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{{#Wiki_filter:' ,, __ . ** Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 | {{#Wiki_filter:' ,, __ . ** Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President | ||
Senior Vice President | -Nuclear Operations | ||
-Nuclear Operations | * JUL 16 1997 LR-N970449 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 SUPPLEMENTAL RESPONSE TO A NOTICE OF VIOLATION INSPECTION REPORT 50-311/97-06 SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 Gentlemen: | ||
* JUL 16 1997 LR-N970449 | Inspection Report No. 50-311/97-06 for Salem Nuclear Generating Station Unit No. 2 was transmitted to Public Electric & Gas Company (PSE&G) on May 30, 1997. Within the scope of this report, one violation of NRC requirements was c.i ted. The violation involved the failure to follow established procedures for the documentation of test results. By letter dated June 30, 1997 (Our Ref: LR-N970371), PSE&G submitted its response to the cited violation. | ||
United States Nuclear Regulatory | As stated in the original PSE&G response, the root cause of the violation (all f; cited examples) was attributed to poor human performance of l)J personnel performing the activities and poor human performance by management in the oversight of these activities. | ||
Commission | The corrective actions stated in the June 30 response were designed to address ';* the root cause in its broadest form. To provide a complete understanding of PSE&G's actions taken, PSE&G is supplementing the June 30, 1997 original response to address the specific actions taken relative to each of the cited examples. | ||
Document Control Desk Washington, DC 20555 SUPPLEMENTAL | Mssrs. D. Powell and M. Rencheck of PSE&G discussed the submittal of this supplemental response with Mr. W. Ruland (NRC Region I) via telephone on July 9, 1997. 9707220344 970716 PDR ADOCK 05000311 G PDR *..* *,_, _ .. \J Printedon | ||
RESPONSE TO A NOTICE OF VIOLATION | |||
INSPECTION | |||
REPORT 50-311/97-06 | |||
SALEM GENERATING | |||
STATION UNIT NO. 2 DOCKET NO. 50-311 Gentlemen: | |||
Inspection | |||
Report No. 50-311/97-06 | |||
for Salem Nuclear Generating | |||
Station Unit No. 2 was transmitted | |||
to Public | |||
Electric & Gas Company (PSE&G) on May 30, 1997. Within the scope of this report, one violation | |||
of NRC requirements | |||
was c.i ted. The violation | |||
involved the failure to follow established | |||
procedures | |||
for the documentation | |||
of test results. By letter dated June 30, 1997 (Our Ref: LR-N970371), PSE&G submitted | |||
its response to the cited violation. | |||
As stated in the original PSE&G response, the root cause of the violation (all f; cited examples) | |||
was attributed | |||
to poor human performance | |||
of l)J personnel | |||
performing | |||
the activities | |||
and poor human performance | |||
by management | |||
in the oversight | |||
of these activities. | |||
The corrective | |||
actions stated in the June 30 response were designed to address ';* the root cause in its broadest form. To provide a complete understanding | |||
of PSE&G's actions taken, PSE&G is supplementing | |||
the June 30, 1997 original response to address the specific actions taken relative to each of the cited examples. | |||
Mssrs. D. Powell and M. Rencheck of PSE&G discussed | |||
the submittal | |||
of this supplemental | |||
response with Mr. W. Ruland (NRC Region I) via telephone | |||
on July 9, 1997. 9707220344 | |||
970716 PDR ADOCK 05000311 G PDR *..* *,_, _ .. \J Printedon | |||
\:I Recycled Paper 1111111111111111111111111111111111111111 | \:I Recycled Paper 1111111111111111111111111111111111111111 | ||
*0&4011. | *0&4011. | ||
** * Document Control Desk LR-N970449 | ** | ||
2 JUL 16 1997 Additionally, by letter dated April 11, 1997 (Our Ref-: N97194), PSE&G responded | * Document Control Desk LR-N970449 2 JUL 16 1997 Additionally, by letter dated April 11, 1997 (Our Ref-: N97194), PSE&G responded to a similar violation transmitted in Inspection Report 50-311/96-21. | ||
to a similar violation | This violation involved deficient conditions for the testing of the Control Room Area Air Conditioning System. As a result of subsequent PSE&G investigation, as well as NRC inspections, other deficient conditions were identified relative to the same design modification test procedures. | ||
transmitted | In light of the applicability of these findings to Control Room Area Air Conditioning, and in response to Inspection Report 50-311/97-06 request, PSE&G considers the information provided in the June 30, 1997 letter to be relevant to the April 11, 1997 response. | ||
in Inspection | In the June 30, 1997 response, PSE&G stated that (Corrective action E) ten non-HVAC system Special Test Procedures (STPs) in five systems were reviewed. | ||
Report 50-311/96-21. | PSE&G would like to expand on this corrective action by identifying the procedures reviewed. | ||
This violation | The STPs reviewed are: Fire Protection 2EC-3298 Package 1 -STPs 1-3 lEC-3701 Package 1 -STP 1 Electrical 2EC-3332 Package 2 -STPs 1 & 2 Diesel lEC-3529 Package 2 -STP 1 Service Water 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 11 -STP 1 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 17 -STPs 1-7 2EC-3590 Package 18 -STPs 1-5 Safety Injection 2EC-3461 Package 1 -STPs 1 & 2 95-4933 | ||
involved deficient | ** Document Control Desk LR-N970449 3 JUL 16 1997 Attachment I to this letter contains the original violation as cited in Inspection Report 50-311/97-06. | ||
conditions | Attachment II contains PSE&G's supplemental information relative to these *events. Should there be any questions regarding this submittal, please contact us. Sincerely, | ||
for the testing of the Control Room Area Air Conditioning | ** | ||
System. As a result of subsequent | * Document Control Desk LR-N970449 Attachment 4 C Mr. Hubert J. Miller, Administrator | ||
PSE&G investigation, as well as NRC inspections, other deficient | -Region I U. s. Nuclear Regulatory Commission | ||
conditions | .475 Allendale Road King of Prussia, PA 19406 JUL 16 1997 Mr. L. N. Olshan, Licensing Project Manager -Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall | ||
were identified | -Salem (X24) USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933 ATTACHMENT I LR-N970449 NOTICE OF VIOLATION Public Service Electric & Gas Company Docket No: | ||
relative to the same design modification | Salem Nuclear Generating Station License No: DPR-75 Unit 2 During an NRC inspection conducted on March 1 to April 12, 1997, violations of NRC requirements were identified. | ||
test procedures. | In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG-1600, the violations are listed below: Appendix B, Criterion V of 10 CFR 50 requires that activities affecting quality be prescribed by procedures and shall be accomplished in accordance with those procedures. | ||
In light of the applicability | Procedure NC.DE-AP.ZZ-0012(Q), "Test Program", Revision 6, Section 5.2.c requires testing to be conducted with approved step-by-step Special Test Procedures, existing procedures, or standards. | ||
of these findings to Control Room Area Air Conditioning, and in response to Inspection | Section 5.2.e requires recording test data on data sheets . | ||
Report 50-311/97-06 | * Section 5.2.f requires evaluating test results to ensure they are acceptable prior to restoring plant equipment. | ||
request, PSE&G considers | * Contrary to the above, post-modification test procedures for Salem cdntrol room area air conditioning system (CAACS) were not followed, required.data was not recorded, and plant equipment was restored with test results outside established acceptance criteria, as evidenced by the following examples: | ||
the information | : 1. Procedure lEC-3505 package No. 1 STP-2, Revision 2, *control Area Air Conditioning System (CAACS) and Emergency Air Conditioning System (EACS) Coil Test Procedure (to verify heat transfer capability of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation of an Action Request (AR) to clean the coils if the coil appearance was not "bare metal or shiny appearance". | ||
provided in the June 30, 1997 letter to be relevant to the April 11, 1997 response. | The condition of the coil for 1HVE200, recorded on Attachment 7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated . 1 ATTACHMENT I LR-N970449 | ||
In the June 30, 1997 response, PSE&G stated that (Corrective | : 2. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential for leakage into the control room pressure boundary], attachment 7.3 establishes EACS charcoal filter housing and duct maximum allowable leakage test acceptance criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established acceptance criteria, but the test results were approved and the EACS system was restored to service. 3. Procedure lEC-3505 Package No. 1 STP-4, Revision 3, attachment 7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric pressure recorded in inches of mercury (inHg) and initial boundary pressures in pounds per square foot (psf) absolute (abs.), the test pressures were less than the required 4 inwc. 4. Procedure lEC-3505 Package No. 1 Revision 3, Appendix A, steps 2.e and 2.h require recording the initial and final times of the test. The times were not recorded. | ||
action E) ten non-HVAC system Special Test Procedures (STPs) in five systems were reviewed. | : 5. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring review of test data by the test engineer was incorrectly deleted by Modification Concern and Resolution 297. This is* a Severity Level IV problem (Supplement 1). 2 ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "1. Procedure lEC-3505 package No. 1 STP-2, 2, Control Area Air Conditioning System (CAACS) and Emergency Air Conditioning System (EACS) Coil Test Procedure (to verify heat transfer capability of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation of an Action Request (AR) to clean the coils if the coil appearance was not "bare metal or shiny appearance". | ||
PSE&G would like to expand on this corrective | The condition of the coil for 1HVE200, recorded on Attachment 7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated." (1) The reason for the violation. | ||
action by identifying | The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the *CAV project team and testing personnel and management oversight. | ||
the procedures | Personnel involved failed to meet PSE&G's standard of procedural compliance. | ||
reviewed. | Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria. | ||
The STPs reviewed are: Fire Protection | In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing.and implementing the CAV_Special Test Procedures." * (2) The corrective steps that have been taken. 1. AR 970320247 was issued to evaluate the white chalky film observed on the coil. The white chalky film (lead oxide) observed on the coil was the result of chemical cleaning of the EACS coil by the vendor. This white chalky substance was evaluated and determined to have no effect on the heat transfer characteristic of the coil . 1 | ||
2EC-3298 Package 1 -STPs 1-3 lEC-3701 Package 1 -STP 1 Electrical | * | ||
2EC-3332 Package 2 -STPs 1 & 2 Diesel lEC-3529 Package 2 -STP 1 Service Water 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 11 -STP 1 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 17 -STPs 1-7 2EC-3590 Package 18 -STPs 1-5 Safety Injection | * ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 | ||
2EC-3461 Package 1 -STPs 1 & 2 95-4933 | : 2. The design change test procedure acceptance criterion was revised as per the above evaluation and vendor recommendation. | ||
** Document Control Desk LR-N970449 | : 3. LR-N970371, dated June 30, 1997, -contains additional information. | ||
3 JUL 16 1997 Attachment | (3) The corrective steps that will be taken to avoid further violations. | ||
I to this letter contains the original violation | LR-N970371, dated June 30, 1997, contains the required information. | ||
as cited in Inspection | (4) The date when full compliance will be achieved. | ||
Report 50-311/97-06. | PSE&G achieved compliance when the AR 970320247 was issued. LR-N970371, dated June 30, 1997, contains additional information . 2 | ||
Attachment | * ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "2. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential for leakage into the control room pressure | ||
II contains PSE&G's supplemental | * boundary], attachment 7.3 establishes EACS charcoal filter housing and duct maximum allowable leakage test acceptance criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established acceptance criteria, but the test results were approved and the EACS system was restored to service." (1) The reason for the violation. | ||
information | The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight. | ||
relative to these *events. Should there be any questions | Personnel involved failed to meet PSE&G's standard of procedural compliance. | ||
regarding | Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria. | ||
this submittal, please contact us. Sincerely, | In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) The corrective steps that have been taken. 1. Engineering Evaluation S-C-SC-MEE-1212, Control Area Ventilation: | ||
** * Document Control Desk LR-N970449 | Review of CREACS Filter Housing Test Requirements and Acceptance Criteria, issued on May 30, 1997, evaluated the recorded leakage rate acceptable. | ||
Attachment | : 2. Modification Concern and Resolution (MCR) 193 to the design change test procedure revised the leakage rate 3 | ||
4 C Mr. Hubert J. Miller, Administrator | * ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 acceptance criterion based on Control Room Dose Calculation and was evaluated in Engineering Evaluation S-C-SC-MEE-1212. | ||
-Region I U. s. Nuclear Regulatory | : 3. LR-N970371, dated June 30, 1997, contains additional information. | ||
Commission | (3) The corrective steps that will be taken to avoid further violations. | ||
.475 Allendale | LR-N970371, dated June 30, 1997, contains the required information. | ||
Road King of Prussia, PA 19406 JUL 16 1997 Mr. L. N. Olshan, Licensing | (4) The date when full compliance will be achieved. | ||
Project Manager -Salem U. S. Nuclear Regulatory | PSE&G achieved compliance when the Engineering Evaluation was issued demonstrating that the recorded leakage rate was acceptable, and MCR 193 to lEC-3505 revised the leakage rate acceptance criterion. | ||
Commission | LR-N970371, dated June 30, 1997, contains additional information . 4 | ||
One White Flint North 11555 Rockville | * ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "3. Procedure lEC-3505 Package No. 1 STP-4, Revision 3, attachment 7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric pressure recorded in inches of mercury (inHg) and initial boundary pressures in pounds per square foot (psf) absolute (abs.), the test pressures were less than the required 4 inwc." (1) The reason for the violation. | ||
Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall | The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight. | ||
-Salem (X24) USNRC Senior Resident Inspector | Personnel involved failed to meet PSE&G's standard of procedural compliance. | ||
Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering | Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria. | ||
33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933 | In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) The corrective steps that have been taken. 1. Engineering Evaluation S-C-SC-MEE-1212, Control Area *ventilation: | ||
ATTACHMENT | Review of CREACS Filter Housing Test Requirements and Acceptance Criteria, issued on May 30, 1997, evaluated the higher initial test pressures and accepted the test data. 2. The HEPA and Charcoal Filter Housing decay calculations were revised with acceptable results. 3. The test procedure acceptance criteria was revised. 4. LR-N970371, dated June 30, 1997, contains additional information . 5 ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 (3) The corrective steps that will be takeri to avoid further violations. | ||
I LR-N970449 | dated June 30, 1997, contains the required information. | ||
NOTICE OF VIOLATION | (4) The date when full compliance will be achieved. | ||
Public Service Electric & Gas Company Docket No: | PSE&G achieved compliance when the Engineering Evaluation was issued determining that the higher recorded test pressures were acceptable, the test procedure acceptance criteria was revised, and the HEPA and Charcoal Filter Housing decay calculations were revised. LR-N970371, dated June 30, 1997, contains additional information . | ||
Salem Nuclear Generating | * 6 I ---.. ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "4. Procedure lEC-3505 Package No. 1 STP-4, 3, Appendix A, steps 2.e and 2.h require recording the initial and final times of the test. The times were not recorded." (1) The reason for the violation. | ||
Station License No: DPR-75 Unit 2 During an NRC inspection | The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight. | ||
conducted | Personnel involved failed to meet PSE&G's standard of procedural compliance. | ||
on March 1 to April 12, 1997, violations | Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria. | ||
of NRC requirements | In addition inadvertent removal of *the test engineer acceptance signoff by the project team is an example of inattention to *detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) The corrective steps that have been taken. 1. The test engineers responsible have been counseled and advised of the importance of strict procedure compliance. | ||
were identified. | Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was *recorded, which was the only value necessary for the required calculation. | ||
In accordance | : 2. LR-N970371, dated June 30, 1997, contains additional information. | ||
with the "General Statement | (3) The corrective steps that will be taken to avoid further violations. | ||
of Policy and Procedure | LR-N970371, dated June 30, 1997, contains the required information . | ||
for NRC Enforcement | * 7 | ||
Actions." NUREG-1600, the violations | ... ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 (4) The date when full compliance will be achieved. | ||
are listed below: Appendix B, Criterion | PSE&G achieved compliance when the test was completed satisfactorily. | ||
V of 10 CFR 50 requires that activities | Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was recorded, which was the only value necessary for the required calculation. | ||
affecting | |||
quality be prescribed | |||
by procedures | |||
and shall be accomplished | |||
in accordance | |||
with those procedures. | |||
Procedure | |||
NC.DE-AP.ZZ-0012(Q), "Test Program", Revision 6, Section 5.2.c requires testing to be conducted | |||
with approved step-by-step | |||
Special Test Procedures, existing procedures, or standards. | |||
Section 5.2.e requires recording | |||
test data on data sheets . * Section 5.2.f requires evaluating | |||
test results to ensure they are acceptable | |||
prior to restoring | |||
plant equipment. | |||
* Contrary to the above, post-modification | |||
test procedures | |||
for Salem cdntrol room area air conditioning | |||
system (CAACS) were not followed, required.data | |||
was not recorded, and plant equipment | |||
was restored with test results outside established | |||
acceptance | |||
criteria, as evidenced | |||
by the following | |||
examples: | |||
1. Procedure | |||
lEC-3505 package No. 1 STP-2, Revision 2, *control Area Air Conditioning | |||
System (CAACS) and Emergency | |||
Air Conditioning | |||
System (EACS) Coil Test Procedure (to verify heat transfer capability | |||
of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation | |||
of an Action Request (AR) to clean the coils if the coil appearance | |||
was not "bare metal or shiny appearance". | |||
The condition | |||
of the coil for 1HVE200, recorded on Attachment | |||
7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated . 1 | |||
ATTACHMENT | |||
I LR-N970449 | |||
2. Procedure | |||
lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential | |||
for leakage into the control room pressure boundary], attachment | |||
7.3 establishes | |||
EACS charcoal filter housing and duct maximum allowable | |||
leakage test acceptance | |||
criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established | |||
acceptance | |||
criteria, but the test results were approved and the EACS system was restored to service. 3. Procedure | |||
lEC-3505 Package No. 1 STP-4, Revision 3, attachment | |||
7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric | |||
pressure recorded in inches of mercury (inHg) and initial boundary pressures | |||
in pounds per square foot (psf) absolute (abs.), the test pressures | |||
were less than the required 4 inwc. 4. Procedure | |||
lEC-3505 Package No. 1 | |||
Revision 3, Appendix A, steps 2.e and 2.h require recording | |||
the initial and final times of the test. The times were not recorded. | |||
5. Procedure | |||
lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring | |||
review of test data by the test engineer was incorrectly | |||
deleted by Modification | |||
Concern and Resolution | |||
297. This is* a Severity Level IV problem (Supplement | |||
1). 2 | |||
ATTACHMENT | |||
II SUPPLEMENTAL | |||
RESPONSE TO NOTICE OF VIOLATION | |||
SALEM GENERATING | |||
STATION UNIT 2 LR-N970449 | |||
"1. Procedure | |||
lEC-3505 package No. 1 STP-2, | |||
2, Control Area Air Conditioning | |||
System (CAACS) and Emergency | |||
Air Conditioning | |||
System (EACS) Coil Test Procedure (to verify heat transfer capability | |||
of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation | |||
of an Action Request (AR) to clean the coils if the coil appearance | |||
was not "bare metal or shiny appearance". | |||
The condition | |||
of the coil for 1HVE200, recorded on Attachment | |||
7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated." (1) The reason for the violation. | |||
The root cause for the violation | |||
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation | |||
was poor human performance | |||
by the *CAV project team and testing personnel | |||
and management | |||
oversight. | |||
Personnel | |||
involved failed to meet PSE&G's standard of procedural | |||
compliance. | |||
Personnel | |||
did not properly revise CAV Special Test Procedures (STPs) in accordance | |||
with PSE&G procedures | |||
to reflect changes in testing methodology | |||
and acceptance | |||
criteria. | |||
In addition inadvertent | |||
removal of the test engineer acceptance | |||
signoff by the project team is an example of inattention | |||
to detail. PSE&G management | |||
also did not provide an adequate level of management | |||
oversight | |||
of personnel | |||
preparing.and | |||
implementing | |||
the CAV_Special | |||
Test Procedures." * (2) The corrective | |||
steps that have been taken. 1. AR 970320247 | |||
was issued to evaluate the white chalky film observed on the coil. The white chalky film (lead oxide) observed on the coil was the result of chemical cleaning of the EACS coil by the vendor. This white chalky substance | |||
was evaluated | |||
and determined | |||
to have no effect on the heat transfer characteristic | |||
of the coil . 1 | |||
* * ATTACHMENT | |||
II SUPPLEMENTAL | |||
RESPONSE TO NOTICE OF VIOLATION | |||
SALEM GENERATING | |||
STATION UNIT 2 LR-N970449 | |||
2. The design change test procedure | |||
acceptance | |||
criterion | |||
was revised as per the above evaluation | |||
and vendor recommendation. | |||
3. LR-N970371, dated June 30, 1997, -contains | |||
additional | |||
information. | |||
(3) The corrective | |||
steps that will be taken to avoid further violations. | |||
LR-N970371, dated June 30, 1997, contains the required information. | LR-N970371, dated June 30, 1997, contains the required information. | ||
"5. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring review of test data by the test engineer was incorrectly deleted by Modification Concern and Resolution 297." (1) The reason for the violation. | |||
The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight. | |||
Personnel involved failed to meet PSE&G's standard of procedural compliance. | |||
Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria. | |||
In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) 1. 2. 3. | |||
* The corrective steps that have been taken. The test engineer responsible for removing the procedure step was counseled. | |||
A review signature was added for a level III sign off of test results. The test results were reviewed by a level III test engineer . 8 | |||
_, *-I l ... * | |||
* ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 | |||
: 4. LR-N970371, dated June 30, 1997, contains additional information. | |||
(3) The corrective steps that will be taken to avoid further violations. | |||
LR-N970371, dated June 30, 1997, contains the required information. | |||
(4) The date when full compliance will be achieved. | |||
PSE&G achieved compliance when a review signature was added for a level III sign off of test results and the test results were reviewed by a level III test engineer. | |||
LR-N970371, dated June 30, 1997, contains additional information . 9}} | |||
"5. Procedure | |||
lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring | |||
review of test data by the test engineer was incorrectly | |||
deleted by Modification | |||
Concern and Resolution | |||
297." (1) The reason for the violation. | |||
The root cause for the violation | |||
was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation | |||
was poor human performance | |||
by the CAV project team and testing personnel | |||
and management | |||
oversight. | |||
Personnel | |||
involved failed to meet PSE&G's standard of procedural | |||
compliance. | |||
Personnel | |||
did not properly revise CAV Special Test Procedures (STPs) in accordance | |||
with PSE&G procedures | |||
to reflect changes in testing methodology | |||
and acceptance | |||
criteria. | |||
In addition inadvertent | |||
removal of the test engineer acceptance | |||
signoff by the project team is an example of inattention | |||
to detail. PSE&G management | |||
also did not provide an adequate level of management | |||
oversight | |||
of personnel | |||
preparing | |||
and implementing | |||
the CAV Special Test Procedures." (2) 1. 2. 3. * The corrective | |||
steps that have been taken. The test engineer responsible | |||
for removing the procedure | |||
step was counseled. | |||
A review signature | |||
was added for a level III sign off of test results. The test results were reviewed by a level III test engineer . 8 | |||
_, *-I l ... * * ATTACHMENT I I SUPPLEMENTAL | |||
RESPONSE TO NOTICE OF VIOLATION | |||
SALEM GENERATING | |||
STATION UNIT 2 LR-N970449 | |||
4. LR-N970371, dated June 30, 1997, contains additional | |||
information. | |||
(3) The corrective | |||
steps that will be taken to avoid further violations. | |||
LR-N970371, dated June 30, 1997, contains the required information. | |||
(4) The date when full compliance | |||
will be achieved. | |||
PSE&G achieved compliance | |||
when a review signature | |||
was added for a level III sign off of test results and the test results were reviewed by a level III test engineer. | |||
LR-N970371, dated June 30, 1997, contains additional | |||
information . 9 | |||
}} |
Revision as of 20:00, 31 July 2019
ML18102B455 | |
Person / Time | |
---|---|
Site: | Salem ![]() |
Issue date: | 07/16/1997 |
From: | Storz L Public Service Enterprise Group |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
References | |
50-311-97-06, 50-311-97-6, LR-N970449, NUDOCS 9707220344 | |
Download: ML18102B455 (15) | |
Text
' ,, __ . ** Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President
-Nuclear Operations
- JUL 16 1997 LR-N970449 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 SUPPLEMENTAL RESPONSE TO A NOTICE OF VIOLATION INSPECTION REPORT 50-311/97-06 SALEM GENERATING STATION UNIT NO. 2 DOCKET NO. 50-311 Gentlemen:
Inspection Report No. 50-311/97-06 for Salem Nuclear Generating Station Unit No. 2 was transmitted to Public Electric & Gas Company (PSE&G) on May 30, 1997. Within the scope of this report, one violation of NRC requirements was c.i ted. The violation involved the failure to follow established procedures for the documentation of test results. By letter dated June 30, 1997 (Our Ref: LR-N970371), PSE&G submitted its response to the cited violation.
As stated in the original PSE&G response, the root cause of the violation (all f; cited examples) was attributed to poor human performance of l)J personnel performing the activities and poor human performance by management in the oversight of these activities.
The corrective actions stated in the June 30 response were designed to address ';* the root cause in its broadest form. To provide a complete understanding of PSE&G's actions taken, PSE&G is supplementing the June 30, 1997 original response to address the specific actions taken relative to each of the cited examples.
Mssrs. D. Powell and M. Rencheck of PSE&G discussed the submittal of this supplemental response with Mr. W. Ruland (NRC Region I) via telephone on July 9, 1997. 9707220344 970716 PDR ADOCK 05000311 G PDR *..* *,_, _ .. \J Printedon
\:I Recycled Paper 1111111111111111111111111111111111111111
- 0&4011.
- Document Control Desk LR-N970449 2 JUL 16 1997 Additionally, by letter dated April 11, 1997 (Our Ref-: N97194), PSE&G responded to a similar violation transmitted in Inspection Report 50-311/96-21.
This violation involved deficient conditions for the testing of the Control Room Area Air Conditioning System. As a result of subsequent PSE&G investigation, as well as NRC inspections, other deficient conditions were identified relative to the same design modification test procedures.
In light of the applicability of these findings to Control Room Area Air Conditioning, and in response to Inspection Report 50-311/97-06 request, PSE&G considers the information provided in the June 30, 1997 letter to be relevant to the April 11, 1997 response.
In the June 30, 1997 response, PSE&G stated that (Corrective action E) ten non-HVAC system Special Test Procedures (STPs) in five systems were reviewed.
PSE&G would like to expand on this corrective action by identifying the procedures reviewed.
The STPs reviewed are: Fire Protection 2EC-3298 Package 1 -STPs 1-3 lEC-3701 Package 1 -STP 1 Electrical 2EC-3332 Package 2 -STPs 1 & 2 Diesel lEC-3529 Package 2 -STP 1 Service Water 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 11 -STP 1 2EC-3590 Package 6 -STPs 1-3 2EC-3590 Package 17 -STPs 1-7 2EC-3590 Package 18 -STPs 1-5 Safety Injection 2EC-3461 Package 1 -STPs 1 & 2 95-4933
- Document Control Desk LR-N970449 3 JUL 16 1997 Attachment I to this letter contains the original violation as cited in Inspection Report 50-311/97-06.
Attachment II contains PSE&G's supplemental information relative to these *events. Should there be any questions regarding this submittal, please contact us. Sincerely,
- Document Control Desk LR-N970449 Attachment 4 C Mr. Hubert J. Miller, Administrator
-Region I U. s. Nuclear Regulatory Commission
.475 Allendale Road King of Prussia, PA 19406 JUL 16 1997 Mr. L. N. Olshan, Licensing Project Manager -Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. Marschall
-Salem (X24) USNRC Senior Resident Inspector Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 95-4933 ATTACHMENT I LR-N970449 NOTICE OF VIOLATION Public Service Electric & Gas Company Docket No:
Salem Nuclear Generating Station License No: DPR-75 Unit 2 During an NRC inspection conducted on March 1 to April 12, 1997, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG-1600, the violations are listed below: Appendix B, Criterion V of 10 CFR 50 requires that activities affecting quality be prescribed by procedures and shall be accomplished in accordance with those procedures.
Procedure NC.DE-AP.ZZ-0012(Q), "Test Program", Revision 6, Section 5.2.c requires testing to be conducted with approved step-by-step Special Test Procedures, existing procedures, or standards.
Section 5.2.e requires recording test data on data sheets .
- Section 5.2.f requires evaluating test results to ensure they are acceptable prior to restoring plant equipment.
- Contrary to the above, post-modification test procedures for Salem cdntrol room area air conditioning system (CAACS) were not followed, required.data was not recorded, and plant equipment was restored with test results outside established acceptance criteria, as evidenced by the following examples:
- 1. Procedure lEC-3505 package No. 1 STP-2, Revision 2, *control Area Air Conditioning System (CAACS) and Emergency Air Conditioning System (EACS) Coil Test Procedure (to verify heat transfer capability of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation of an Action Request (AR) to clean the coils if the coil appearance was not "bare metal or shiny appearance".
The condition of the coil for 1HVE200, recorded on Attachment 7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated . 1 ATTACHMENT I LR-N970449
- 2. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential for leakage into the control room pressure boundary], attachment 7.3 establishes EACS charcoal filter housing and duct maximum allowable leakage test acceptance criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established acceptance criteria, but the test results were approved and the EACS system was restored to service. 3. Procedure lEC-3505 Package No. 1 STP-4, Revision 3, attachment 7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric pressure recorded in inches of mercury (inHg) and initial boundary pressures in pounds per square foot (psf) absolute (abs.), the test pressures were less than the required 4 inwc. 4. Procedure lEC-3505 Package No. 1 Revision 3, Appendix A, steps 2.e and 2.h require recording the initial and final times of the test. The times were not recorded.
- 5. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring review of test data by the test engineer was incorrectly deleted by Modification Concern and Resolution 297. This is* a Severity Level IV problem (Supplement 1). 2 ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "1. Procedure lEC-3505 package No. 1 STP-2, 2, Control Area Air Conditioning System (CAACS) and Emergency Air Conditioning System (EACS) Coil Test Procedure (to verify heat transfer capability of Unit 1 CAACS and Unit 1 EACS cooling coil units), steps 5.5.3.7 and 5.5.4.7 required the initiation of an Action Request (AR) to clean the coils if the coil appearance was not "bare metal or shiny appearance".
The condition of the coil for 1HVE200, recorded on Attachment 7.12 was" ... covered with white chalky film ... " and an AR to clean the coil was not initiated." (1) The reason for the violation.
The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the *CAV project team and testing personnel and management oversight.
Personnel involved failed to meet PSE&G's standard of procedural compliance.
Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria.
In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing.and implementing the CAV_Special Test Procedures." * (2) The corrective steps that have been taken. 1. AR 970320247 was issued to evaluate the white chalky film observed on the coil. The white chalky film (lead oxide) observed on the coil was the result of chemical cleaning of the EACS coil by the vendor. This white chalky substance was evaluated and determined to have no effect on the heat transfer characteristic of the coil . 1
- ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449
- 2. The design change test procedure acceptance criterion was revised as per the above evaluation and vendor recommendation.
- 3. LR-N970371, dated June 30, 1997, -contains additional information.
(3) The corrective steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information.
(4) The date when full compliance will be achieved.
PSE&G achieved compliance when the AR 970320247 was issued. LR-N970371, dated June 30, 1997, contains additional information . 2
- ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "2. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Control Area Ventilation (CAV) Leakage Test [for leak testing the ductwork and filter housing which have the potential for leakage into the control room pressure
- boundary], attachment 7.3 establishes EACS charcoal filter housing and duct maximum allowable leakage test acceptance criteria of 8.0 cubic feet per minute (cfm). Actual leakage rates recorded were 10.78 cfm for Unit 1 and 10.59 cfm for Unit 2. Both recorded leakage rates were outside the established acceptance criteria, but the test results were approved and the EACS system was restored to service." (1) The reason for the violation.
The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight.
Personnel involved failed to meet PSE&G's standard of procedural compliance.
Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria.
In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) The corrective steps that have been taken. 1. Engineering Evaluation S-C-SC-MEE-1212, Control Area Ventilation:
Review of CREACS Filter Housing Test Requirements and Acceptance Criteria, issued on May 30, 1997, evaluated the recorded leakage rate acceptable.
- 2. Modification Concern and Resolution (MCR) 193 to the design change test procedure revised the leakage rate 3
- ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 acceptance criterion based on Control Room Dose Calculation and was evaluated in Engineering Evaluation S-C-SC-MEE-1212.
- 3. LR-N970371, dated June 30, 1997, contains additional information.
(3) The corrective steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information.
(4) The date when full compliance will be achieved.
PSE&G achieved compliance when the Engineering Evaluation was issued demonstrating that the recorded leakage rate was acceptable, and MCR 193 to lEC-3505 revised the leakage rate acceptance criterion.
LR-N970371, dated June 30, 1997, contains additional information . 4
- ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "3. Procedure lEC-3505 Package No. 1 STP-4, Revision 3, attachment 7.3 requires an EACS charcoal filter housing and duct test pressure of 4.0 inches water column (inwc). Based on the atmospheric pressure recorded in inches of mercury (inHg) and initial boundary pressures in pounds per square foot (psf) absolute (abs.), the test pressures were less than the required 4 inwc." (1) The reason for the violation.
The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight.
Personnel involved failed to meet PSE&G's standard of procedural compliance.
Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria.
In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) The corrective steps that have been taken. 1. Engineering Evaluation S-C-SC-MEE-1212, Control Area *ventilation:
Review of CREACS Filter Housing Test Requirements and Acceptance Criteria, issued on May 30, 1997, evaluated the higher initial test pressures and accepted the test data. 2. The HEPA and Charcoal Filter Housing decay calculations were revised with acceptable results. 3. The test procedure acceptance criteria was revised. 4. LR-N970371, dated June 30, 1997, contains additional information . 5 ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 (3) The corrective steps that will be takeri to avoid further violations.
dated June 30, 1997, contains the required information.
(4) The date when full compliance will be achieved.
PSE&G achieved compliance when the Engineering Evaluation was issued determining that the higher recorded test pressures were acceptable, the test procedure acceptance criteria was revised, and the HEPA and Charcoal Filter Housing decay calculations were revised. LR-N970371, dated June 30, 1997, contains additional information .
- 6 I ---.. ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 "4. Procedure lEC-3505 Package No. 1 STP-4, 3, Appendix A, steps 2.e and 2.h require recording the initial and final times of the test. The times were not recorded." (1) The reason for the violation.
The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight.
Personnel involved failed to meet PSE&G's standard of procedural compliance.
Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria.
In addition inadvertent removal of *the test engineer acceptance signoff by the project team is an example of inattention to *detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) The corrective steps that have been taken. 1. The test engineers responsible have been counseled and advised of the importance of strict procedure compliance.
Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was *recorded, which was the only value necessary for the required calculation.
- 2. LR-N970371, dated June 30, 1997, contains additional information.
(3) The corrective steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information .
- 7
... ATTACHMENT II SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449 (4) The date when full compliance will be achieved.
PSE&G achieved compliance when the test was completed satisfactorily.
Although the start and finish time were not recorded and cannot be retrieved, the total test duration time was recorded, which was the only value necessary for the required calculation.
LR-N970371, dated June 30, 1997, contains the required information.
"5. Procedure lEC-3505 Package No. 1, STP-4, Revision 3, Step 5.6.1, requiring review of test data by the test engineer was incorrectly deleted by Modification Concern and Resolution 297." (1) The reason for the violation.
The root cause for the violation was provided in LR-N970371, dated June 30, 1997, and restated below for completeness; "The reason for the violation was poor human performance by the CAV project team and testing personnel and management oversight.
Personnel involved failed to meet PSE&G's standard of procedural compliance.
Personnel did not properly revise CAV Special Test Procedures (STPs) in accordance with PSE&G procedures to reflect changes in testing methodology and acceptance criteria.
In addition inadvertent removal of the test engineer acceptance signoff by the project team is an example of inattention to detail. PSE&G management also did not provide an adequate level of management oversight of personnel preparing and implementing the CAV Special Test Procedures." (2) 1. 2. 3.
- The corrective steps that have been taken. The test engineer responsible for removing the procedure step was counseled.
A review signature was added for a level III sign off of test results. The test results were reviewed by a level III test engineer . 8
_, *-I l ... *
- ATTACHMENT I I SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION SALEM GENERATING STATION UNIT 2 LR-N970449
- 4. LR-N970371, dated June 30, 1997, contains additional information.
(3) The corrective steps that will be taken to avoid further violations.
LR-N970371, dated June 30, 1997, contains the required information.
(4) The date when full compliance will be achieved.
PSE&G achieved compliance when a review signature was added for a level III sign off of test results and the test results were reviewed by a level III test engineer.
LR-N970371, dated June 30, 1997, contains additional information . 9