ML20135D940

Insp Rept 50-483/97-03 on 970105-0215.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support

ML20135D940
Person / Time
Site:	Callaway
Issue date:	02/28/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135D928	List: ML20135D925 ML20135D931 ML20135D940
References
50-483-97-03, 50-483-97-3, NUDOCS 9703060127
Download: ML20135D940 (14)

See also: IR 05000483/1997003

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ENCLOSURE 2 ,

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV i

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Docket No.: 50-483 l

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License No.: NPF-30  ;

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Report No.: 50-483/97-03 i

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Licensee: Union Electric Company  !

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Facility: Callaway Plant l

Location: Junction Highway CC and Highway O

Fulton, Missouri 1

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Dates: January 5 through February 15,1997 )

Inspectors: D. G. Passehl, Senior Resident inspector

F. L. Brush, Resident inspector -

Approved By: W. D. Johnson, Chief, Project Branch B

ATTACHMENT: Supplementallnformation

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9703060127 970228 i

PDR ADOCK 05000483 i

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EXECUTIVE SUMMARY

! Callaway Plant

NRC Inspection Report 50-483/97-03

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Operations

• Control room operator shift turnovers and briefings were good (Section 01.1).

• Operator response to a main condenser circulating water tube leak was good

(Section 01.2).

• The inspactors identified a violation involving the licensee's f ailure to properly

document overtime excesses as required by procedure (Section 06.1).

Maintenance

• A maintenance task in the reactor containment building at full power was well ,

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planned and executed (Section M4.1).

• A noncited violation was identified when the licensee discovered that preventive

maintenance work packages for safety-related equipment were not performed by

their late date (Section M8.2).

Enaineerina

• The licensee's response to a 10 CFR Part 21 notification on pressure transmitters

was prompt and thorough (Section E4.1).

Plant Suocort

• Housekeeping in the liquid radwaste evaporator room was poor (Section R2.1).

• The degree to which the licensee corrected previously identified discrepancies in the

radwaste building was mixed (Section R2.1).

• Health physics briefings and coverage of the maintenance work in the reactor

containment building, at full power, were good (Section R4.1).

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Report Details

Summary of Plant Status

The plant was at 100 percent power throughout muah of the report period.

On February 14,1997, the licensee reduced plant power to 30 percent when the level of

steam generator sulfates increased following a main condenser tube leak. The licensee

was returning the plant to full power operation at the end of the report period.

I. Operations

01 Conduct of Operations

01.1 Control Room Shif t Chanaes (71707)

The inspectors observed various control room operator shift changes and briefings

using Procedure ODP-ZZ-00003," Shift Relief and Turnover," Revision 14. The

oncoming operators properly walked down the panels, performed annunciator

checks, read the control room operator logs, and discussed the plant status with the

off-going operators.

The shift supervisors conducted thorough bnefings with the oncoming operators.

The topics included operator assignments, any equipment problems, and scheduled

surveillance and maintenance activities.

The inspectors did not note any problems with the turnovers and briefings.

01.2 Operator Resoonse to a Main Condenser Tube Rupture

a. Insoection Scoce (71707)

The inspectors reviewed the operator response to a main condenser circulating

water tube leak and the subsequent plant power reduction.

b. Observations and Findinas

On February 14,1997, control room operators received an annunciator alarm from

the plant chemistry cold laboratory. The cold laboratory was used for

nonradiological water chemistry analysis. The operators immediately contacted the

onshift chemistry technician. The technician determined that a main condenser tube

leak was occurring in Pass 4 of the circulating water system. Equipment operators

immediately isolated the leak.

As a result of the tube leak, Steam Generator A sulf ates exceeded 100 parts per

billion. This placed the plant in Action Level 2 per Procedure APA-ZZ-01021,

" Secondary Chemistry Program," Revision 10. The operators reduced plant power

to 30 percent as required by the procedure. The licensee plugged the affected

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tubes and returned Pass 4 to service. After steam generator sulfate levels returned

to normal, the operators commenced raising plant power. l

c. Conclusions

! The inspectors concluded that the operators took prompt and appropriate actions to

minimize the effect of the tube leak on the plant.

O2 Operational Status of Facilities and Equipment

O 2.1 Enoineered Safety Feature System Waikdowns (71707_)

The inspectors used Inspection Procedure 71707 to walk down accessible portions

of the following engineered safety features and vital systems

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• Motor-Driven Auxiliary Feedwater Pump Trains A and B;

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• Turbine-Driven Auxiliary Feedwater Pump and Associated Components; i

{ * Emergency Boration Trains A and B;  !

+ 125 Vdc and 120 Vac Vital Power Supply Systems; and l

) * Containment Spray Trains A and B. )

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Equipment operability, material condition, and housekeeping were acceptablein all  ;

cases. Some minor discrepancies were brought to the licensee's attention and l

corrected. The inspectors did not identify any substantive concerns as a result of

these walkdowns.

5 O 2.2 Plant Tours i

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l The inspectors toured portions of the auxiliary, diesel, fuel, containment, and

turbine buildings, as well as the essential service water pump house and the

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ultimate heat sink cooling tower structure. Overall material condition of equipment

in these buildings was good.

j The inspectors noted some oil and water leaks on various pieces of equipment.

The leaks the inspectors noted had already been identified and tagged with

condition tags by the licensee. An additional tag was placed on some components,

as part of a new leak tracking program. The additional tags were intended to

eventually replace condition tags for oil leaks and dry boron deposits. The licensee

stated that the program may be expanded to include other types of leaks.

The new tags would be removed by the system engineer when cleaning is no longer

required or replaced with a condition tag if repair is required. The tags were

intended to allow system engineers to identify how often a component is being

cleaned. The tags have an initial and date block for each cleaning that is performed.

The tags would be tracked by the licensee's work control system.

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The inspectors determined that, if used as intended, the new tags should enhance

materialcondition of the plant.

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06 Operations Organization and Administration

i 06.1 Operations Workina Hours Review

a. Inspection Scope (71707)

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The inspectors reviewed the use of overtime by operations department personnel to

l verify consistency with regulatory requirements.

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b. Observations and Findinos

i The inspectors reviewed the hours worked by licensed operators from December 1

! through 8,1996. This covered the period during a forced outage to repair hydraulic

oil leaks on the actuator for feedwaterisolation Valve D. The working hours were

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governed by Technical Specification 6.2.2.f and Administrative

Procedure APA-ZZ-00905," Limitations of Callaway Plant Staff Working Hours,"

i Revision 3.

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The inspectors assessed the licensee's compliance with Procedure APA-ZZ-OO905

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by reviewing time cards for all 12 licensed operators assigned to the reactor

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operator and balance-of-plantoperator positions. The inspectors then reviewed

" Request to Exceed NRC Overtime Restrictions" forms to determine if overtime ir.

i excess of the limits was properly authorized and documented.

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The inspectors found that two individuals exceeded Procedure APA-ZZ-00905

overtime limits by working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48-hour period. Both

j excesses were without evidence of prior authorization and documentation.

Specifically:

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• On December 4 and 5,1996, Operator A worked 27.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in a 48-hour

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• On December 5 and 6,1996, Operator B worked 26.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> in a 48-hour

period.

Administrative Procedure APA ZZ 00905," Limitations of Callaway Plant Staff l

Working Hours," Revision 3, Step 3.2, required that deviations from working hour

restrictions be approved by the Manager, Callaway Plant, or the Emergency Duty

Officer. Step 3.2 further stated that individuals requesting deviation shall document

the request on the " Request to Exceed NRC Overtime Restrictions" form prior to

exceeding the overtime restriction. Failure to obtain approval for the operator

overtime excesses is a violation (50-483/9703-01).

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c. Conclusions

The inspectors concluded that the licensee had not effectivelyimplemented its

policy governing the work hours of the operations department staff.

08 Miscellaneous Operations issues

08.1 (Closed) Licensee Event Report 50-483/96003: Auxiliary Feedwater Actuation After

Main Feedwater Pumo Trio

On October 12,1996, an engineered safety features system actuation occurred.

Main feedwater Pump A tripped and both motor-driven auxiliary feedwaterpumps

started. The plant was in Mode 3 at the time. All systems responded as expected.

Prior to the trip of main feedwater Pump A, operators were performing control rod

drop time testing. The feedwater system had been aligned to support the rod drop

testing with main feedwaterPump A running in the recirculation mode. Residual

heat in the feedwater preheating system caused pressure at the discharge of main

feedwater Pump A to increase to the engineered safety features actuation setpoint.

The licensee's corrective actions included revising the following procedures to

require blocking the auxiliary feedwater actuation signal after entering Mode 3:  ;

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• ETP-SF-ST001 - Control Rod Drop Time Test, Revision 0; j

• ODP-ZZ-00014- Operational Mode Change Requirements, Revision 13; and

• OTG-ZZ-00005- Plant Shutdown 20 Percent Power to Hot Standby,

Revision 12.

The licensee' walked down the high pressure heater string and found no damage.

The licensee intended to upgrade the control room simulator to model the event.

The inspectors reviewed the licensee's corrective actions and consider this item

closed.

08.2 (Closed) Licensee Event Report 50-483/96004: Manual Reactor Trio Durino Rod

Droo Testina Followina a Diaital Rod Position Indication System Failure

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On November 11,1996, the reactor operators initiated a manual reactor trip in

accordance with plant procedures following the loss of digital rod position indication i

for Control Rod M4. The loss of indication occurred during additional rod drop

testing following the 1996 refueling outage.

The licensee determined that worn pins in an Amphenol connector caused the loss

of position indication. The licensee repaired the pins and replaced the Amphenol

connector. The licensee later determined that plant Technical Specifications did not

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l require operators to trip the plant if digital rod position indication for one control rod

is lost while in Mode 3. The licensee intended to change Procedure ESP-ZZ 0020,

" Rod Position Indication Checkout," Revision 6, to direct the operators to manually

insert the control rods if position indication is lost on a control rod while in Mode 3.

There were no rod position indication problems during the remainder of the testing. -l

] The inspectors have no further concerns with this item and consider it closed. '

11. Maintenance

M1 Conduct of Maintenance

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M 1.1 General Comments - Maintenance

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a. Inspection Scoce (62703)

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The inspectors observed all or portions of the following work activities

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• Work Activity W182847- Repair Position Indication on Safetyinjection

System Test Line Isolation Valve EMHV8871:

1 * Work Activity W184400- Troubleshoot Ammeter Indication on 125 VDC ,

Swing Battery Charger B; I

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• Work Activity P556217- Clean Tubes on Residual Heat Removal Pump Room

Cooler B; and

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• Work Activity W593975- Replace Steam Generator C Power Operated Relief

j Valve Actuator Diaphragm.

j b. Observations and Findinos

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I The inspectors found the work performed under these activities to be professional

j and thorough. All work observed was performed with the work packages present

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and in active use. The inspectors frequently observed supervisors and system

engineers monitoring job progress, and quality control personnel were present when l

required. Housekeeping and foreign materialexclusion controls were satisfactory.

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! Some minor weaknesses were identified and discussed with appropriate licensee

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M1.2 General Comments - Surveillance  !

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a. insoection Scone (61726)

The inspectors observed all or portions of the following test activities:

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Surveillance Procedure OSP-SB-0001 A- Reactor Trip Breaker A Actuating  ;

Device Operational Test: L

• Surveillance Procedure ISF-SB-00A29- Functional Analysis: Solid State

j Protection System Train A Functional Test; and,

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• Surveillance Procedure ISF-SB-00A32- Functional Analysis, Solid State i

, Protection System Train B Functional Test.

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l b. Observations and Findinas

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j Surveillance testing observed during this inspection period was conducted l

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satisfactorilyin accordance with the licensee's approved procedures and the 7

. Technical Specifications. j

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j M4 Maintenance Staff Knowledge and Performance

M4.1 Safety Iniection System Test Line Containment isolation Valve

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a. Inspection Scone (62707) l

l The inspectors observed the repair of position indication for safety injection system l

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i test line reactor containment building isolation Valve EMHV8871.

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1 b. Observations and Findinas

) The inspectors observed the prejob briefing, containment building entry briefing,

work on the valve position indicator, and postmaintenancetesting. The briefings

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were very thorough, in addition to covering potential radiological hazards, the

location of sensitive reactor protection system instruments and foreign material

exclusion controls were discussed.

The maintenance workers were well prepared, which minimized the length of time

spent in the containment building. Communications'oetween the job site and

control room were established which facilitated the repair effort. Health physics

coverage is discussed in paragraph R4.1. The inspectors did not note any problems

with the repair or the postmaintenance test. The job was well planned and l

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M8 Miscellaneous Maintenance issues

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M8.1 (Closed) Violation 50-483/9607-02: Failure to Adhere to the Reauirements of

Continuous Use Procedures While Performina Surveillance Tests i

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Licensee personnel f ailed to follow procedures during performance of two

surveillance tests. One was a periodic test on Emergency Diesel Generator A. The

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other was a test on solid state protection system Train B. Both tests were  !

accomplished using procedures designated as " continuous use," meaning that the

procedure must be followed exactly as written. The requirements of continuous use l

procedures were described in Administrative Procedure APA-ZZ-00100," Procedure l

Adherence," Revision 11.  !

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The licensee's corrective actions included training personnel on the importance of j

following continuous use procedures. Additionally, the training stressed that,if a  ;

continuous use procedure cannot be followed as written, an approved procedure ,

revision or temporary change must be completed prior to continuing with the  !

procedure. l

The inspectors did not observe any further instances of licensee personnel failing to  ;

follow continuous use procedures. Further, the inspectors reviewed the licensee's I

corrective action reporting system and noted no other instances of personnel failing ,

to follow continuous use procedures. *

The inspectors have no further concerns with this item and consider it closed.  !

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M8.2 (Closed) Violation 50-483/9602-01: Preventive Maintenance Tasks on  !

Safetv-Related Eauioment were not Performed Within the Established Time interval _i

and a Reovired Technical Evaluation was not Performed  :

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The inspectors reviewed the licensee's actions to address the subject violation. The I

inspectors reviewed the licensee's computer database to determine whether any

instances existed when preventive maintenance tasks on safety-related equipment

were not performed within established time intervals. The inspectors also reviewed '

the licensee's corrective action reporting system to identify whether the licensee

identified any such instances.

The inspectors' review of the licensee's computer database on January 10,1997,

found no indication that the licensee f ailed to perform preventive maintenance tasks

on safety-related equipment within established time intervals. However, the

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inspectors' review of the licensee's corrective action system found that the licensee

had identified two incidents in which preventive maintenance tasks on i

safety-related equipment were not performed within the established time interval  !

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and the technical evaluation was not performed to assess the effect on the

i equipment. The licensee identified the two incidents in early December 1996.

Technical evaluations are documented on forms called " Deferral Notices" in

l accordance with Administrative Procedure APA-ZZ-00330," Preventive Maintenance

Program," Revision 12.

One incident involved the failure to sample the lube oil on Emergency Diesel

! Generator B by the late date of November 20,1996. The other involved the failure

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to sample oil from the Terry turbine on the turbine-driven auxiliary feedwater pump

by the late date of November 26,1996. The licensee subsequently performed

techriical evaluations and identified no concerns.

The licensee rescheduled the oil sampling for the two components. Sampling of the

tube oil on Emergency Diesel Generator B was performed on January 8,1997, with

satisf actory results. Sampling of oil from the Terry turbine was performed on

January 27,1997, with satisf actory results.

The inspectors reviewed corrective step [,,the licensee implemented as documented

in the response to the origina' violction n'iolation 50-483/9602-01). The corrective

steps involved placing a software lock on the computerized work control database

to prevent preventive maintenance activities from being inappropriately scheduled

beyond the late date.

For the two recent occurrences, work was properly scheduled prior to the late

dates. The preventive maintenance work packages were generated; however, the

packages were never issued to the craft. The licensee determined that work control

personnel erred in not issuing the preventive maintenance work packages on the

schedule dates.

Section 4.11 of Administrative Procedure APA-ZZ-00330," Preventive Maintenance

Program," Revision 12, required that Deferral Notices be processed prior to

preventive maintenance activities on safety-related equipment being extended

beyond the late date. The failure to adhere to this requirement is considered a

violation of Section 4.11 of Administrative Procedure APA-ZZ-00330. This

licensee-identified and corrected violation is being treated as a noncited violation,

consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-483/9703-02).

The inspectors concluded that the cause of the latest violation is different from the

cause of the original violation. The latest violation was caused by personnel error,

while the original violation was caused by a computer system fault that allowed

preventive maintenance tasks to extend beyond the late date.

The licensee has instituted a practice of having personnel review the preventive

maintenance database on a frequent basis to become aware of preventive

maintenance tasks that would become late in the near future so that appropriate

action can be taken. The licensee was also working on a way to automate this l

process for the longer term.

The inspectors concluded that the licensee was proceeding in an acceptable manner

and consider the original violation closed.

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111. Enaineerina ,

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E2 Engineering Support of Facilities and Equipment

E2.1 Review of Facility Conformance to Updated Final Safety Analvsis Report

Commitments

A recent discovery of a licensee operating their facility in a manner contrary to the

Final Safety Analysis Report description highlighted the need for a special focused

review that compares plant practices, procedures, and/or parameters to the Final  !

Safety Analysis Report description. While performing the inspections discussed in l

this report, the inspectors reviewed the applicable portions of the Final Safety l

Analysis Report that related to the areas inspected. No inconsistencies were noted l

between the wording of the Updated Safety Analysis Report and the plant practices, '

procedures, and/or parameters observed by the inspectors.

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E4 Engineering Staff Knowledge and Performance

E4.1 10 CFR Part 21 Notification on ITT Barton Pressure Transmitters

a. Insoection Scoce (37551)

The inspectors reviewed the licensee's response to a 10 CF'i Part 21 notification.

b. Observations and Findinas

The inspectors informed the licensee that ITT Barton had issued a 10 CFR Part 21  ;

notification on Model 753 pressure transmitters. The manuf acturer stated that the i

transmitters could be subject to corrosion in the electricalportions of the device.

The potential problem did not affect the pressure boundary portion of the j

transmitters. l

The licensee determined that there were seven of the subject gauges installed. Six

of the gauges were mounted in safety-related systems, but the electrical signal was

used for indication only and not to actuate safety-related equipment. The seventh I

gauge was used in a nonsafety-related system. The licensee reviewed surveillance i

records for all seven gauges. The licensee did not note any problems with signal

drift or other indications of pending f ailure,

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The inspectors found that the licensee's response to this concern was prompt and j

thorough. The inspectors agreed with the licensee's findings and did not have any  ;

further concerns.  ;

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IV. Plant Support

R1 Radiological Protection and Chemistry Controls

R1.1 Observations of RadioloaicalWork Practices l

a. Inspection Scope (71750)

The inspectors observed radiological work practices during tours of the plant,

b. Observations and Findinas

The inspectors observed health physics personnel, including supervisers, routinely

touring the radiologically controlled areas. Prejob briefs for work in rat;iological

controlled areas were satisfactory, with open discussions on radiological and

personal safety. Licensee personnel observed performing work in radiological

control areas exhibited good radiation worker practices. ContaminatM areas and

high radiation areas were properly posted. Area surveys posted outside rooms in

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th auxiliary building were current. The inspectors checked a sample of doors and

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cornainers rec. . sed to be locked for the purpose of radiation protection and found

no problems.

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R2 Status of Radiological Protection and Chemistry Facilities and Equipment

R2.1 Radwaste Buildina Tour I

a. Inspection Scope (7175_0_)

The inspectors accompanied licensee personnel on a detailed walkdown of the

2000 foot elevation and the 2030 foot elevation of the radwaste building. The tour l

was performed to inspect radiologically controlled areas not normally accessible due l

to high radiation or contamination.

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b. Observations and Findinas

The inspectors obtained the results of the licensee's last walkdown which was

performed in August 1996. The licensee had corrected some discrepancies and had  ;

not corrected others. Most were housekeeping deficiencies, such as pieces of tape  !

or other debris, that the licensee tracked by issuing " yellow cards." The " yellow j

cards" were sent to the responsible department or the responsible person assigned l

! to the area for action. Based on the repetitive nature of the items, the inspectors

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determined that the licensee was not using the " yellow cards" effectively.

Also, the inspectors identified a housekeeping concern in Room 7204, which

housed the liquid radwaste evaporator. Plant insulators and electricians had been I

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working in the room replacing heat trace on various components. There was I

considerable insulation dust and debris present, including dry boric acid. The  ;

inspectors discussed this concern with the maintenance supervisor. The J

maintenance supervisor later toured the area with the radwaste supervisor. The

maintenance supervisor stated that the condition of the room did not meet

expectations. A corrective action document was initiated,

c. Conclusions

Overall material condition and housekeeping of normally inaccessible rooms of the

2000 foot elevation and the 2030 foot elevation of the radwaste building were

adequate. The degree to which the licensee took followup action to correct

identified discrepancies during previous walkdowns was mixed. The licensee was

not using " yellow cards" effectively. Housekeeping was poor in Room 7204.

R4 Staff Knowledge and Performance

R4.1 Reactor Buildina Entry at Full Power

l a. Inspection Scope (71750)

The inspectors attended the radiological protection briefing and observed the health

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physics technician' coverage of a reactor building entry at 100 percent power. This

, was in conjunction with the maintenance effort discussed in paragraph M4.1.

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b. Observations and Findinas

The briefing, conducted by a health physics supervisor, was very thorough. The

radiological hazards at the job site were fully explained. Health physics personnel

issued proper dosimetry for the entry. The health physics technician at the job site

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ensured personnel were aware of the dose levels in the area. The technician also

continuously monitored the area dose in the event that radiological conditions

! changed. Overall, the health physics support of the maintenance effort was good.

The inspector did not note any problems with this effort.

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V. Manaaement Meetinas

j X1 Exit Meeting Summary

The exit meeting was conducted on r e bruary 14,1997. The licensee expressed a

position on the violation in this report.

l During the discussion of operations department working hours review l

l (Section 06.1), the licensee stated that management made a conscious decision for  :

the personnel to work the extra hours to support simulator training for the oncoming

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crew. The licensee agreed that the overtime form was not completed as required.

The licensee stated thet they did not believe that this violation was significant

enough to warrant a cited violation.

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The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was

identified.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED ,

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Licensee

R. D. Affolter, Manager, Callaway Plant

H. D. Bono, Supervising Engineer, Licensing Fuels and Site Licensing ,

R. E. Farnam, Superv'sor, Health Physics  !

J. M. Gloe, Superintendent, Maintenance i

G. A. Hughes, Supervisor, Independent Safety Engineering Group

K. W. Kuechenmeister, Superintendent, Design Engineering

R. T. Lamb, Superintendent, Operations

J. V. Laux, Manager, Quality Assurance

J. A. McGraw, Superintendent, Nuclear Engineering Technical Support j

R. D. Miller, Supervisor, Radiological Waste and Environmental '

C. D. Naslund, Manager, Nuclear Engineering )

G. L. Nevels, Supervisor, Radiological Chemistry l

M. A. Reidmeyer, Engineer, Quality Assurance

R. R. Roselius, Superintendent, Chemistry and Rad Waste

T. P. Sharkey, Supervising Engineer, Safety Related Mechanical Systems

M. E. Taylor, Assistant Manager, Work Control

W. A. Witt, Superintendent, System Engineeririg

INSPECTION PROCEDURES USED

37551 Onsite Engineering

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61726 Surveillance Observation j

62707 Maintenance Observation

71707 Plant Operations

71750 Plant Support Activities

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92700 Onsite LER Review

92901 Followup Plant Operations

92902 Followup Maintenance

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ITEMS OPENED, CLOSED, AND DISCUSSED

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Ooened

9703-01 VIO Operations working hour review (Section 06.1).

9703-02 NCV Failure to adhere to preventive maintenance schedule on i

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safety-related equipment (Section M8.2).

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Closed

96003 LER Auxiliary feedwater actuation after a main feedwater pump

trip on high discharge pressure (Section 08.1).

96004 LER Reactor trip when digital rod position indication f ailed

(Section 08.2).

9607-02 VIO Failure to adhere to requirements of a continuous use

procedure (Section M8.1).

9703-02 NCV Failure to adhere to preventive maintenance schedule on l

safety-related equipment (Section M8.2). !l

9602-01 VIO Preventive maintenance tasks on safety-related equipment

,

were late, without accompanying technical evaluation i

(Section M8.2).

l

I