ML20198B179

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Advises of Planned Insp Effort Resulting from Calvert Cliffs NPP Review Conducted on 981110.Details of Insp Rept for Next 6 Months & Historical Listing of Plant Issues Considered During Process Encl
ML20198B179
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 12/10/1998
From: Doerflein L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Cruse C
BALTIMORE GAS & ELECTRIC CO.
References
NUDOCS 9812180093
Download: ML20198B179 (25)


Text

. .. - . - ~ . _ - - - - - _ - . - _ - . . . .. - . _. - .-

December 10, 1998 l-l ,'

l Mr. Charles H. Cruse

- Vice President - Nuclear Energy Baltimore Gas and Electric Company

- Calvert Cliffs Nuclear Power Plant l - 1650 Calvert Cliffs Parkway

'. Lusby, MD 20657-4702 l

SUBJECT:

MID YEAR INSPECTION RESOURCE PLANNING MEETING - CALVERT CLIFFS

Dear Mr. Cruse:

On November 10,1998, the NRC staff held an inspection resource planning meeting  ;

l llRPM). The IRPM provided a coordinated mechanism for Region I to adjust inspection  ;

' schedules, as needed, prior to the conclusion of the Plant Performance Review cycle in '

May 1999.

Enclosure 1 contains a historical listing of plant issues, referred to as the Plant issues Matrix (PIM), that were considered during this IRPM process to arrive at an integrated view .;

of licensee performance trends. ' The PIM includes only items from inspection reports or other docketed correspondence between the NRC and Baltimore Gas and Electric Company.' The IRPM may also have considered some predecisional and draft material that -

does not appear in the attached PIM, including observations from events and inspections  ;

that had occurred since the last NRC inspection report was issued, but had not yet received full review and consideration. This material will be placed in the PDR as part of the normalissuance of NRC inspection reports and other correspondence.

I 1This letter advises you of our planned inspection effort resulting from the Calvert Cliffs l k Nuclear Pcwer Plant IRPM review. It is provided to minimize the resource impact on your  ;

staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite. Enclosure 2 details our inspection plan for the next .

6 months. Resident inspections are not listed due to their ongoing and continuous nature.

We willinform you of any changes to the inspection plan, if you have any questions, please contact me at 610-337-5378.

Sincerely, Original Signed by:

i

~^

] 9812190093 DR ADOCK 0 991210 Lawrence T. Doerflein, Chief i

e g7 Projects Branch 1 Division of Reactor Projects g

, l' l 0FFICIAL RECORD COPY -iM l

Mck 'RES/EET~

Charles H. Cruse 2 Docket Nos. 50-317,50-318

Enclosures:

1) Plant issues Matrix
2) Inspection Plan cc w/encis:

B. Moritgomery, Director, Nuclear Regulatory Matters (CCNPP)

R. McLean, Administrator, Nuclear Evaluations J. Walter, Engineering Division, Public Service Commission of Maryland K. Burger, Esquire, Maryland People's Counsel R. Ochs, Maryland Safe Energy Coalition State of Maryland (2)

1 i

Charles H. Cruse 3 Distribution w/encls:

H. Miller, RA/W. Axelson, DRA (1)

C. Hehl, DRP l l J. Wiggins, DRS  ;

R. Crlenjak, DRP l L. Nicholson, DRS L. Doerflein, DRP DRS Branch Chiefs J. Lanning, DRM l

W. Cook, DRP R. Nimitz, DRS l S. Chaudhary, DRS J G. Smith, DRS M. Oprendek, DRP '

R.Junod,DRP I Nuclear Safety Information Center (NSIC)

PUBLIC NRC Resident inspector Region i Docket Room (with concurrences)

Distribution w/encls: (VIA E-MAIL)

G. Shear, RI EDO Coordinator i S. Stewart - Calvert Cliffs S. Bajwa, NRR A. Dromerick, NRR M. Campion, RI Inspection Program Branch, NRR (IPAS)

R. Correia, NRR l_ DOCDESK.

DOCUMENT NAME: G:\lRPM\CC-IRPM.LTR To receive a copy of this document, indicate in the box: "C" = Copy without ,

attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy OFFICE Rl/DRP g l Rl/DRP J' NAME WCook W D LDoerfleingfly DATE 12/$ /98 12/10/98 l OFFICIAL RECORD COPY r

l l

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 7/29/98 Positive IR 98-07 N OPS 1A During Unit i start-up and power ascension, the inspectors observed that detailed pre-job 1B briefings were held, operations supervisors provided good oversight of control room activities, 3A and reactor engineering personnel were observed providing good direction and oversight of test procedures. The inspectors also observed excellent communications between the operators, engineers, and supervisors and proper use of procedures. Engineering oversight of the service water, main turbine, and feedwater systems during the start-up was very good and contributed to an event-free transition to power operation.

7/29/98 Positive IR 98-07 L OPS 3A Operations department actions to reduce the number of mispositioning events have been 3C effective and the heightened sensitivity to mispositioning by tracking these events was a good safety practice.

7/29/98 Positive IR 98-07 N OPS 3A The performance by the nuclear fuel operations staff during fuel transfer to the Independent 3C Spent Fuel Storage Installation was good, with appropriate concems for safety, radiation controls, and foreign materials exclusion. Communications between operators, radiation safety technicians, and reactor engineering personnel were clear and concise.

4/1/98 Positive IR 98-301 N OPS 3B A retake written examination was administered to one SRO candidate who had failed the original examination administered in October 1997. This individual passed the retake examination and was issued a license.

5/30/98 Positive IR 98-06 N OPS 3A The inspectors found the conduct of operations on both units to be very good. Fuel was 3C reloaded into the Unit 1 reactor without problems following a ten year inservice inspection of the reactor vessel and intemals. Throughout a subsequent reduced inventory period on Unit 1. BGE limited work that could affect essential core cooling systems, including work in the switchyard and other electric power supplies. The reduced inventory evolution was completed without pro'olems and with a high regard for reactor safety.

5/30/98 Positive IR 98-06 N OPS 3A The performance of a nuclear plant operator during an auxiliary building tour was good with a 3B proper focus on equipment status and plant conditions. Communications between the plant operator and the control room were formal and complete.

3/14/98 Positive IR 98-01 N OPS 1A Plant operations were conducted safely with a proper focus on continued nuclear safety. In general, the conduct of plant operations was professional and safety-conscious. Operation's shift tumover briefings were effectively conducted. BGE's efforts to reduce the number of control room deficiencies and the number of deficiencies requiring compensatory operator action have been positive.

Page 1 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 3/14/98 Positive IR 98-01 N OPS 1C Safety tours conducted by the General Supervisor Nuclear Plant Operations and operator performance observations conducted by shift supervisors were two examples of management oversight initiatives implemented by Operations management. The inspectors concluded that Operations management implemented aggressive efforts to reduce valve, switch, and breaker mispositionings during the last twelve months which have been successful as demonstrated by the reduced number of mispositionings.

2/7/98 Positive IR 97-08 N OPS 1A The inspectors concluded that the non-licensed plant operators observed during two plant tours were experienced and knowledgeable. BGE established processes for problem identification, communications, and procedure adherence were well implemented.

2/7/98 VIO IR 97-08 N OPS 1C Two examples of BGE's failure to develop adequate test procedures to ensure the operability of VIO 97-08-01 the Control Element Assembly (CEA) secondary position indicating systems were identified.

This was a violation of Appendix B, Criterion XI, Test Control.

2/7/98 VIO IR 97-08 N OPS 3A The inspectors concluded that BGE was slow to recognize that the secondary CEA indication VIO 97-08-02 system was inoperable, the plant had operated outside technical specifications, and that this event was reportable. Recent unreliability of the primary CEA indication system contributed to BGE's difficultyin determining which CEA indication system was inoperable. This was a violation of TS 3.1.3.3.

2/7/98 Positive IR 97-08 N OPS 1A The control room operators were attentive and responsive to plant conditions, and knowledgeable of the status of annunciators. Safety and risk significant systems and support systems were appropriately aligned during periodic main control panel walkdowns.

12/20/97 VIO IR 97-07 L OPS 4A The LER described an April 1997 occurrence where fuel was moved with the Unit 2 refueling LER 97-001 1C machine when overload protection was cut out during part of the fuel movement. The overload VIO 96-10-01 limit of 3000 pounds was required to be in service for the entire length of travel. The refueling machine overload limit switch design was inadequate, as the circuit was automatically bypassed for six inches of travel. At the time of the bypass, the fuel assembly would be out of the core and in the hoist box. The circuitry was modified to comply with the TS requirement. This was a violation of TS refueling requirements.

Page 2 of 21 i

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 12/20/97 VIO IR 97-07 L OPS 3A The LER desc:ibed an April 1997 occurrence where fuel was moved in the spent fuel pool LER-97-003 3B without meeting the TS requirement for exhaustir.g fuel pool ventilation through charcoal filters.

EA-97-192- Personnel failed to ensure the proper ventilation line-up prior to moving fuel due to poor 11014 communications between the parties involved. This was another example where different groups used multiple, overlapping procedures to accomplish one task, with no ownership of the entire process. This was a violation of Appendix B, Criterion V, Instruction, Procedures, and Drawings.

12/20/97 VIO IR 97-07 N OPS 3A Air from the spent fuel pool area was leaking out into the auxiliary building while fuel was being EA-97-192- 1C moved (a condition outside the design basis) in January 1997. A surveillance to demonstrate 11014 operability of the SFP vent. system had not been performed since Sept.1994. Credit was taken for a partial test performed in July,1995. Procedures did not address system operation with unusual or abnormal fan configurations in other parts of the auxiliary building not directly associsted with the spent fuel pool.

11/21/97 Positive IR 97-10 N OPS 3B The inspectors found very good self and peer checking prior to non-emergency activities and good peer post-checking of emergency activities were observed during the simulator operating exam.

11/21/97 Negative IR 97-10 N OPS 3B The November 1997 exam generated and reviewed by BGE and their contractor was a low 1C quality effort as indicated by exam comments. BGE provided 13 written exam comments foCow ng the exam, and the NRC deleted questions or revised answers on 8 questions based on the comments.

11/21/97 Negative IR 97-10 N OPS 3B The initially submitted written examination (November 1997) did not meet the guidelines in the 1C Examiner Standards; therefore, the examination initially submitted did not appear to receive an acceptable level of review. An excessive number of questions were directed at certain systems and there were an insufficient number of questions at the SRO level on the SRO written examination.

11/21/97 Positive IR 97-10 N OPS 3B Overall, cand:date performance during the November 1997 operating tests was good. No significant generic Weaknesses were identified; however, severa! candidates experienced difficulty Icca-ing manual valves during performance of in-plant JPMs.

Page 3 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 11/21/97 Negative IR 97-10 S OPS 3B Two SRO candidates did not pass the written portion of the November 1997 initial exam. All other candidates successfully passed the exam. Three RO and four SRO candidates (two instant and two upgrades) were administered initial exams.

12/20/97 NCV IR 97-07 L OPS 1C Core alterations performed on Unit 2 in April 1997 with the containment purge valve isolation Negative LER 97-002 system inoperable and with the personnel airlock open. TS 3.9.9 required that with the system NCV 97-07-03 inoperable, each penetration providing direct access from the containment to the outside atmosphere would be closed. BGE was in compliance with Standard Technical Specifications (STS), however the Calvert Cliffs TS did not include the words " containment purge". Discussed with NRR, who clarified the intent of the TS. Issue had minor safety significance and was not l cited.

12/20/97 Positive IR 97-07 N OPS 1C The plant operations and safety review committee (POSRC) demonstrated a strong safety 4B perspective. Poor quality assessments and proposed activities were rejected. Split vote opinions did not involve safety issues and were clearly documented.

12/20/97 Positive GR 97-07 N OPS 1C BGE met goals for reducing operator work around deficiencies and had aggressively categorized 2A and evaluated them to minimize operational risk. Although there are severallongstanding work SC arounds, no single deficiency or deficiencies in their aggregate represented a safety concem.

12/20/97 Positive IR 97-07 N OPS 1A Operations were well conducted, with operators both attentive and responsive to plant conditions, implementing multiple detailed on-line safety risk assessments for planned SR equipment outages.

11/1/97 Negative IR 97-06 N OPS 1C Licensed operator exams were administered appropriately in November 1997; however, the inspectors noted some concems in the areas of simulator and JPM debriefs, JPM critical task identification, and evaluator cuing.

11/1/97 Positive IR 97-06 N OPS 1C The licensed operator requalification program was implemented acceptably. Operator performance during the annual operating test was good. The operations and training departments worked effectively to maintain operator knowledge and skills at desired levels of performance.

Page 4 of 21

Enclosure 1 CALVERT CLIFFS I & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 11/1/97 Negative IR 97-06 N OPS 3B Operator preparedness for use of self-contained breathing apparatus (SCBA) was weak. A 1C number of operators did not know the location of the equipment, some operators wore facial hair that would inhibit SCBA use, and some operators had not trained with the equipment for five years. BGE responded by requiring that operators be clean shaven and established a practical training plan for SCBAs.

11/1/97 Positive IR 97-06 N OPS 2A While BGE had not met their established goal for the number of control room deficiencies; efforts to reduce the total number of deficiencies had been aggressive.

11/1/97 Positive IR 97-06 N OPS 1A The conduct of operations was professional and safety-conscious. The operations and engineering departments implemented multiple and detailed safety risk assessments for planned safety related equipment outages. The applicable system Technical Specification limiting condition for operation was entered and exited correctly for the equipment outage times.

11/1/97 Positive IR 97-06 N OPS 1B Operator actions in response to an October 1997 automatic trip from a loss of condenser LER 97-009 3A vacuum was very good and included completion of the appropriate emergency operating 5B procedures, periodic status briefings, and detailed evaluation of plant conditions. BGE did a thorough review of the transient and the plant was retumed to fu!! power without complication after the cause was understood and corrected.

11/1/97 Positive IR 97-06 N OPS 1C BGE actions to minimize risk during a reactor coolant pump seal replacement were notable.

2A During the seat replacement, a number of control room deficiencies were corrected. The plant 1B was retumed to full power without complication.

7/29/98 Positive IR 98-07 N MAINT 3A Surveillance testing was done in a well controlled manner consistent with safety requirements.

4B Pre-evolution briefings were detailed and included discussions of potential problems and 3C contingency plans. Testing was sufficient in scope to demonstrate that the subject equipment would perform their required safety functions. Engineering personnel provided effective maintenance and surveillt,nce testing oversight.

5/30/98 Positive IR 98-06 N MAINT 2B The Unit 1 core suppod barrel was lifted and removed from the reactor vessel without 3C complication. The evolution was conducted in a well controlled manner with very good radiological controls and maintenance department coordination. The inspector found the corresponding BGE maintenance rule activities for the reactor cooiant system to be appropriate.

Page 5 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 4/16/98 Strength IR 98-04 N MAINT 4C BG&E's overall performance on safety assessments before taking equipment out of service was 3A acceptable. The team determined that BG&E had implemented an effective on-line maintenance program, which appropriately considered risk in the planning, scheduling and implementation of the work weeks.

4/16/98 Positive IR 98-04 N MAINT 3A System managers and engineers had excellent knowledge of their systems and very good 3B knowledge of their MR responsibilities. The team determined this was a positive attribute of the program. Operations personnel had a basic understanding of the MR and their responsibilities.

4/16/98 Positive IR 98-04 N MAINT 3A The performance of the Expert Panel to address the risk significance of systems, taking into SA account the limitations of PRA analyses and the identification of risk-significant systems was acceptable.

4/16/98 Negative IR 98-04 N MAINT 4C The program adequately implemented balancing availability and reliability. The (a)(3) evaluation SA reflected a thorough approach and it met the requirements of paragraph (a)(3) of the rule for SC balancing availability and reliability. The team also noted that despite the corrective actions associated with improving the timeliness of developing performance goals for SSCs required to be monitcred under (a)(1) of the rule, several examples of excessive time periods between the identification of functional failures and the development of appropriate goals were identified by the team. Accordingly, the previous identification of this program deficiency in the (a)(3) periodic assessment coupied with the ineffective implementation of corrective actions in response to this ,

issue represented a missed opportunity to correct an adverse finding. '

4/16/98 Positive IR 98-04 N MAINT 4C Goals and corrective actions established by BG&E for identified (a)(1) SSCs were acceptable.

48 Additionally, the condition monitoring program for structures was found to be acceptable and SSC performance criteria were appropriately linked to the probability risk assessment (PRA) 4/16/98 Negative IR 98-04 N MAINT 4C The Maintenance Rule Assessment Report 97-AR-01-EAU was comprehensive in scope and SA that the resultant recommendations and issue Reports identified significant areas for improvement. However, BG&E did not act aggressively on many of these self-identified items and therefore missed opportunities to correct program deficiencies associated with the MR imc!ementation. These deficiencies were resolving the concems associated with the reliability index and handling repetitive functional failures in a timely manner.

Page 6 of 21

Enclosure 1 CALVERT CLIFFS I & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code Item Description 4/16/98 Violation IR 98-04 N MAINT 4B SSC scoping was appropriately implemented and adequate technicaljustification was provided VIO 98-04-03 4C for those SSCs excluded from scope with one exception. A past inspection item (URI 97-05-01) identified that BG&E failed to put in scope of the MR safety related emergency lighting outside the control room. This was a violation of 10 CFR 50.65(b). Also, SSCs were added to the scope of the rule as identified by the licensee after initial MR implementation in July 1996 and BG&E is being credited for identifying this aspect.

4/16/98 Violation IR 98-04 N MAINT 4B No performance criteria had been established for the EDG building HVAC system. This was a VIO 98-04-02 4C violation of 10 CFR 50.65(a)(2).

4/16/98 Violation IR 98-04 N MAINT 4B A number of systems, structures and components (SSCs) within the scope of the Maintenance VIO 98-04-01 4C Rule (MR) were permitted to remain under 10 CFR 50.65(a)(2) when preventative maintenance SA failed to assure that these SSCs remained capable of performing their intended function. This was a violation of 10 CFR 50.65(a)(2) 3/14/98 Positive IR 98-01 N MAINT SA The inspectors concluded that the Worker Risk Assessment Process (WRAP) has been an SC effective initiative to aid in continuous improvement of industrial safety practices for maintenance personnel. Maintenance management has recently expanded this program in an effort to improve radiation safety practices for maintenance personnel.

3/14/98 Positive IR 98-01 N MAINT 3A The observed maintenance and surveillance testing was conducted safely and in accordance 1C with BGE approved procedures and controls. Workers were knowledgeable and performed work effectively. Good supervisory oversight of maintenance was observed during this period.

Operators demonstrated good use of self-checking techniques. The pre-test briefings performed by operations personnel were excellent in scope, content, and level of detail.

2/7/98 Positive IR 97-08 N MAINT 3A The observed maintenance and surveillance tests were conducted safely and in accordance with BGE approved procedures and controls. Thorough and detailed pre-test briefings were a strength of the surveillance testing observed. Quality verification personnel provided effective oversight of selected maintenance jobs.

12/20/97 Positive IR 97-07 N MAINT 3A Observed maintenance was conducted safely and in accordance with BGE approved procedures. Workers were knowledgeable and performed work effectively.

12/20/97 Positive IR 97-07 N MAINT 3A Observed surveillance testing was conducted safely.

Page 7 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID l SFA Code item Description 12/20/97 Positive IR 97-07 N MAINT 2B The housekeeping program was an effective initiative in identifying cleanliness problems and 3C improving overall plant cleanliness. The program provided BGE with objective enteria to assess the adequacy of corrective actions for housekeeping deficiencies.

12/20/97 NCV IR 97-07 L MAINT 2B Surveillance testing of the Emergency Diesel Generator's (EDG's) did not meet TS Negative LER 97-002 3B 4.8.1.1.2.d.3.c. Non-critical engine trips were automatically bypassed on a Safety injection NCV 97-07-01 4B Actuation Signal (SIAS) concurrent with the LOOP. BGE tested on SIAS only. The surveillance test procedures were inadequate because of an incorrect interpretation of the wording of the TS by plant personnel. This TS violation was not cited.

11/1/97 Positive IR 97-06 L MAINT SA A leak repair activity was stopped by the BGE nuclear assessment department after identification that fire protection, injection pressure, and injection volume had not been assessed. The BGE nuclear assessment department actions were aggressive and prudent.

11/1/97 Negative IR 97-06 N MAINT 28 A leak repair activity on the high pressure main turbine was initiated without normal engineering assessment. The effort was stopped by the BGE nuclear assessment department after identification that fire protection, injection pressure, and injection volume had not been assessed. Initial maintenance department preparaticns for the high pressure turbine leak repair were poor.

11/1/97 Positive IR 97-06 N MAINT 3B in general, maintenance was conducted safely and in accordance with approved procedures.

3A Workers were knowledgeable and performed work effectively.

11/1/97 Negative IR 97-06 S MAINT 3A An automatic reactor trip occurred in October 1997 when a main condenser vacuum breaker LER 97-009 2A opened at full power. The cause was an improper wire termination due to poor work practice.

7/29/98 Positive IR 98-07 L ENG 4A The BGE engineering staff responded approp iately to ABB Combustion Engineering concems 4C regarding an error in the limiting hot channel departure from nucleate boiling determination for both units. The BGE evaluation was completed in a timely manner and included an appropriate engineering evaluation for continued operability and assurance of margins of nuclear safety.

5/30/98 Positive IR 98-06 N ENG 2B The Unit 1 inservice inspection program was well planned and implemented. The steam 4B generator inspection and pressurizer heater sleeve inspection and repair were completed in a SC well control led manner with an emphasis on safety. A flaw indication on the reactor pressure vessel was dispositioned in accordance with industry standards. In all activities, BGE engineering provided very good support, including disposition of inspection indications.

Page 8 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 3/14/98 Positive IR 98-01 f2 ENG 4C BGE established an adequate process to track design issues, received from Transnuclear West, associated the NUTECH Horizontal Modular Storage System. BGE develowd and followed a comprehensive process to ensure all design and quality assurance issues which might have affected its dry shielded canister were resolved.

3/14/98 VIO 1R 98-01 N ENG 4C BGE's application for a license for use of the NUHOMS system at the Calvert Cliffs independent VIO 98 spent fuel storage installation, undar a site specific license, did not provide complete and 01 accurate information regarding the behavior of the dry shielded canister during a vertical top drop accident This was a violation of 10 CFR 72.11.

3/14/98 VIO IR 98-01 N ENG 4C BGE did not adequately resolve all of the design issues and, more significantly, did not identified VIO 98 01-02 an unreviewed safety question involving an equipment malfunction of a different type than any evaluated previously in the Updated Safety Analysis Report The inspectors concluded that this was a violation of 10 CFR 72.48(a)(2)(ii). The inspectors further concluded that the safety significance of these findings was minimized due to the low probability of, and minimal consequences associated with, a vertical top end drop accident 3/14/98 Positive IR 98-01 N ENG 4C Overall, the continuing training provided to selected engineering and technical support staff personnel provided an excellent overview of the development, results, and applications of the Calvert Cliffs Probabilistic Risk Assessment The probabilistic risk assessment training was appropriate in scope and detail and the stated teaming objectives were effectively met 3/27/98 URI 1R 98-80 N ENG 4A BGE has improved the quality of the ventilation system testing program. Although ventilation URI 98-80-01 calculations have been refined and non-conservative or incorrect design assumptions removed, some control room ventilation concems were unresolved pending NRC review of an impending BGE submittal on control room habitability. The concems related to the acceptability of calculated control room doses after updating, the need for a 50.59 determination, reportability, use of corrective action systems, and NRC notifications on systems not in accident analyses.

Testing was initiated to verify that the ventilation systems can perform their design function as described in the FSAR and TS bases. These issues remain unresolved.

3/27/98 Positive IR 98-80 N ENG 4A BGE's engineering and design control activities regarding emergency diesel generators and the service water system were satisfactory. The engineering staff had taken prompt actions to resolve identified service water system problems.

Page 9 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 3/27/98 VIO Negative N ENG 4A The team noted that there were some weaknesses in the thoroughness of calculations, and the NCV VlO 98-80-05 adequacy of test results, evaluations and troubleshooting. Violations were identified regarding URI VIO 98-80-03 test control (unacceptable acceptance criteria for a battery test) and corrective action (repeated NCV 98-80-02 attempts to correct a diesel problem). A non-cited violation was identified for calculational errors URI 98-80-04 of minor significance. An unresolved item involving the adequacy of TS required battery testing remained open.

3!27/98 Positive IR 98-80 N ENG 4C BGE's safety evaluations (50.59) were well-written, technically rigorous, and in accordance with implementing procedures. 50.59 evaluation screenings were appropriately performed; no temporary or modifications reviewed were erroneously screened as not requiring a full safety evaluation.

3/27/98 NCV IR 98-80 N ENG 4B Operability determinations were technically well-written and showed an improving trend through Positive NCV 98-80-06 1997 in level of detail and supporting documentation. Several minor administrative deficiencies regarding operability determinations represented a non-cited violation.

3/27/98 NCV IR 98-80 N ENG 48 The engineering department provided effective and timely support in response to operations

  • Positive NCV 98-80-07 needs. Communications between the departments were generally good, with a notable exception of an instance involving degradation of the Low Pressure Safety injection (LPSI) system in January 1998, judged to be a non-cited violation of TS.

3/27/98 Positive IR 98-80 N ENG 4C POSRC presentations of safety evaluations and screenings were good. The POSRC and the OSSRC were appropriately carrying out their roles and responsibilities.

3/2798 Positive IR 98-80 N ENG 4B Training supplied by engineering to operators was generally good, with improvements noted  ;

subsequent to performance problems following the implementation of the digital feedwater modification.

3/27/98 Positive IR 98-80 N ENG 4C Problems were appropriately identified, reported, and processed through the issue Reporting 4B System. Root cause snalyses were commensurate with the safety significance of the issue.

4A Corrective actions were comprehensive for high priority issues but were not aggressively managed for lower category problems. Self-assessments and audits were of high quality, having sufficient scope and depth. Management was taking appropriate measures to improve the effectiveness of the corrective action program.

Page 10 of 21  ;

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 3/27/98 Positive IR 98-80 N ENG 4B The Mndon surveillance program was extensive and short term actions were appropriate. The lons term action development schedule was acceptable. Inspector Follow-up Item No.97-05-03 for both units was closed.

2/7/98 NCV IR 97-08 L ENG 4B When the secondary position indicating system was replaced during the 1994 Unit 1 refueling Negative NCV 97-08-03 outage, BGE's design control measures did not identify the need to change the variable power supply voltage and revise the applicable plant procedures and drawings. This violation of Appendix B, " Design Control" was not cited.

1/13/98 NCV IR 98-80 L ENG 2A Damage was found on the stanchion and restraining steel of a Unit 1 low pressure safety Negative IR 97-08 4B injection (LPSI) system pipe support located on the common discharge line. Both LPSI headers LER 98-003 were declared inoperable Technical Specification 3.0.3 was entered, and a plant shutdown was NCV 98-80-07 initiated. The damage was suspected to be the result of water hammer. A temporary modification was performed to remove the support. An engineering evaluation was performed to retum the systems to an operable status. The plant shutdown was terminated. The failure to enter the TS LCO in a timely manner was not cited.

1/4/98 VIO IR 97-08 S ENG 4A Unit 1 entered a condition outside of Technical Specifications due to having both secondary LER 98-001 2A (reed switch) control element assembly position indications out-of-service. Both the full-out and VIO 97-08-02 the voltage divider indications were inoperable. The cause of the voltage divider position indication being inoperable was a high setting on the power supply voltage. The high setting resulted from a combination of a drift in the power supply setting and engineering's failure to update the power supply voltage setting after the indication system was modified in 1994. This was a violation of TS.

2/11/98 Positive NRC Ltr of N ENG 4C Review of the third ten-year Inservice Test Program identified that BGE has maintained a focus 2/11/98 4B on safety in the development of their Inservice Testing (IST) Program.

2/11/98 Negative NRC Ltr of N ENG 4C Review of the third ten-year Inservice Test Program denied two relief requests and identified that 2/11/98 4B several required further BGE action. A contractor conducted program scope review revealed three items were potentially in non- compliance with ASME Code requirements.

12/20/97 Negative IR 97-07 S ENG 4C The inspectors concluded that BGE had implemented an effective saltwater performance URI 96-06-03 monitoring program in 1994. The initial performance monitoring report was thorough and detailed. However, the program guidance document was not maintained up-to-date and the program has not been continually implemented. Revisions to the program may be required after the installation of new service water heat exchangers.

Page 11 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Descnption 12/20/97 Positive IR 97-07 L ENG 1A BGE effectively implemented the operating procedures and corrective actions necessary to LER 96-001 2A maintain the operability and reliability of the SRW heat exchangers. Although the BGE efforts URI 94-80-01 4A had been effective, the operability of the service water heat exchangers continued to be URI 94-80-03 challenged by changing micro- and macro-fouling. The inspectors considered the potential for changing fouling factors and fouling rates will require continued BGE attention.

11/1/97 Positive IR 97-06 N ENG SC BGE had taken appropriate actions to address industry identified concems with the fatigue of welds on the 1 B,2A, and 2B emergency diesel generator tube-oil and jacket water piping systems.

11/1/97 VIO IR 97-06 N ENG 4C BGE stored ammonium hydroxide solution within the protected area boundary without ensuring VIO 97-06-02 4B that the plant was fully prepared for a potential spill of the storage tank contents. The need to place control room ventilation in the recirculation mode and to have the licensed operators don respiratory protection had not been fully considered. Procedures for response to an ammonia spill had not been developed. This was a violation of TS.

11/1/97 VIO IR 97-06 N ENG 4A Safety evaluation screening reports completed for toxic material tank installations had not VIO 97-06-01 considered the UFSAR and no safety evaluations were written to provide the basis that the changes did not involve unreviewed safety questions. In 1986, BGE increased the on-site storage of liquid ammonia from 55 gallon drums to a 5600 gallon storage tank without completing a written safety evaluation. Further, BGE had approved the replacement of the 5600 gallon tank with an 8500 gallon tank without a written safety evaluation providing the basis that the change did not involve an unrev;ewed safety question. This was a violation of 10 CFR 50.59.

7/29/98 VIO IR 98-07 N PS 3A A testing technician exhibited poor contamination control practices while working across a VIO 98-07-02 2B contaminated area boundary. The absence of clear contamination control policies and 3C procedures, mis-communication of radiation safety instructions, and incomplete training were identified as contributing causes for this event. Overall, this event represented continued poor radiological control practices at the facility.

Page 12 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 5/30/98 Positive IR 98-06 N PS SC BGE property implemented the work stipulations specified in sections A.1, A.2, and A.3 of the 3C NRC Confirmatory Act;on Letter issued in response to radiological protection problems. The inspectors observed that BGE was successful in separating planning activities from pre-job briefings. Additionally, BGE effectively communicated radiation safety expectations and assured compliance of field personnel by direct supervisory oversight. BGE plant assessment personnel were observed providing independent oversight of the pre-job planning and briefing meetings.

2/17/98 Positive IR 98-03 N PS SC BGE took action to review, eva!uate, and upgrade the radiation protection program following the April 3,1997, Unit 2 spent fuel pool diving event and the series of high radiation area access control events that occurred in early/mid-1997.

2/17/98 Positive IR 98-03 N PS SC There was generally a high level of management attention and oversight directed to resumption of diving activities and enhancement of the radiation protection program.

2/17/98 Positive IR 98-03 N PS 1C NRC review indicated generally good planning and preparation for the up coming April 1998 Unit 1 outage. BGE was reviewing planned work activities from a radiological risk perspective and generally good efforts were ongoing to identify risk significant areas / issues before the Unit 1 outage and modify program areas and procedures, as appropriate.

2/17/98 ED IR 98-03 N PS SA Weaknesses in evaluation of radiological conditions in the reactor cavity during the previous Unit Weakness VIO 98-03-01 2 outage and the subsequent planning and conduct of radiological work in the area, were VIO 98-03-02 identified. Although no personnel exposures in excess of regulatory limits was apparent, the failure to adequately evaluate the existing radiological conditions was identified as a violation of 10 CFR 20.15%) and 10 CFR 20.1703(a)(3). An airbome radioactivity area generated by the j event was not posted as required by 10 CFR 20.1902. Enforcement Discretion (ED) for these l violations was exercised.

I 3/14/98 Strength IR 98-01 N PS 1C Overall, BGE implemented an adequate radioactive waste processing, handling, storage, and transportation program. Good effo:ts continued to reduce quantities of radioactive waste, including liquid radioactive waste, released from the facility. Personnel involved in radioactive waste and material shipping received appropriate training and were knowledgeable of applicable regulatory requirements. Regulatory documents (e.g certificates of compliance and disposal facility licenses) were maintained current and were effectivelyimplemented. BGE effectively updated its UFSAR to describe its present waste processing, handling, and storage activities.

f 3/14/98 Negative IR 98-01 N PS SA A quality assurance audit of radioactive wMe activities was not well structured or defined.

l l 1

Page 13 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 2/7/98 Positive IR 97-08 N PS 3A BGE Security was effectively maintaining and competently administrating the security program.

2A Alarm station operators were knowledgeable of their duties and responsibilities, and communications requirements were being performed in accordance with the NRC-approved physical security plan. Security equipment was being properly tested and maintained as evidenced by minimal compensatory posting. Assessment aids had good picture quality and excellent zone overlap.

2/7/98 VIO IR 97-08 N PS 3B Two on-shift chemistry technicians were unable to correctly interpret the significance of VIO 97-08-06 simulated radiation readings for assuming the level of core damage in table top walkthroughs.

They did not follow their procedure when they failed to consult with the interim Site Emergency Coordinator to develop this assumption. This was a violation of 10 CFR 50.54(q). The inspectors noted that this training deficiency was similar to the exercise weakness observed in NRC Inspection Report 97-09.

2/7/98 VIO IR 97-08 N PS 2A Communication circuit testing was in violation of NRC requirements from September 1996 VIO 97-08-05 through September 1997. The corrective actions which were taken prior to the inspection exit interview and which were presented in an meeting at the Region I offices on February 2,1998, were adequate in response to this violation.

2/7/98 Positive IR 97-08 N PS 28 Overall, the emergency preparedness (EP) facilities, equipment, supplies and instrumentation were being adequately maintained. Facility inventory verifications were adequately performed.

BGE's changes to the Emergency Response Plan and Emergency Response Plan implementing Procedures were made in accordance with 10 CFR 50.54(q) of NRC regulations.

2/7/98 Positive IR 97-08 N PS 4B A review of the fire protection program found excellent procedura! guidance for the conduct of fire protection activities, an effective penetration seal program, appropriate control of fire brigade qualification, effective audits for identifying problems and initiating corrective actions, and good control of comoustible materials.

2/7/98 Positive IR 97-08 N PS 4B The BGE Self-Assessment of compliance with Appendix R to 10 CFR 50 was found to be a good initiative and valuable tool for identifying areas for improvement.

Page 14 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 11/20/97 Strength IR 97-09 N PS 1C Overall EP exercise performance was good. The Emergency Response Facilities (ERFs) were staffed and activated in a timely manner. The event classifications were correct and timely and offsite notifications were completed within 15 minutes. In the Technical Support Center (TSC),

the Reactor Core Engineering Team performed an exce!!ent analysis of time to core uncovering and cladding damage. The overall performance in the Operations Support Center (OSC) was very good and capable of ensuring protection of onsite emergency responders. The media center performance was good with effective communications between the licensee, county, and state personnel. '

11/20/97 Negative IR 97-09 N PS 1C An exercise weakness was identified in the dose assessment area at the Emergency Operations 3B Facility (EOF). The dosa assessment team produced unreasonable projections due to the operators' lack of understanding and knowledge of how to manipulate and interpret the licensee's automated dose assessment models. Because of this, the licensee could not adequately demonstrate that they were able to make a technically sound PAR based on radiological conditions.

11/20/97 Negative IR 97-09 N PS SA The inspectors determined that the licensee's formal critique did not meet the expectations described in NUREG-0654, Appendix E of Part 50 and NRC Procedure Module 82301. It appeared to be more of a " fact-finding" discussion than a formal presentation of exere:ise findings with preliminary qualitative assessment.

12/20/97 Negative IR 97-07 N PS 3B Weaknesses were identified in training and qualification of newly appointed professional level personnel, including the radiation protection manager. Also, not all appropriate personnel received training on some newly revised procedures. BGE assigned an individual as an interim RPM who would be responsible for program management, including approval authority, while the selected RPM would be appropriately trained and obtained the required experience.

12/20/97 Positive IR 97-07 N PS 1C BGE implemented a generally well defined sampling and analysis program in accordance with NRC Bulletin 80-10. Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored, Uncontrolled Release to the Environment. NRC review identified trace soil contamination (below Radiological Environmental Monitoring Program (REMP) Lower Limits of Detection (LLD) levels) at the station north outfall 002. BGE initiated a review of the issue.

Page 15 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 12/20/97 Positive IR 97-07 N PS 3C BGE provided general!y conservative intemal exposure contro, of its workers in its application of a wcighted derived air concentration (DAC) for potential exposure to airbome transuranics. BGE did reduce its transuranic DAC pending further evaluation of the acceptability of general use of such a DAC for all exposure scenarios.

12/20/97 Positive IR 97-07 N PS 1C BGE implemented a genera!!y effective contamination control program. However, criteria for use in evaluating laundry selected for re-monitoring needed improvement.

12/20/97 Negative IR 97-07 N PS 3A Radiation safety coverage requirements for fuel handling within the spent fuel pool were ambiguous and confusing. BGE implementation of a commitment to the NRC for continuous coverage during all work in the Spent Fuel Pool (SFP) was poor. In general, the inspectors noted that many procedures used by radiological controls personnel were complex and not user-friendly.

12/20/97 Positive IR 97-07 N PS 3B Radiological controls were appropriately implemented. Areas were found to be generally clean 3A and well maintained. Workers were found to be knowledgeable of the required radiological controls.

11/20/97 Negative IR 97-09 N PS 3B The dose assessment team could not adequately demonstrate that they could perform dose 1C projections for use in making a technically sound protective action recommendation based on radiological conditions. This was identified as an EP exercise weakness, however, this weakness did not preclude an overall exercise finding of good performance.

11/20/97 Positive IR 97-09 N PS 3B The Technical Support Center staff performance was an EP exercise strength. The Reactor 48 Core Engineering Team's analysis of the time to core uncovering and cladding damage was excellent.

11/20/97 Positive IR 97-09 N PS 2B Overall performance of the emergency response organization was good during the emergency 3B preparedness exercise inspection. Simulated events were accurately diagnosed, mitigation actions were performed, emergency declarations were timely and accurate, and offsite agencies were notified promptly.

12/20/97 VIO IR 97-07 N PS 3A A radiation survey of the spent fuel pool area was not performed during a shift when plant VIO 97-07-02 operators were working, as was required by the special work permit. BGE personnel believed a survey had been performed because there was a radiation technician assigned to the area.

However, the radiation technician never entered the spent fuel pool area to perform a survey, nor was he responsible for monitoring the operators' activities. This was a violation of TS 6.4.1.

Page 16 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 11/1/97 VIO 1R 97-06 N PS 3A Radiation safety technician performance weaknesses were observed during high radiation area VIO 97-06-06 coverage of a reactor coolant pump seat replacement that included poor placement of an air sampler and lack of knowledge of radiation levels of a canister that was located in the work area.

Sampling location represented an inadequate survey during Reactor Coolant Pump (RCP) work.

This was violation of 10 CFR 20.1501.

11/1/97 Positive IR 97-06 N PS 2A Waikdowns of various fire protection equipment, including fire hydrants, sprinkler piping, hose and nozzle storage boxes, and emergency fire pumps verified that all of the fire equipment was in good material condition and no problems were identified.

11/1/97 VIO IR 97-06 N PS 3A During the initial containment entry following a reactor trip, two radiation safety technicians made VlO 97-06-07 a high radiation entry without following the Special Work Permit requirement to wear the Thermoluminescent Dosimeter (TLD) on the outside of the Anti-C ciothing, with the beta window exposed. This was a violation of TS 6.4.1.

11/1/97 Positive IR 97-06 N PS 3A Good control and oversight to prevent foreign material from entering the reactor coolant system during reactor coolant pump seal replacement was observed.

11/1/97 VIO IR 97-06 N PS 3A Radiation safety technician performance weaknesses were observed during high radiation area VIO 97-06-05 3B coverage of a reactor coolant pump (RCP) seal replacement that included inadequate controi cf a worker who was not wearing the special work permit (SWP) required water resistant protective clothing and was observed spraying down a highly contaminated seal cartridge. This was a violation of TS 6.4.1.

11/1/97 Negative IR 97-06 N PS 3A Communication deficiencies were observed in a radiation safety technician tumover and in pre-job briefing for a reactor coc ant pump seal reolacement.

11/1/97 VIO 1R 97-06 N PS iC BGE had not developed and enplemented a procedure to prevent personnel contaminations VIO 97-06-04 from occurring as a result of contaminated Anti-C clothing. Although no significant skin contaminations had been observed, Anti-C articles that Md been retumed to Calvert Cliffs from the laundry vendor, were at times contaminated above the limits specified in the Calvert Cliffs procedure for laundering of Anti-C clothing. No procedure existed which specified actions to be taken when articles were found above the monitoring limits, including criteria for sample expansion, assessment of the contamination in excess of the limits, and actions to ensure that laundered clothing contaminated above acceptable limits was not made availab;e for general use. This was a vio'ation of TS 6 4.1.

Page 17 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX Date Type Source ID SFA Code item Description 11/1/97 Positive IR 97 06 N PS 1C The programs for radiological environmental monitoring (REMP) and meteorological monitoring program (MMP) continued to be effective. Management oversight of the REMP and MMP was effective. The quality assurance audits were of sufficient technical depth to identify and assess

+

program Strengths and Weaknesses. BGE audits evaluated the technical adequacy of implementing procedures, technical specification and offsite dose calculation manual implementation, and practices.

Page 18 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX ABBREVIATIONS USED IN PLANT ISSUES MATRIX (PIM) TABLE BGE Baltimore Gas & Electric CEA Control Element Assembly EOF Emergency Operations Facility EP Emergency Preparedness ERF Emergency Response Facilities FS 4 Final Safety Analysis Report JPM Job Performance Measure RO Reactor Operator LOOP Loss of Off-site Power LPSI Low Pressure Safetv Injection SRO Senior Reactor Operator NI NuclearInstrumentation NRC Nuclear Regulatory Commission OSC Operations Support Center OSSRC Offsite Safety Review Committee POSRC Plant Operations and Safety Review Committee RCS Reactor Coolant System REMP Radiological Environmental Monitoring Program SFP Spent Fuel Pool SIAS Safety injection Actuation Signal TSC Technical Support Center Page 19 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX GENERAL DESCRIPTION OF PIM TABLE COLUMNS D;te The actual date of an event or significant issue for those items that have a clear date of occurrence (mainly LERs), the date the source of the information was issued (such as for EALs), or the last date of the inspection period (for irs).

Type The categorization of the item or finding - see the Type / Findings Type Code table, below.

3, The document that describes the findings: LER for Licensee Event Reports, EAL for Enforcement Action Letters, or IR for NRC Inspection Reports.

ID Identification of who discovered issue: N for NRC; L for Licensee; or S for Self Identifying (events).

SFA SALP Functional Area Codes: OPS for Operations; MAINT for Maintenance; ENG for Engineering; and PS for Plant Support.

Code Template Code - see table below.

Details of NRC findings on LERs that have safety significance (as stated in irs), findings described in IR Executive Summaries, and Item Description amplifying information contained in EALs.

TYPE / FINDINGS CODES Licensing Licensing issue from NRR ED Enforcement Discretion - No Civil Penalty MISC Miscellaneous - Emergency Preparedness Finding (EP), Declared Emergency, Nonconformance issue.

Strength Overall Strong Licensee Performance etc. The type of a!I MISC findings are to be put in the WIakness OverallWeak Licensee Performance em es@on mn p

eel

  • Escalated Enforcement item - Waiting Final NRC '

Action 1 Operational Performance: A - Normal Operations; B - Operations During Transients; and C - Programs and Processes VIO Violation LevelI,11, Ill, or IV 2 Material Condition: A - Equipment Condition or B - Programs and Processes 3 Human Performance: A - Work Performance; B - Knowledge, Skills, and DEV Deviation from Licensee Commitment to NRC Abilities / Training; C - Work Environment Positive Individual Good Inspection Finding 4 Engineering / Design: A - Design; B - Engineering Support; C - Programs and Negative Individual PoorInspection Finding Processes LER Licensee Event Report to the NRC 5 Problem identification and Resolution: A -Identification; B - Analysis; and C -

URI " Unresolved item from inspection Report Resolution Page 20 of 21

Enclosure 1 CALVERT CLIFFS 1 & 2 PLANT ISSUES MATRIX l NOTES:

Eels are apparent violations of NRC requirements that are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Action" (Enforcement Policy),

NUREG-1600. However, the NRC has not reached its final enforcement decision on the issues identified by the Eels and ,

the PIM entries may be modified when the final decisicrw are made. Before the NRC makes its enforcement decisim. e licensee will be provided with an opportunity to either (1) respond to the apparent violaVon or (2) request a predecision't enforcement conference.

URis are unresolved items about which more information is required to determine whether the issue in question is an acceptable item, a deviation, a nonconformance, or a violation.

However, the NRC has not reached its final conclusions on the issues, and the PIM entries may be modified when the final conclusions are made.

Page 21 of 21

Enclosure 2 CALVERT CLIFFS INSPECTION PLAN FOR DECEMBER 1998 THROUGH MAY 1999 I inspection No. Program Area / Title Planned Dates g Type 92904 Followup - Plant Support 12/07/98 1 RI 71002 Licensing Renewal Inspection 2/1/99 TBD- Core 84750 Radioactive Waste Treatment, and Effluent and Environmental 1/11/99 1 Core Monitoring N/A initial License Examination Preparation 1/11/99 3 OA N/A Initial Ucense Examination Administration 1/25/99 3 OA 83750 Occupational Radiation Exposure - Outage 3/22/99 1 Core 83750 Occupational Radiation Exposure - NonOutage 5/10/99 1 Core -

Legend.

IP -

Inspection Procedure Number Tl -

Temporary Instruction Program / Sequence Number .

Core -

Minimum NRC Inspection Program (mandatory at all plants)

OA -

Otherinspection Activity RI -

Additional Inspection Effort Planned by Region i SI -

Safetyinitiative Inspection TBD -

To Be Determined E2-1

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