ML18152A488

Responds to NRC 891222 Ltr Re Violations Noted in Insp Repts 50-280/89-34 & 50-281/89-34 on 891029-1125.Corrective Actions:Steps in Operating Procedure 2-OP-1.3 Associated W/ Valve Test Being Evaluated for Inclusion in OP-7.1.1

ML18152A488
Person / Time
Site:	Surry
Issue date:	02/06/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-880, NUDOCS 9002220547
Download: ML18152A488 (13)

See also: IR 05000280/1989034

Text

-. VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 6, 1990 United States Nuclear Regulatory

Commission

Attention:

Document Control Desk Washington, D.C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SORRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION

-Ser_i al No. NL/RPC Docket Nos. License Nos. NRC INSPECTION

REPORT NOS. 50-280/89-34

AND 50-281/89-34 89-880 R3 50-280 50-281 . DPR-32 DPR-37 We have reviewed your letter dated December 22, 1989, in reference

to the NRC inspection

conducted-

on October 29 -November 25, 1989, for Surry Power Station. The inspection

was reported in Inspection

Report Nos! 50-280/89-34

and 50-281/89-34.

Our response to the violations

described

in the Notice of Violation

is provided in Attachment

1. Your letter expressed

concern over the material condition

of the process monitoring

instrumentation.

You requested

that we address our program to assure that process monitoring

equipment

is maintained

operable and outline specific actions being taken to return inoperable

process instrumentation

to service in an expeditious

manner.* -Operability

of the process monitoring

instrumentation

is demonstrated

periodically

through the station's

surveillance

and testing program. If a component

is found to be inoperable, alternative

measures are employed to monitor the parameter

in accordance

with Technical

Specifications

and a.station

deviation

is submitted.

On December 21, 1989, a station deviation

trending report was submitted

to the Chairman of the Station Nuclear Safety Operating

Committee (SNSOC), which discussed

recurring

problems with process radiation

monitors.

To more fully address these issues, the SNSOC established

a subcommittee

composed of senior technical

staff members. The subcommittee

has been tasked to review process radiation

monitoring

operations

data sources, including

equipment

operability

history, and to submit a report on its findings by February 28, 1990. 6ased on this report, SNSOC will assign further actions as appropriate.

We are keeping the NRC Resident Inspectors

informed of the progress and results of this review. The project to replace and return _the component

cooling water (CCW) heat exchanger

service water effluent monitors to operation

is being implemented

in conjunction

with the ongoing project to replace the CCW heat exchangers.

One. of the four installed

heat exchangers

has been replaced and the installation

of the associated

service water effluent monitor is scheduled

for completion

in February 1990, subject to receipt of the remaining

equipment.

The next two CCW heat exchangers

are scheduled

for replacement

during the Unit I ref~jPel~;/

9002220547

900206 PDR ADOCK 05000280 I,., Q PNV

The final CCW heat The alternative

remain in effect outage currently

planned for the fourth quarter of 1990. exchanger

is scheduled

for the second quarter of 1991. sampling measures specified

by Technical

Specifications

will until completion

of the project. In a telephone

conversation

between Mr. S. Shaeffer of the NRC Region II staff and Mr. D. Sommers of my staff, an extension

of 15 days was granted for our reply to this Notice of Violation.

We have no objection

to this inspection

report being made a matter of public disclosure.

Should you have .any further questions, please contact us. Very truly yours, &\-S~ W. L. Stewart Senior Vice President

-Nuclear Attachment

cc: U.S. Nuclear Regulatory

Commission

Region II 101 Marietta Street, N.W. Suite 2900 , Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector

Surry Power Station --------, I

NRC Comment ATTACHMENT

1 REPLY TO A NOTICE OF VIOLATION

REPORTED DORING THE NRC INSPECTIONS

ON OCTOBER 29 -NOVtMBER 25, 1989 INSPECTION

REPORT NOS. 50-280/89-34

AND 50-281/89-34

During the Nuclear Regulatory

Commission (NRC) inspection

conducted

on October 29 -November 25, 1989, violations

of NRC requirements

were identified.

In accordance

with the '.'General

Statement

of Policy and Procedure

for NRC Enforcement

Actions, 11 10 CFR Part 2, Appendix C ( 1989), the violations

are listed below: * A. 10 CFR 50, Appendix B, Criteriori

V, requires that activities

affecting

quality shall be prescribed

by documented

instructions

or procedures

appropriate

to the circumstances.

Contrary to the above, activities

affecting

quality were not prescribed

by adequate instructions

and/or procedures, in that: 1. Operating

Procedure, 2-0P-1.3, Unit Startup Operation

(350/450 to HSD), Revision dated June 14, 1989, did not adequately

caution the operators

to maintain specific pressure control prior to testing reactor coolant system accumulator

discharge

valves. On November 21, 1989, during Unit 2 startu~, operators

allowed the reactor coolant system pressure to eiceed 1000 psig, prior to cipening and de-energizing

the accumulator

discharge

isolation

valve motor operators, a violation

of Technical . Specification

3.3.A.10.

2. On November 13, 1989, a resin waste transfer evolution

was conducted

without adequate*

procedure

control resulting

in three licensee employees

being contaminated

when a pipe cap was removed from a pressurized

system; 3. On approximately

October 25, 1989, the Unit 2 flood control dikes, which protect against flooding of the service water supply motor control valves to the recirculation

spray heat exchangers, were removed with inadequate

modification

and operation

procedure

control resulttng

in heatup of the unit above 350°F, on November 6 and 20, 1989, with inoperable

recirculation

spray systems, a violation

of Technical

Specification

3.4. This violation

has been. categorized

as a Severity Level IV violation (Supplement

I) for Unit 2. B. 10 CFR 50, Appendix B, Criterion

VII, requires that measures and controls shall be established

to prevent the use of incorrect

or defective

material, parts, and components.

1 of 11

• • * Contrary to . the above, adequate measures were not established

to prevent incorrect

gaskets from being installed

in components

in that: 1. Work Order 87218, dated October 28, 1989, identified

that an incorrect

gasket had been installed

in. safety injection

check valve 2""'.SI-79

during the previous outage. This condition

had contributed

to a failure of the valve,to properly seat during subsequent

unit operation.

2. Inspection

of safety injection

check valve 2-SI-91 in accordance

with Engineering

Work -Request 89-6848, dated November 3, 1989, indicated

that an incorrect

gasket had been installed

during the previous outage. 3. After interim corrective

action was conducted

for examples 1 and 2 above on November 1, 1989, incorrect

gaskets were installed

in a Unit 2 pressurizer

safety valve on November 14, 1989, and subsequent

review revealed potential

incorrect

gaskets in the Unit 1 pressurizer

safety valves. This violation

has been categorized

as a Severity Level IV violation

.(Supplement

I) for Units 1 and 2. C. * Technical

Specification

3.7, Table 3.7.5(a) requires that grab samples be collected

and analyzed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever radioactive

liquid effluent monitoring

instrumentation

is out of service. Contrary to the above, grab* samples were not collected

and analyzed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in that, on August 2, 1989, samples for the Component

cooling service water effluent line were collected

and analyzed 30 minutes outside the required 12-hour timeframe.

This violation

has been categorized

as a Severity Level IV violation (Supplement

I) for Units 1 and 2. 2 of 11 ~.;-;-:

• RESPONSE TO NOTICE OF VIOLATION . INSPECTION

REPORT NOS. 50-280/89-34

AND 50-281/89-34

A. 10CFR50, Appendix B, Criterion

V, requires that activities

affecting

quality shall be prescribed

by documented

instructions

or procedures

appropriate

to the circumstances

.. Contrary to the above, activities

affecting

quality were not prescribed

by adequate instructions

and/or procedures, in that: 1. Operating

procedure, 2-0P-1.3, Unit Startup Operation

(350/450 to HSD), Revision dated June 14, 1989, did not adequately

caution the operators

to maintain specific pressure control prior to testing reactor coolant system accumulator

discharge

valves. On November 21, 1989, during Unit 2 startup, operators

allowed the reactor coolant system pressure to exceed 1000 psig, prior to opening and de-energizing

the accumulator

discharge

isolation

valve motor operators, a violation

of Technical*

Specification

3.3.A.10.

(1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION:

The violation

is correct as stated. (2) REASON FOR VIOLATION

Upon completion

of OP-7.1.1 (Leak Testing Accumulator

Check Valves), the electricians

were directed.to

reinstall

the seal-in contacts for the motor operated accumulator

discharge

valves. While waiting fof this step to be completed, the operations

shift reviewed the procedure

and decided to begin fncreasing

RCS pressure.

The shift had noted the 11 caution 11 prior to step 5.43. of 2-0P-1.3 which reads, 11 RCS pressure must remain less than 2000 psig until Step 5.62 is satisfied 11 , and intended to be just below 2000 psig when arriving at step 5.62. However, when the operator closed the accumulator

MOV in accordance

with step 5.41, he realized that the RCS should have been maintained

at less than 1000 psig to perform 2-PT-18.5 (Flushing

of Sensitized

Stainless

Steel Piping -Emergency

Borate and Acc~mulator

MOV Cycling).

• It is important

to note that it has been our interpretation

of Technical

Specification

3.3.A.10 that the basis for the requirement (RCS pressure greater than 1000 psig when placing the accumulators

in servjce and de-energizing

the associated

discharge

MOVs) was to provide sufficient

differential

between RCS and accumulator

pressures

to avoid spurious injections

• . It is from this perspective

that no violation

of Technical

Specifications

was initially

considered

to have occurred as a result of this event. The event investigation

focused on the violation

of Operating

Procedure

2-0P-1.3 when RCS pressure exceeded 1000 psig prior to completion

of 2-PT-18.5.

(3) CORRECTIVE

STEPS WHICH 'HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The accumulator

discharge

valves were opened and their circuit breakers opened. RCS pressure was controlled

per* 2-0P-1.3 and 2-PT-18.5

was * performed

satisfactorily.

The unit SRO and the unit RO were disciplined.

3 of 11 .~--* .. "' ~* *."" *r. *" .. '. ' .

• • * ,* ' (4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The steps in 2-0P-1.3 which are associated

with the accumulator

check valve test are being evaluated

for inclusion

in OP-7.1.1.

The 11 caution 11 prior to step 5.31 of the existing OP-1.3 which -reads, 11 RCS pressure.

must not exceed 1000 psig unti-1 PT-18.5 is complete (Step 5.42). will be strengthened

and added to OP-7.1.1.

Technical

Specification

3.3.A.10 will be reviewed for potential

clarification

of both the specification

and bases. (5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

Full compliance

will be achieved on June 30, 1990 when the procedures

are modified as described

above . 4 of 11

~-A. RESPONSE TO NOTICE OF VIOLATION

INSPECTION

REPORT NOS. 50-280/89-34

AND 50-281/89-34

10CFR50, Appendix 8, Criterion

V, requires that activities

affecting

quality shall be prescribed

by documented

instructions

or procedures

appropriate

to the circumstances.

Contrary to the above, activities

affecting

quality were not prescribed

by adequate instructions

and/or procedures, in that: 2. On November 13, 1989, a resin waste transfer evolution

was conducted

without adequate procedure

control resulting

in three licensee employees

being contaminated

when a pipe cap was removed from a pressurized

system. (1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION:

The violation

is correct as stated. (2) REASON FOR VIOLATION:

The event occurred*

due to pressure in a iection of the resin transfer header piping. An inservice

leak test was performed

on the header line on October 16, 1989. The procedure

used is typically

performed

on piping as part of the Inservice

Testing (IST) Program.*

Following

the use of this procedure~

the tested piping is returned to service and no instructions

are provided for depressurization

of the piping. However, the* resin header line was not returned to service and the line could not be drained because decontamination

support had not been provided.

There was no documentation

that the line was left in a pressurized

condition, and this information

was not provided to the appropriate

supervisor.

In addition, seat leakage on diaphragm

valves on the upstream system piping may have contributed

to the pressure in the header. On November 13, 1989, while making final hose connections

in preparation

for transferring

resin from the resin waste header to the receiving

vessel, it was necessary

to remove a cam-lock cap. The cam-lock fitting did not hav~ an upstream isolation

valve at the fitting which could be usJd for isolation

while the hose connections

were being made. The operators

began the removal of the cam-lock fitting by opening one of the* dog-ear connectors.*

The cap was manipulated

in an attempt to relieve any pressure on the 1 i ne. When rio water was observed, .* the remaining*

connector

was opened and the cap blew off spraying the employees

with contaminated

water. The resin transfer procedure

did not provide instructions

or cautions on the correct operation

of the cam-lock fitting. In addition, the procedure

did not provide an appropriate

level of detail for certain portions of the waste transfer process. * (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

In accordance

with station practice, the individuals

involved prepared a report of the event and presented

it to station management.

5 of 11

• • * An additional

instruction

page for the operation

of cam-lock type fittings was developed.

This attachment

will be used with evolutions

utilizing

cam-lock fittings, until permanent

procedure

changes can be completed.

The resin transfer header has been modified to provide an isolation

valve upstream at the cam~lock fitting. Resin transfer activities

were suspended

and no resin transfer activities

will occur pending station safety committee (SNSOC) approval of a procedure

providing

the additional

detailed steps for the evolutions

involved in the* transfer process. (4) .CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

A revision is being made to the procedure

for resin transfers

to provide more detailed instructions

for the evolutions

in the resin transfer process including

instructions

for cam-lock fittings.

A list of procedures

that involve equipment

using cam-lock fittings is being developed.

These procedures

will be revised to include appropriate

cautions.

Since the lack of an appropriate

inservice

leak testing procedure

may have contributed

to the event, an additional

testing procedure

for inser~ice

leak testing will be developed

to include instructions

for d~pressurization

of the tested piping if it is not placed in service following

the test. (5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

Resin transfers

may resume when a revised procedure

is approved by the SNSOC. The procedure

rev1s1ons

covering the use of cam-lock fittings and the development

of a procedure

for inservice

leak testing will be completed

by June 30, 1990. Full compliance

will be achieved on June 30, 1990. -During review of this event and a subsequent

event in January involving

instrument

air to this system, weaknesses

were identified

in the configuration

control and modification

turnover processes.

Although not a direct contributor

to the above violation, these weaknesses

are being reviewed and applicable

corrective

actions initiated . 6 of 11 i ., "" ,----on" .J

• • A. RESPONSE TO NOTICE OF VIOLATION

INSPECTION

REPORT NOS. 50-280/89-34

AND 50~281/89-34

I0CFR50, Appendix B, Criterion

V, requires that activities

affecting

quality shall be prescribed

by documented

instructions

or procedures

appropriate

to the circumstances.

Contrary to the above, activities

affecting

quality were not prescribed

by adequate instructions

and/or procedures, in that: -* 3. On approximately

October 25, 1989, the Unit* 2 flood control dikes, which protect against flooding of the service water supply motor control valves to the recirculation

spray heat exchangers, were removed with inadequate

modification

and operation

procedure

control resulting

in heatup of the unit above 350° F, on November 6 and 20, 1989, with inoperable

recirculation

spray systems, a violation

of Technical

Specification

3.4. (1) ADMISSION

0~ DENIAL OF THE ALLEGED VIOLATION:

The violation

is correct as stated. (2) REASON FOR VIOLATION:

A Design Change was being implemented

to replace portions of the Service Water piping* and to i_nstall new 8 11 service water supply lines. A portion of the buried piping was routed just north of the service water valve pit containing

the service water supply valves. (2-SW-MOV-203A-D)

to the recirculation

spray heat exchangers.

The original design and safety analysis had been prepared anticipating

that the missile protection

cover plates could be installed

without affecting

the dikes around the SW valve pit. However, the dikes created an interference

when installing

the plates, and a Field Change was issued revising the installation

drawing to permit temporary

removal and replacement

of the dike wall 11 as required 11* * UFSAR Appendix 9C on the flood control system was not* complete in its description

of the flood protection

barriers, nor were the dikes physically

labeled in the field to identify them as components

of the flood _control system. As a result~ the flood protection

significance

of the dike components

was overlooked, and the field change did not provide procedural

steps to control this activity nor to limit the period during which the dike wall was removed. (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED: (a) The dikes were reinstalled

on the same day the condition

was identified. (b) The station flood protection

dikes throughout

the plant have been labeled with a cautionary

_legend. (c) A memorandum

describing

the incident and taken to ~revent iecurrence

of inadequate

revi.ew was distributed

to Design December 4, 1989. 7 of 11 corrective

actions to be Field Change preparation

and Engineering

personnel

on .. .*.** ... ~:**. .........

_,*~-... -"['"";:",";";-:***

I I -I I I -------------

• * (4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The following

corrective

actions will be taken to avoid recurrence: (a) Information

on the flood protection

barriers will be included in the continuing

training sessions for the Technical_

Support Staff to enhance general awareness

of the need to maintain integrity

of these barriers. (b) The UFSAR section on flood control will be reviewed and a change request processed

to provide more complete information

on the flood protection

barriers. (c) An engineering

review of the adequacy of testing and maintenance

of flood control measures has *been initiated. ( 5) THE .DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

Full compliance

will be achieved when the corrective

actions identified

in item (4) above are completed

on September

30, 1990. The UFSAR change wfll be included in the annual update subsequent

to September

30, 1990. 8 of 11

• • • B. RESPONSE TO NOTICE OF VIOLATION

INSPECTION

REPORT NOS. 50-280/89-34

AND 50-281/89-34

10 CFR 50, Appendix B, Criterion

VIII, requires that measures.and

controls . shall be established

to prevent the use of incorrect

or defective

material, parts,* and components.

Contrary to the above, adequate measures were not established

to .Prevent incorrect

gaskets from being installed

in components

in that: 1. Work Order 87218, dated October 28, 1989, identified

that an incorrect

gasket had been installed

in safety injection

check valve 2-Sl-79 during the previous outage. This condition

had contributed

to a failure of the valve to properly seat during subsequent

unit operation.

2. Inspection

of safety injection

check valve 2-SI..;.91

in accordance

with * Engineering

Work Request 89-684B, dated November 3, 1989, indicated

that an incorrect

gasket had been installed

during the previous outage. 3. After interim corrective

action was conducted

for examples 1 and 2 above on November 1, 1989, incorrect

gaskets were installed

in a Unit 2 pressurizer

safety valve on November 14, 1989, and subsequent

review revealed potential

incorrect

gaskets in the Unit 1 pressurizer

safety valves. (1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION:

The violation

is correct as stated. (2) REASON FOR VIOLATION:

Inaccuracies

existed in certain aspects of model work orders in the area of parts and associated

stock numbers required to perform the task. The model work orders were not subject to a formal control program and verification

of the parts listed on the model work order were not performed

by planning or maintenance

personnel.

This omission resulted in incorrect

gaskets being installed

in two (2) safety injection

check valves (2-SI-79/2-SI-91)

when model work order parts listings were used. Another incident occurred whereby wrong gasket material was installed

on a Unit 2 pressurizer

safety valve due to the same inadequacie~.

• (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Upon initi,ll discovery

of wrong material installation

on certain safety related* components, an investigation

was performed

within the maintenance

department.

The problem was determined

to be inadequate

parts verification

prior to .job implementation.

The information

concerning

parts listed on the model work order was being incorrectly

assumed as being correct. Once this problem was identified, an interim verification

of parts for safety related work was established.

The corrective

steps taken by the Maintenance

Department

were as follows: a. Oeve l opment of an "Engineering

Parts Validation

Program" which established

the process whereby engineering

personnel

ensure that 9 of 11

~. b. correct parts/components (with regard to technical

data and materials)

are installed

in the respective

system per design and licensing

requirements.

This program applies to safety related and non-safety

related * (with special regulatory

significance)

work orders. Implementation

of this 11 Validation

Program 11 was effective

on November 1, 1989. The Maintenance

Engineering

Department

currently

performs this function.

Since _the implementation

of the parts validation

process, there was the one instance referenced

in the violation

where the Maintenance

Department

inadvertently

installed

wrong gaskets in a Unit 2 pressurizer

safety valve. At that time,. the validation

process was still in the initial stages, and it is felt that the incident was an isolated case. The validation

process of parts verification

now is very closely controlled.

Since the incorrect

gasket installation

on November 14, 1989, there have been no identified

cases of incorrect

parts usage. (4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

Concerning

the Unit 1 Pressurizer

Safety Valves and the possibility

of incorrect

gasket material being installed, the safety significance

of this configuration

has been evaluated

and determined

to be acceptable

for continued

operation.

Work requests will be submitted

to remove valves and inspect/replace

gaskets as necessary

to ensure the c-orrect gasket type is installed.

This replacement

of gaskets will be performed

at the next refueling

outage. (5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

Full compliance

with regard to programmatic

changes for parts validation

measures was achieved on November 15, 1989, although the pressurizer

safety * valve gasket concern on Unit 1 will be resolved during the upcoming refueling

outage. 10 of 11

.. ' RESPONSE TO NOTICE OF VIOLATION

INSPECTION

REPORT NOS. 50-280/89-34

AND 50-281/89-34

C. Technical

Specification

3.7 5 Table 3.7.5(a) requires that grab samples be collected

and analyzed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever radioactive

liquid effluent monitoring

instrumentation

is out of service. Contrary to the aboves grab samples were not collected

and analyzed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in thats on August 2, 1989 5 * samples for the component

cooling service water effluent line were collected

and analyzed 30 minutes outside the required 12-hour time frame. (1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION:

The violation

is correct ~s stated. (2) REASON FOR VIOLATION:

The cause of the event was personnel

error. The turbine building operator log requires sampling once per eight hour shift. The previous sample had been obtained early in the shift, and the liquid waste control room operator did not effectively

communicate

to the turbine building operator when the next sample would be required .. (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The event was reviewed with the turbine building and liquid waste operators.

The liquid waste operator was disciplined.

• * The liquid waste control room operator's

log has been revised to include a section that specifically

identifies

the time and date the heat exchangers

were last sampled and the ti~e when the next sample is to be taken. (4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

Design work is in progress to replace the existi~g component

cooling service water radiation

monitoring

system concurrent

with replatement

of the Component

Cooling Water Heat Exchangers.

The new design consists of a detector that will be mounted in a dry well in each heat exchanger.

This design contains no piping subject to fouling and provides an individual

detector for each heat exchanger.

(5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

Ful.l compliance

with Technical

Specifications

was achieved August 2, 1989. The heat exchanger

replacement

project is underway and is currently

scheduled

to be completed

by Spring, 1991. 11 of 11