Information Notice 1999-14, Unanticipated Reactor Water Draindown at Quad Cities Unit 2, Arkansas Nuclear One Unit 2, & FitzPatrick: Difference between revisions

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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY
{{#Wiki_filter:UNITED STATES


COMMISSION
NUCLEAR REGULATORY COMMISSION


===OFFICE OF NUCLEAR REACTOR REGULATION===
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001 May 5, 1999 NRC INFORMATION


NOTICE 99-14: UNANTICIPATED
WASHINGTON, D.C. 20555-0001 May 5, 1999 NRC INFORMATION NOTICE 99-14: UNANTICIPATED REACTOR WATER DRAINDOWN


REACTOR WATER DRAINDOWN AT QUAD CITIES UNIT 2, ARKANSAS NUCLEAR ONE UNIT 2, AND FITZPATRICK
AT QUAD CITIES UNIT 2, ARKANSAS NUCLEAR ONE
 
UNIT 2, AND FITZPATRICK


==Addressees==
==Addressees==
Line 29: Line 30:


==Purpose==
==Purpose==
The U.S. Nuclear Regulatory
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert
 
Commission (NRC) is issuing this information
 
notice to alert addressees
 
to the potential
 
for personnel
 
errors during infrequently
 
performed
 
evolutions
 
that result in, or contribute
 
to, events such as the inadvertent


draining of water from the reactor vessel during shutdown operations.
addressees to the potential for personnel errors during infrequently performed evolutions that


It is expected that recipients
result in, or contribute to, events such as the inadvertent draining of water from the reactor


will review the information
vessel during shutdown operations. It is expected that recipients will review the information for


for applicability
applicability to their facilities and consider actions, as appropriate, to prevent a similar


to their facilities
occurrence. However, suggestions contained in this information notice are not NRC


and consider actions, as appropriate, to prevent a similar occurrence.
requirements; therefore, no specific action or written response to this notice is required.


However, suggestions
DescriDtion of Circumstances
 
contained
 
in this information
 
notice are not NRC requirements;
therefore, no specific action or written response to this notice is required.DescriDtion
 
of Circumstances


Quad Cities Unit 2 On February 24, 1999, Quad Cities Unit 2 was in cold shutdown with reactor water temperature
Quad Cities Unit 2 On February 24, 1999, Quad Cities Unit 2 was in cold shutdown with reactor water temperature


at 131 'F and reactor water level at 80 inches indicated
at 131 'F and reactor water level at 80 inches indicated level (normal level during operations is
 
level (normal level during operations
 
is 30 inches indicated


or 173 inches above the top of active fuel [TAF]). Core cooling was being maintained
30 inches indicated or 173 inches above the top of active fuel [TAF]). Core cooling was being


in a band of 120 'F to 170 OF by the OA" loop of the shutdown cooling mode of the residual heat removal (RHR) system after being switched from the nB" loop at 12:32 a.m.During the switch over the licensee inadvertently
maintained in a band of 120 'F to 170 OF by the OA" loop of the shutdown cooling mode of the


failed to close the OA RHR minimum flow valve as required by the procedure.
residual heat removal (RHR) system after being switched from the nB" loop at 12:32 a.m.


Sometime later operators
During the switch over the licensee inadvertently failed to close the OA RHR minimum flow


noted a decreasing
valve as required by the procedure. Sometime later operators noted a decreasing reactor water


reactor water level and at about 1:02 a.m. secured the *2A RHR pump and isolated shutdown cooling. At 1:55 a.m. operators
level and at about 1:02 a.m. secured the *2A RHR pump and isolated shutdown cooling. At


restored the *2A' loop of shutdown cooling to the proper lineup and started the *2A RHR pump. Water level had decreased
1:55 a.m. operators restored the *2A' loop of shutdown cooling to the proper lineup and started


to a minimum of about 45 inches indicated, and reactor water temperature
the *2A RHR pump. Water level had decreased to a minimum of about 45 inches indicated, and reactor water temperature had risen to a maximum of about 163 OF. Forced circulation of


had risen to a maximum of about 163 OF. Forced circulation
reactor vessel water using a reactor recirculation pump remained in effect throughout the event.


of reactor vessel water using a reactor recirculation
On the basis of post event reviews, It appears that the minimum flow valve in the OA loop was


pump remained in effect throughout
left open because the nuclear station operator failed to ensure that the tasks were performed in


the event.On the basis of post event reviews, It appears that the minimum flow valve in the OA loop was left open because the nuclear station operator failed to ensure that the tasks were performed
the sequence specified in the operating procedures. The nuclear station operator who was


in the sequence specified
(7008              PD(L                Hort<<4qj-Oiif qqos(J5 C7Ffcj


in the operating
ANW\\b


procedures.
IN 99-14 May 5, 1999 directing the evolution from the control room gave the non-licensed operator permission to de- energize the breaker for the WARHR minimum flow valve operator before the valve was taken


The nuclear station operator who was (7008 PD(L H ort<<4qj-Oiif
to the required closed position. De-energizing the breaker also removed power to the valve


qqos(J5 C7Ffcj ANW\\b
position indicator lights in the control room. Thus, when the nuclear station operator tried to


IN 99-14 May 5, 1999 directing
verify that the valve was closed, there was no position indication in the control room to make


the evolution
that verification. The nuclear station operator made the incorrect assumption that the valve was


from the control room gave the non-licensed
already closed and moved to the next step in the procedure. This failure to close the WAX      RHR


operator permission
minimum flow valve opened a drain path from the reactor to the suppression pool. To further


to de-energize the breaker for the WA RHR minimum flow valve operator before the valve was taken to the required closed position.
complicate the event, the operating crew did not recognize that there was any problem until


De-energizing
approximately 10 minutes had passed and the water level had decreased about 13 inches


the breaker also removed power to the valve position indicator
because of a misinterpretation of causes of the level decrease. After detecting the decrease, the operating crew was slow to react, which allowed the level to decrease another 20 inches


lights in the control room. Thus, when the nuclear station operator tried to verify that the valve was closed, there was no position indication
before the operators isolated shutdown cooling which terminated the draindown. The licensee


in the control room to make that verification.
estimated that a total of 6000 to 7000 gallons was drained from the reactor to the suppression


The nuclear station operator made the incorrect
pool.


assumption
Operations staff practices including poor communications, poor activity briefings for high-risk


that the valve was already closed and moved to the next step in the procedure.
activities, lack of effective pre-shift briefings, inadequate supervision of important control room


This failure to close the WAX RHR minimum flow valve opened a drain path from the reactor to the suppression
activities, inadequate monitoring of control room panels, and slow event response may have


pool. To further complicate
contributed to the event. Although the unintended loss of inventory to the suppression pool


the event, the operating
highlighted significant weaknesses in plant operations, the safety significance was minimized by


crew did not recognize
two features. First, a reactor recirculation pump remained in service throughout the event


that there was any problem until approximately
which served to distribute decay heat. Second, an automatic isolation of shutdown cooling


10 minutes had passed and the water level had decreased
would have occurred at 8 inches indicated level which would have stopped the draining event.


about 13 inches because of a misinterpretation
An indicated water level of 8 inches corresponds to approximately 151 inches of water level


of causes of the level decrease.
above the TAF in the reactor core.


After detecting
===Arkansas Nuclear One Unit 2===
On February 2, 1999, at Arkansas Nuclear One Unit 2, the operators were draining the


the decrease, the operating
refueling canal in preparation for installing the reactor vessel head. Refueling was complete


crew was slow to react, which allowed the level to decrease another 20 inches before the operators
and steam generator nozzle dams were installed. The operators were using the two low


isolated shutdown cooling which terminated
pressure safety injection (LPSI) pumps to drain the canal to the refueling water storage tank;
one pump also served as the shutdown cooling pump. The rate of draindown was


the draindown.
approximately 3.3 Inches per minute. When the water level reached 105 inches, the reactor


The licensee estimated
operator noted that level started to lower rapidly. Operators stopped one of the LPSI pumps


that a total of 6000 to 7000 gallons was drained from the reactor to the suppression
and instructed a local operator to close the isolation valve to the refueling water tank. This


pool.Operations
manually operated valve required 55 turns of the handwheel to fully close. Within


staff practices
approximately 1.5 minutes, the reactor vessel level had dropped below the 65 inch level (where


including
reduced inventory begins) and continued down to 56 inches before the valve could be fully


poor communications, poor activity briefings
closed. (Reference zero on these level instruments is the bottom of the hot leg, with mid-loop


for high-risk activities, lack of effective
being defined at approximately 24 inches.) The average rate of level decrease between 105


pre-shift
IN 99-14 May 5, 1999 inches and 56 inches was approximately 33 inches per minute. At its lowest level, 56 inches


briefings, inadequate
indicated, there were still 93 inches of water above the TAF. Using the high pressure safety


supervision
injection (HPSI) pump the operators brought the level back up to 90 inches. The plant was in


of important
reduced inventory operations (below 65 inches) for approximately 7 minutes. During the event


control room activities, inadequate
the level remained well above the point where LPSI pump cavitation would be expected. The


monitoring
licensee concluded that the safety significance of the event was minimal because multiple


of control room panels, and slow event response may have contributed
sources of makeup water were available, redundant mitigation equipment was available, and


to the event. Although the unintended
the operators were quick to recognize and respond to the event.


loss of inventory
On the basis of post event reviews, it was determined that the procedure used for draining


to the suppression
down the refueling canal was inadequate in that it incorrectly stated that the draindown should


pool highlighted
be secured at the 90-inch level. The procedure should have directed that the rate of draining


significant
be secured at the 106-inch level so that appropriate precautions could be taken before


weaknesses
resuming the draindown. These precautions should have Included reminders to the operating


in plant operations, the safety significance
crew that below the 106-inch level the level will drop much more quickly due to the transition of


was minimized
pumping from a large volume in the refueling canal to a small volume In the reactor vessel.


by two features.
Therefore, in order to maintain control of the water level, the draindown rate should be


First, a reactor recirculation
decreased and an operator should be stationed to directly monitor the level.


pump remained in service throughout
Additional factors that contributed to this event include: the operators received little specific


the event which served to distribute
training on this evolution; the crew was inexperienced in performing this task; the task should


decay heat. Second, an automatic
have been classified as an infrequent task requiring a more thorough briefing; and, operators


isolation
failed to station an operator in a position where he could directly monitor the water level in the


of shutdown cooling would have occurred at 8 inches indicated
refueling canal. Instead they monitored it remotely using a video camera that did not provide a


level which would have stopped the draining event.An indicated
clear picture of the water level.


water level of 8 inches corresponds
FitzPatrick


to approximately
On December 2, 1998, at the James A. FitzPatrick Nuclear Power Plant, the operators were in


151 inches of water level above the TAF in the reactor core.Arkansas Nuclear One Unit 2 On February 2, 1999, at Arkansas Nuclear One Unit 2, the operators
the process of reassembling the reactor following refueling. Operators were controlling the


were draining the refueling
reactor vessel water level at 357 inches above TAF by adjusting the water discharge rate to


canal in preparation
compensate for the constant input from the control rod drive cooling water system. While in this


for installing
condition, the licensees risk analysis requires that reactor vessel water level be monitored using


the reactor vessel head. Refueling
two independent level indicators. To meet this requirement, the licensee designated a wide


was complete and steam generator
range indicator which provided Indication up to the top of the reactor vessel and an RHR


nozzle dams were installed.
interlock level indicator which provided indication in the range from -150 inches to +200 Inches


The operators
as the instruments to be used during this evaluation.


were using the two low pressure safety injection (LPSI) pumps to drain the canal to the refueling
In order for the wide-range level Indicator to remain available with the reactor head removed, a


water storage tank;one pump also served as the shutdown cooling pump. The rate of draindown
temporary standpipe and fill funnel were used to replace a portion of the reference leg. At the


was approximately
time of the event, the licensee was in the process of removing this temporary standpipe and


3.3 Inches per minute. When the water level reached 105 inches, the reactor operator noted that level started to lower rapidly. Operators
reinstalling the original reference leg components. As the water drained from the standpipe, it


stopped one of the LPSI pumps and instructed
caused the wide-range level indicator to erroneously show an increasing water level. For a


a local operator to close the isolation
period of approximately one hour the operators in the control room, unaware that the ongoing


valve to the refueling
maintenance would cause an error in the indicated water level, compensated for the apparent


water tank. This manually operated valve required 55 turns of the handwheel
increasing level by increasing the discharge rate. This action had the effect of reducing the


to fully close. Within approximately
IN 99-14 May 5, 1999 actual water level from 357 inches to 255 inches. During the same time period, the operators


1.5 minutes, the reactor vessel level had dropped below the 65 inch level (where reduced inventory
were also in the process of filling and venting the reactor feedwater piping, which could have


begins) and continued
affected the reactor water level. Once the normal reference leg piping had been reinstalled and


down to 56 inches before the valve could be fully closed. (Reference
the reference leg began to refill, the indicated level decreased from 357 inches to the actual


zero on these level instruments
level of 255 inches. The second level instrument, which does not come on-scale until the level


is the bottom of the hot leg, with mid-loop being defined at approximately
goes below 200 inches, remained off-scale high.


24 inches.) The average rate of level decrease between 105 IN 99-14 May 5, 1999 inches and 56 inches was approximately
When operators discovered the level discrepancy, they used a temporary pressure gauge


33 inches per minute. At its lowest level, 56 inches indicated, there were still 93 inches of water above the TAF. Using the high pressure safety injection (HPSI) pump the operators
connected to the reactor vessel low-point tap to confirm the actual water level. After confirming


brought the level back up to 90 inches. The plant was in reduced inventory
the accuracy of the wide-range indicator, they restored the reactor vessel water level to 357 inches. The 100-inch error represented approximately 14,000 gallons of water. The licensee


operations (below 65 inches) for approximately
determined that the safety significance of this event was low since the reactor was in cold


7 minutes. During the event the level remained well above the point where LPSI pump cavitation
shutdown with low decay heat and the reactor water level remained well above the TAF. In


would be expected.
addition, the drain-down would have been limited by an automatic Isolation of the draindown


The licensee concluded
path, which would have occurred prior to vessel level reaching 177 Inches above the TAF.


that the safety significance
The licensee's post event review identified: weaknesses in the operator's knowledge of the


of the event was minimal because multiple sources of makeup water were available, redundant
reactor assembly process; lack of explicit detail in the reactor assembly procedure; and, weaknesses in the plant risk assessment process. Contrary to the assumption that two


mitigation
designated reactor water level indicators were available, only one indicator, the wide-range


equipment
instrument, was available in the range above 200 inches. When the reference leg on the wide- range instrument was disassembled and drained, the one usable indicator was rendered


was available, and the operators
unavailable. The second instrument was pegged off-scale high and remained that way


were quick to recognize
throughout the event because the level never dropped below 200 inches. A post event review by


and respond to the event.On the basis of post event reviews, it was determined
the licensee indicated that other reactor water level instruments, remained operable during the


that the procedure
event but, apparently the operators did not rely on these other instruments or notice the


used for draining down the refueling
discrepancy between them and the wide range Indicator. Proposed corrective actions included


canal was inadequate
procedural enhancements to ensure that reactor level instrumentation credited by the outage


in that it incorrectly
risk assessment remains available during reactor disassembly and reassembly.
 
stated that the draindown
 
should be secured at the 90-inch level. The procedure
 
should have directed that the rate of draining be secured at the 106-inch level so that appropriate
 
precautions
 
could be taken before resuming the draindown.
 
These precautions
 
should have Included reminders
 
to the operating crew that below the 106-inch level the level will drop much more quickly due to the transition
 
of pumping from a large volume in the refueling
 
canal to a small volume In the reactor vessel.Therefore, in order to maintain control of the water level, the draindown
 
rate should be decreased
 
and an operator should be stationed
 
to directly monitor the level.Additional
 
factors that contributed
 
to this event include: the operators
 
received little specific training on this evolution;
the crew was inexperienced
 
in performing
 
this task; the task should have been classified
 
as an infrequent
 
task requiring
 
a more thorough briefing;
and, operators failed to station an operator in a position where he could directly monitor the water level in the refueling
 
canal. Instead they monitored
 
it remotely using a video camera that did not provide a clear picture of the water level.FitzPatrick
 
On December 2, 1998, at the James A. FitzPatrick
 
Nuclear Power Plant, the operators
 
were in the process of reassembling
 
the reactor following
 
refueling.
 
Operators
 
were controlling
 
the reactor vessel water level at 357 inches above TAF by adjusting
 
the water discharge
 
rate to compensate
 
for the constant input from the control rod drive cooling water system. While in this condition, the licensees
 
risk analysis requires that reactor vessel water level be monitored
 
using two independent
 
level indicators.
 
To meet this requirement, the licensee designated
 
a wide range indicator
 
which provided Indication
 
up to the top of the reactor vessel and an RHR interlock
 
level indicator
 
which provided indication
 
in the range from -150 inches to +200 Inches as the instruments
 
to be used during this evaluation.
 
In order for the wide-range
 
level Indicator
 
to remain available
 
with the reactor head removed, a temporary
 
standpipe
 
and fill funnel were used to replace a portion of the reference
 
leg. At the time of the event, the licensee was in the process of removing this temporary
 
standpipe
 
and reinstalling
 
the original reference
 
leg components.
 
As the water drained from the standpipe, it caused the wide-range
 
level indicator
 
to erroneously
 
show an increasing
 
water level. For a period of approximately
 
one hour the operators
 
in the control room, unaware that the ongoing maintenance
 
would cause an error in the indicated
 
water level, compensated
 
for the apparent increasing
 
level by increasing
 
the discharge
 
rate. This action had the effect of reducing the
 
IN 99-14 May 5, 1999 actual water level from 357 inches to 255 inches. During the same time period, the operators were also in the process of filling and venting the reactor feedwater
 
piping, which could have affected the reactor water level. Once the normal reference
 
leg piping had been reinstalled
 
and the reference
 
leg began to refill, the indicated
 
level decreased
 
from 357 inches to the actual level of 255 inches. The second level instrument, which does not come on-scale until the level goes below 200 inches, remained off-scale
 
high.When operators
 
discovered
 
the level discrepancy, they used a temporary
 
pressure gauge connected
 
to the reactor vessel low-point
 
tap to confirm the actual water level. After confirming
 
the accuracy of the wide-range
 
indicator, they restored the reactor vessel water level to 357 inches. The 100-inch error represented
 
approximately
 
14,000 gallons of water. The licensee determined
 
that the safety significance
 
of this event was low since the reactor was in cold shutdown with low decay heat and the reactor water level remained well above the TAF. In addition, the drain-down
 
would have been limited by an automatic
 
Isolation
 
of the draindown path, which would have occurred prior to vessel level reaching 177 Inches above the TAF.The licensee's
 
post event review identified:
weaknesses
 
in the operator's
 
knowledge
 
of the reactor assembly process; lack of explicit detail in the reactor assembly procedure;
and, weaknesses
 
in the plant risk assessment
 
process. Contrary to the assumption
 
that two designated
 
reactor water level indicators
 
were available, only one indicator, the wide-range
 
instrument, was available
 
in the range above 200 inches. When the reference
 
leg on the wide-range instrument
 
was disassembled
 
and drained, the one usable indicator
 
was rendered unavailable.
 
The second instrument
 
was pegged off-scale
 
high and remained that way throughout
 
the event because the level never dropped below 200 inches. A post event review by the licensee indicated
 
that other reactor water level instruments, remained operable during the event but, apparently
 
the operators
 
did not rely on these other instruments
 
or notice the discrepancy
 
between them and the wide range Indicator.
 
Proposed corrective
 
actions included procedural
 
enhancements
 
to ensure that reactor level instrumentation
 
credited by the outage risk assessment
 
remains available
 
during reactor disassembly
 
and reassembly.


Discussion
Discussion


Personnel
Personnel errors appear to have caused, or contributed to, these three inadvertent reactor
 
errors appear to have caused, or contributed
 
to, these three inadvertent
 
reactor vessel draindown
 
events. The likelihood
 
of personnel
 
errors is dependent
 
upon the operators knowledge
 
of the task gained through previous experience
 
and training.
 
It is also dependent upon the quality of the procedures
 
used to perform the task, the level of supervision, the adequacy of pre-job briefings, fatigue, and distractions
 
resulting
 
from multiple tasks. In each of the events, the plant staff made errors during a seldom-performed
 
evolution.
 
Because it was a seldom-performed
 
evolution, more training, better pre-job briefings, closer supervision, and procedures
 
that contain more details than those for frequently


performed
vessel draindown events. The likelihood of personnel errors is dependent upon the operators


activities
knowledge of the task gained through previous experience and training. It is also dependent


might have prevented
upon the quality of the procedures used to perform the task, the level of supervision, the


these events.
adequacy of pre-job briefings, fatigue, and distractions resulting from multiple tasks. In each of


IN 99-14 May 5, 1999 This information
the events, the plant staff made errors during a seldom-performed evolution. Because it was a


notice requires no specific action or written response.
seldom-performed evolution, more training, better pre-job briefings, closer supervision, and


If you have any questions
procedures that contain more details than those for frequently performed activities might have


about the information
prevented these events.


in this notice, please contact the technical
IN 99-14 May 5, 1999 This information notice requires no specific action or written response. If you have any


contact listed below, the appropriate
questions about the information in this notice, please contact the technical contact listed below, the appropriate regional office, or the appropriate Office of Nuclear Reactor Regulation (NRR)
project manager.


regional office, or the appropriate
Ledyard B. Marsh, Chief


Office of Nuclear Reactor Regulation (NRR)project manager.Ledyard B. Marsh, Chief Events Assessment, Generic Communications
Events Assessment, Generic Communications


And Non-Power
And Non-Power Reactors Branch


Reactors Branch Division of Regulatory
Division of Regulatory Improvement Programs


Improvement
Office of Nuclear Reactor Regulation


===Programs Office of Nuclear Reactor Regulation===
Technical contact:    Chuck Petrone, NRR
Technical


contact: Chuck Petrone, NRR 301-415-1027 E-mail: cdDRenrc.aov
301-415-1027 E-mail: cdDRenrc.aov


REFERENCES:
REFERENCES:
NRC Integrated
NRC Integrated Inspection Report No. 50-333/98-08, issued February 10, 1999 (Accession No.
 
Inspection
 
Report No. 50-333/98-08, issued February 10, 1999 (Accession
 
No.9902170348)
for the James A. FitzPatrick
 
Nuclear Power Plant for the period November 22, 1998, through January 10, 1999.Attachment:
List of Recently Issued NRC Information
 
Notices
 
~~ Attachment
 
1 IN 99-14 May 5, 1999 Page 1 of I LIST OF RECENTLY ISSUED NRC INFORMATION
 
NOTICES Information
 
Date of Notice No. Subject Issuance Issued to 99-13 Insiahts from NRR Inspections
 
4129199 All holders of operatina
 
licenses of Low-and Medium-Voltage
 
===Circuit Breaker Maintenance===
Programs for nuclear power reactors 99-12 Year 2000 Computer Systems Readiness
 
Audits Incidents
 
Involving


the Use of Radioactive
9902170348) for the James A. FitzPatrick Nuclear Power Plant for the period November 22,
1998, through January 10, 1999.


Iodine-131
Attachment: List of Recently Issued NRC Information Notices
4/28/99 4/23/99 All holders of operating


licenses or construction
~~ Attachment 1 IN 99-14 May 5, 1999 Page 1 of I


permits for nuclear power plants All medical use licensees 99-11 97-15, Sup 1 Reporting
LIST OF RECENTLY ISSUED


of Errors and 4/16/99 Changes in Large-Break/Small- Break Loss-of-Coolant
NRC INFORMATION NOTICES


Evaluation
Information                                          Date of


Models of Fuel Vendors and Compliance
Notice No.            Subject                      Issuance    Issued to


with 10 CFR 50.46(a)(3)
99-13            Insiahts from NRR Inspections      4129199    All holders of operatina licenses
All holders of operating


licenses for nuclear power reactors, except those who have permanently
of Low-and Medium-Voltage                      for nuclear power reactors


cease operations
Circuit Breaker Maintenance


and have certified
Programs


that fuel has been permanently
99-12            Year 2000 Computer Systems          4/28/99    All holders of operating licenses


removed from the reactor 99-10 99-09 Degradation
Readiness Audits                              or construction permits for nuclear


of Prestressing
power plants


4/13/99 Tendon Systems in Prestressed
99-11            Incidents Involving the Use of    4/23/99   All medical use licensees


===Concrete Containments===
Radioactive Iodine-131
Problems Encountered
97-15, Sup 1    Reporting of Errors and            4/16/99    All holders of operating licenses


When 3/24/99 Manually Editing Treatment
Changes in Large-Break/Small-                  for nuclear power reactors, except


Data on The Nucletron
Break Loss-of-Coolant Evaluation              those who have permanently


Microselectron-HDR (New) Model 105.999 Urine Specimen Adulteration
Models of Fuel Vendors and                    cease operations and have


4/1/99 All holders of operating
Compliance with 10 CFR 50.46(a)(3)            certified that fuel has been


licenses for nuclear power reactors All medical licensees
permanently removed from the


authorized
reactor


to conduct high-dose-rate (HDR)remote after loading brachytherapy
99-10            Degradation of Prestressing        4/13/99    All holders of operating licenses


treatments
Tendon Systems in Prestressed                  for nuclear power reactors


All holders of operating
Concrete Containments


licensees for nuclear power reactors and licensees
99-09            Problems Encountered When          3/24/99    All medical licensees authorized


authorized
Manually Editing Treatment Data                to conduct high-dose-rate (HDR)
                on The Nucletron Microselectron-HDR            remote after loading


to possess or use formula quantities
(New) Model 105.999                            brachytherapy treatments


of strategic
99-08            Urine Specimen Adulteration        4/1/99      All holders of operating licensees


special nuclear material 99-08 OL = Operating
for nuclear power reactors and


License CP = Construction
licensees authorized to possess


Permit
or use formula quantities of


IN 99-xx April xx, 1999 Page 5of 5 This information
strategic special nuclear material


notice requires no specific action or written response.
OL = Operating License


If you have any questions
CP = Construction Permit


about the information
IN 99-xx


in this notice, please contact the technical
April xx, 1999 Page 5of 5 This information notice requires no specific action or written response. If you have any


contact listed below, the appropriate
questions about the information in this notice, please contact the technical contact listed below, the appropriate regional office, or the appropriate office of Nuclear Reactor Regulation (NRR)
            Project Manager.


regional office, or the appropriate
Ledyard B. Marsh, Chief


office of Nuclear Reactor Regulation (NRR)Project Manager.Ledyard B. Marsh, Chief Events Assessment, Generic Communications
Events Assessment, Generic Communications


And Non-Power
And Non-Power Reactors Branch


Reactors Branch Division of Regulatory
Division of Regulatory Improvement Programs


Improvement
Office of Nuclear Reactor Regulation


===Programs Office of Nuclear Reactor Regulation===
Technical contact:        Chuck Petrone, NRR
Technical


contact: Chuck Petrone, NRR 301-415-1027 E-mail: cdRDanrc.aov
301-415-1027 E-mail: cdRDanrc.aov


REFERENCES:
REFERENCES:
NRC Integrated
            NRC Integrated Inspection Report No. 50-333198-08, issued February 10, 1999 (Accession No.


Inspection
9902170348) for the James A. FitzPatrick Nuclear Power Plant for the period November 22,
            1998, through January 10, 1999.


Report No. 50-333198-08, issued February 10, 1999 (Accession
Attachments:
            1. List of Recently Issued NMSS Information Notices


No.9902170348)
2. List of Recently Issued NRC Information Notices
for the James A. FitzPatrick


Nuclear Power Plant for the period November 22, 1998, through January 10, 1999.Attachments:
DOCUMENT NAME: G:ICDPDRAININ\DRAIN.0B.WPD
1. List of Recently Issued NMSS Information


Notices 2. List of Recently Issued NRC Information
To receive a copy of this document, Indicate In the box C=Copy w/o attachmentlenclosure E=Copy with attachment/enclosure N = No copy


Notices DOCUMENT NAME: G:ICDPDRAININ\DRAIN.0B.WPD
OFFICE        PECB:DRIP        I        Tech Editor            l      DRCH                  I        PDIV-1              I


To receive a copy of this document, Indicate In the box C=Copy w/o attachmentlenclosure
NAME          CPetrone I_                                                RGallo  1                    MNolangfarP.


E=Copy with attachment/enclosure
DATE            V/0199 F      .


N = No copy OFFICE PECB:DRIP
[3 /1/99 V.                            .


I Tech Editor l DRCH I PDIV-1 I NAME CPetrone I_ RGallo 1 MNolangfarP.
4/4I9
                                                                                                .      .


DATE V /0199 [3 /1/99 4 /4I9 1' /0g99 F .V. ...OFFICE PDI-1 IA .I PDIII-2 I C:PECB:DRIP
1' /0g99 OFFICE         PDI-1         IA .I         PDIII-2               I       C:PECB:DRIP         I


I NAME 2 Jiiam RPulsjier
NAME         2Jiiam                      RPulsjier                     LMarsh


LMarsh DATE lf/499 I1'/t 99 I /99 OFFICIAL RECORD COPY
DATE         lf/499                     I1'/t 99                           I /99 OFFICIAL RECORD COPY


IN 99-14 May 5, 1999 This information
IN 99-14 May 5, 1999 This information notice requires no specific action or written response. If you have any


notice requires no specific action or written response.
questions about the information in this notice, please contact the technical contact listed below, the appropriate regional office, or the appropriate Office of Nuclear Reactor Regulation (NRR)
            project manager.


If you have any questions
[arig        sjid by]
                                                                  Ledyard B. Marsh, Chief


about the information
Events Assessment, Generic Communications


in this notice, please contact the technical
And Non-Power Reactors Branch


contact listed below, the appropriate
Division of Regulatory Improvement Programs


regional office, or the appropriate
Office of Nuclear Reactor Regulation


Office of Nuclear Reactor Regulation (NRR)project manager.[arig sjid by]Ledyard B. Marsh, Chief Events Assessment, Generic Communications
Technical contact:          Chuck Petrone, NRR


And Non-Power
301-415-1027 E-mail: cdr)ODnrc.gov
 
Reactors Branch Division of Regulatory
 
Improvement
 
===Programs Office of Nuclear Reactor Regulation===
Technical
 
contact: Chuck Petrone, NRR 301-415-1027 E-mail: cdr)ODnrc.gov


REFERENCES:
REFERENCES:
NRC Integrated
            NRC Integrated Inspection Report No. 50-333/98-08, issued February 10, 1999 (Accession No.


Inspection
9902170348) for the James A. FitzPatrick Nuclear Power Plant for the period November 22,
            1998, through January 10, 1999.


Report No. 50-333/98-08, issued February 10, 1999 (Accession
Attachment: List of Recently Issued NRC Information Notices


No.9902170348)
DOCUMENT NAME: S:XDRPMSEC\99-14.IN
for the James A. FitzPatrick
 
Nuclear Power Plant for the period November 22, 1998, through January 10, 1999.Attachment:
List of Recently Issued NRC Information
 
Notices DOCUMENT NAME: S:XDRPMSEC\99-14.IN


*See previous concurrence
*See previous concurrence


To receive a copy of this document.
To receive a copy of this document. indicate in the box C=CoDv w/o attachment/enclosure E=CoDv with attachment/enclosure N = No coov
 
indicate in the box C=CoDv w/o attachment/enclosure


E=CoDv with attachment/enclosure
OFFICE        PECB:DRlIP        I      Tech Editor            l      DRCH                  l-ii  PDIV-1                lI


N = No coov OFFICE PECB:DRlIP
NAME          CPetrone*                  BCalure*                        RGallo*                      MNolan*
  DATE          04/27/99 .3/15/99                                        _________04128199            = 04/27/99
              1                                                    .    .                      .


I Tech Editor l DRCH l-ii PDIV-1 lI NAME CPetrone*
OFFICE         PDI-1             I       PD111-2                         C:PECB:DJRIP         I
BCalure* RGallo* MNolan*DATE 04/27/99 .3/15/99 _________04128199
= 04/27/99 1 ...OFFICE PDI-1 I PD111-2 C:PECB:DJRIP


I NAME JWilliams*  
NAME           JWilliams*                 RPulsifer'                     _I-Marsh _       __ _
RPulsifer'  
  DATE            04/27/9             .   04/27/99                     k,-u99 OFFICIAL RECORD COPY}}
I-Marsh _ _ __ _DATE 04/27/9 .04/27/99 k,-u99 OFFICIAL RECORD COPY}}


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

Latest revision as of 04:49, 24 November 2019

Unanticipated Reactor Water Draindown at Quad Cities Unit 2, Arkansas Nuclear One Unit 2, & FitzPatrick
ML031040444
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, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant  Entergy icon.png
Issue date: 05/05/1999
From: Marsh L
Division of Regulatory Improvement Programs
To:
References
IN-99-014, NUDOCS 9905070080
Download: ML031040444 (8)


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 May 5, 1999 NRC INFORMATION NOTICE 99-14: UNANTICIPATED REACTOR WATER DRAINDOWN

AT QUAD CITIES UNIT 2, ARKANSAS NUCLEAR ONE

UNIT 2, AND FITZPATRICK

Addressees

All holders of licenses for nuclear power, test, and research reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees to the potential for personnel errors during infrequently performed evolutions that

result in, or contribute to, events such as the inadvertent draining of water from the reactor

vessel during shutdown operations. It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to prevent a similar

occurrence. However, suggestions contained in this information notice are not NRC

requirements; therefore, no specific action or written response to this notice is required.

DescriDtion of Circumstances

Quad Cities Unit 2 On February 24, 1999, Quad Cities Unit 2 was in cold shutdown with reactor water temperature

at 131 'F and reactor water level at 80 inches indicated level (normal level during operations is

30 inches indicated or 173 inches above the top of active fuel [TAF]). Core cooling was being

maintained in a band of 120 'F to 170 OF by the OA" loop of the shutdown cooling mode of the

residual heat removal (RHR) system after being switched from the nB" loop at 12:32 a.m.

During the switch over the licensee inadvertently failed to close the OA RHR minimum flow

valve as required by the procedure. Sometime later operators noted a decreasing reactor water

level and at about 1:02 a.m. secured the *2A RHR pump and isolated shutdown cooling. At

1:55 a.m. operators restored the *2A' loop of shutdown cooling to the proper lineup and started

the *2A RHR pump. Water level had decreased to a minimum of about 45 inches indicated, and reactor water temperature had risen to a maximum of about 163 OF. Forced circulation of

reactor vessel water using a reactor recirculation pump remained in effect throughout the event.

On the basis of post event reviews, It appears that the minimum flow valve in the OA loop was

left open because the nuclear station operator failed to ensure that the tasks were performed in

the sequence specified in the operating procedures. The nuclear station operator who was

(7008 PD(L Hort<<4qj-Oiif qqos(J5 C7Ffcj

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IN 99-14 May 5, 1999 directing the evolution from the control room gave the non-licensed operator permission to de- energize the breaker for the WARHR minimum flow valve operator before the valve was taken

to the required closed position. De-energizing the breaker also removed power to the valve

position indicator lights in the control room. Thus, when the nuclear station operator tried to

verify that the valve was closed, there was no position indication in the control room to make

that verification. The nuclear station operator made the incorrect assumption that the valve was

already closed and moved to the next step in the procedure. This failure to close the WAX RHR

minimum flow valve opened a drain path from the reactor to the suppression pool. To further

complicate the event, the operating crew did not recognize that there was any problem until

approximately 10 minutes had passed and the water level had decreased about 13 inches

because of a misinterpretation of causes of the level decrease. After detecting the decrease, the operating crew was slow to react, which allowed the level to decrease another 20 inches

before the operators isolated shutdown cooling which terminated the draindown. The licensee

estimated that a total of 6000 to 7000 gallons was drained from the reactor to the suppression

pool.

Operations staff practices including poor communications, poor activity briefings for high-risk

activities, lack of effective pre-shift briefings, inadequate supervision of important control room

activities, inadequate monitoring of control room panels, and slow event response may have

contributed to the event. Although the unintended loss of inventory to the suppression pool

highlighted significant weaknesses in plant operations, the safety significance was minimized by

two features. First, a reactor recirculation pump remained in service throughout the event

which served to distribute decay heat. Second, an automatic isolation of shutdown cooling

would have occurred at 8 inches indicated level which would have stopped the draining event.

An indicated water level of 8 inches corresponds to approximately 151 inches of water level

above the TAF in the reactor core.

Arkansas Nuclear One Unit 2

On February 2, 1999, at Arkansas Nuclear One Unit 2, the operators were draining the

refueling canal in preparation for installing the reactor vessel head. Refueling was complete

and steam generator nozzle dams were installed. The operators were using the two low

pressure safety injection (LPSI) pumps to drain the canal to the refueling water storage tank;

one pump also served as the shutdown cooling pump. The rate of draindown was

approximately 3.3 Inches per minute. When the water level reached 105 inches, the reactor

operator noted that level started to lower rapidly. Operators stopped one of the LPSI pumps

and instructed a local operator to close the isolation valve to the refueling water tank. This

manually operated valve required 55 turns of the handwheel to fully close. Within

approximately 1.5 minutes, the reactor vessel level had dropped below the 65 inch level (where

reduced inventory begins) and continued down to 56 inches before the valve could be fully

closed. (Reference zero on these level instruments is the bottom of the hot leg, with mid-loop

being defined at approximately 24 inches.) The average rate of level decrease between 105

IN 99-14 May 5, 1999 inches and 56 inches was approximately 33 inches per minute. At its lowest level, 56 inches

indicated, there were still 93 inches of water above the TAF. Using the high pressure safety

injection (HPSI) pump the operators brought the level back up to 90 inches. The plant was in

reduced inventory operations (below 65 inches) for approximately 7 minutes. During the event

the level remained well above the point where LPSI pump cavitation would be expected. The

licensee concluded that the safety significance of the event was minimal because multiple

sources of makeup water were available, redundant mitigation equipment was available, and

the operators were quick to recognize and respond to the event.

On the basis of post event reviews, it was determined that the procedure used for draining

down the refueling canal was inadequate in that it incorrectly stated that the draindown should

be secured at the 90-inch level. The procedure should have directed that the rate of draining

be secured at the 106-inch level so that appropriate precautions could be taken before

resuming the draindown. These precautions should have Included reminders to the operating

crew that below the 106-inch level the level will drop much more quickly due to the transition of

pumping from a large volume in the refueling canal to a small volume In the reactor vessel.

Therefore, in order to maintain control of the water level, the draindown rate should be

decreased and an operator should be stationed to directly monitor the level.

Additional factors that contributed to this event include: the operators received little specific

training on this evolution; the crew was inexperienced in performing this task; the task should

have been classified as an infrequent task requiring a more thorough briefing; and, operators

failed to station an operator in a position where he could directly monitor the water level in the

refueling canal. Instead they monitored it remotely using a video camera that did not provide a

clear picture of the water level.

FitzPatrick

On December 2, 1998, at the James A. FitzPatrick Nuclear Power Plant, the operators were in

the process of reassembling the reactor following refueling. Operators were controlling the

reactor vessel water level at 357 inches above TAF by adjusting the water discharge rate to

compensate for the constant input from the control rod drive cooling water system. While in this

condition, the licensees risk analysis requires that reactor vessel water level be monitored using

two independent level indicators. To meet this requirement, the licensee designated a wide

range indicator which provided Indication up to the top of the reactor vessel and an RHR

interlock level indicator which provided indication in the range from -150 inches to +200 Inches

as the instruments to be used during this evaluation.

In order for the wide-range level Indicator to remain available with the reactor head removed, a

temporary standpipe and fill funnel were used to replace a portion of the reference leg. At the

time of the event, the licensee was in the process of removing this temporary standpipe and

reinstalling the original reference leg components. As the water drained from the standpipe, it

caused the wide-range level indicator to erroneously show an increasing water level. For a

period of approximately one hour the operators in the control room, unaware that the ongoing

maintenance would cause an error in the indicated water level, compensated for the apparent

increasing level by increasing the discharge rate. This action had the effect of reducing the

IN 99-14 May 5, 1999 actual water level from 357 inches to 255 inches. During the same time period, the operators

were also in the process of filling and venting the reactor feedwater piping, which could have

affected the reactor water level. Once the normal reference leg piping had been reinstalled and

the reference leg began to refill, the indicated level decreased from 357 inches to the actual

level of 255 inches. The second level instrument, which does not come on-scale until the level

goes below 200 inches, remained off-scale high.

When operators discovered the level discrepancy, they used a temporary pressure gauge

connected to the reactor vessel low-point tap to confirm the actual water level. After confirming

the accuracy of the wide-range indicator, they restored the reactor vessel water level to 357 inches. The 100-inch error represented approximately 14,000 gallons of water. The licensee

determined that the safety significance of this event was low since the reactor was in cold

shutdown with low decay heat and the reactor water level remained well above the TAF. In

addition, the drain-down would have been limited by an automatic Isolation of the draindown

path, which would have occurred prior to vessel level reaching 177 Inches above the TAF.

The licensee's post event review identified: weaknesses in the operator's knowledge of the

reactor assembly process; lack of explicit detail in the reactor assembly procedure; and, weaknesses in the plant risk assessment process. Contrary to the assumption that two

designated reactor water level indicators were available, only one indicator, the wide-range

instrument, was available in the range above 200 inches. When the reference leg on the wide- range instrument was disassembled and drained, the one usable indicator was rendered

unavailable. The second instrument was pegged off-scale high and remained that way

throughout the event because the level never dropped below 200 inches. A post event review by

the licensee indicated that other reactor water level instruments, remained operable during the

event but, apparently the operators did not rely on these other instruments or notice the

discrepancy between them and the wide range Indicator. Proposed corrective actions included

procedural enhancements to ensure that reactor level instrumentation credited by the outage

risk assessment remains available during reactor disassembly and reassembly.

Discussion

Personnel errors appear to have caused, or contributed to, these three inadvertent reactor

vessel draindown events. The likelihood of personnel errors is dependent upon the operators

knowledge of the task gained through previous experience and training. It is also dependent

upon the quality of the procedures used to perform the task, the level of supervision, the

adequacy of pre-job briefings, fatigue, and distractions resulting from multiple tasks. In each of

the events, the plant staff made errors during a seldom-performed evolution. Because it was a

seldom-performed evolution, more training, better pre-job briefings, closer supervision, and

procedures that contain more details than those for frequently performed activities might have

prevented these events.

IN 99-14 May 5, 1999 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 contact listed below, the appropriate regional office, or the appropriate Office of Nuclear Reactor Regulation (NRR)

project manager.

Ledyard B. Marsh, Chief

Events Assessment, Generic Communications

And Non-Power Reactors Branch

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contact: Chuck Petrone, NRR

301-415-1027 E-mail: cdDRenrc.aov

REFERENCES:

NRC Integrated Inspection Report No. 50-333/98-08, issued February 10, 1999 (Accession No.

9902170348) for the James A. FitzPatrick Nuclear Power Plant for the period November 22,

1998, through January 10, 1999.

Attachment: List of Recently Issued NRC Information Notices

~~ Attachment 1 IN 99-14 May 5, 1999 Page 1 of I

LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

99-13 Insiahts from NRR Inspections 4129199 All holders of operatina licenses

of Low-and Medium-Voltage for nuclear power reactors

Circuit Breaker Maintenance

Programs

99-12 Year 2000 Computer Systems 4/28/99 All holders of operating licenses

Readiness Audits or construction permits for nuclear

power plants

99-11 Incidents Involving the Use of 4/23/99 All medical use licensees

Radioactive Iodine-131

97-15, Sup 1 Reporting of Errors and 4/16/99 All holders of operating licenses

Changes in Large-Break/Small- for nuclear power reactors, except

Break Loss-of-Coolant Evaluation those who have permanently

Models of Fuel Vendors and cease operations and have

Compliance with 10 CFR 50.46(a)(3) certified that fuel has been

permanently removed from the

reactor

99-10 Degradation of Prestressing 4/13/99 All holders of operating licenses

Tendon Systems in Prestressed for nuclear power reactors

Concrete Containments

99-09 Problems Encountered When 3/24/99 All medical licensees authorized

Manually Editing Treatment Data to conduct high-dose-rate (HDR)

on The Nucletron Microselectron-HDR remote after loading

(New) Model 105.999 brachytherapy treatments

99-08 Urine Specimen Adulteration 4/1/99 All holders of operating licensees

for nuclear power reactors and

licensees authorized to possess

or use formula quantities of

strategic special nuclear material

OL = Operating License

CP = Construction Permit

IN 99-xx

April xx, 1999 Page 5of 5 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 contact listed below, the appropriate regional office, or the appropriate office of Nuclear Reactor Regulation (NRR)

Project Manager.

Ledyard B. Marsh, Chief

Events Assessment, Generic Communications

And Non-Power Reactors Branch

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contact: Chuck Petrone, NRR

301-415-1027 E-mail: cdRDanrc.aov

REFERENCES:

NRC Integrated Inspection Report No. 50-333198-08, issued February 10, 1999 (Accession No.

9902170348) for the James A. FitzPatrick Nuclear Power Plant for the period November 22,

1998, through January 10, 1999.

Attachments:

1. List of Recently Issued NMSS Information Notices

2. List of Recently Issued NRC Information Notices

DOCUMENT NAME: G:ICDPDRAININ\DRAIN.0B.WPD

To receive a copy of this document, Indicate In the box C=Copy w/o attachmentlenclosure E=Copy with attachment/enclosure N = No copy

OFFICE PECB:DRIP I Tech Editor l DRCH I PDIV-1 I

NAME CPetrone I_ RGallo 1 MNolangfarP.

DATE V/0199 F .

[3 /1/99 V. .

4/4I9

. .

1' /0g99 OFFICE PDI-1 IA .I PDIII-2 I C:PECB:DRIP I

NAME 2Jiiam RPulsjier LMarsh

DATE lf/499 I1'/t 99 I /99 OFFICIAL RECORD COPY

IN 99-14 May 5, 1999 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 contact listed below, the appropriate regional office, or the appropriate Office of Nuclear Reactor Regulation (NRR)

project manager.

[arig sjid by]

Ledyard B. Marsh, Chief

Events Assessment, Generic Communications

And Non-Power Reactors Branch

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contact: Chuck Petrone, NRR

301-415-1027 E-mail: cdr)ODnrc.gov

REFERENCES:

NRC Integrated Inspection Report No. 50-333/98-08, issued February 10, 1999 (Accession No.

9902170348) for the James A. FitzPatrick Nuclear Power Plant for the period November 22,

1998, through January 10, 1999.

Attachment: List of Recently Issued NRC Information Notices

DOCUMENT NAME: S:XDRPMSEC\99-14.IN

  • See previous concurrence

To receive a copy of this document. indicate in the box C=CoDv w/o attachment/enclosure E=CoDv with attachment/enclosure N = No coov

OFFICE PECB:DRlIP I Tech Editor l DRCH l-ii PDIV-1 lI

NAME CPetrone* BCalure* RGallo* MNolan*

DATE 04/27/99 .3/15/99 _________04128199 = 04/27/99

1 . . .

OFFICE PDI-1 I PD111-2 C:PECB:DJRIP I

NAME JWilliams* RPulsifer' _I-Marsh _ __ _

DATE 04/27/9 . 04/27/99 k,-u99 OFFICIAL RECORD COPY