ML20214T255

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Discusses Plant Readiness to Exceed 5% Power.Util Estimates All Activities Required Prior to Exceeding 5% Power Will Be Completed by Early Sept 1986
ML20214T255
Person / Time
Site: Perry, 05000000
Issue date: 08/07/1986
From: Norelius C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Bernero R
Office of Nuclear Reactor Regulation
Shared Package
ML20214T134 List:
References
FOIA-87-271 NUDOCS 8706100179
Download: ML20214T255 (16)


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AUS 7 1986 MEMORANDUM FOR: R. Bernero, Director, Division of Boiling Water Reactor Licensing FROM:

Charles E. Norelius, Director, Division of Reactor Projects, Region III SUSJECT: CLEVELAND ELECTRIC ILLUMINATING COMPANY (CEI), PERRY UNIT 1, STATUS OF PREPAREDNESS TO EXCEED 5% POWER This memorandum is forwarded to provide you information on the preparedness of Perry, Unit 1, to exceed Si power. This includes a sumary of all pertinent activities since issuance of the low power license, but highlights those activities since my previous memo on this subject dated June 24, 1986.

Enclosures 1 and 2 include a description of the current plant status, operation-al sumary, and a sumary of significant inspection activities since license issuance. Enclosure 3 provides a status of CEI's progress in completing license conditions and resolving Region III open items. Enclosure 4 is a

( brief sumary of significant event reports that resulted in issuance of LERs by the licensee. Enclosure 5 is a status of Perry allegations being tracked as open by Region III.

Licensee progress through the power ascension program has proceeded at a slower pace than expected. Delays can be attributed to several factors including:

e:;uipment problems such as, fueling equipment problems, Intermediate Range Monitor (IRM) electrical noise problems, repeated Drywell and Containment personnel airlock problems, and safety-related Instrucent Air preeperational and surveillance testing problems; delays associated with the startup source depletion problem which required removal and replacement of 16 fuel bundles and selected startup sources; and delays associated with the off-gas charcoal fire.

In addition, the licensee has proceeded, by design, in a cautious, deliberate manner.

CEI currently estimates that they will have completed all activities required by the NRC to exceed 5% p Wer by early September. We are currently not aware of any Region 111 issue that would result in a delay beyond the CEI estimated date, contingent upon satisfactory resolution of the issues presented in the enclosures to this memo. ..

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B706100179 870604 PDR FOIA PDR GRADER 87-271

R. Bernero 7 gg 7g If you have any questions concerning this matter, please contact me or M . R. C. Knop of my staff.

g /g & -[. nd-Charles E. Norelius, Director Division of Reactor Projects

Enclosures:

1. Plant Status and Operational Summary
2. Significant Inspection Activities
3. Status of License Conditions and Open Items
4. Significant Event Reports
5. Allegation Status cc w/ enclosures:

J. Taylor, IE J. Partlow, IE

-J. Stef ano, NRR A. B. Davis, RIII SRI, Perry

( J. Hind, RIII C. Paperiello, RIII E. Greenman, RIII F. Hawkins, RIII J. Harrison, RIII C. Hehl RIII '

R. Warnick, RIII M. Phillips, RIII E. Knop, RIII D. Danielson, RIII J. Muffett, RIII J. Creed, RIII .

R. Greger, RIII M. Schumacher, RIII M. Ring, RIII RIII W. Snell,ick-Barger, RIII J. McCorm d#

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ENCLOSURE 1 Plant Status and Operational Sumary The licensee received their license on March 18, 1986, and began loading fuel on March 21, 1986. Fuel loading was completed on April 24, 1986. Initial criticality occurred on June 6, 1986. The licensee is currently in Non-Nuclear Heat Up (NNHU) and will proceed from there to Nuclear Heat Up.

The licensee currently expects to be in a position to exceed 5% power on or after September 3, 1986.

Prior to exceeding 5% power, the licensee must complete or resolve license conditions and Region III open items described in Enclosure 3 of this report.

In addition, the following activities must be completed:*

1. 179 Work Orders must be completed.
2. 45 Master Deficiency items must be resolved.
3. 50 Surveillance Instructions must be run for credit.
4. 21 systems require System Operability Verifications (SOVs).

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  • Status from licensee as of July 31, 1986.

l Licensee operating performance during fuel loading activities and initial j criticality was generally adequate. Control room comunications and control of activities were acceptable with the exception of an equipment out of service activity that resulted in violation of the limiting condition for operation for the plant vent radiation monitors.

Approximately 52 NRC notifications per 10 CFR 50.72 have been initiated by the licensee due te events at the plant since license issuance. Nearly 50'. of these events were due to operator error which has caused some concern but which in itself is not considered abnomal for a plant at this stage in operation.

Concerns arising from these events were discussed in a management meeting on June 5, 1986, with CEl.

l On June 20, 1986, the licensee declared an Unusual Event based upon determina- l tion that a fire existed in the Off-Gas treatment system charcoal adsorbers. l The fire is believed to have been started as a result of positioning space  !

heaters in close proximity to the charcoal adsorber tanks during testing. l After temperature profiles led NRC and licensee officials to believe the fire l was out, the licensee teminated the Unusual Event on June 23, 1986. I A CAL was prepared to review and approve theJicensee's recovery plan. In addition, a Region III inspection team was dispatched to the site to review the event. After the team had approved the licensee's recovery plan and sampling plan for the adsorber beds, the fire rekindled on July 6, 1986.

2 i Rekindling occurred when an air purge of both trains was started indicating the fire had not been put out as earlier believed. The licer.see again declared an Unusual Event on July 6, 1986, and terminated the Unusual Event on July 8, 1986.

The licensee completed replacement of charcoal in all eight off-gas system

, adsorber vessels on July 29, 1986.

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ENCLOSURE 2 Significant Inspection Activities Initially, 24-hour coverage of fuel load activities was provided by Region III to meet IE Inspection Module 72302 requirements and verify that plant operations followed their approved program. Coverage of initial criticality was performed per IE Inspection Module 72526 requirements. Inspector observations indicated fuel loading activities and performance of initial criticality were well coordinated and that licensee personnel proceeded in a cautious and deliberate rr.anner.

In addition, a detailed review of the plan: preventive maintenance program was performed to ensure that safety related ecuipment was being properly maintained.

The inspector had found that the maintenance program was generally adequate.

The inspector identified some areas where improvements in the control of repetitive work tasks was needed.

The Perry SALF 6 Board was held on June 20, 1986, and the ShlP licensee meeting was held at Perry on July 15, 1986. Perry received four Category I ratings in the assessment areas of Ele:trical Power and Instrumentation and Control Systems, Li:ensing Activities, Emergency Preparedness, and Security. All the otier assessment areas were rated l Category 2.

( A Region III Operational Readiness inspection was performed at Perry from July 7 through July 25, 1986. Seven inspectors participated in the inspection at various times during the inspection period, including two EG&G consultants.

Areas reviewed during the Operational Readiness inspection included: implemen-tation of design changes and modifications; preventive maintenance; control of lifted leads, jumpers, and temporary mechanical alterations; annunciator status and control; operation of the plant; control of out of service equipment and equipment tagging; and the operational Quality Assurance program. During the inspectier no violations of regulatory requirements or deviations from corritments were identified. The Operational Readiness review indicated that plant mar.agement and operations and support personnel were following administrative controls and that implementation of activities associated with plant operations was being conducted in accordance with plant procedures and instructions.

Throughout the charcoal fire event, Region III provided inspector coverage at the site to review and monitor the licensee's actions concerning the event and assoc'iated recovery plan. Regional inspectors also monitored the licensee's reperformance of off-gas adsorber vault refrigeration system testing and reviewed the licensee's evaluation of metallurgical effects on the adsorber vessels and piping , ,

ENCLOSURE 3 Status of License Conditions and Open Items The following is a brief description and status of license conditions and open items that must be completed by the licensee prior to the staff concluding that Ferry is ready to exceed 5% power.

Initial Criticality Ncte: All activities required to be completed prior to Initial Criticality were 4.ccomplished as required. The status of these items has been repeated in this report for completeness.

A. Licensee to perfom instrument loop walkdowns and complete engineering approved interim as-built drawings which show instrument valves and piping as required by Special Project Plan 1028 for criticality.

License Condition Attachment 1, Iter B.5.

Status The initial criticality portion of this work was completed as required and review by the NRC per Open Item (440/86008-04).

[ B. Licensee to perfom a reverification of System Operating Instructions as comitted by letter dated March 4,1986, to Region III.

License Condition Attachment 1, Item B.4.

Status The initial criticality portion of this work was completed as required.

The NRC will close this issue in IR 440/86018 per Open Item (440/86006-01).

C. Licensee to provide its program for evaluation of the audibility problems encountered on evacuation of personnel from high noise areas. 1.E. Bulletin 79018.

License Condition Attachment 1 Item B.2.

Statn The licensee formulated a completion schedule that was agreeable with Region III (Letter from Edelman to Keppler, dated May 9, 1986). -

Review of the completed work by the NRC,will follcw per Open Item (440/ 79018-BB) . This closes this license condition.

D. Licensee to complete installation of all raceway separation barriers l required to meet IEEE 384-1974 independence requirements.

License Condition Attachment 1, Item B.I. l l

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Status Region III reviewed licensee's completed activities per Open Item (440/85018-01) and closed this item in Inspection Report 440/86011.

E. Initial Criticality preoperational test and testing exceptions identified by the licensee in a February 27, 1986, letter to Region III must be completed.

Licensee Condition Attachment 1, Item A.

Status 4

Licensee has completed loading of HVAC charcoal filters and testing of the Solid Radwaste Disposal System (G51), Combustible Gas Control System (M51), Technical Suppcrt Center HVAC (M52), Training Center E0F Ventilatior. System (M53), Liquid Radwaste Disposal System (G50),

and the Emergency Service Water System (P45).

1 The residents performed a review of the above tests and found them to

. be acceptable.

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Testing remaining to be completed prior to exceeding 5% power includes the ir.tegrated HVAC verification and flow balancing test (M99), recirculation system flow transmitter functional test (B33), leak detection system flow rate monitor repair and calibration (E31), and off-gas system equipment i

testing (M64).

F. The licersee must complete the validation of the perry Emergency

, Instructions, and issue a summary report. i i

License Condition Attachment 3.

Status 4

Licensee validation is complete and the sunnary report was sent to NRR per letter dated April 24, 1986.

Nuclear Ekatup i

A. Licensee must make the Turbine Plant Sampling System Points, that measure specific conductivity, pH, sodium, and dissolved oxygen at various locations of the condensers, operational prior to Nuclear Heatup.

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Status Licensee work is ongoing and expected to be completed prior to Nuclear Heatup. Region III review of this item will follow per Open Item (440/85070-02).

Prior To Exceeding 5% Power A. Licensee must implement the activities remaining to complete the Detailed Contrel Room Design Review and correct all human engineering discrepancies (HEDs) identified in Attachment 3, Paragraph 1, to their license.

License Condition 2.C.(7).

Status Most activities were :ompleted by May 19, 1986. A letter to NRR was sent on May 28, 1986, and closed out all issues with the exception of completion of certain HEDs. Followup letters were sent July 11 and July 29, 1986, closing out the remaining 1ssues.

B. Licensee to obtain letters of agreement from all school districts for the supply of buses for evacuation.

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LicenseCondition2.C.(8)(a).

Status Letters of agreement have been obtained and should be documented in SSER 10.

C. Licensee to verify that the training of Fire Protection personnel in radiological monitoring and decontamination proceoures are completed and verify that the necessary decontamination equipment has been provided at the fire department facilities for each reception center.

License Condition 2.C.(8)(b).

Status The above activities have been completed and should be documented in SSER 10.

D. Licensee must make further confirmatocy analysis of equipment in the containment that have not been qualified for pressure survivability, or have a narrow margin of pressure survivability.

4 License Condition'2.C.(10)(a).

Status The analysis is reportedly completed and a final letter was sent to NRR on July 17, 1986. NRR should address this item in SSER 10.

E. Licensee must ensure that written procedures are available for operation of the hydrogen igniter system.

License Condition 2.C.(10)(b).

Status Work is ongoing by the licensee, and is expected to be completed by August 8, 1986.

F. Licensee must obtain, install, and test IEEE Class IE qualified isolation transformers in the power supply for Division III APRM circuits.

License Condition Attachment 1, Item B.3.

[ Status Licensee activities are ongoing at this time and scheduled to be completed by August 15, 1986.

G. Licensee to perform a reverification of System Operating Instructions as committed to by letter dated March 4, 1986, to Region III.

License Condition Attachment 1, Item B.4.

Status Reverification has been completed by the licensee. Review by the NRC will follow per Open Item (440/86006-01).

H. Licensee to install identification tags on instrurnent valves identified in a commitment letter dated March 14, 1986, to Region III concerning instrument valve lineup verification.

License Condition Attachment 1, Item B.S.

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Work is completed by the licensee. Review by NRC will follow per Open Item (440/86006-04).

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1. Supplement No. 9 to the Perry Safety Evaluation Report (NUREG-0887) requires that certain confirmatory actions concerning the January 31, 1986, earthquake be performed by the licensee and a report sent to NRR.

Status The licensee sent a Final Report to NRR on June 24, 1986. NRR should address this issue in SSER 10.

J. The following are three open items that must be closed prior to the licensee exceeding Si power.

1. Evaluation of Cable Tray Supports for fire. (440/85090-01)

Status Th s item has been completed by the licensee and requires Region III review.

2. 501's technically inadequate and a work order was not properly prepared or implemented (440/86006-01).

( Status Licensee has completed work and Region III is to review the completed packages.

3. Part 21 dated March 10, 1986, concerning possible damage to the elastomer liner in the Clearflow Company foot valve mounted in the Emergency Diesel lube oil sump tank (440/86002PP).

Status Licensee work has been completed. NRC is to review the licensee's completed package.

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  • t ENCLOSURE 4 Significant Event-Reports  ;

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Since the license issuance, there have been 29 LER's submitted. The LER  :

l descriptions provided below were taken from the LER abstracts provided l by the licensee. LER 86-001-0 through LER 86-013-0 were included in the June 24, 1986, revision of this report and repeated in this revision for completeness. q LER 86-001-0 i

Reactor Protection System (RPS) actuations occurred due to upscale trips of the neutron monitoring system Intermediate Range Monitors (IRMs). These trips were L

l attributed to " noise" in the IRMs caused by grounding bus fluctuations. The j actuations occurred during initial fuel loading (prior to initial criticality).

LER 86-002-0 1 Division II, Channels A and B Redundant Reactivity Control System (RRCS)

Alternate Rod Insertion (ARI) actuation occurred, which resulted in a Scram Discharge Instrument Volume (SDIV) high level trip of the Reactor Protection System (RPS) (control rods were already fully inserted). The RRCS Channel B trip was caused by reinstalling a Card Select Decoder (CSD) printed circuit card, which had been removed to verify its calibration date. The Channel A

[ trip was initiated when the digital display was being redirected from the monitor mode to the off mode.

LER 86-003-0

! A Reactor Water Cleanup (RWCU) System outboard containment isolation. During performance of a monthly leak detection surveillance test, a technician working i in a cramped location inside a panel touched a lifted wire to the relay housing i which blew the 120 vac fuse in the RWCU isolation logic and caused an outboard -

! contJinment isolation. -

LER 86-004-0 l On April 13, 1986, the Containment /Drywell Purge System continued to operate and i was not secured as required by Technical Specifications when the Unit 1 Plant Vent Radiation Monitor was de energized to perform preventive maintenance. A 4 Limiting Condition for Operation was not met for 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. l

) LER 86-005-0 i On April 21, May 10, May 17, and May 19, 986, the Control Room Heating i Ventilating and Air Conditioning (CRHVAC) system shifted into its' l Emergency Recirculation (ER) mode due to high Chlorine Gas Monitor trip i signals. The cause of the first actuation was a defective filament in the optic lamp. The second, third, and fourth events were caused by paper torn

, in the monitors.

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LER 86-006-0 On April 22 and April 25, 1986, neutron monitoring system instrumentat' ion upscale trips resulted in one manual and one automatic Reactor Protection System (RPS) actuations. i

  • The instrumentation spikes were attributed to electrical noise; however, APRM >J card vibration is also being evalusted as a contributing factor.

LER 86-007-0 On April 14, 1986, Reactor Water Cleanup (RWCU) systerr outboard containment isolation valve G33-F0004 was rendered inoperable by removal of a jumper supplying power to its closing circuit. The associated inboard containment isolation valve G33-F0001 was not isolated within four hours as required by Technical Specification 3.6.4.

LER 86-008-0 On April 30, 1986, shift operators discovered the containmer,t fire hose reel inboard / outboard supply isolation valves in the open position. During core alterations, Technical Specification requires that these valves be closed in order to satisfy containment integrity. The subsequent investigation

[ determined that the valves had been open before the start of core alterations (March 21, 1986) and that shift operators neglected to initiate the proper administrative controls to track the position of these valves.

LER 86-009-0 On May 4, 1956, a Reactor Water Cleanup (RWCU) System outboard containment, isolation occurred. Actuation was due to a technician shorting a lifted wire to a relay hcusing which blew the 120 vac fuse in the RWCU isolation logic and caused an outboard containment isolation. .

LER 86-010-0 On May 7,1986, it was discovered that the carbon dioxide (CO 2 ) fire suppression system was not available to the Diesel Generator Building and fire hose reel in the Control Complex. They were isolated from their CO2 source j without compensatory measures from April 26 to May 7. )

The cause of the uncompensated impairment was failure to reopen a CO2 Pressure *l control valve following maintenance on CO2 control panels. l i

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LEE 86-011-0 4

't Gaseous effluent vent' stack flow estimates were not performed every four hours as required,by Technical Specifications during two different required time intervals. '

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Ouring the first event, poor communications between two plant groups resulted ,

4 in Turbine Building Heater Bay Vent Stack Flow estimates being performed using i an inoperable instrument. Flow estimates were again missed when the Unit 2

,P lant Vent Radiation Monitor was taken out of servite. This problem was caused by an operator failing to properly review the existing plant conditions at shift turnover. ,t

'LER 86-012-0 i On May 8,1986, neutrci monitcring system Intermediate Range Mo'nitor (IRM) instruments "C" and "G" were declared inoperable due to an overdue surveillante.

The associsted Reactor Protection System (RPS) trip system was not placed -

in the trip ~ed p condition within one hour as required by Technical Specifications 3.3.1.

LER 013-0 '

(' On May 12,1986, at 1320 and 1630, the standby train of the Annulus Exhaus't

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'l Train Gas-Treatment System (AEGTS) actuated when the operating train experienced a loss of power due to the deenergization of a Division II 480V load center.

1 The cause of the events was determined to be ~a faulty ground 'cher current J

. relay which was tripping prematurely, thus opening the load center supply breaker.

LER 86-014-0 On May 4,1955 a hold down bolt on a Control Rod Drive System Hydraulic ControLUnit (HCU) was found to be missing. Four other HCUs were observed with hold'down bolts not in contact with the HCU frame. On May 15, further investigation revealed that.all of the HCUs had been installed with bolt

, torque values differing from the requirements of the seismic testing in the s Environmental Qualificatio'n' Report. In addition, branch function box brackets:

were observed to be attached to 16 HCus. The HCUs had not been seismically qualified with these junction boxes attached to the HCU frame.

j LER 86-015-0 On May 20, 1986, a Reactor Protection System (RPS) actuation occurred as a' '

resdit' of a high Scram Discharge Instrument Volume (SDIV) level trip. A valve.

tagout had been authorized ar.d hung for the performance of maintenance on a s I

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4 Control Rod Hydraulic Control Unit. The tagout resulted in the depressuriza-tion of the Scram Pilot Air Header allowing the scram inlet and outlet valves to open and the Scram Discharga Volume vent and drain valves to close, thus routing water into the SDIV. A full RPS actuation occurred when the SDIV level reached the high level trip point.

LER 86-016-0 On May 26, 1986, the inboard containment isolation valves for the Reactor Water Cleanup (RWCU) System automatically isolated due to a spike from the RWCU Pump Room "B" High Differential Temperature switch. The spike was generated when the switch, E31-N613B, was taken to the " Read" position. An infontation tag had been hung on the "A" RWCU Leak Detection temperature sw4th panel, warning that reading tt'e modules can result in RWCU isolation.

A similar tag had not been hung on the "B" panel.

g 86-017-0

'On 7 c/ 29,1986, at 2209, 2245 and 2300, mechanical maintenance workers caused a En cior Protection System (RPS) actuation while performing a pressure test

-r. the sensing line of the RPS turbine first stage pressure transmitters (PT).

[ LER 86-018-0 Between 2100 June 6 and 1530 June 7, 1986, a thermal power and reactor coolant temperature verification surveillance was not performed once per hour as required by Technical Specifications. This surveillance is required wiiile in Operational Condition 2 (Startup) during the performan:e of low power Physics Testing under the provisions of a Special Test Exception for primary containment and drywell integrity.

LER 86-019-0 On May 30,1986, the Division 2 Diesel Generator Building Ventilation Supply Fan (ESF System) was discovered to be running unexpectedly. '

LER 86-020-0 On May ,31,1986, the Backup Hydrogen Purge Isolation Valves auto closed after an operator inappropriately deenergized the Drywell Radiation monitors during performance of a surveillance.

LER 86-021-0 , ,

On June 2,1986 it was discovered that five recirculation damper actuators in the Diesel Generator Building Ventilation System (DGBVS) were inoperable due to seal failures. .

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LER 86-022-0 On June 9,1986, two surveillance tests of the Rod Pattern Control Systems were not performed at their required interval.

LER 86-023-0 On June 11, 1986, the Control Room HVAC system shifted into its Emergency Recirculation mode at three different times due to high chlorine gas monitor trip signals. These trips were due to Perry technician error and not actual high chlorine gas.

LER 86-024-0 On June 12, 1986, a gaseous effluent noble gas grab sample was not collected and analyzed as required by a Technical Specification.

LER 86-025-0 On June 27, 1986, the Containment Vacuum Relief System valves opened while the Containment Vessel and Drywell Purge System was running in the refuel mode.

This event was primarily due to a design problem in the Containment Vessel

( and Drywell Purge systems' supply and exhaust flow control logic.

LER 86-026-0 On June 18, 1986, Containment Isolation Valves unexpectedly auto closed in the following systems: Condensate Transfer and Storage, Containment Vessel Chilled Water, and Plant Radiation Monitoring. During the performance of a preoperational test a technician inadvertently grounded a power lead resulting in the containment isolation signals to the containment isolation valves in the above systems.

LER 86-027-0 On June 26, 1986, at 0423, 2315 and June 27, at 1507, personnel errors caused ESF actuations during installation of a Reactor Water Cleanup design change.

LER 86-028-0 On June 27, 1986, a Reactor Protection System actuation occurred due to low reactor vessel water level when Reactor Recirculation System Pump B was started in accordance with a deficient test instruction.

LER 86-029-0 On June 27, 1986, the Annulus Exhaust Gas Treatment System "B" exhaust fan automatically started due to a false low flow signal from the "A" train.

( ENCLOSURE 5 ALLEGATION STATUS There is one allegation that is currently open and requires inspections by Region III staff (non 01 staff). In addition, there are three allegations being reviewed by 01 and, although resolved from a technical viewpoint by Region III specialists, remain open pending completion of 01's investigation for potential wrongdoing.

The allegation that is currently open and requiring Region III staff review concerns events associated with the pre-signing of Test Change Notices. The licensee had notified the NRC of their identification of this practice prior to the allegation being received by the region. However, the allegation contains additional information. This matter will be reviewed prior to the licensee exceeding 5% power.

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