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{{#Wiki_filter:I ft Ii-UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555January 22, 1990NRC INFORMATION NOTICE NO. 90-02: POTENTIAL DEGRADATION OF SECONDARYCONTAINMENT
{{#Wiki_filter:I ft I i-UNITED STATES NUCLEAR REGULATORY
 
COMMISSION
 
===OFFICE OF NUCLEAR REACTOR REGULATION===
WASHINGTON, D.C. 20555 January 22, 1990 NRC INFORMATION
 
NOTICE NO. 90-02: POTENTIAL
 
DEGRADATION
 
===OF SECONDARY CONTAINMENT===


==Addressees==
==Addressees==
:All holders of operating licenses or construction permits for boiling waterreactors (BWRs).
:
All holders of operating
 
licenses or construction
 
permits for boiling water reactors (BWRs).


==Purpose==
==Purpose==
:This information notice is intended to alert addressees to potential problemsinvolving degradation of secondary containment as a result of unforeseen inter-actions with various normal plant ventilation systems and inadequate surveillancetesting of secondary containment integrity. It is expected that recipients willreview the information for applicability to their facilities and consider actions,as appropriate, to avoid similar problems. However, suggestions contained inthis information notice do not constitute NRC requirements; therefore, no specificaction or written response is required.Detcription of Circumstances:Duane Arnold Energy CenterDuring a reactor building exhaust ventilation inspection, an Iowa Electricsystem engineer discovered a large hole in the duct work (see Figure 1).This hole allowed the main plant ventilation system to communicate directlywith the reactor building ventilation system, thus bypassing the standby gastreatment system (SGTS) and providing a direct path for an untreated releaseof radioactive effluents to the environment. This pathway would have existedeven with an automatic Engineered Safety Feature (ESF) isolation of the reactorbuilding ventilation system and an autostart of the SGTS. The licensee dis-covered that .its normal secondary containment integrity surveillance test(which requires a measurement of 0.25 inch water vacuum with one train ofSGTS operating) was still apparently satisfied with the main plant ventilationfans running. This has been the test configuration used at the plant sinceinitial startup in 1974. However, upon conducting the test with the SGTSoperating as designed and the main plant ventilation secured, the 0.25-inchvacuum could not be achieved because of numerous secondary containment leaks.A 10 CFR 50.72 4-hour notification was made to the NRC upon this discovery.The licensee determined that during the performance of the secondary contain-ment integrity surveillance as it was previously conducted, the main plant9001160420 Zjl_ _v c
: This information
 
notice is intended to alert addressees
 
to potential
 
problems involving
 
degradation
 
of secondary
 
containment
 
as a result of unforeseen
 
inter-actions with various normal plant ventilation
 
systems and inadequate
 
surveillance
 
testing of secondary
 
containment
 
integrity.
 
It is expected that recipients
 
will review the information
 
for applicability
 
to their facilities
 
and consider actions, as appropriate, to avoid similar problems.
 
However, suggestions
 
contained
 
in this information
 
notice do not constitute
 
NRC requirements;  
therefore, no specific action or written response is required.Detcription
 
of Circumstances:
Duane Arnold Energy Center During a reactor building exhaust ventilation
 
inspection, an Iowa Electric system engineer discovered
 
a large hole in the duct work (see Figure 1).This hole allowed the main plant ventilation
 
system to communicate
 
directly with the reactor building ventilation
 
system, thus bypassing
 
the standby gas treatment
 
system (SGTS) and providing
 
a direct path for an untreated
 
release of radioactive
 
effluents
 
to the environment.
 
This pathway would have existed even with an automatic
 
Engineered
 
Safety Feature (ESF) isolation
 
of the reactor building ventilation
 
system and an autostart
 
of the SGTS. The licensee dis-covered that .its normal secondary
 
containment
 
integrity
 
surveillance
 
test (which requires a measurement
 
of 0.25 inch water vacuum with one train of SGTS operating)  
was still apparently
 
satisfied
 
with the main plant ventilation
 
fans running. This has been the test configuration
 
used at the plant since initial startup in 1974. However, upon conducting
 
the test with the SGTS operating
 
as designed and the main plant ventilation
 
secured, the 0.25-inch vacuum could not be achieved because of numerous secondary
 
containment
 
leaks.A 10 CFR 50.72 4-hour notification
 
was made to the NRC upon this discovery.
 
The licensee determined
 
that during the performance
 
of the secondary
 
contain-ment integrity
 
surveillance
 
as it was previously
 
conducted, the main plant 9001160420
Zjl_ _v c
 
IN 90-02 January 22, 1990 ventilation, turbine building ventilation, and the radwaste building ventila-tion exhaust fans had aided the SGTS in drawing the required vacuum. Because surveillance
 
tests performed
 
since initial unit startup usually indicated
 
that the required negative pressure had been obtained, numerous secondary
 
contain-ment integrity
 
deficiencies
 
went undetected
 
and uncorrected.
 
===The maintenance===
to correct this overall degradation
 
of the secondary
 
containment
 
required more than 3 weeks of effort to locate and repair numerous door seals, electrical
 
penetrations, steam tunnel boot seals, dampers, building seals, and duct systems.These repairs resulted in an improvement
 
in the measured secondary
 
containment
 
vacuum from less than 0.08 inch of water to greater than 0.25 inch of water, as determined
 
by retesting
 
with a new surveillance
 
test procedure.
 
This test now requires all major plant exhaust ventilation
 
fans that potentially
 
communicate
 
with secondary
 
containment
 
to be secured.Continued
 
testing after repairs has shown that one main plant exhaust ventilation
 
fan can still draw an approximate
 
500 to 1000 standard cubic feet-per-minute (SCFM)volume' from the reactor building ventilation
 
system (the secondary
 
containment
 
boundary)
when the ESF-required
 
isolation
 
is in effect. As this circumstance
 
could result in an untreated
 
ground-level
 
release under certain accident scenarios, the licensee developed
 
alarm response procedures
 
designed to secure the main plant ventilation
 
fans when secondary
 
containment
 
isolation
 
is initiated
 
and main plant exhaust ventilation
 
radiation
 
monitors reach specified
 
values. Iowa Electric is also considering
 
long-term
 
corrective
 
action involving
 
hardware modifications
 
that would prevent main plant ventilation
 
from drawing air out of the reactor building under accident conditions.
 
Monticello
 
As a result of the secondary
 
containment
 
deficiencies
 
identified
 
at Duane Arnold, the NRC resident inspector
 
contacted
 
the licensee for the Monticello
 
plant con-cerning the procedures
 
and practices
 
for testing the secondary
 
containment
 
system.The licensee had normally tested the secondary
 
containment
 
integrity
 
with the main plant exhaust fans running and isolated both supply and exhaust fans in the reactor building.
 
However, on October 14, 1989, the licensee conducted the secondary
 
containment
 
integrity
 
test with the main plant exhaust fans secured and was not able to maintain the 0.25-inch
 
water vacuum required by the technical
 
specifications.
 
The vacuum reached in the reactor building was only 0.1 inch of water. Preliminary
 
investigation
 
revealed that failure of the test was due to leaks in the reactor building supply and exhaust system dampers and various other secondary
 
containment
 
leaks. The licensee also believes that the operation
 
of the main plant exhaust fans assisted the SGTS in drawing the required vacuum on the secondary
 
containment, thus establishing
 
a path that bypassed the SGTS. A 10 CFR 50.72 notification
 
was made to the NRC.Discussion
 
of Safety Significance:
Plant heating, ventilation, and air conditioning (HVAC) systems are diverse among boiling water reactors.
 
Interactions
 
between these systems and the standby gas treatment
 
system could mask degradation
 
of the secondary
 
contain-ment boundary during surveillance
 
testing and could exacerbate
 
such degradatiof+t'
by diverting
 
flow from the SGTS following
 
an accident.
 
-
K>IN 90-02 January 22, 1990 For those plants discussed
 
above, a portion of the secondary
 
containment
 
boundary is formed by the ductwork and isolation
 
dampers of the reactor build-ing ventilation
 
system. This system exhausts to a common plenum area within the reactor building, but outside secondary
 
containment, where ventilation
 
flows from other plant HVAC systems are also directed.
 
The high-capacity
 
main plant ventilation
 
exhaust fans take suction from the plenum area and discharge the flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity
 
to the reactor building ventilation
 
system components
 
that form part of the secondary
 
containment
 
boundary, the potential
 
exists for air flow to bypass the SGTS even when the secondary
 
containment
 
is isolated.
 
Further, if the main plant ventilation
 
fans are operated during surveillance
 
testing, degradation
 
of secondary
 
containment
 
could go undetected
 
as the main plant fans and the SGTS fans could collectively
 
draw the required vacuum.In view of the possibility
 
of the main plant ventilation
 
systems masking deficiencies
 
in SGTS and/or secondary
 
containment
 
integrity
 
and of creating possible untreated
 
release paths under accident conditions, licensees
 
for other BWR plants may wish to review the design and operation
 
of major plant ventila-tion systems and to review their secondary
 
containment
 
integrity
 
surveillance
 
procedures.
 
This information
 
notice requires no specific action or written response.
 
If you have any questions
 
about the information
 
in this notice, please contact one of the technical
 
contacts listed below or the appropriate
 
NRR project manager.Charles E. Rossi, Director Division of Operational
 
===Events Assessment===
Office of Nuclear Reactor Regulation
 
Technical
 
Contacts:
William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:
1. Figure 1 -Reactor Building Ventilation
 
2. List of Recently Issued NRC Information
 
Notices
 
Attachment
 
1 IN 90-02 January 22, 1990 Failed DucUng Isolatlon
 
Dampers Reactor Buiding VentShaft Fgure 1 Reactor Building Ventilation
 
Iw/I1-89 A1087 K>Attachment
 
2 IN 90-02 January 22, 1990 ti e.-..11 -1..,-1-LIST OF RECENTLY ISSUED NRC INFORMATION
 
NOTICES Information
 
Date of Notice No. Subject Issuance Issued to 90-01 89-90 89-89 89-88 89-87 89-45, Supp. 2 89-86 89-85 89-84 Importance
 
of Proper Response to Self-Identified
 
Violations
 
by Licensees Pressurizer
 
===Safety Valve Lift Setpoint Shift Event Notification===
Worksheets
 
Recent NRC-Sponsored
 
Testing of Motor-Operated
 
Valves Disabling
 
of Emergency Diesel Generators
 
by Their Neutral Ground-Fault
 
Protection
 
Circuitry Metalclad, Low-Voltage
 
Power Circuit Breakers Refurbished
 
with Substandard
 
Parts Type HK Circuit Breakers Missing Close Latch Anti-Shock Springs.EPA's Interim Final Rule on Medical Waste Tracking and Management
 
Failure of Ingersoll
 
Rand Air Start Motors as a Result of Pinion Gear Assembly Fitting Problems 1/12/90 12/28/89 12/26/89 12/26/89 12/19/89 12/15/89 12/15/89 12/15/89 12/12/89 All holders of NRC materials
 
licenses.All holders of OLs or CPs for PWRs.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All medical, academic, industrial, waste broker, and waste disposal site licensees.
 
All holders of OLs or CPs for nuclear power reactors.OL = Operating
 
License CP = Construction
 
Permit
 
IN 90-02 January 22, 1990 For those plants discussed
 
above, a portion of the secondary
 
containment
 
boundary is formed by the ductwork and isolation
 
dampers of the reactor build-ing ventilation
 
system. This system exhausts to a common plenum area within the reactor building, but outside secondary
 
containment, where ventilation
 
flows from other plant HVAC systems are also directed.
 
The high-capacity
 
main plant ventilation
 
exhaust fans take suction from the plenum area and discharge the flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity
 
to the reactor building ventilation
 
system components
 
that form part of the secondary
 
containment
 
boundary, the potential
 
exists for air flow to bypass the SGTS even when the secondary
 
containment
 
is Isolated.
 
Further, if the main plant ventilation
 
fans are operated during surveillance
 
testing, degradation
 
of secondary
 
containment
 
could go undetected
 
as the main plant fans and the SGTS fans could collectively
 
draw the required vacuum.In view of the possibility
 
of the main plant ventilation
 
systems masking deficiencies
 
in SGTS and/or secondary
 
containment
 
integrity
 
and of creating possible untreated
 
release paths under accident conditions, licensees
 
for other BWR plants may wish to review the design and operation
 
of major plant ventila-tion systems and to review their secondary
 
containment
 
integrity
 
surveillance
 
procedures.
 
This information
 
notice requires no specific action or written response.
 
If you have any questions
 
about the information
 
in this notice, please contact one of the technical
 
contacts listed below or the appropriate
 
NRR project manager.Charles E. Rossi, Director Division of Operational
 
===Events Assessment===
Office of Nuclear Reactor Regulation
 
Technical
 
Contacts:
William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:
1. Figure 1 -Reactor Building Ventilation
 
2. List of Recently Issued NRC Information
 
Notices Document Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES
 
D *C/OGCB:DOEA:NRR
 
*RPB:ARM *D/DST:NRR
 
E CHBerlinger
 
TechEd AThadani 01//190 01/10/90 12/21/89 12/18/89*OGCB:DOEA:NRR*RIII
 
*PD33:DRSP:NRR
 
*SPLB:DST:NRR*C/SPLB:DST:NRR
 
RJKiessel
 
EGGreenman
 
===JRHall JKudrick CEMcCracken===
11/16/89 11/21/89 11/16/89 12/12/89 12/12/89 IN 90-XX January xx, 1990 For those plants discussed
 
above, a portion of the secondary
 
containment
 
boundary is formed by the ductwork and isolation
 
dampers of the reactor build-ing ventilation
 
system. This system exhausts to a common plenum area within the reactor building, but outside secondary
 
containment, where ventilation
 
flows from other plant HVAC systems are also directed.
 
The high-capacity
 
main plant ventilation
 
exhaust fans take suction from the plenum area and discharge the flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity
 
to the reactor building ventilation
 
system components
 
that form part of the secondary
 
containment
 
boundary, the potential
 
exists for air flow to bypass the SGTS even when the secondary
 
containment
 
is isolated.
 
Further, if the main plant ventilation
 
fans are operated during surveillance
 
testing, degradation
 
of secondary
 
containment
 
could go undetected
 
as the main plant fans and the SGTS fans could collectively
 
draw the required vacuum.In view of the possibility
 
of the main plant ventilation
 
systems' masking deficiencies
 
in SGTS and/or secondary
 
containment
 
integrity
 
and of creating possible untreated
 
release paths under accident conditions, licensees
 
for other BWR plants may wish to review the design and operation
 
of major plant ventila-tion systems and to review their secondary
 
containment
 
integrity
 
surveillance
 
procedures.
 
This information
 
notice requires no specific action or written response.
 
If you have any questions
 
about the information
 
in this notice, please contact the technical
 
contacts listed below or the appropriate
 
NRR project manager.Charles E. Rossi, Director Division of Operational
 
===Events Assessment===
Office of Nuclear Reactor Regulation
 
Technical
 
Contacts:
William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:
1. Figure 1 -Reactor Building Ventilation
 
2. Figure 2 -Exhaust Fan Room 3. List of Recently Issued NRC Information
 
Notices Document Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES
 
D/DOEA:NRR
 
C/OGCB:D C Byt;*RPB:ARM
 
*D/DST:NRR
 
CERossi CHBerline
 
j) TechEd AThadani 01/ /90 01/Y,/90-
' 12/21/89 12/18/89*OGCB:DOEA:NRR*RIII
 
*PD33:DRSP:NRR
 
*SPLB:DST:NRR*C/SPLB:DST:NRR
 
RJKiessel
 
EGGreenman
 
JRHall -lf JKudrick CEMcCracken
 
11 11/21 11/16/8w 12/12/89 12/12/89 441/44s~4 IN 89-XX%2 ~November
 
xx, 1989 standby gas treatment
 
system could mask degradation
 
of the secondary
 
contain-ment boundary during surveillance
 
testing and could exacerbate
 
such degradation
 
by diverting
 
flow from the SGTS following
 
an accident.For those plants discussed
 
above, a portion of the secondary
 
containment
 
boundary is formed by the ductwork and isolation
 
dampers of the reactor build-ing ventilation
 
system. This system exhausts to a common plenum area within the reactor building, but outside secondary
 
containment, where ventilation
 
flows from other plant HVAC systems are also directed.
 
The high capacity main plant ventilation
 
exhaust fans take suction from the plenum area and discharge the flow out through the reactor building roof stacks. Due to the high capa-city of the main plant exhaust fans and their proximity
 
to the reactor building ventilation
 
system components
 
that form part of the secondary
 
containment
 
boundary, the potential
 
exists for air flow to bypass the SGTS even when the secondary
 
containment
 
is isolated.
 
Further, if the main plant ventilation
 
fans are operated during surveillance
 
testing, degradation
 
of secondary
 
containment
 
could go undetected
 
as the main plant fans and SGTS fans could collectively
 
draw the required vacuum.In view of the possibility
 
of main plant ventilation
 
systems masking deficien-cies in SGTS and/or secondary
 
containment
 
integrity
 
and of creating possible untreated
 
release paths under accident conditions, other BWR plants may wish to review the design and operation
 
of major plant ventilation
 
systems and to review their secondary
 
containment
 
integrity
 
surveillance
 
procedures.
 
This information
 
notice requires no specific action or written response.
 
If you have any questions
 
about the information
 
in this notice, please contact the technical
 
contacts listed below or the appropriate
 
NRR project manager.Charles E. Rossi, Director Division of Operational
 
===Events Assessment===
Office of Nuclear Reactor Regulation
 
Technical
 
Contacts: William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:
1. Figure 1 -Reactor Building Ventilation
 
2. Figure 2 -Exhaust Fan Room 3. List of Recently Issued NRC Information
 
Notices Document Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES
 
sit D/DOEA:NRR
 
C/OGCB:DOEA:NRR
 
RPB:ARO'CERossi CHBerlinger
 
TechEd 11/ /89 11/ /89 ftH/.Zf/*OGCB:DOEA:NRR*RIII
 
*PD33:DRSP:NRR


IN 90-02January 22, 1990 ventilation, turbine building ventilation, and the radwaste building ventila-tion exhaust fans had aided the SGTS in drawing the required vacuum. Becausesurveillance tests performed since initial unit startup usually indicated thatthe required negative pressure had been obtained, numerous secondary contain-ment integrity deficiencies went undetected and uncorrected. The maintenanceto correct this overall degradation of the secondary containment required morethan 3 weeks of effort to locate and repair numerous door seals, electricalpenetrations, steam tunnel boot seals, dampers, building seals, and duct systems.These repairs resulted in an improvement in the measured secondary containmentvacuum from less than 0.08 inch of water to greater than 0.25 inch of water, asdetermined by retesting with a new surveillance test procedure. This test nowrequires all major plant exhaust ventilation fans that potentially communicatewith secondary containment to be secured.Continued testing after repairs has shown that one main plant exhaust ventilationfan can still draw an approximate 500 to 1000 standard cubic feet-per-minute (SCFM)volume' from the reactor building ventilation system (the secondary containmentboundary) when the ESF-required isolation is in effect. As this circumstancecould result in an untreated ground-level release under certain accident scenarios,the licensee developed alarm response procedures designed to secure the mainplant ventilation fans when secondary containment isolation is initiated andmain plant exhaust ventilation radiation monitors reach specified values. IowaElectric is also considering long-term corrective action involving hardwaremodifications that would prevent main plant ventilation from drawing air outof the reactor building under accident conditions.MonticelloAs a result of the secondary containment deficiencies identified at Duane Arnold,the NRC resident inspector contacted the licensee for the Monticello plant con-cerning the procedures and practices for testing the secondary containment system.The licensee had normally tested the secondary containment integrity with themain plant exhaust fans running and isolated both supply and exhaust fans inthe reactor building. However, on October 14, 1989, the licensee conductedthe secondary containment integrity test with the main plant exhaust fanssecured and was not able to maintain the 0.25-inch water vacuum required bythe technical specifications. The vacuum reached in the reactor building wasonly 0.1 inch of water. Preliminary investigation revealed that failure ofthe test was due to leaks in the reactor building supply and exhaust systemdampers and various other secondary containment leaks. The licensee alsobelieves that the operation of the main plant exhaust fans assisted the SGTSin drawing the required vacuum on the secondary containment, thus establishinga path that bypassed the SGTS. A 10 CFR 50.72 notification was made to the NRC.Discussion of Safety Significance:Plant heating, ventilation, and air conditioning (HVAC) systems are diverseamong boiling water reactors. Interactions between these systems and thestandby gas treatment system could mask degradation of the secondary contain-ment boundary during surveillance testing and could exacerbate such degradatiof+t'by diverting flow from the SGTS following an accident. -
SPLB: R RJKiessel
K>IN 90-02January 22, 1990 For those plants discussed above, a portion of the secondary containmentboundary is formed by the ductwork and isolation dampers of the reactor build-ing ventilation system. This system exhausts to a common plenum area withinthe reactor building, but outside secondary containment, where ventilationflows from other plant HVAC systems are also directed. The high-capacity mainplant ventilation exhaust fans take suction from the plenum area and dischargethe flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity to the reactor buildingventilation system components that form part of the secondary containmentboundary, the potential exists for air flow to bypass the SGTS even when thesecondary containment is isolated. Further, if the main plant ventilation fansare operated during surveillance testing, degradation of secondary containmentcould go undetected as the main plant fans and the SGTS fans could collectivelydraw the required vacuum.In view of the possibility of the main plant ventilation systems maskingdeficiencies in SGTS and/or secondary containment integrity and of creatingpossible untreated release paths under accident conditions, licensees for otherBWR plants may wish to review the design and operation of major plant ventila-tion systems and to review their secondary containment integrity surveillanceprocedures.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact oneof the technical contacts listed below or the appropriate NRR project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contacts: William L. Axelson, Region III(708) 790-5574John A. Kudrick, NRR(301) 492-0871James R. Hall, NRR(301) 492-1391Attachments:1. Figure 1 -Reactor Building Ventilation2. List of Recently Issued NRC Information Notices


Attachment 1IN 90-02January 22, 1990 Failed DucUngIsolatlon DampersReactor BuidingVentShaftFgure 1Reactor Building VentilationIw/I1-89A1087 K>Attachment 2IN 90-02January 22, 1990 ti e.-..11 -1..,-1-LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to90-0189-9089-8989-8889-8789-45,Supp. 289-8689-8589-84Importance of ProperResponse to Self-IdentifiedViolations by LicenseesPressurizer Safety ValveLift Setpoint ShiftEvent NotificationWorksheetsRecent NRC-SponsoredTesting of Motor-OperatedValvesDisabling of EmergencyDiesel Generators byTheir Neutral Ground-FaultProtection CircuitryMetalclad, Low-VoltagePower Circuit BreakersRefurbished withSubstandard PartsType HK Circuit BreakersMissing Close Latch Anti-Shock Springs.EPA's Interim Final Ruleon Medical Waste Trackingand ManagementFailure of Ingersoll RandAir Start Motors as a Resultof Pinion Gear AssemblyFitting Problems1/12/9012/28/8912/26/8912/26/8912/19/8912/15/8912/15/8912/15/8912/12/89All holders of NRCmaterials licenses.All holders of OLsor CPs for PWRs.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All holders of OLsor CPs for nuclearpower reactors.All medical, academic,industrial, wastebroker, and wastedisposal site licensees.All holders of OLsor CPs for nuclearpower reactors.OL = Operating LicenseCP = Construction Permit
EGGreenman


IN 90-02January 22, 1990 For those plants discussed above, a portion of the secondary containmentboundary is formed by the ductwork and isolation dampers of the reactor build-ing ventilation system. This system exhausts to a common plenum area withinthe reactor building, but outside secondary containment, where ventilationflows from other plant HVAC systems are also directed. The high-capacity mainplant ventilation exhaust fans take suction from the plenum area and dischargethe flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity to the reactor buildingventilation system components that form part of the secondary containmentboundary, the potential exists for air flow to bypass the SGTS even when thesecondary containment is Isolated. Further, if the main plant ventilation fansare operated during surveillance testing, degradation of secondary containmentcould go undetected as the main plant fans and the SGTS fans could collectivelydraw the required vacuum.In view of the possibility of the main plant ventilation systems maskingdeficiencies in SGTS and/or secondary containment integrity and of creatingpossible untreated release paths under accident conditions, licensees for otherBWR plants may wish to review the design and operation of major plant ventila-tion systems and to review their secondary containment integrity surveillanceprocedures.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact oneof the technical contacts listed below or the appropriate NRR project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contacts: William L. Axelson, Region III(708) 790-5574John A. Kudrick, NRR(301) 492-0871James R. Hall, NRR(301) 492-1391Attachments:1. Figure 1 -Reactor Building Ventilation2. List of Recently Issued NRC Information NoticesDocument Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCESD *C/OGCB:DOEA:NRR *RPB:ARM *D/DST:NRRE CHBerlinger TechEd AThadani01//190 01/10/90 12/21/89 12/18/89*OGCB:DOEA:NRR*RIII *PD33:DRSP:NRR *SPLB:DST:NRR*C/SPLB:DST:NRRRJKiessel EGGreenman JRHall JKudrick CEMcCracken11/16/89 11/21/89 11/16/89 12/12/89 12/12/89 IN 90-XXJanuary xx, 1990 For those plants discussed above, a portion of the secondary containmentboundary is formed by the ductwork and isolation dampers of the reactor build-ing ventilation system. This system exhausts to a common plenum area withinthe reactor building, but outside secondary containment, where ventilationflows from other plant HVAC systems are also directed. The high-capacity mainplant ventilation exhaust fans take suction from the plenum area and dischargethe flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity to the reactor buildingventilation system components that form part of the secondary containmentboundary, the potential exists for air flow to bypass the SGTS even when thesecondary containment is isolated. Further, if the main plant ventilation fansare operated during surveillance testing, degradation of secondary containmentcould go undetected as the main plant fans and the SGTS fans could collectivelydraw the required vacuum.In view of the possibility of the main plant ventilation systems' maskingdeficiencies in SGTS and/or secondary containment integrity and of creatingpossible untreated release paths under accident conditions, licensees for otherBWR plants may wish to review the design and operation of major plant ventila-tion systems and to review their secondary containment integrity surveillanceprocedures.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact thetechnical contacts listed below or the appropriate NRR project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contacts: William L. Axelson, Region III(708) 790-5574John A. Kudrick, NRR(301) 492-0871James R. Hall, NRR(301) 492-1391Attachments:1. Figure 1 -Reactor Building Ventilation2. Figure 2 -Exhaust Fan Room3. List of Recently Issued NRC Information NoticesDocument Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCESD/DOEA:NRR C/OGCB:D C Byt;*RPB:ARM *D/DST:NRRCERossi CHBerline j) TechEd AThadani01/ /90 01/Y,/90- ' 12/21/89 12/18/89*OGCB:DOEA:NRR*RIII *PD33:DRSP:NRR *SPLB:DST:NRR*C/SPLB:DST:NRRRJKiessel EGGreenman JRHall -lf JKudrick CEMcCracken11 11/21 11/16/8w 12/12/89 12/12/89441/44s~4 IN 89-XX%2 ~November xx, 1989 standby gas treatment system could mask degradation of the secondary contain-ment boundary during surveillance testing and could exacerbate such degradationby diverting flow from the SGTS following an accident.For those plants discussed above, a portion of the secondary containmentboundary is formed by the ductwork and isolation dampers of the reactor build-ing ventilation system. This system exhausts to a common plenum area withinthe reactor building, but outside secondary containment, where ventilationflows from other plant HVAC systems are also directed. The high capacity mainplant ventilation exhaust fans take suction from the plenum area and dischargethe flow out through the reactor building roof stacks. Due to the high capa-city of the main plant exhaust fans and their proximity to the reactor buildingventilation system components that form part of the secondary containmentboundary, the potential exists for air flow to bypass the SGTS even when thesecondary containment is isolated. Further, if the main plant ventilation fansare operated during surveillance testing, degradation of secondary containmentcould go undetected as the main plant fans and SGTS fans could collectivelydraw the required vacuum.In view of the possibility of main plant ventilation systems masking deficien-cies in SGTS and/or secondary containment integrity and of creating possibleuntreated release paths under accident conditions, other BWR plants may wish toreview the design and operation of major plant ventilation systems and toreview their secondary containment integrity surveillance procedures.This information notice requires no specific action or written response. Ifyou have any questions about the information in this notice, please contact thetechnical contacts listed below or the appropriate NRR project manager.Charles E. Rossi, DirectorDivision of Operational Events AssessmentOffice of Nuclear Reactor RegulationTechnical Contacts:William L. Axelson, Region III(708) 790-5574John A. Kudrick, NRR(301) 492-0871James R. Hall, NRR(301) 492-1391Attachments:1. Figure 1 -Reactor Building Ventilation2. Figure 2 -Exhaust Fan Room3. List of Recently Issued NRC Information NoticesDocument Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES sitD/DOEA:NRR C/OGCB:DOEA:NRR RPB:ARO'CERossi CHBerlinger TechEd11/ /89 11/ /89 ftH/.Zf/*OGCB:DOEA:NRR*RIII *PD33:DRSP:NRR SPLB: RRJKiessel EGGreenman JRHall *udri11/16/89 11/21/89 11/16/89 WMIAl'D/DST:NRRniMAK /89C/SPLB:DST: WG9CEMcCracken,_ --/d 89  
JRHall *udri 11/16/89 11/21/89 11/16/89 WMI Al'D/DST:NRR ni MAK /89 C/SPLB:DST:  
}}
WG9 CEMcCracken,_  
--/d 89}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Revision as of 13:45, 31 August 2018

Potential Degradation of Secondary Containment
ML031130355
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date: 01/22/1990
From: Rossi C E
Office of Nuclear Reactor Regulation
To:
References
IN-90-002, NUDOCS 9001160420
Download: ML031130355 (9)


I ft I i-UNITED STATES NUCLEAR REGULATORY

COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555 January 22, 1990 NRC INFORMATION

NOTICE NO. 90-02: POTENTIAL

DEGRADATION

OF SECONDARY CONTAINMENT

Addressees

All holders of operating

licenses or construction

permits for boiling water reactors (BWRs).

Purpose

This information

notice is intended to alert addressees

to potential

problems involving

degradation

of secondary

containment

as a result of unforeseen

inter-actions with various normal plant ventilation

systems and inadequate

surveillance

testing of secondary

containment

integrity.

It is expected that recipients

will review the information

for applicability

to their facilities

and consider actions, as appropriate, to avoid similar problems.

However, suggestions

contained

in this information

notice do not constitute

NRC requirements;

therefore, no specific action or written response is required.Detcription

of Circumstances:

Duane Arnold Energy Center During a reactor building exhaust ventilation

inspection, an Iowa Electric system engineer discovered

a large hole in the duct work (see Figure 1).This hole allowed the main plant ventilation

system to communicate

directly with the reactor building ventilation

system, thus bypassing

the standby gas treatment

system (SGTS) and providing

a direct path for an untreated

release of radioactive

effluents

to the environment.

This pathway would have existed even with an automatic

Engineered

Safety Feature (ESF) isolation

of the reactor building ventilation

system and an autostart

of the SGTS. The licensee dis-covered that .its normal secondary

containment

integrity

surveillance

test (which requires a measurement

of 0.25 inch water vacuum with one train of SGTS operating)

was still apparently

satisfied

with the main plant ventilation

fans running. This has been the test configuration

used at the plant since initial startup in 1974. However, upon conducting

the test with the SGTS operating

as designed and the main plant ventilation

secured, the 0.25-inch vacuum could not be achieved because of numerous secondary

containment

leaks.A 10 CFR 50.72 4-hour notification

was made to the NRC upon this discovery.

The licensee determined

that during the performance

of the secondary

contain-ment integrity

surveillance

as it was previously

conducted, the main plant 9001160420

Zjl_ _v c

IN 90-02 January 22, 1990 ventilation, turbine building ventilation, and the radwaste building ventila-tion exhaust fans had aided the SGTS in drawing the required vacuum. Because surveillance

tests performed

since initial unit startup usually indicated

that the required negative pressure had been obtained, numerous secondary

contain-ment integrity

deficiencies

went undetected

and uncorrected.

The maintenance

to correct this overall degradation

of the secondary

containment

required more than 3 weeks of effort to locate and repair numerous door seals, electrical

penetrations, steam tunnel boot seals, dampers, building seals, and duct systems.These repairs resulted in an improvement

in the measured secondary

containment

vacuum from less than 0.08 inch of water to greater than 0.25 inch of water, as determined

by retesting

with a new surveillance

test procedure.

This test now requires all major plant exhaust ventilation

fans that potentially

communicate

with secondary

containment

to be secured.Continued

testing after repairs has shown that one main plant exhaust ventilation

fan can still draw an approximate

500 to 1000 standard cubic feet-per-minute (SCFM)volume' from the reactor building ventilation

system (the secondary

containment

boundary)

when the ESF-required

isolation

is in effect. As this circumstance

could result in an untreated

ground-level

release under certain accident scenarios, the licensee developed

alarm response procedures

designed to secure the main plant ventilation

fans when secondary

containment

isolation

is initiated

and main plant exhaust ventilation

radiation

monitors reach specified

values. Iowa Electric is also considering

long-term

corrective

action involving

hardware modifications

that would prevent main plant ventilation

from drawing air out of the reactor building under accident conditions.

Monticello

As a result of the secondary

containment

deficiencies

identified

at Duane Arnold, the NRC resident inspector

contacted

the licensee for the Monticello

plant con-cerning the procedures

and practices

for testing the secondary

containment

system.The licensee had normally tested the secondary

containment

integrity

with the main plant exhaust fans running and isolated both supply and exhaust fans in the reactor building.

However, on October 14, 1989, the licensee conducted the secondary

containment

integrity

test with the main plant exhaust fans secured and was not able to maintain the 0.25-inch

water vacuum required by the technical

specifications.

The vacuum reached in the reactor building was only 0.1 inch of water. Preliminary

investigation

revealed that failure of the test was due to leaks in the reactor building supply and exhaust system dampers and various other secondary

containment

leaks. The licensee also believes that the operation

of the main plant exhaust fans assisted the SGTS in drawing the required vacuum on the secondary

containment, thus establishing

a path that bypassed the SGTS. A 10 CFR 50.72 notification

was made to the NRC.Discussion

of Safety Significance:

Plant heating, ventilation, and air conditioning (HVAC) systems are diverse among boiling water reactors.

Interactions

between these systems and the standby gas treatment

system could mask degradation

of the secondary

contain-ment boundary during surveillance

testing and could exacerbate

such degradatiof+t'

by diverting

flow from the SGTS following

an accident.

-

K>IN 90-02 January 22, 1990 For those plants discussed

above, a portion of the secondary

containment

boundary is formed by the ductwork and isolation

dampers of the reactor build-ing ventilation

system. This system exhausts to a common plenum area within the reactor building, but outside secondary

containment, where ventilation

flows from other plant HVAC systems are also directed.

The high-capacity

main plant ventilation

exhaust fans take suction from the plenum area and discharge the flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity

to the reactor building ventilation

system components

that form part of the secondary

containment

boundary, the potential

exists for air flow to bypass the SGTS even when the secondary

containment

is isolated.

Further, if the main plant ventilation

fans are operated during surveillance

testing, degradation

of secondary

containment

could go undetected

as the main plant fans and the SGTS fans could collectively

draw the required vacuum.In view of the possibility

of the main plant ventilation

systems masking deficiencies

in SGTS and/or secondary

containment

integrity

and of creating possible untreated

release paths under accident conditions, licensees

for other BWR plants may wish to review the design and operation

of major plant ventila-tion systems and to review their secondary

containment

integrity

surveillance

procedures.

This information

notice requires no specific action or written response.

If you have any questions

about the information

in this notice, please contact one of the technical

contacts listed below or the appropriate

NRR project manager.Charles E. Rossi, Director Division of Operational

Events Assessment

Office of Nuclear Reactor Regulation

Technical

Contacts:

William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:

1. Figure 1 -Reactor Building Ventilation

2. List of Recently Issued NRC Information

Notices

Attachment

1 IN 90-02 January 22, 1990 Failed DucUng Isolatlon

Dampers Reactor Buiding VentShaft Fgure 1 Reactor Building Ventilation

Iw/I1-89 A1087 K>Attachment

2 IN 90-02 January 22, 1990 ti e.-..11 -1..,-1-LIST OF RECENTLY ISSUED NRC INFORMATION

NOTICES Information

Date of Notice No. Subject Issuance Issued to 90-01 89-90 89-89 89-88 89-87 89-45, Supp. 2 89-86 89-85 89-84 Importance

of Proper Response to Self-Identified

Violations

by Licensees Pressurizer

Safety Valve Lift Setpoint Shift Event Notification

Worksheets

Recent NRC-Sponsored

Testing of Motor-Operated

Valves Disabling

of Emergency Diesel Generators

by Their Neutral Ground-Fault

Protection

Circuitry Metalclad, Low-Voltage

Power Circuit Breakers Refurbished

with Substandard

Parts Type HK Circuit Breakers Missing Close Latch Anti-Shock Springs.EPA's Interim Final Rule on Medical Waste Tracking and Management

Failure of Ingersoll

Rand Air Start Motors as a Result of Pinion Gear Assembly Fitting Problems 1/12/90 12/28/89 12/26/89 12/26/89 12/19/89 12/15/89 12/15/89 12/15/89 12/12/89 All holders of NRC materials

licenses.All holders of OLs or CPs for PWRs.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All medical, academic, industrial, waste broker, and waste disposal site licensees.

All holders of OLs or CPs for nuclear power reactors.OL = Operating

License CP = Construction

Permit

IN 90-02 January 22, 1990 For those plants discussed

above, a portion of the secondary

containment

boundary is formed by the ductwork and isolation

dampers of the reactor build-ing ventilation

system. This system exhausts to a common plenum area within the reactor building, but outside secondary

containment, where ventilation

flows from other plant HVAC systems are also directed.

The high-capacity

main plant ventilation

exhaust fans take suction from the plenum area and discharge the flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity

to the reactor building ventilation

system components

that form part of the secondary

containment

boundary, the potential

exists for air flow to bypass the SGTS even when the secondary

containment

is Isolated.

Further, if the main plant ventilation

fans are operated during surveillance

testing, degradation

of secondary

containment

could go undetected

as the main plant fans and the SGTS fans could collectively

draw the required vacuum.In view of the possibility

of the main plant ventilation

systems masking deficiencies

in SGTS and/or secondary

containment

integrity

and of creating possible untreated

release paths under accident conditions, licensees

for other BWR plants may wish to review the design and operation

of major plant ventila-tion systems and to review their secondary

containment

integrity

surveillance

procedures.

This information

notice requires no specific action or written response.

If you have any questions

about the information

in this notice, please contact one of the technical

contacts listed below or the appropriate

NRR project manager.Charles E. Rossi, Director Division of Operational

Events Assessment

Office of Nuclear Reactor Regulation

Technical

Contacts:

William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:

1. Figure 1 -Reactor Building Ventilation

2. List of Recently Issued NRC Information

Notices Document Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES

D *C/OGCB:DOEA:NRR

  • RPB:ARM *D/DST:NRR

E CHBerlinger

TechEd AThadani 01//190 01/10/90 12/21/89 12/18/89*OGCB:DOEA:NRR*RIII

  • PD33:DRSP:NRR
  • SPLB:DST:NRR*C/SPLB:DST:NRR

RJKiessel

EGGreenman

JRHall JKudrick CEMcCracken

11/16/89 11/21/89 11/16/89 12/12/89 12/12/89 IN 90-XX January xx, 1990 For those plants discussed

above, a portion of the secondary

containment

boundary is formed by the ductwork and isolation

dampers of the reactor build-ing ventilation

system. This system exhausts to a common plenum area within the reactor building, but outside secondary

containment, where ventilation

flows from other plant HVAC systems are also directed.

The high-capacity

main plant ventilation

exhaust fans take suction from the plenum area and discharge the flow through the reactor building roof stacks. Because of the high capa-city of the main plant exhaust fans and their proximity

to the reactor building ventilation

system components

that form part of the secondary

containment

boundary, the potential

exists for air flow to bypass the SGTS even when the secondary

containment

is isolated.

Further, if the main plant ventilation

fans are operated during surveillance

testing, degradation

of secondary

containment

could go undetected

as the main plant fans and the SGTS fans could collectively

draw the required vacuum.In view of the possibility

of the main plant ventilation

systems' masking deficiencies

in SGTS and/or secondary

containment

integrity

and of creating possible untreated

release paths under accident conditions, licensees

for other BWR plants may wish to review the design and operation

of major plant ventila-tion systems and to review their secondary

containment

integrity

surveillance

procedures.

This information

notice requires no specific action or written response.

If you have any questions

about the information

in this notice, please contact the technical

contacts listed below or the appropriate

NRR project manager.Charles E. Rossi, Director Division of Operational

Events Assessment

Office of Nuclear Reactor Regulation

Technical

Contacts:

William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:

1. Figure 1 -Reactor Building Ventilation

2. Figure 2 -Exhaust Fan Room 3. List of Recently Issued NRC Information

Notices Document Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES

D/DOEA:NRR

C/OGCB:D C Byt;*RPB:ARM

  • D/DST:NRR

CERossi CHBerline

j) TechEd AThadani 01/ /90 01/Y,/90-

' 12/21/89 12/18/89*OGCB:DOEA:NRR*RIII

  • PD33:DRSP:NRR
  • SPLB:DST:NRR*C/SPLB:DST:NRR

RJKiessel

EGGreenman

JRHall -lf JKudrick CEMcCracken

11 11/21 11/16/8w 12/12/89 12/12/89 441/44s~4 IN 89-XX%2 ~November

xx, 1989 standby gas treatment

system could mask degradation

of the secondary

contain-ment boundary during surveillance

testing and could exacerbate

such degradation

by diverting

flow from the SGTS following

an accident.For those plants discussed

above, a portion of the secondary

containment

boundary is formed by the ductwork and isolation

dampers of the reactor build-ing ventilation

system. This system exhausts to a common plenum area within the reactor building, but outside secondary

containment, where ventilation

flows from other plant HVAC systems are also directed.

The high capacity main plant ventilation

exhaust fans take suction from the plenum area and discharge the flow out through the reactor building roof stacks. Due to the high capa-city of the main plant exhaust fans and their proximity

to the reactor building ventilation

system components

that form part of the secondary

containment

boundary, the potential

exists for air flow to bypass the SGTS even when the secondary

containment

is isolated.

Further, if the main plant ventilation

fans are operated during surveillance

testing, degradation

of secondary

containment

could go undetected

as the main plant fans and SGTS fans could collectively

draw the required vacuum.In view of the possibility

of main plant ventilation

systems masking deficien-cies in SGTS and/or secondary

containment

integrity

and of creating possible untreated

release paths under accident conditions, other BWR plants may wish to review the design and operation

of major plant ventilation

systems and to review their secondary

containment

integrity

surveillance

procedures.

This information

notice requires no specific action or written response.

If you have any questions

about the information

in this notice, please contact the technical

contacts listed below or the appropriate

NRR project manager.Charles E. Rossi, Director Division of Operational

Events Assessment

Office of Nuclear Reactor Regulation

Technical

Contacts: William L. Axelson, Region III (708) 790-5574 John A. Kudrick, NRR (301) 492-0871 James R. Hall, NRR (301) 492-1391 Attachments:

1. Figure 1 -Reactor Building Ventilation

2. Figure 2 -Exhaust Fan Room 3. List of Recently Issued NRC Information

Notices Document Name: INFO NOTICE -JACKIW, KIESSEL*SEE PREVIOUS CONCURRENCES

sit D/DOEA:NRR

C/OGCB:DOEA:NRR

RPB:ARO'CERossi CHBerlinger

TechEd 11/ /89 11/ /89 ftH/.Zf/*OGCB:DOEA:NRR*RIII

  • PD33:DRSP:NRR

SPLB: R RJKiessel

EGGreenman

JRHall *udri 11/16/89 11/21/89 11/16/89 WMI Al'D/DST:NRR ni MAK /89 C/SPLB:DST:

WG9 CEMcCracken,_

--/d 89