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| {{Adams | | {{Adams |
| | number = ML20205B791 | | | number = ML20234E507 |
| | issue date = 03/13/1987 | | | issue date = 07/02/1987 |
| | title = Insp Rept 50-382/86-28 on 861117-21.Violation Noted:Failure to Comply W/Procedures for Control of Temporary Alterations | | | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/86-28.Ack That Rev 3 to Procedure UNT-5-004 May Be Limited in Scope to Installed Equipment & Not Specifically Violated |
| | author name = Boardman J, Hunnicutt D | | | author name = Gagliardo J |
| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| | addressee name = | | | addressee name = Dewease J |
| | addressee affiliation = | | | addressee affiliation = LOUISIANA POWER & LIGHT CO. |
| | docket = 05000382 | | | docket = 05000382 |
| | license number = | | | license number = |
| | contact person = | | | contact person = |
| | document report number = 50-382-86-28, NUDOCS 8703300044 | | | document report number = NUDOCS 8707070593 |
| | package number = ML20205B729 | | | title reference date = 04-16-1987 |
| | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | | | document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE |
| | page count = 12 | | | page count = 2 |
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| {{#Wiki_filter:. . | | {{#Wiki_filter:, - |
| APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION
| | . 9 3 In Reply Refer To: |
| | Docket: 50-382/86-28 M gg Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations N-80 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen: |
| | Thank you for your letter of April 16, 1987, in response to our letter I and Notice of Violation dated March 17, 198 We have reviewed your reply and ! |
| | find it responsive to the concerns raised in our Notice of Violation. We acknowledge that your Procedure UNT-5-004, Revision 3, may be limited in scope |
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| | to installed equipment and therefore was not specifically violated; however, 1 |
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| ==REGION IV==
| | the failure of your Procedure ME-7-002, Revision 5 to assure proper restoration of equipment following a bench test is still in violation of the requirements of 10 CFR 50, Appendix B, Criterion V to provide documented procedures of a type appropriate to the circumstance We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine |
| NRC Inspection Report: 50-382/86-28 License: NPF-38 Docket: 50-382 Licensee: Louisiana Power & Light Company (LP&L)
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| N-80 317 Baronne Street New Orleans, Louisiana 70160 Facility Name: Waterford Steam Electric Station, Unit 3 Inspection Conducted: November 17-21, 1986 Inspector: kN 3//3/F7 | | Sincerely, |
| | .Dricinal Signed by: |
| | R.E.HALU J. E. Gagliardo, Chief Reactor Projects Branch cc: |
| | Louisiana Power & Light Company ATTN: G. E. Wuller, Onsite Licensing Coordinator P. O. Box B Killona, Louisiana 70066 RIV:RSB/0S y)Y OS gg RSB |
| | /N RPB JRBoardman:gt DMHunnicutt TFWesterman gJEGagliardo 7 / 1 /87 ]/)/87 1/t/87 7/(/87 |
| | ?Dk 3 670702 F l0$[K 05000382PDR I |
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| | . 1 -4 Louisiana Power & Light Company 2 |
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| John Boardman, Reactor Inspector Operations Da'te Section, Reactor Safety Branch Accompanied by: Howard Stromberg, EG&G ,
| | Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P. O. Box B 1 Killona, Louisiana 70066 1 |
| Clarke Kido, EG&G Approved By: h/
| | . Middle South Services ATTN: Mr. R. T. Lally l P. O. Box 61000 ! ' |
| D. M. Hunnicutt, Chief, Operations Section 3//3/F7 Date '
| | New Orleans, Louisiana 70161 Louisiana Power & Light Company ATTN: K. W. Cook, Nuclear Safety and Regulatory Affairs Manager 317 Baronne Street P. O. Box 60340 ; |
| Reactor Safety Branch Inspection Summary:
| | New Orleans, Louisiana 70160 i |
| Inspection Conducted November 17-21, 1986 (Report 50-382/86-28)
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| Areas Inspected: A Region IV team inspection of licensee maintenance activities was performed. The inspection covered maintenance program implementation, maintenance program, instrument and control maintenance, and electrical maintenanc Results: Of the four areas inspected, one violation was identified (failure to comply with procedures for control of temporary alterations).
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| %33$$ock | | Louisiana Radiation Control Program Director I i |
| | bec to DMB (IE01) |
| | bcc distrib. by RIV: . |
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| | *RPB *D. Weiss, RM/ALF i |
| | *RRI R. D. Martin, RA i |
| | *SectionChief(RPB/A) DRSP RPSB *RSB |
| | * MIS System * Project Inspector, RPB |
| | *RSTS Operator *R. Hall |
| | *RIV File NRR Project Manager |
| | *w/766 l i |
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| DETAILS Persons Contacted
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| *J. Dewease, Senior Vice President, Nuclear Operations
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| *R. P. Barkhurst, Vice President, Nuclear Operations
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| *K. L. Brewster, Lic. Eng., Operational Licensing
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| *N. S. Carns, Plant Manager
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| *K. W. Cook, Nuclear Safety & Regulatory Affairs Manager
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| *C R. Gains, Operations Interface
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| *T. F. Gerrets, Nuclear QA Manager
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| *J. R. McGaha, 0&M Assistant Plant Manager
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| *F. J. Engle Bracht, Nuclear Administrative Services Manager
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| *S. A. Alleman, Assistant Plant Manager, Technical Services
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| *T. H. Smith, Maintenance Superintendent
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| *A. S. Lockhart, Nuclear Operational Safety Analysis Manager
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| *K. L. Brewster, Licensing Engineer - Operational Licensing T. Moore, Electrical Supervisor T. Smith, Maintenance Superintendent B. Thigpen, Mechanical Maintenance Assistant Superintendent J. Begnaud, Mechanical Supervisor, Nuclear L. Lehmann, Mechanical Supervisor, Nuclear The NRC inspector also interviewed additional licensee and contractor personnel during the inspectio * Denotes those attending the exit interview on November 21, 198 The senior resident inspector attended the exit intervie . Actions on Previous Findings (Closed) Unresolved Item (50-382/8504-02) Closure of Ebasco purchase orders. For the orders included in the inspector's sample, licensee personnel provided documentation of closure satisfying the NRC inspector that no significant problem appears to exist in this are . Temporary Alteration Control During the inspection, the NRC inspector reviewed the following procedures provided by licensee personnel:
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| UNT-5-004, Revision 3, Administrative Procedure Temporary Alteration Control
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| ME-7-002, Revision 5. Maintenance Procedure Molded-Case Circuit Breakers and Thermal Overload Relays
| | LO UlSI POWE R & AN L1GHTA / 317 NEWBARONNE |
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| | STREET ORLEANS, LOUISlANA P. O BOX 60340 70160 * (504) 595 3100 U1'sl$ES SE April 16, 1987 ? |
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| ...- , | | W3P87-1010 A4.05 QA |
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| | ' % Fu; . l U.S. Nuclear Regulatory Commission L M \~- '':p!":I }li ATTN: Document Control Desk ;j |
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| | ll Washington, D.C. 20555 ~ |
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| | g 2 l jgp i r i L i Subject: Waterford 3 SES I Docket No. 50-382 |
| | , License No. NPF-38 NRC Inspection Report 86-28 |
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| | Attached is the Louisiana Power and Light Company (LP&L) y,esponse to Violation No. 8628-01 identified in Inspection Report No. 86-2 If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-349 l l |
| | l Very truly yours, C |
| | oY l A h K.W. Cook Nuclear Safety and Regulatory Affairs Manager T( y s |
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| | KWC:KLB:ssf . |
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| | \ cu cc: R.D. Martin, NRC Region IV s G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR V' |
| | g NRC Resident Inspectors Office , |
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| UNT-5-004, Revision 3. Section 3.1 defines a temporary alternation as any short tem addition to, removal from or change in the function of a system or any of its components which is not in accordance with approved-Waterford III desig Specific controls are required by UNT-5-004, Revision 3. for temporary alterations, unless prescribed controls are contained in procedures which perform temporary alteration ME-7-002, Revision 5. specifies and defines performance testing of molded-case circuit breakers. Certain tests, such as the instantaneous trip test, Section 8.5, specify removal of current-limiting fuses and their replacement with shorting devices for the performance of the tes No note, or procedure step, specifies or requires, the removal of the shorting devices, and replacement of the fuses required for breaker operability after completion of testin Procedure ME-7-002, Revision 5, does not reference procedure UNT-5-00 ' Licensee personnel indicated that temporary replacement of fuses with shorting bars, particularly for shop testing, had not been considered to be a temporary modificatio Failure to comply with UNT-5-004, Revision 3, Sections 4.0 and 5.0, and subsections thereto, in the removal and replacement of fuses for testing of circuit breakers is an apparent violation of 10 CFR Part 50, Appendix B, Criterion V, and ANSI N18.7-1976, Section 5. (382/8628-01) Maintenance Program The NRC inspector reviewed the licensee's maintenance progra Appropriate personnel in management, supervision, and crafts were interviewed concerning their areas of responsibility and their understanding of the applicable procedure The plant was preparing for its first refueling outage when the inspection was conducted. Certain corrective and many preventive maintenance actions had been rescheduled to be accomplished during the outage. Various training classes had been held to prepare personnel for work on components such as valves, pumps, snubbers, and energency diesel generator Personnel were temporarily reassigned to handle responsibilities in maintenance planning and scheduling, plant engineering, and maintenance trainin . .
| | E.L. Blake |
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| | W.M. Stevenson s' |
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| | ,_ g "AN EOUAL OPPORTUNITY EMPLOYER" |
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| Based on interviews with maintenance personnel and observation of Condition Identifications Work Authorization (CIWAs) 28583, 29923, and 23768 it appeared to the NRC inspector that the licensee relies heavily upon worker experience and verbal communication in the performance of maintenanc Maintenance procedures required careful interpretation and were usually augmented by the worker's personal experience or detailed instructions from the most cognizant supervisor. A concern of the NRC inspector was that some procedures as written may be too vague for a worker
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| ; with limited experience to properly perform the task. It appeared that procedural corrections and clarifications considered necessary by maintenance personnel were not being routed to the planner so that the procedures could be amended, as appropriat This concern was discussed with the licensee, who indicated that a reorganization is scheduled shortly to more closely integrate personnel and responsibilities. In implementation of this concept, the snubber maintenance program is undergoing review by plant engineering, maintenance planning, and mechanical maintenanc The NRC inspector reviewed three maintenance activities (CIWAs 28583, 29923, and 23768). The CIWAs were reviewed to determine craft compliance with maintenance procedures, adequacy of maintenance procedures, and if required procedures and materials were present during work performanc Two completed corrective maintenance and three preventive maintenance CIWAs were reviewe In addition, the maintenance history files for the essential chillers were reviewed to determine if previous Freon leaks had occurred. No concerns were identified. The following mechanical maintenance tasks were reviewed: CIWA 25630, boric acid makeup tank pump discharge drain valve seat leak repair, CIWA 27322, essential chiller B temperature controller Freon leak repai PM Task Carri MWORFRAB2, essential chiller WC1AB refrigerant filter changeou PM Task Card MWORFRAB2, essential chiller WCIAB compressor oil and filter changeou EQ Task Card MW0EFWP02, emergency feedwater pump AB (Terry Turbine)
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| oil system inspect, clean, and change filter Two additional concerns were identified during this review of the maintenance progra The first was that a plant wide trending analysis program did not appear to be implemented. The second concern was that there did not appear to be a procedure being used that ensured consistency in the documents transferred to storage. In a number of packages (see Sections 4 and 5 below) there were sections that did not appear to be completed as required, and at times it could not be verified if all
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| | Attcch2:nt to W3P87-1010 |
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| | Sheet 1 of 2 |
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| | LP&L Response To Violation No. 8628-01 1 VIOLATION No. 8628-01 Failure to Follow Procedures for Control of Temporary Modifications 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be accomplished in accordance with approved procedures. ANSI N18.7-1976, to which the licensee is committed, Section 5.2.2, requires that procedures shall be followed. Licensee Procedure UNT-5-004, Revision 3, " Administrative Procedure Temporary Alteration Control,'' identifies specific requirements for the control and restoration of tcmporary modifications. This procedure specifies that procedures requiring temporary modifications shall either appropriately reference UNT-5-004, or contain the specified controls for temporary modification Contrary to the above, the NRC inspector on November 19, 1986, identified that licensee Procedure ME-7-002, Revision 5 " Maintenance Procedure Molded-Case Circuit Breakers and Thermal Relays," did not contain required |
| | ,. controls for temporary removal and replacement of current limiting fuses during performance testing of the circuit breakers, nor reference UNT-5-00 . |
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| | This is a Severity Level IV violatio RESPONSE (1) Reason for the Violation This violation cites procedure ME-7-002, Molded Case Circuit Breakers and Thermal Relays, "for not containing required controls for temporary alterations as specified by UNT-5-004, Temporary Alteration control". Although ME-7-002. inadvertently omitted steps that would ensure proper restoration of equipment to its design operating condition, we do not feel that it viol'ated UNT-5-004. UNT-5-004 is a procedure written to control temporary alterations to existing, installed, operational plant equipment. ME-7-002 is a procedure which removes a piece of equipment and bench tests it. Temporary changes, |
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| | modifications, disassembly or reassembly of the equipment once removed from the plant is not considered a temporary alteration and should not fall under the requirements of UNT-5-004. Nonetheless, procedures controlling maintenance in these situations must be adequate to ensure complete and proper restoration of equipment; this is the area in which ME-7-002 was deficien (2) Corrective Action That Has Been Taken ME-7-002 has been revised to require removal of any shorting alocks that could have been previously installed, re-installation of fuses and independent verification of the came. The possibility that shorting devices could have been left in breakers previously tested by this procedure has also been considered. We are confident that this is not the case based on the following: |
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| applicable documents were in the stored document files. This will remain an open item (382/8628-02) pending further review during a subsequent inspectio . Maintenance Program Implementation The NRC inspector obtained a list of maintenance activities which were scheduled for the week of November 17-21, 1986. He selected three for inspection to determine compliance with the regulations and the Waterford 3 Administrative Procedure The three maintenance activities were detailed on Condition Identification and Work Authorization (CIWAs) for the following corrective maintenance:
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| troubleshoot Freon leak found at electrical box on the compressor to Essential Chiller AB, troubleshoot RCS leakage past seals on Charging Pump B, and preventive maintenance of type PSA-3 mechanical snubber The CIWAs were identified as CIWA 28583, 29923, and 23768, respectivel Each CIWA was reviewed for authorizing signatures, spare parts control, inspection adequacy, mechanical qualification, adequacy of maintenance performed and post-maintenance functional testing and restoration. The CIWA's were also reviewed to determine compliance with the requirements of the following procedures:
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| MM-1-002, Revision 2, " Mechanical Maintenance Practice," dated August 24, 198 MD-1-007, Revision 2, " Preventive Maintenance Task Identification,"
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| dated November 15, 198 "
| | . Section 8.6 (Thermal Element Time Delay Test) of ME-7-002 did , |
| MD-1-004, Revision 6, " Preventive Maintenance Scheduling," dated May 21, 198 *
| | contain a note requiring removal of shorting devices and j re-installation of fuses. Section.8.6 is required each'tima the breaker is teste (Section 8.5, Instantaneous Trip-Test, had no such provisions, but is only required on newly installed breakers.) |
| UNT-5-002, Revision 5, " Administrative Procedure, Condition Identification and Work Authorization (CIWA)," dated January 13, 198 *
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| MD-1-011, Revision 3, Maintenance Procedure Development, Review, Approval, Change, Revision, Deletion MD-1-014, Revision 1, " Administrative Procedure, Conduct of Maintenance," dated November 21, 198 MM-6-023, Revision 1, " Mechanical Snubber (Shock Arresters)
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| Maintent.nce," dated October 21, 198 .
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| MM-7-011, Revision 3, " Mechanical Snubber Test," dated November 14, 198 The troubleshooting of the Essential Chiller AB Freon leak was witnessed by the NRC inspector. The NRC inspector reviewed the job from receipt of the CIWA by the maintenance mechanic, through the mechanic's disassembly and inspection of the pump out compressor, his written work order instructing the planner to contact the vendor for detailed information and replacement parts, the planner's purchase order for the spare parts, and the maintenance supervisor's commitment to reassemble and test the chille Upon disassembly of the electrical box on the pump out compressor, the mechanics found that an unused electrical connection had been improperly sealed with a fibrous plug, and a cardboard and plastic spacer. A telephone call to the compressor manufacturer indicated that a double locking nut connection should have been made. The licensee amended the CIWA to plug the connection as specified by the manufacturer. The licensee intended to correct only Chiller AB, although there are two other identical chillers at the plant.
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| , The NRC inspector had two concerns relating to this maintenance work. The first concern was that the technical manual for the pump-out compressor lacked sufficient detail to describe the correct electrical connection When the licensee started work, he determined that the technical manual did not provide sufficient detail to allow repairs to be made. When disassembly was completed, the manufacturer was called ar.d his advice was followed to make repairs. These licensee actions adequately addressed this concer A second concern was that the licensee did not intend to inspect the other two essential chillers unless a similar Freon leak occurred, at which time the licensee would follow the same corrective action. The licensee was asked to confirm that the unused electrical connections for each essential chiller pump out compressor has been properly plugged and ensure that preventive measures are in place to prevent recurrence of the Freon leak problem. The licensee's actions had no significant effect on safety. The components were safety-related. The licensee was not correcting a known common mode failure mechanism that affected 2 of 3 safety system The troubleshooting of a charging pump seal leak was followed by the NRC inspector. The NRC inspector witnessed the job from receipt of the CIWA by the mechanic, through the obtaining of spare parts, verification of the status of equipment tagged out, and clearance for access to the vital are The NRC inspector discontinued observations during seal replacement and functional testing because of work area health physics requirement The licensee determined that the root cause of the seal failure was deficient packing. No concerns were identifie _ _ _ _ - _ _ _ . _ . _ _ _ _ _ . _ _ . _ _ . . _ _ _ _ _ _ _ _ _ _ | |
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| .. . | | . To date there have been no instances of shorting devices found in breakers removed from service for maintenanc All of the Electrical Maintenance procedures which cover circuit breaker testing (ME-3-315, ME-3-325, ME-3-327, ME-3-330, |
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| | ME-4-111 ME-4-131, ME-4-143, ME-4-145, ME-4-146, ME-4-155, ME-7-100) have been reviewed and no similar deficiencies were foun , |
| | (3) Corrective Action To Be Taken j No further action deemed necessary w-(4) Date When Full Compliance Will Be Achieved - |
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| | Full compliance was achieved on April 8, 198 l |
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| The NRC inspector followed preventive maintenance of Type PSA-3 mechanical snubbers that was in progress. Licensee personnel used procedure MM-6-023, Revision 1. During work, the NRC inspector observed that several steps in MM-6-023 were not followed (for example, step:. 8.2.1.10, .11, and .12),
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| since they applied only to a major overhaul of the snubber. Prior approval to omit the steps had not been documented, or authorized by the maintenance supervisor. The mechanic's work was based on procedure MM-6-023, in general, plus " hands-on" experience gained from a snubber workshop held at the vendor's factory. Revision 1 of procedure MM-6-023 was verified to be the latest revision controlled by the document records departmen Discussions with the mechanic, supervisor, and planner indicated that the snubber procedure would be revised in the near futur The NRC inspector noted a weakness dealing with the administrative aspects of the above maintenance. As stated in the previous paragraphs, the mechanics did not perform several steps that the craftsmen knew or believed, were optional. This practice can result in an error and maintenance which is not approved. The NRC inspector's concern was that a junior mechanic was undergoing on-the-job training by a senior mechanic who did not follow the maintenance procedure as written. The licensee was asked to review procedures MM-6-023 and MM-7-11 and ensure that the appropriate steps are identified for performance of all levels of maintenance specified by these procedures. This review will ensure compliance with step 14 of Attachment 6.10 to Procedure MD-1-011, which indicates that an optional step in a maintenance procedure shall be clearly identified as suc . Licensee Instrumentation Maintenance Program The NRC inspector performed an inspection of the maintenance program in the instrument and control areas in accordance with Inspection and Enforcement Manual Section 62704 and the Waterford 3 Administrative Procedures. Maintenance history, calibration records, procedures, work item tracking forms, and maintenance work request forms were obtained and reviewed. Selected instrument and control supervisors and technicians of the I&C Maintenance Organization were interviewed to determine their areas of responsibilities, functions, and qualification Two work activities in progress were witnessed by the NRC inspector to determine if the technicians were following appropriate maintenance procedures. The two activities were: (1) MI-5-160, Revision 1, Calibration of Plant Protection System Test and Calibration Card and Digital Volt Meter (DVM), and (2) MI-3-350, Revision 5, Containment Purge Isolation Area Radiation Monitor Channel "A" or "B" Functional Test ARM-IR-5024S 50255, 5027 There were a number of discrepancies noted during the performance of these activitie The following are examples of procedures not being followed: Step 8.4 of MI-5-160 (Calibration of Plant Protection System Test and Calibration Card and DVM) indicated that the DVM should be turned on and set to Volt Direct Current (VDC) Auto with the "As Found" block to be filled in on Attachment 10.1. The technicians performing the
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| calibration understood this step to mean the test instrument and not the DVM being calibrated. An entry was not made in Attachment 1 for the DVM. The actions were not consistent with the procedure. It should be noted that the instruction was misleadingly vague, since it appeared to be applicable to the test instrument instead of the DVM which is constantly energized and does not have an " Auto" positio Step 8.28 of MI-5-160 required that a calibration sticker be attached to the DV Instead it was attached to the panel above the DV Step 8.1.1 of MI-3-350 (Containment Purge Isolation Area Radiation Monitor Channel "A" or "B" Functional Test (ARM-IR-5027S)) required a jumper to be used when the Containment Purge Isolation Valves are shut. Discussions with the technicians indicated that the jumper installation was not always performed. Operations personnel dictated jumper installation and decided whether or not a potential existed for the valves to be operated before testing was completed. The procedure does not allow this choice.
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| The second item found during work observations was that the procedures were in error in a number of step The following are examples where errors were noted: Step 8.19 of MI-5-160 indicated that both " Bistable Select" switches should be verified in the "Of f" position. Only one has an off position; the other has a line indicating of Step 8.20 of MI-5-160 indicated that the " Input Select" switch was to be set to " Input." The switch was not removed from or verified in the " Input" position at the start of the procedure. It is possible that the switch should have been verified in the " Input" position at the start of the procedure in order to ensure correct voltages, Step 8.3.4 of MI-3-350 indicated that the health physics technician was to be informed that the monitor was back in service. The procedure, however, does not require the health physics technician to be informed when it was removed from service. This was an omission from this procedure. The technician indicated that most of the other procedures had this requirement correctly identified. It should be noted that the I&C technician informed the health physics technician when the instrument was removed from service for testing, however, it was done as a normal practic The third item identified during work observations was that the procedures permitted specific or " equivalent" instruments to be used for performing a procedure. However, the licensee had not identified which instruments are equivalent to each other; nor was the basis for equivalency verified before testing was performed. This policy does not assure that instrument sensitivity requirements will be me _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ -
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| Examples found by the NRC inspector where one instrument was identified and another used were as follows: Procedure MI-5-160, Revision 1, Step 6.0, indicated a Fluke 8500A DVM was to be used. Instead, a health physics (HP) instrument was use Procedure MI-3-350, Step 6.0, indicated a Fluke 8600A Digital Multimeter was to be used. Instead, an HP instrument was use Documentation associated with ten completed maintenance activities was obtained and reviewed. The ten activities were: CIWA 028825, nitrogen pump level switch NG-ILS-3006 out of calibratio CIWA 025448, component cooling water to dry tower isolation valve low air pressure switch CC-IPS-3085B mounting repair CIWA 029024, charging pump AB spurious low suction pressure trip switch (CVC-MPMP0001AB) troubleshootin CIWA 025719, steam generator No. 1 pressure transmitter SG-IPT-1013A erratic output troubleshooting, CIWA 025913, boric acid condensate tank "B" level controller (BM-ILIC-0626) repai CIWA 022177, annunciator LO705 troubleshooting and repai CIWA 006276, SUPS IAB blown fuse F42 replacemen CIWA 023828, chill water pressure transmitter CHW-IPT-5011BS leaking vent plug replacement, CIWA 025452, containment spray flow transmitter CS-IFT-7122AS high flow indicatio CIWA 028099, boric acid condensate tank "B" level controller (BM-ILIC-0626) maintenanc The review of these completed items identified three areas of apparent weakness as follows:
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| The first area was a concern related to not identifying equivalent instruments. CIWA (Condition Identification Work Authorization)
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| 028825 (item a. above) identifies a 0-415 inches water column (INWC)
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| instrument to be used for calibration where an 0-830 INWC was use As stated previously, this does not ensure that necessary instrument sensitivities are me Another example was seen in CIWA-025448 (item b. above) where a 0-100 psi Heise test gauge and Fluke 8600A
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| DVM were identified for use as test equipment. Instead of using the identified equipment, a Helicoid 0-100 psi gauge and a Triplet meter were use *
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| The second weakness identified during review by the NRC inspector was that there appeared to be inconsistencies in the document review process. In CIWA 025719 (item d. above) Section D (corrective maintenance control section) was not filled out. CIWA 025913 (item e. above) identified one of the test instruments by manufacturer's name and not by its control numbe This does not permit easy traceabilit *
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| A third weakness was incomplete reviews as identified in CIWA 022177 (item f. above). On CIWA 022177, addendum page 11, it was indicated that plant engineering was to evaluate the acceptability of the switches used for initiating the alarm. It was not apparent that the review had been performed. No other weaknesses were noted during the
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| review of these maintenance documents. These concerns will be an open item (382/8628-03) to be reviewed generically during a subsequent inspectio . Licensee Electrical Maintenance Program The NRC inspector performed an inspection of the Maintenance Program in the electrical area. Maintenance history, work item tracking forms, maintenance work requests, qualification records, document control procedures, and replacement part control records were obtained and reviewed. Selected Electrical Maintenance Organization personnel (electrical supervisors and electricians) were interviewed to determine their areas of responsibilities, functions, and qualification Three maintenance action items were witnessed to ensure that the electricians performin0 the maintenance tasks followed the appropriate maintenance procedures. All three items involved the testing of HPCI Pump AB relays. Testing was performed in accordance with the following procedures:
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| ' ME-7-035, Revision 1, G.E. Auxiliary Relays, Models HGA11A through HGA11X ME-7-030, Revision 1 G.E. Auxiliary Relays Models HGA17A through HGA17T ME-7-033, Revision 1, G.E. Auxiliary Relay HGA14 The NRC inspector identified two areas of concern. The first concern involved test equipment. In maintenance procedure ME-7-035, Step 6.2.1, Doble equipment, or equivalent, was identified to be used to perform the testing. The technicians performing the job used Multiamp equipmen Equivalency was not determined. As stated previously, not determining equivalency or having an established equivalency list in advance fails to ensure that instrument sensitivities are acceptabl . _ _ _ . __-. --
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| The second concern related to the adequacy of the procedures. Step 7.0 of maintenance procedure ME-7-033 indicated that the acceptance criterion was for the relay to pick up at rated powe The rated power was not included as part of the documentation but was determined by the technician from memory. This practice does not assure that the testing is acceptabl Another example was seen in Step 8.3.1.1 of ME-7-033, where terminals 1 and 7 were to be used for continuity verification when the relay was energize These terminals were connected to spare contact The procedure did not provide for checking contacts actually in use. This practice does not provide assurance that the relay will provide the protection intende No other concerns were identified during work observation j Procedures and other documentation associated with the following 11 i completed electrical maintenance activities were reviewed: CIWA 027805, wet cooling tower fan 6A breaker (ACC-EBTR-315A12MS)
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| replacemen CIWA 027484, dry cooling tower fan 58 motor (CC-EMTR-315B-3F) lug repai CIWA 006299, diesel generator feeder breaker (EBKR-3A145) spring release interlock support repai CIWA 021284, flow transmitters CC-IF-5570AS and BS hydro-test validatio CIWA 004376, static uninterruptable power supply (SUPS) 3B-5 bypass ,
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| transformer firing board (ID-IDEN-PSM85) temporary modificatio l CIWA 004392, SUPS 3B-S Bypass transformer firing board ;
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| (ID-IDEN-PSM85) testing,
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| ' CIWA 005619, MCC 38213 and 38311 missing grommets (MCC-CABLE-GR0MS)
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| evaluation and repai .
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| CIWA 009388, all safety related motor operated valves inspection and
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| i CIWA 025125, reactor building purge exhaust fan E22 motor '
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| (HVRE-MTR-3A7AS) polarization index procedure revisio : CIWA 027249, cabinet C-24 temperature control (IC-ITC-3024) burnt wire repairs, CIWA 023669, fuel handling building flitration unit B heater
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| (HVFIHPL51148) troubleshooting and repair.
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| l 12 During the review of completed maintenance packages by the NRC inspector, one concern was identified. This involved document completion and review.
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| In CIWAs (025125, 02749, 023669, and 006299), Section D (Corrective Maintenance Controls Section) of the first page was not completed, or was filled out incorrectl These deficiencies in themselves were not highly I significant, however, they demonstrated a weakness in the final document I
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| review proces Three additional items were reviewed during review of the licensee's l
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| l The first item was the overcurrent testing of breakers important to safet This involved the concern that some breaker manufacturers
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| have specified that alternating current (AC) overcurrent testing be
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| performed only once in the lifetime of a circuit breaker, with
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| ! subsequent testing to be done using direct current (DC). The l licensee response to their concern indicated that it was applicable to one type of circuit breaker at Waterford. The breakers in question were tested using an AC test source, filtering the output through a rectifier bank when testing the breaker. The testing
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| l The second item was the replacement of Agastat time delay relays in emergency diesel generator sequencing circuits. The licensee was questioned about the use of qualified replacement relays. Procedures governing relay replacement were reviewed and found acceptabl *
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| The third item was the meggering (high voltage insulation test) for long installed runs of cables. The licensee's current practice is to megger cables at the circuit breakers. This practice is acceptable when cable runs are short. When the cable runs are long, the voltage drop in the cable could prevent a valid test of insulation breakdown l resistance. The licensee committed to reviewing this concern. This
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| will remain an open item (382/8628-04) to be reviewed during a subsequent inspectio . Exit Interview l
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| l The NRC inspector met with the NRC senior resident inspector and the l licensee representatives identified in paragraph 1 at the conclusion of I
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| the inspection on November 21, 198 The NRC inspector summarized the scope and findings of the inspection.
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217L0101999-10-18018 October 1999 Provides Update of Waterford 3 Effort for Review of Ufsar. Info Listed Includes Background Mgt Expectations,Review Status & Results,Clarifications Re Review & Conclusions ML20217L0141999-10-18018 October 1999 Submits Update to NRC Staff Re Circumstances & Plans for Submitting Certification Rept on Waterford 3 Plant Specific Simulator ML20217G7051999-10-14014 October 1999 Forwards Comments on Four of NRC RO Examination Questions for Exam Administered During Week of 991004 05000382/LER-1999-014, Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal1999-10-12012 October 1999 Forwards LER 99-014-00,providing Details of Reactor Shutdown Due to Loss of RCP Controlled bleed-off Flow.Attached Commitment Identification/Voluntary Enhancement Form Identifies All Commitments Contained in Submittal ML20217D5151999-10-0707 October 1999 Forwards Application for Renewal of SRO License for C Fugate License SOP-43039-3,IAW 10CFR55.57.Without Encls ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted 05000382/LER-1999-013, Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form1999-09-23023 September 1999 Forwards LER 99-013-00,providing Details of Exceeding TS Limits for RCS Cooldown Rates.All Commitments Contained in Submittal Are Identified on Encl Commitment Identification/ Voluntary Enhancement Form IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C2471999-09-16016 September 1999 Forwards Five Final Applications for RO Licenses for G Esquival,Jm Hearn,Md Lawson,Re Simpson & PI Wood.Written Exam & Operating Test to Be Administered,Is Requested. Encls Withheld ML20212C2391999-09-16016 September 1999 Requests Cancellation of SRO Licenses for Bn Coble,License SOP-43835,due to Job Assignment Location & CA Rodgers, License SOP-43537-1,due to Resignation from Company, Effective 990901 ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211P4121999-09-0707 September 1999 Requests NRC Staff Review & Approval of Integrated Nuclear Security Plan (Insp) & Integrated Security Training & Qualification Plan (Ist&Q), for Use by All Entergy Operations,Inc.Encl Withheld,Per 10CFR2.790(d) ML20211M8391999-09-0303 September 1999 Forwards Revised Epips,Including Rev 25 to EP-001-020,rev 24 to EP-001-030,rev 25 to EP-001-040,rev 30 to EP-002-100,rev 22 to EP-001-010,rev 27 to EP-002-010,rev 26 to EP-002-102 & Rev 16 to EP-002-190.Listed Proprietary Revs to Epips,Encl ML20211L3681999-09-0202 September 1999 Forwards Five Preliminary Applications for Reactor Operator Licenses for Individuals Listed,Iaw 10CFR55.31.Encls Withheld ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy 05000382/LER-1999-011, Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form1999-08-31031 August 1999 Forwards LER 99-011-00,providing Details of Reactor Shutdown Due to Loss of Controlled bleed-off Flow.All Commitments Contained in Submittal Identified on Attached Commitment Identification/Voluntary Enhancement Form ML20211M3641999-08-30030 August 1999 Forwards Written Examination,Operating Tests & Supporting Ref Matl Identified in Attachment 2 of ES-210,in Response to NRC .Encl Withheld ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211E3281999-08-26026 August 1999 Forwards fitness-for-duty Performance Data for Period of 990101-0630,IAW 10CFR26.71(d).Ltr Does Not Contain Commitments 05000382/LER-1999-009, Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately1999-08-26026 August 1999 Forwards LER 99-009-00 Re Discovery of Condition of Noncompliance with App R Involving Inadequate Separation of Essential Cables Routed in Fire Area RAB-30 in Rab. Compensatory Measures Were Established Immediately 05000382/LER-1999-010, Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form1999-08-26026 August 1999 Forwards LER 99-010-00,providing Details of Inadequate Pumping Capacity in Dry Cooling Tower Area.All Commitments Contained in Submittal Are Identified on Attached Commitment Identification Voluntary Enhancement Form ML20211F5421999-08-24024 August 1999 Forwards Proposed marked-up TS Page Xviii, Index Administrative Controls, Correcting Page Number Re TS Change Request NPF-38-220.Editorial Changes for TS Change NPF-38-221 Discussed ML20211F3561999-08-24024 August 1999 Forwards CTS Pages & TS Proposed marked-up Pages for Insertion Into TS Change Request NPF-38-207 Re Efas, Originally Submitted on 980702.Original NSHC Determination Continues to Be Applicable ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20211C5101999-08-19019 August 1999 Forwards Certified Copies of Liability Insurance Policy Endorsements Issued in First Half of 1999 for Each Entergy Operations,Inc Nuclear Unit,Per 10CFR140.15 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S0561999-08-12012 August 1999 Submits Voluntary Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for NRC Fys 2000 & 2001 for Waterford 3 ML20210Q6161999-08-12012 August 1999 Forwards Corrected Copy of Monthly Operating Rept for July 1999 for Waterford 3.Original Rept,Submitted with ,Contained Typos ML20217F2661999-08-12012 August 1999 Forwards Copy of 1999 Waterford 3 Biennial Exercise Package to Be Performed Using Waterford 3 CR Simulator ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams 05000382/LER-1999-008, Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl1999-07-29029 July 1999 Forwards LER 99-008-00,re Failure to Perform Testing of ESF Filtration Units Per TS Srs.Commitments Made by Util Also Encl ML20210H4291999-07-29029 July 1999 Forwards Response to NRC Rai,Associated with TS Change Request NPF-38-208,proposing to Replace Ref to Supplement 1 with Ref to Supplement 2 of Calculative Methods for CE Small Break LOCA Evaluation Model, in ACs Section of TSs ML20210F9451999-07-27027 July 1999 Forwards Proprietary & non-proprietary Version of Rev 29 to EPIP EP-002-100, Technical Support Ctr Activation,Operation & Deactivation. Proprietary Info Withheld,Per 10CFR2.790 ML20210D3171999-07-23023 July 1999 Submits Proposal for Final Resolution of Reracking Spent Fuel Pool at Plant,Per License Amend 144,issued by NRC in .No New Commitments Are Contained in Ltr 05000382/LER-1999-007, Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached1999-07-23023 July 1999 Forwards LER 99-007-00,providing Details of Operation Outside Tornado Missile Protection Licensing Basis for turbine-driven Emergency Feedwater Pump Exhaust Stack & Steam Supply Piping.All Commitments Identified on Attached ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations ML20209G9771999-07-13013 July 1999 Forwards Objectives & Guidelines for Waterford 3 Emergency Preparedness Exercise Scheduled for 991013.List of Objectives cross-referenced Where Applicable to Relevant Sections of NUREG-0654 IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20209D4051999-07-0707 July 1999 Forwards Revised TS Pages to Replace Attachment C,Entirely in Original TS Change Request NPF-38-207,per 990519 Discussion with C Patel of Nrc.Changes to Action 20 Delete Word Requirement & Revise Word Modes to Mode 1999-09-09
[Table view] Category:NRC TO UTILITY
MONTHYEARML20058E8621990-11-0101 November 1990 Forwards Understanding of Current Status of Unimplemented GSIs at Facility,Per 900626 Response to Generic Ltr 90-04. Timely Completion of Encl GSIs Urged ML20058G1561990-10-31031 October 1990 Requests That Matl Listed in Encl 1, Ref Matl Requirements for Reactor/Senior Reactor Operator Licensing Exams, Be Furnished by 901207 for Retake of Operating Exams Scheduled for 910122 ML20058B3101990-10-23023 October 1990 Forwards Insp Rept 50-382/90-22 on 900905-1001 & Notice of Violation IR 05000382/19900231990-10-17017 October 1990 Submits Revised Schedule for Electrical Distribution Sys Functional Insp 50-382/90-23.Insp Team Will Arrive at Plant Site on 910107 ML20058B2681990-10-17017 October 1990 Informs That Util Response to Generic Ltr 90-03, Relaxation of Staff Position in Generic Ltr 83-28,Item 2.2 Part 2, 'Vendor Interface for Safety-Related Components,' Acceptable ML20058A6711990-10-16016 October 1990 Forwards Insp Rept 50-382/90-21 on 900910-14.No Violations or Deviations Noted ML20058A4771990-10-16016 October 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-17 ML20062B6231990-10-12012 October 1990 Confirmation of Action Ltr CAL-90-06,confirming That Plant Will Not Enter Mode 2 Until NRC Confirms Actions Assuring That Adequate Safety Exists for Continued Power Operation IR 05000382/19900151990-10-11011 October 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-15.NRC Unable to Clearly Determine Actions Intended to Address Overall Retest & Program Weaknesses ML20059N7041990-10-10010 October 1990 Ack Receipt of Util 900717 Response to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount ML20059K8651990-09-14014 September 1990 Forwards Interfacing Sys LOCA Insp Rept 50-382/90-200 on 900730-0810.Deficiencies in Availability of Design Calculations,Check Valve Maint & Plant Equipment Labeling Noted ML20059K3601990-09-14014 September 1990 Ack Receipt of Scenario for 1990 Emergency Preparedness Exercise ML20059D5901990-08-28028 August 1990 Forwards Insp Rept 50-382/90-17 on 900625-29.No Violations or Deviations Noted.Exercise Weakness Re Performance of Emergency Responders Noted ML20056B4841990-08-22022 August 1990 Forwards Errata to Amend 62 to License NPF-38,consisting of Revised Bases Page Re Time Intervals for Surveillance Requirements,Per 900717 Application & Generic Ltr 89-14 ML20056B2731990-08-16016 August 1990 Ack Receipt of 900720 & 0803 Ltrs Re Objectives & Guidelines for Annual Emergency Preparedness Exercise.Objectives Appear Reasonable.Exercise Scenario & Associated Matls Should Be Submitted at Least 60 Days Prior to Exercise for NRC Review ML20058P3441990-08-15015 August 1990 Advises That Although Adequate Info Provided to Justify Continued Plant Operation Until Plant Completes Final Rept Per Schedule Delineated by NRC Bulletin 88-11,adequate Bases Not Provided for 40-yr Plant Life ML20056A0301990-07-30030 July 1990 Forwards Insp Rept 50-382/90-11 on 900625-29.No Violations or Deviations Noted IR 05000382/19900021990-07-27027 July 1990 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/90-02 ML20055G7951990-07-19019 July 1990 Forwards Insp Rept 50-382/90-14 on 900625-29 & Notice of Violation.Actions Taken Re Previously Identified Insp Findings Also Examined ML20055E6501990-07-0909 July 1990 Discusses Generic Implications & Resolutions of Control Element Assembly (CEA) Failures at Maine Yankee.Waterford Unit 3 Does Not Have Old Style CEAs Installed in Reactor Core & Does Not Plan to Use Any in Future ML20055C9751990-06-26026 June 1990 Forwards Page 6a for Insertion in Insp Rept 50-382/90-09 ML20055C7781990-06-15015 June 1990 Forwards Insp Rept 50-382/90-09 on 900501-31.No Violations or Deviations Noted.One Unresolved Item Identified.Licensee Test Acceptance Criteria Did Not Appear to Account for Effect of Flow on Valve Closing Time ML20059M9171990-06-13013 June 1990 Forwards NRC Performance Indicators for First Quarter 1990. W/O Encl ML20055C4121990-03-0202 March 1990 Ack Receipt of & Check for $50,000 in Payment for Civil Penalty Imposed by NRC 900202 Order.Corrective Actions Will Be Examined During Future Insp ML20055C2991990-02-23023 February 1990 Advises That 890410 Changes to Emergency Plan,Acceptable ML20248G1871989-10-0202 October 1989 Forwards Insp Rept 50-382/89-25 on 890828-0901.No Violations or Deviations Noted ML20248C6531989-09-27027 September 1989 Forwards Insp Rept 50-382/89-23 on 890801-31.Violations Noted.Enforcement Conference Scheduled for 891011 in Region IV Ofc to Discuss Violation,Reason for Occurrence & Corrective Actions ML20248A4091989-09-26026 September 1989 Requests That Jl Pellet Be Removed from Distribution for Controlled Documents Updates & Revs ML20247Q4211989-09-22022 September 1989 Provides Results of Review of Amend to Rev 5 of Inservice Testing Program for Pumps & Valves.Amend to Rev 5 Acceptable for Implementation & That Testing Requirements Impractical for Item for Which Relief Being Granted ML20247R5681989-09-21021 September 1989 Forwards Amend 4 to Indemnity Agreement B-92,reflecting Changes to 10CFR140, Financial Protection Requirements & Indemnity Agreements, for Signature ML20247J6851989-09-15015 September 1989 Forwards Insp Rept 50-382/89-16 on 890717-21 & Notice of Violation ML20247D4781989-09-11011 September 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-05 ML20247F2211989-09-0808 September 1989 Forwards SER Accepting Util 881007,890203,0301 & 0717 Ltrs Re Compliance W/Atws Rule 10CFR50.62 ML20247H8501989-09-0808 September 1989 Ack Receipt of 890531 & 0821 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-07. NRC Disagrees W/Licensee Denial of Violation.Implementation of Corrective Actions Will Be Reviewed During Future Insp ML20246P6081989-09-0606 September 1989 Forwards Summary of 890712 Meeting w/C-E Owners Group & Utils Re General Design Features of Diverse ESFAS to Be Installed,Per 10CFR50.62.Safety Evaluation on Plant Design Expected to Be Issued in Near Future ML20246N3131989-08-31031 August 1989 Ack Receipt of Re Violations Noted in Insp Rept 50-382/89-08 & 890516 Notice of Violation.Requests Supplemental Response Re Examples 1-3 of Notice ML20247A5841989-08-30030 August 1989 Forwards Summary of Region Iv/Senior Util Executive Meeting on 890818.Agenda & List of Attendees Also Encl ML20246M6491989-08-29029 August 1989 Forwards Amend 56 to License NPF-38 & Safety Evaluation. Amend Increases Frequency of Channel Calibrs from Quarterly to Monthly on Waste Gas Holdup Sys Explosive Gas Monitoring Sys ML20245J0021989-08-14014 August 1989 Confirms 890808 Conversation W/Rp Barkhurst Re Util Participation in NRC Impact Survey Scheduled for 891010 & Submits Info Re Survey ML20245L3311989-08-11011 August 1989 Forwards Insp Rept 50-382/89-22 on 890701-31 & Notice of Violation IR 05000382/19890121989-08-11011 August 1989 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-12.Excluding Incident 1,Violation 382/8912-02 Should Stand as Cited. Response W/Corrective Actions Requested within 30 Days ML20245J2451989-08-0909 August 1989 Advises That Requalification Exams Scheduled for Wk of 890911 Changed to Wk of 890905 to Accommodate New INPO Schedule Issued in May 1989 IR 05000382/19890051989-07-31031 July 1989 Discusses Insp Rept 50-382/89-05 on 890213-17 & Forwards Notice of Violation.No Addl Info Was Provided to Change NRC Position & Therefore Util in Violation of Requirements.Basis for NRC Determination of Violation Provided IR 05000382/19890061989-07-28028 July 1989 Ack Receipt of 890706 Supplemental Response Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/89-06 1990-09-14
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217L0421999-10-21021 October 1999 Forwards Insp Rept 50-382/99-20 on 990815-0925 & Notice of Violation.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217N2111999-10-19019 October 1999 Forwards Insp Rept 50-382/99-14 on 990913-17 & 1004-08.No Violations Noted.Licensed Operator Requalification Program, Effective,Utilized Systems Approach to Training & Showed Continued Improvements Over Previous Insp Findings ML20217C6251999-10-0505 October 1999 Informs That NRC Reviewed Util Ltr & Encl Exercise Scenario Package for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Based on Review,Nrc Determined That Exercise Appropriate to Meet Objectives ML20212J6921999-09-29029 September 1999 Forwards Insp Rept 50-382/99-18 on 990830-0902.One Noncited Violation Identified Re Failure to Follow Procedural Instructions to Ensure That Members on Fire Brigade Shift Were Qualified ML20216G2441999-09-27027 September 1999 Forwards Insp Rept 50-382/99-19 on 990830-0903.No Violations Noted IR 05000382/19993011999-09-21021 September 1999 Informs That NRC License Exam Previously Associated with NRC Insp Rept 50-382/99-301 Will Be Incorporated Into NRC Insp Rept 50-382/99-14 ML20212D8761999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of Waterford 3.During Assessment Period,Number of Personnel Errors Occurred,Which Demonstrated Lack of Attention to Detail by Plant Personnel.Historical Listing of Issues,Encl ML20212C5881999-09-14014 September 1999 Forwards Insp Rept 50-382/99-15 on 990719-23 with Continuing in Ofc Insp Until 0819.No Violations Noted ML20211Q4421999-09-0909 September 1999 Forwards Insp Rept 50-382/99-07 on 990601-11.Three Violations Being Treated as Noncited Violations ML20211K9741999-09-0101 September 1999 Forwards Insp Rept 50-382/99-16 on 990704-0814.Two Severity Level IV Violations Identified & Being Treated as Noncited Violations,Consistent with App C of Enforcement Policy ML20211G5751999-08-27027 August 1999 Forwards RAI Re IPEEE Submittal.Please Provide RAI within 60 Days of Receipt of Ltr,Per Util Response to GL 88-20,suppl 4 ML20211F4611999-08-24024 August 1999 Informs That NRC Reviewed Ltr & Encl Objectives for Waterford 3 Emergency Plan Exercise Scheduled for 991013.Exercise Objectives Appropriate to Meet Emergency Plan Requirements ML20211G1731999-08-23023 August 1999 Informs That Info Submitted in ,B&W Rept 51-1234900-00,will Be Withheld from Public Disclosure,Per 10CFR2.790 ML20210T9791999-08-18018 August 1999 Discusses Which Responded to Reconsideration of Violation Denial (EA 98-022) Enforcement Action Detailed in .Concludes That Violation Occurred as Stated ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210R9231999-08-11011 August 1999 Forwards Insp Rept 50-382/99-10 on 990719-23.Violations Noted.Nrc Has Determined That One Severity Level IV Violation of NRC Requirements Occurred ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210D8701999-07-23023 July 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Plan Requests for Relief ISI-018 Through ISI-020 for Entergy Operations,Inc,Unit 3 ML20210B1521999-07-15015 July 1999 Forwards Insp Rept 50-382/99-13 on 990523-0703.Three Violations Being Treated as Noncited Violations IR 05000382/19990081999-07-12012 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-08 Issued on 990503 ML20209E5231999-07-0909 July 1999 Informs That as Result of NRC Review of Util Responses to GL-92-01,rev 1 & Suppl 1,staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.This Closes Staff Efforts Re TAC MA0583 ML20196E6931999-06-22022 June 1999 Forwards Corrected Ltr Re Changes to Rev 19 to Emergency Plan.Original Ltr Had Error in Subject Line ML20196E0831999-06-21021 June 1999 Forwards Insp Rept 50-382/99-12 on 990524-27.No Violations Noted.Purpose of Insp Was to Conduct Assessment of Emergency Preparedness Program ML20196D9941999-06-18018 June 1999 Forwards Insp Rept 50-382/99-11 on 990524-28.No Violations Noted ML20195J8091999-06-17017 June 1999 Forwards Safety Evaulation Re First 10-yr Interval Inservice Insp Relief Request for Plant,Unit 3 ML20196C8711999-06-15015 June 1999 Discusses Insp Rept 50-382/99-08 & Forwards Notice of Violation Re Unescorted Access Which Was Mistakenly Granted to Individual Whose Background Investigation Indicated That He Had Failed Prior Drug Screening with Another Employer ML20196F3721999-06-0909 June 1999 Corrected Ltr Forwarding Rev 19 to Emergency Plan ML20195G3711999-06-0909 June 1999 Ack Receipt of Ltr Dtd 981223,which Transmitted Waterford 3 Steam Electric Station Emergency Plan,Rev 24,under Provisions of 10CFR50,App E,Section V.No Violations of 10CFR50.54(q) Identified During Review ML20207E8541999-06-0303 June 1999 Forwards SE Accepting Licensee 990114 Submittal of one-time Request for Relief from ASME B&PV Code IST Requirements for Pressurizer Safety Valves at Plant,Unit 3 ML20207G3441999-06-0303 June 1999 Forwards Insp Rept 50-382/99-09 on 990411-0522 & Notice of Violation.One Violation Identified & Being Treated as Noncited Violation C ML20207D3771999-05-27027 May 1999 Ack Receipt of 990401 & 0504 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/99-01 on 990303 ML20207A5121999-05-24024 May 1999 Refers to Which Responded to NOV & Proposed Imposition of Civil Penalty Sent by .Violations A,B & E Withdrawn & Violations C & D Changed to Severity Level IV ML20206U7851999-05-18018 May 1999 Forwards Insp Rept 50-382/99-06 on 990405-09.Three Violations of NRC Requirements Occurred & Being Treated as non-cited Violations ML20206N6961999-05-11011 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization, Division of Licensing Project Management Created ML20206S4411999-05-10010 May 1999 Forwards Insp Rept 50-382/99-05 on 990228-0410.Three Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20206H3841999-05-0707 May 1999 Informs That on 990407,NRC Administered Generic Fundamental Exam Section of Written Operator Licensing Exam.Licensee Facility Did Not Participate in Exam,However Copy of Master Exam,With Answer Key,Encl for Info.Without Encl ML20206K0951999-05-0606 May 1999 Discusses Insp Rept 50-382/99-08 Issued 990503 Without Cover Ltr Documenting EA Number & Subject Line Indicated NOV Which Was Incorrect.Corrected Cover Ltr Encl ML20206F4701999-05-0303 May 1999 Forwards Insp Rept 50-382/99-08 on 990405-07.One Apparent Violation Re Failure to Review & Consider Derogatory Access Authorization Background Info as Required by PSP Identified & Being Considered for Escalated Enforcement Action ML20206K1211999-05-0303 May 1999 Corrected Cover Ltr Forwarding Insp Rept 50-382/99-08 on 990405-07.One Violations Noted & Being Considered for Escalated EA ML20205N7251999-04-13013 April 1999 Forwards Summary of 990408 Meeting with EOI in Jackson, Mississippi Re EOI Annual Performance Assessment of Facilities & Other Issues of Mutual Interest.List of Meeting Attendees & Licensee Presentation Slides Encl ML20205M0561999-04-0909 April 1999 Forwards Insp Rept 50-382/99-04 on 990301-19.One Violation of NRC Requirements Occurred & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20205J8781999-04-0505 April 1999 Forwards Insp Rept 50-382/99-02 on 990117-0227.No Violations Noted.Inspectors Determined That Six Violations Occurred & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy ML20205J0901999-04-0202 April 1999 Informs That Info Submitted by & 970313 Affidavit Will Be Withheld from Public Disclosure,Per 10CFR2.790(b) (5) ML20205A4681999-03-26026 March 1999 Forwards Insp Rept 50-382/99-03 on 990308-12.Two Violations of Radiation Protection Requirements Occurred & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20205A6141999-03-25025 March 1999 Forwards SE Accepting Request to Use Mechanical Nozzle Seal Assemblies (Mnsas) as an Alternative Repair Method,Per 10CFR50.55a(a)(3)(i) for Reactor Coolant Sys Application at Plant,Unit 3 ML20205F3311999-03-19019 March 1999 Advises of Planned Insp Effort Resulting from Plant,Unit 3 PPR Review,Which Was Completed on 990211.Performance at Plant,Unit 3 Was Acceptable ML20204E4941999-03-17017 March 1999 Discusses TSs Bases Change Re 3/4.4.1,3/4.6.1.7,3/4.6.3, 3/4.7.12 & 3/4.8.4.Forwards Affected Bases Pp B 3/4 4-1, B 3/4 6-3,B 3/4 6-4,B 3/4 7-7 & B 3/4 8-3 ML20207F1251999-03-0303 March 1999 Forwards Insp Rept 50-382/99-01 on 990125-29 & 0208-12 & Notice of Violations ML20203H8501999-02-17017 February 1999 Forwards SE Accepting Licensee 970701 Submittal of Second Ten Year ISI Program & Associated Relief Request for Plant, Unit 3.Nine Relief Requests Had Been Authorized Previously & Proposed Alternatives Remain Authorized ML20203D7211999-02-11011 February 1999 Forwards Request for Addl Info Re Licensee 970317 & 990111 Responses to GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. Response Should Be Provided within 60 Days 1999-09-09
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. 9 3 In Reply Refer To:
Docket: 50-382/86-28 M gg Louisiana Power & Light Company ATTN: J. G. Dewease, Senior Vice President Nuclear Operations N-80 317 Baronne Street New Orleans, Louisiana 70160 Gentlemen:
Thank you for your letter of April 16, 1987, in response to our letter I and Notice of Violation dated March 17, 198 We have reviewed your reply and !
find it responsive to the concerns raised in our Notice of Violation. We acknowledge that your Procedure UNT-5-004, Revision 3, may be limited in scope
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to installed equipment and therefore was not specifically violated; however, 1
the failure of your Procedure ME-7-002, Revision 5 to assure proper restoration of equipment following a bench test is still in violation of the requirements of 10 CFR 50, Appendix B, Criterion V to provide documented procedures of a type appropriate to the circumstance We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine
Sincerely,
.Dricinal Signed by:
R.E.HALU J. E. Gagliardo, Chief Reactor Projects Branch cc:
Louisiana Power & Light Company ATTN: G. E. Wuller, Onsite Licensing Coordinator P. O. Box B Killona, Louisiana 70066 RIV:RSB/0S y)Y OS gg RSB
/N RPB JRBoardman:gt DMHunnicutt TFWesterman gJEGagliardo 7 / 1 /87 ]/)/87 1/t/87 7/(/87
?Dk 3 670702 F l0$[K 05000382PDR I
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. 1 -4 Louisiana Power & Light Company 2
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Louisiana Power & Light Company ATTN: N. S. Carns, Plant Manager P. O. Box B 1 Killona, Louisiana 70066 1
. Middle South Services ATTN: Mr. R. T. Lally l P. O. Box 61000 ! '
New Orleans, Louisiana 70161 Louisiana Power & Light Company ATTN: K. W. Cook, Nuclear Safety and Regulatory Affairs Manager 317 Baronne Street P. O. Box 60340 ;
New Orleans, Louisiana 70160 i
Louisiana Radiation Control Program Director I i
bec to DMB (IE01)
bcc distrib. by RIV: .
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- SectionChief(RPB/A) DRSP RPSB *RSB
- MIS System * Project Inspector, RPB
- RIV File NRR Project Manager
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LO UlSI POWE R & AN L1GHTA / 317 NEWBARONNE
STREET ORLEANS, LOUISlANA P. O BOX 60340 70160 * (504) 595 3100 U1'sl$ES SE April 16, 1987 ?
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W3P87-1010 A4.05 QA
' % Fu; . l U.S. Nuclear Regulatory Commission L M \~- :p!":I }li ATTN: Document Control Desk ;j
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ll Washington, D.C. 20555 ~
g 2 l jgp i r i L i Subject: Waterford 3 SES I Docket No. 50-382
, License No. NPF-38 NRC Inspection Report 86-28
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Attached is the Louisiana Power and Light Company (LP&L) y,esponse to Violation No. 8628-01 identified in Inspection Report No. 86-2 If you have any questions on the response, please contact G.E. Wuller, Operational Licensing, at (504) 464-349 l l
l Very truly yours, C
oY l A h K.W. Cook Nuclear Safety and Regulatory Affairs Manager T( y s
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KWC:KLB:ssf .
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\ cu cc: R.D. Martin, NRC Region IV s G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR V'
g NRC Resident Inspectors Office ,
E.L. Blake
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W.M. Stevenson s'
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,_ g "AN EOUAL OPPORTUNITY EMPLOYER"
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Attcch2:nt to W3P87-1010
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Sheet 1 of 2
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LP&L Response To Violation No. 8628-01 1 VIOLATION No. 8628-01 Failure to Follow Procedures for Control of Temporary Modifications 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be accomplished in accordance with approved procedures. ANSI N18.7-1976, to which the licensee is committed, Section 5.2.2, requires that procedures shall be followed. Licensee Procedure UNT-5-004, Revision 3, " Administrative Procedure Temporary Alteration Control, identifies specific requirements for the control and restoration of tcmporary modifications. This procedure specifies that procedures requiring temporary modifications shall either appropriately reference UNT-5-004, or contain the specified controls for temporary modification Contrary to the above, the NRC inspector on November 19, 1986, identified that licensee Procedure ME-7-002, Revision 5 " Maintenance Procedure Molded-Case Circuit Breakers and Thermal Relays," did not contain required
,. controls for temporary removal and replacement of current limiting fuses during performance testing of the circuit breakers, nor reference UNT-5-00 .
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This is a Severity Level IV violatio RESPONSE (1) Reason for the Violation This violation cites procedure ME-7-002, Molded Case Circuit Breakers and Thermal Relays, "for not containing required controls for temporary alterations as specified by UNT-5-004, Temporary Alteration control". Although ME-7-002. inadvertently omitted steps that would ensure proper restoration of equipment to its design operating condition, we do not feel that it viol'ated UNT-5-004. UNT-5-004 is a procedure written to control temporary alterations to existing, installed, operational plant equipment. ME-7-002 is a procedure which removes a piece of equipment and bench tests it. Temporary changes,
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modifications, disassembly or reassembly of the equipment once removed from the plant is not considered a temporary alteration and should not fall under the requirements of UNT-5-004. Nonetheless, procedures controlling maintenance in these situations must be adequate to ensure complete and proper restoration of equipment; this is the area in which ME-7-002 was deficien (2) Corrective Action That Has Been Taken ME-7-002 has been revised to require removal of any shorting alocks that could have been previously installed, re-installation of fuses and independent verification of the came. The possibility that shorting devices could have been left in breakers previously tested by this procedure has also been considered. We are confident that this is not the case based on the following:
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. W3P87-1010
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Sheet 2 of 2 !
. Section 8.6 (Thermal Element Time Delay Test) of ME-7-002 did ,
contain a note requiring removal of shorting devices and j re-installation of fuses. Section.8.6 is required each'tima the breaker is teste (Section 8.5, Instantaneous Trip-Test, had no such provisions, but is only required on newly installed breakers.)
. To date there have been no instances of shorting devices found in breakers removed from service for maintenanc All of the Electrical Maintenance procedures which cover circuit breaker testing (ME-3-315, ME-3-325, ME-3-327, ME-3-330,
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ME-4-111 ME-4-131, ME-4-143, ME-4-145, ME-4-146, ME-4-155, ME-7-100) have been reviewed and no similar deficiencies were foun ,
(3) Corrective Action To Be Taken j No further action deemed necessary w-(4) Date When Full Compliance Will Be Achieved -
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Full compliance was achieved on April 8, 198 l
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