -
to fuel load and that other documents not needed 'for operation but required to !
support other activities (i.e., plant modifications) will be updated in a ;
timely manner. '
2 A meeting was held at the Fermi-2 site with Region III and NRR management on February 13, 1985 at which the applicant presented its comprehensive program to identify and correct drawing discrepancies. An NRR management meeting at the ,
Fermi-2 site on this and other matters was held on February 20, 1985. NRR management stated its requirement that this issue be resolved prior to license issuance.
Region III review of the applicant's actions related to the as-built document findings is continuing. A detailed verification of the effectiveness of the applicant's program is in progress and will be sufficiently complete to assure .
that the design drawings accurately reflect the configuration of rne plant ,
prior to fuel load.
Completion of the applicant's activities required prior !
to fuel load should be consistent with a mid-March 1985 fuel lo.d date. j Operating Procedures Review During the review of operating procedures for the associ' ate (s_urveillance pro-cedures, inspectors found the applicant's review to be inadequate. An excessive number of "LATERS" in place of the required information were found. In addition, set points and limits given in procedures did not agree with.the Fermi-2 Tech-nical Specifications. Theaplicant has reviewed,these findings and established {
a program to correct the problems % Inspections by. Regio Q II are in progress.
Region III does not see this issue as a restraint to issuing the license.
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LICENSING STATUS FOR FERMI-2 .
! Emergency failures. Due diesel generators Nos.11 and 12 were found to have crankshaft bearing to the complete failure of one or more bearings on EDG No.11, damage to related pistons, cylinder liners and the upper crankshaft also occurred.
The damage to these two diesel generators has been attributed by the applicant to inadequate lubrication of the upper crankshaft bearings when the diesels were started.
Prelubrication for routine starts had been discontinued after the diesels were modified to provide automatic prelubrication. The applicant has now revised its starting procedures for non-emergency starts to require pre-lubrication. Changes were also made in the surveillance testing procedures for the diesels.
/t' Diesel Nos.13. an 14 were not damaged and have been declared operable aft'er ,
surveli'ance testing. Repairs are underway on Units Nos. 11*and 12.
Both are expected to be operational by March 8, 1985. NRR management stated at the site meeting on February 20, 1985 that all four diesel generators must be operational prior to OL issuance.
Security -
,All security related activities and open items have either been completed or closed.
- 1 Allegations i
At andpresent, two assigned there to are OI.twenty-three open a$ legation files assigned to Region III Region III is following up on these, but does not :
anticipate that they will impact on the licensing schedule based on information known to date.
~
i The applicant is continuing a program called "SAFETEAM" in which all departing !
personnel are invited to volunteer any concerns related to Fermi-2. ' Region III personnel periodically review all concerns for significant issnes and the re-sponses to all concerns.
QA and IDVP QA Branch has evaluated Amendment 59 and the Cygna IDVP Report. Two confirma-tion actions are identified in the SSER. The applicant has agreed to add the lube oil system and combustion air intake system and make some minor clarifications l-to the Q-List. Cygna has agreed to provide additional information and clarifi-cations to the-IDVP Report.
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- 4 ST4 ' JS OF OPEN FSA.R ISSUES
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PLANT - ENRICO FERMI, UNIT 2 i PM - M. D. LYNCH (x27050) 4 TECHNICAL SPECIFICATIONS: '
$ PROOF & REVIEW:
Proof and review copy sent to reviewers July.'27, 1984; comments requested August 31, 1984.
- FINAL DRAFT
- November 1984 (Applicant has since submitted four sets of changes.) -
\
- FSAR '
Open Issues SSER Schedule
) Responsible Oro. Category Input Issue -
- j. '
- 1. Emergency plan overall EF8/DEPER -
3- 04/85 05/85*
- conclusion >
- 2. Fire protecti )n CMEB/DE 3 03/85 03/85**
3 IDVP QAB, MEB & SGE8 3 02/85 03/85 4- Q-List review QUAB/IE & NRR s, 3 02/85 03/85
- 5. Diesel generators PSB/DSI 2 03/85 03/85***
i .
.; -l
- Final FEMA finding required prior to full power license. '"
- Applicant requested additional fire protection deviations on February 13 1985. , . *
- HRR representative visited the site on March 1, 1985. '
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REC 10N I M&PS Revision NHC NDE MOBILE VAN INSPECTION HISTORY:
Division of Reactor Safety (DRS)
I i l l Type inspection l NDE VAN l l Plant Status l Find,E_qi Inspection Roport Site l Dates lConstruc Oper! Vendor Site SpeciallTeam, Routine? Number I inspection / Findings i I i ,
I i l i l l l L i ma ri c k 1 l 6/18-22 l X 1 N/A I N/A l X I '50-352 Visual,~Hilti bolt, & AWS I l
l 84 I l ,
84-27 inspection, l-l l H !
l l l ,
542 onsite hours l I Unresolved - PSI UT evaluations l 93 offsite hours l 1/DEV X 50-352 - ANI quality concerns l Limerick #1 !7/9-20 l X 2/V10 .4/UNR l U 84-29 .
- Incomplete UT inspec-!
I l 84 I I I tion reports I
) i 1 1 I IViolation - Reporting weld l t
I l , ,
I defects on NCR's I
! l l Violation - Improper ISI UT cali-
! l >l u ,
bration stand i l l l l l Deviation - UT PSI refer points
! ! I l l l l 474 onseto hours i i l l ; Unresolved - Pipe wold identifi-68 offsite hoursl l l l H cations l
Pilgrim 1 18/1-10 l l X N/A 3/UNRI X 50-293 ,
- CRD PT evaluations l 84 l l 1 84-21 - PSI UT documentation ll l l ,
I inspection of replacement recirc.
I l I l piping:
I l l
'38 onsite3 hours l l l .
H Allegation followup inspection:
8 offsite hours. l l l l l PT, RT, Visual, UT thickness l Seabrook 1 8/27-31 l X ,
N/A l N/A X 50-443 windsor probe, alloy analyzer i
! 84 l l 84-12 u j i l i
- 61 onsite hours i l l IWelding, fi l ter meta l, visual 0 offsite hoursl weld, weld rod control, s to rage Bsave r Va l ley 2 19/10-14 iX N/A N/A X 50-412 p rocedu re s l 84 . i '84-13 l l 1 434 onsite hours l l 1 h Unresolved - PSI P rog ram i
192 of fsi te hourbl10/9-20 X ,
1/UNR l X l50-412
! Baaver Valley 2 84 l l 84-1S l
l 376 onsite hours i I l1/V10 l Violation - Radiogrph. I n te rp re tn, 111 offsite hours 2/UNR I Unresolved - misfiled rad i og rphs Clinton Unit 1 111/5-16 X l X 50-461 - stamping / cladding of welds for 84 -
84-35 PSI
~~~
72onsitehoursh12/10-14 X N/A N/A X 50-410 Ultrasonic / thickness tests for CAT 36 offsite hoursL 84 184-18 Inspection Nina Mile #2 '
l i 1 i l I
l
_. an. -
l .
RECION I M&PS Revision NRC NDE MOBILE VAN INSPECTION HISTORY:
Division of Reactor Safety (DRS) l l Type Inspectioni NDE VAN l' l Plant S ".a t u s [ind nos Inspection Report Site Dates lConstruc : Oper Vendor site Special Team ; Routine , Number Inspection / Findings l
l 486 onsite hours 1/14-24 l ;
N/A N/A '
50-277 Performance Genera l ly Good 147 orrsite hours 85 l I X X X X 85-01 l Patch Bottom #2 I l 1
225 onsite hours 1 2/5-11 '
I 50-482 AWS s t ruc tu ra l weld inspection I 72 orrsite hours 85 X N/A N/A X X 85-12 over pa inted surfaces 1 Wo l rC rsek, Kansas l R3 ,
l 1 .
454 onsite hours . 3/11-22 l l l 1/Vio1 I l 50-298 Viola tion-Rejectable Linea r Indi-85 l 65-12 cations not addressed on radio-
! 224 orrsite hours l X 6/UNR X ,
' Coope r Stat ion, I I I i lg raphs. Unresolved-Radiog raphic l NES l l l l N l l Linear ledications i R4 l l l 1 N !
l I I i 168 orrsi te hours l4/22-5/3 l l l 50-354 Performance Genera l ly Good i 473 onsite hours 1 85 l X l I N/A N/A X 85-08 I Hope Creek, NJ l 1 '
H l
135 orrsite hours 6/3 - 14 l l 50-423 Viola t ions - Rad iog raph Mi s inter-440 onsite hours 65 l X 1/Vio 2/Vio X 85-22 pretations-Drawing Control Hillstone #3 l l Unreso lved - PSI UT Cat Block l l , ll l 157 ortsete hours 7/15-26 l l H 1. l 50-443 Violations - None i 497 onsite hours 85 l X l UNR l X l 85-19 Unresolved - Multiple Areas or i
S=; brook #1 H ,
l PSI Prog ram 1
orrsite hours 8/12-16 .
50-423 l Re-verification of Licensee onsite hours 85 X 1 2 UNR X '
85-46 Followup of CAT rindings.
Millstone #3 l H Un re so l ved-PS I Data of Centrifugal l l Castings I
72 orrsite hours' ,
50-445 Violations - Failure to document 384 onsite hours 9/9-20 1 1/UNR 1/Vio 85-14 as-buil t drawings Commanche Peak ' 85 1 x X 50-446 Unresolved - Generic Problems R4 l l 85-11 or cable tray support bot ting l I 104 offsite hours. 10/28-11/8 i l l l 50-435 Violations - None 462 onsite hours I 85 l 1/UNR 12/UNR I i 85-31 Unresolved - Incompleto UT Data Bryon Station #2 1 X i X . - ASME Codo requi rements for UT R3 l ll I cast stainless steel 1 -
Identical vendor weld markings l I on pipe l l l l orrsite hours '12/9-20 h H $0-410 Next NDE Van inspectiun onsite hours 1 85 X X 85-43 Nire Mile #2 Il l l
1 x- . , . , , - , . , ~ , , - , , , - - , _ . - - - , - , - u-,-. -- -
REGION 1 M&PS Revision NRC NDE HOBILE VAN INSPECTION HISTORY:
Division of Reactor Safety (DRS)
! l l Type inspection NDE VAN I I Plant Status i Find n13 Inspection i Report Sito l Dates IConstrue, operl Vendor Site SpeciallTeamlRoutinel Number inspection / Findings i I I I I I I I .I I I 64 hrs offsite i 1/13-31/86 l X l l X l l 50-271 _ Replacement Piping 422 hrs onsite i l l l l l varnont Yankee l l l J l l l l I l l I I I 24 hrs offsite 1 2/18-28/86 l l X l l X l l 1 50-327 Visual inspection structura l VWAC 332 hrs onsite ! I I i i 1 50-326 I acceptance. Units 1 and 2 S:quoysh 1&2 l l 1 I i i ! 86-13 I l_ i l I i i l ! I I l hrs offsita I 9/1-11/86 I l l l l X l l 50-206 l l hrs onsite ! I I i l l l l 86-13 l l Srn onorre i i l i i i i l i l i I I I I I I I I I I i
i I
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. > -f y,,, q APPENDIX 1 ATOMIC SAFETY AND LICENSING BOARD PANEL:
V. SELECTED STATISTICS: FISCAL YEAR 1985 The 55 proceedings conducted this fiscal year included 21 operating license (OL) applications for 30 units valued in excess of $70 billion. Licensing Boards also conducted 34 other proceedings, completing 42% of all cases on the docket.
II. DOCKET CASELOAD DATA The following information covers activities of the Boards up to and during the fiscal year and current pending matters:
A. FY 1985 ACTIVITY:
- 1. Cases Pending October 1, 1984
- 2. 42 Cases Docketed During FY 1985 (including remands and
, multiple boards) +13
- 3. Total Cases 55
- 4. Cases Closed During FY 1985 -23
- 5. Cases Pending October 1, 1985 32 B.
PENDING CASES BY YEAR (NRC):
Cases Pending October 1, 1985 32 Cases Pending October 1, 1984 42 Cases Pending October 1, 1983 47 Cases Pending October 1, 1982 49 Cases Pending October 1, 1981 62 Cases Pending October 1, 1980 69 Cases Pending October 1, 1979 67
- Cases Pending October 1, 1978 57 Cases Pending October 1, 1977 57 Cases Pending October I, 1976 55
, C.
TOTAL NEW CASES CLOSED BY THE PANEL:
- 1. Since October 1, 1972:
' Docketed 393*
Pending 32 Closed 3ET
- Includes 93 proceedings on petitions for hearing.
Page 1 of 5 (1?
- 2. Since November 9, 1962 (date first part time Board was appointed):
Docketed 475*
Pending 32 Closed 443
- Includes 93 proceedings on petitions for hearing.
D. FY 1985 DOCKET ANALYSIS:
- 1. Types of new cases filed:
- a. Operating licenses 1
- b. Operating license amendments 9 (Includes spent fuel pool and transshipment cases)
- c. Construction permits 0
- d. Civil Penalty 1 !
- e. Special proceedings 2
- f. Antitrust 0
- g. Other proceedings 2
- h. Remands 2 IT
- 2. Types of cases closed:
- a. Operating licenses 12
- b. Operating license amendments 4
- c. Construction permits 2
- d. Civil Penalty 0
- e. Special proceedings 3
- f. Antitrust 0
- g. Other proceedings (Spent Fuel pool) 2 77
- 3. Types of cases pending October 1: '84 '85
- a. Operating licenses
- 19 11
- b. Operating license amendments 9 6
- c. Construction permits (suspended) 3 2
- d. Spent fuel pool & transshipment 3 1
- d. Special proceedings 4 5
- e. Antitrust 0 0
- f. .0ther proceedings 4 7 TY TY
- Includes multiple boards.
Page 2 of 5
DOCKET REDUCTION. In the last five fiscal years, Licensing Boards have closed 114 cases, 42 more than the 72 new cases filed.
FY 1986 PROSPECTS. We expect 50 cases on the docket in FY 1986. Of the 32 cases pending October 1, 1984, four "
cases are temporarily suspended. Of the remaining 28 cases a now pending, Licensing Boards anticipate,that during FY 1986 they will complete 16, including at least 4 operating license proceedings affecting four nuclear power plant units. We expect 18 new cases to be docketed during Fiscal Year 1986.
III. OPERATING LICENSES NEW UNITS. From May 1981 to September 30, 1985, Licensing Boards have authorized full power operating licenses for thirty-four (34) new units by closing 24 proceedings ,15 by Initial Decisions. These units include Beaver Valley 2, Byron 1 and 2, Callaway 1, Catawba 1 and 2, Clinton 1 and 2, Diablo Canyon 1 and 2, Enrico Fermi 2, Grand Gulf 1 and 2, Hope Creek, Indian Point 3, Limerick 1 and 2, McGuire 1 and 2, Nine Mile Point 2, Palo Verde 1, 2, and 3, Perry 1 and 2, River Bend 1, San Onofre 1 and 2, St. Lucie 2, Summe. 1, Susquehanna 1 and 2, Waterford 3, and Wolf Creek 1.
IV. CONTENTIONS The data concerning disposition of contentions in Tables 1-10, attached, show that: (1) the expeditious resolution of contentions continues to improve; (2) case management, discovery, and prehearing procedures are effective in achieving their intended purpose of reducing and focusing issues for hearing; and (3) the greatest portion of the Licensing Boards' work takes place in the prehearing phase. To illustrate, in FY 1985, contentions resolved prior to hearing in all operating license proceedings to date total 1,343 out of 1,514 or 89%.
(Table 1)
Generally, the largest number of contentions eliminated prior to hearing during FY 1985 resulted from Licensing Board rejection at the outset pursuant to the rules, e.g.,
38% in operating license cases. Moreover, the large majority of all contentions initially admitted in all proceedings completed during FY 1985 were subsequently resolved prior to hearing through processes such as stipulation, consolidation, withdrawal following negotiations, or summary disposition.
Page 3 of 5
The contentions data generally understate the amount of work involved. Frequently, a single contention contains multiple subparts or issues. Thus, a case having only a few contentions at hearing may in fact be considering many issues. It should also be noted that contentions data in Tables 1 to 10 are approximate because contentions are often reformulated or broken down into mul tiple contentions. The margin of error is ab~out 2 percent.
The data on resolution of contentions confirm the Licensing Boards' active implementation of the procedural devices and guidance contained in the Commission's May 1981
" Statement of Policy on Conduct of Licensing Proceedings",
13 NRC 452 (1981). The Boards expect this trend to continue in FY 1986.
V. HEARINGS The average number of days of hearings for those cases where the record was closed during the fiscal year was only 17 days of hearing and 7 days of orehearing.
OLs. Hearing time for 12 operating license proceedings in which the record was closed during FY 1985 required an average, cumulative total of only 37 days of hearing and an average 10 prehearing days per case, for a total of 47
, hearing days. Total hearing days for pending operating 9 license proceedings presently is substantially less because
! the Shoreham and Limerick proceedings alone accounted for 65
, ; percent of the total. Absent those proceedings, average
- total hearing time is about 25 days. That number is low and reflects the parties' cooperation with Licensing Boards'
- efforts to improve hearing management and thus resolve more
- contentions prior to hearing.
OTHER. The average number of days of hearings required
! to complete all other types of proceedings is less than half the average days of hearing required for operating license and construction permit cases (except for the THI-1 restart proceeding). See Tables 2-7.
VI. AGE OF CASES The average age (length of time considered by a Board)
. of all cases on the docket during the Fiscal Year wes 38
. months. " Average age" means the number of months from the
- time a Licensing Board is first appointed (usually 30 to 60
. days after a license application is formally docketed) until the case is closed or the end of the fiscal year, whichever i Page 4 of 5 l
. 1 is earlier. Average age includes wait'ing time resulting from suspension of work or unavailability of hearing ,
documents (except where cases are suspended, for example, Carroll 1 & 2). " Average age" does not include the time a case may be pending before the Appeal Board or the Commission.
Average age by type for all cases on the docket during FY 1985 was: .
Type if Case Months
- 1. Operating license applications (19) 51
- 2. Operating license amendments (9) 36
. 3. Construction permits (2) 48
- 4. Special proceedings (4) 25
- 5. Spent Fuel ?ool & Transshipment (3) 20
- 6. Othee p-c<..edings (6) 15
- 7. Susper - g6) 36 DOCKET AVERAGE 38 The average was inflated by the presence of a handful of operating license proceedings plagued by problems that delayed resolution of hearing issues or created new ones 4 , late in the process.
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Page 5 of 5 F
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OCTOBER 1, 1985 i
ATOMIC SAFETY AND LICENSING BOARD PANEL PAGE: 2 0F 2 FISCAL YEAR 1985 DOCKET DATA TABLE 1 OPERATING LICENSES DISPOSITION OF CONTENTIONS DAYS OF HEARING TO DATE TOTAL MONTHS RESOLVED BALANCE PRE ON DOCKET ASLBP ASLBP HITH- STIP./ SUMM ADMIT BY BEFORE FOR HEAR- HEAR- TOTAL ACTIVE NAME OF CASE DATE FILED DENIED ADMIT DRAHN OTHER _ RIjiE ASLAP HEARIN1,,, HEARING ING ING TO DATE DOCKET
{
SHIRENAM 02/24/77 141 73 68 0 53 0 3 120 21 21 151 172 99 SHOREHAM EMER. PLANNING 05/11/83 98 24 74 0 0 3 0 98 0 15 72 87 25 SOUTH TEXAS 1 & 2 09/08/78 72 37 27 0 4 1 0 50 22 8 79 87 85 V0GTLE ELEC. PLANT 182 01/31/84 39 16 19 2 2 2 0 39 0 1 0 1 20 NASHINGTON NUCLEAR 1 09/16/82 20 4 14 2 0 0 0 20 0 2 0 2 36 TOTALS: 13T4 3B 3TE 23T TB T 7 Us . 171 185 Tf7 812 982 AVERAGE: 80 30 30 12 10 3 0 71 9 10 28 43 52 PERCENT: 100% 37.8% 37.3% 15.5% 12.2% 4.2% 0.5% 88.7% 11.2%
e 4
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, I fi OCTOBER 1, 1985 4
ATOMIC SAFETY AND LICEHSING BOARD PANEL PAGE: 1 0F 1 FISCAL YEAR 1985 DOCKET DATA TABLE 28 OPERATING AMENDMENTS r
DISPOSITION OF CONTENTIONS DAYS OF HEARING TO DATE i TOTAL MONTHS RESOLVED BALANCE PRE ON DOCKET ASLBP ASLBP HITH- STIP./ SUMM ADMIT BY BEFORE FOR HEAR- HEAR- TOTAL NAME OF CASE DATE ACTIVE FILED DENIED ADMIT DRAHN OTHER R11E ASLAP HEARING HEARING ING ING TO DATE DOCKET LACROSSE (RENEHAL) 11/30/77 25 12 6 0 0 6 0 25 0 2 0 2 65 NORTH ANNA 1 & 2 10/26/82 3 0 3 0 0 0 0 3 0 3 2 5 35 PILGRIM 10/21/83 0 0 0 0 0 0 0 0 0 0 3 3 22 THREE MILE ISLAND 1 07/15/83 2 0 2 0 0 2 0 6 8 7 3 10 16 THREE MILE ISLAND 2 05/15/80 14 0 0 0 10 0 0 10 4 0 0 0 65 TURKEY POINT 3 & 4 11/09/83 18 16 2 0 0 1 0 17 1 8 0 8 23 TURKEY POINT 3 & 4(OLA) 07/16/84 f. -L' 1 0 0 0 0 3 1 7 0 7 15 UCLA RESEARCH REACTOR 06/10/80 24 4 20 0 0 1 0 5 19 25 15 40 64 ZI0li 1 & 2 02/16/84 0 0 0 0 0 0 0 0 0 0 0 0 19 TOTALS: 90 ~33 34 0 to 10 0 69 ~33 37 23 ~73 374 AVERAGE: to 4 4 0 1 1 0 8 4 6 3 8 36 PERCENT: 100% 38.8% 37.7% 0.0% 11.1% 11.1x 0.0% 76.6% 36.6%
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l INTERNATIONAL l
- ENERGY ASSOCIATES
_ LIMITED i
l April 11, 1986 FREEDOM CF INFORMx110N l
Mr. Donnie Grimsley, Director ACT REQUEST ,
-[h -27 3 Division of Rules and Records Office of Administration Q '[~-
l U. S. Nuclear Regulatory Commission / f /_, ,
Washington, D.C. 20555 dbb 7 i
Dear Mr. Grimsley:
Pursuant to the Freedom of Information Act (FOIA), I would like '
to request the following information:
- 1. The names of all plants that have received an operating license (OL) since the accident at Three-Mile Island (TMI) '
in March 1979. t
(b) the Full Power OL issuance date. j !
! i
- 3. For each of these post-TMI OLs, please provide the number !
of NRC staff man-hours expended per calendar or fiscal }
year on license reviews from receipt of CP to receipt of ;
Full Power OL (or to date if the Full Power OL is !
pending). Please provide these hours according to the !
following five program office.1: (1) NRR, (2) IE-HQ, (3) !
Regions, (4) ACRS, and (5) NMES.
- 4. For each of these post-TMI OLs, please provide the number !
of HRC hearing days expended per year, subdivided f according to safety or environmental hearings. r
- 5. For each of these post-TMI OLs, please identify whether or l l not they were subjected to any of the following appraisals l l (if appropriate, how many of each of these appraisals).
(a) Construction Appraisal Team (CAT)
(
(b) Integrated Design Inspection (IDI) l (c) Independent Design Verification Program (IDVP) I (d) Inspection by HRC's Nondestructive Examination Van 1
(e) Other special design or construction verification !
program required or conducted by NRC l s
(f) INPO Construction Appraisal. !
i I
, N@ VmGINI A AVENUE. N W j j W ASHINGTON O C 2N37 ,
202-342 67W I
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a
a
- 6. For each of these post-TMI OLs, please list the number, value, and date of all civil penalties issued by NRC for design, construction and startup (before full power) activities.
Thank you for your assistance. Please do not hesitate to call me if there any question regarding this request or if you think there may be more readily available information that would help me to characterize any of the six areas I have identified herein.
SincNe,Ly, Les y R. Evans Senior Consultant 342-6751
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