IR 05000395/1987023

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App to SALP Rept 50-395/87-23
ML20238D343
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 10/09/1987
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20238D331 List:
References
50-395-87-23-AP, NUDOCS 8801040214
Download: ML20238D343 (15)


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December 24, 1987 ENCLOSURE APPENDIX TO SOUTH CAROLINA ELECTRIC AND GAS COMPANY V. C. SUMMER PLANT SALP BOARD REPORT NO. 50-395/87-23 (DATED OCTOBER 9, 1987)

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8801040214 871224 PDR ADOCK 05000395 0 DCD l ..

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December 24, 1987 I. Meeting Summary A. A meeting was held on October 21, 1987, at South Carolina Electric and Gas Company's V. C. Summer Nuclear Training Center in Jenkinsville, South Carolina, to discuss the SALP Board Report for the V. C. Summer facility.

B. Licensee Attendees:

T. C. Nichols, Jr. , President and Chief Operating Of ficer 0. W. Dixon, Senior Vice President, Operations D. A. Nauman, Vice President, Nuclear Operations 0. S. Bradham, Director, Nuclear Plant Operations R. V. Tanner, Executive Vice President, Santee Cooper W. A. Williams, Jr. , Special Assistant, Nuclear Operations, Santee Cooper D. Moore, ' Director, Quality and Procurement Services J. K. Skolds, Deputy Director, Operations and Maintenance K. W. Nettles, Group Manager, Technical Services D. A. Lavigne, Manager, Materials and Procurement A. M. Paglia, Jr. , Manager, Nuclear Licensing M. N. Browne, Group Manager, Technical and Support Services W. R. Baehr, Manager, Corporate Health Physics and Environmental Programs F. J. Leach, Manager, Quality Assurance S. R. Hunt, Manager, Nuclear Quality Control J. P. Harrison, Manager, Nuclear Operations Services M. D. Quinton, Manager, Maintenance Services

. L. A. Blue, Manager, Support Services

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K. W. Woodward, Manager, Nuclear Operating Tra,ining F. H. Zander, Manager, Nuclear Technical Training G. G. Soult, Manager, Operations C. W. Bowman, Project Controls K. E. Beale, Manager, Nuclear Protection Services C. NRC Attendees:

M. L. Ernst, Deputy Regional Administrator, Region II (RII) l L. A. Reyes, Director, Division of Reactor Projects (DRP), RII {

E. G. Adensam, Director, Project Directorate II-1, Division of l Reactor Projects, NRR -

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H. C. Dance, Chief, Reactor Projects Section 18, DRP, RII 1 J. B. Hopkins, Project Manager, NRR R. L. Prevatte, Senior Resident Inspector, Summer P. C. Hopkins, Resident Inspector, Summer j

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December 24, 1987 J II Errata Sheet - Summer SALP Page Line Now Reads Should Read 10 8 ... radioactive waste shipment . . radioactive waste shipment properly. (86-10) properly. (87-10)

Basis for change: To correct typographical error.

17 1 Two violations were Three violations were identified .., identified ...

17 10 c. Severity Level V violation for failure to promptly evaluate and  ;

classify reactor coolant '

system pressure boundary leakage as an Unusual Event. (87-14)

Basis for change: To correct for the missing Severity Level V violation which should have been located in the Radiological Controls area, 18 29 ... tube plugging, tube .. tube plugging, tube plug removal .. removal . l I

Basis for change: To correct inaccurate information presented in the SALP i Report.

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j 29 1-8 c. Severity Level III .. ]

(Issued: March 11, i 1987; 85E039).

2. Actions without Civil 2. Actions without Civil Penalties Penalties

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Severity Level III . a. Severity Level III ... l (Issued: March 10 (Issued: March 10, l 1987; 86E055). 1987; 86E055). l

b. Severity Level III .

(Issued: March 11, 1987; 85E039).

Basis for change: Item V.E.1.c. was mistakenly categorized as a Severity Level III violation for which a civil penalty was assessed.

This violation should be listed under Item V.E.2. for those violations which did not result in Civil Penalties.

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December 24, 1987 Page Line Now Reads should Read 30 22 1 1 2 1 30 31 7 10 4* 8 10 4*

- Basis for Change: The changes to this Violation Summary page reflect the addition of the violation in the Radiological area discussed above.

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. 10 6. Severity' Level IV violation for failure to specif quantities of carbon-14 and iodine-129 on a ship nt manifest. (86-04)

c. Severity level IV violation for failure to a procedures ere to for health physics computer ftware verification. (86-04) -

d. Severity level IV violation 'for failure o classify a radioactive waste shipment properly. (86- 0)

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Severity level V violation for failure o verify the vo'ume of the geometries used to conduct urveys of gaseous radioactive material releases to th environment. (87-21)

2. Conclusion Category: 1 3. Board Recommendations

A reduced NRC inspection act ity is recommended.

C. Maintenance 1. Analysis During the assessme resident and regio al period, staffs. inspections were performed by the The maintenance organization is adequately staffed and trained to support th operation of the plant.

writer and In 1986, a procedure I

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discipline spare parts specialist wee added to each  !

ventilati nd a maintenance engineer was assigned for heating, '

and air conditioning. Work activities are controll d by well developed procedures and instructions.

The val e censee continues to expand its use of the motor operated f regraphic oiltest analysis system (MOVATS), infrared analysis, analysis and vibration analysis to assist in edictive maintenance. Additional equipment has been obtained for MOVATS and the data' bank has been enlarged as additional equipment is tested. The licensee has achieved success in their use of INp0's Nuclear Plant Reliability Data System to predict

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A and identify failed parts. The use of predictive maintenance data to revise'the schedule of preventative maintenance has led g to a reduction in equipment failures.

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10 REVISION b. Severity Level IV violation for failure to specify quantities of carbcn-14 and iodine-129 on a shipment manifest. (86-04)

c. Severity Level IV violation for failure to adhere to procedures for health physics computer software verification. (86-04)

d. Severity Level IV violation for failure to classify a radioactive waste shipment properly. (87-10)

e. Severity Level V violation for failure to verify the volume of the geometries used to conduct surveys of gaseous radioactive material releases to the environment. (87-21)

2. Conclusion Category: 1 3. Board Recommendations

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A reduced NRC inspection activity is recommended.

C. Maintenance 1. Analysis During the assessment period, inspections were performed by the resident and regional staffs.

The maintenance organization is adequately staffed and trained to support the operation of the plant. In 1986, a procedure writer and a spare parts specialist were added to each discipline and a maintenance engineer was assigned for heating, e ventilation and air conditioning. Work activities are controlled by well developed procedures and instructions.

The licensee continues to expand its use of the motor operated valve analysis test system (MOVATS), infrared analysis, ferrographic oil analysis and vibration analysis to assist in predictive maintenance: Additional equipment has been obtained for MOVATS and the data bank has been enlarged as additional equipment is tested. The licensee has achieved success in their use of INP0's Nuclear Plant Reliability Data System to predict and identify failed parts. The use of predictive maintenance data to revise the schedule of preventative maintenance has led to a reduction in equipment failures.

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w T' o violations were deficiency:

identified and as indicated abo J

indicative of a programmatic ot L

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Severity t.evel IV violation for an inadequate pr cedure defining emergency. notification of offsite authorities f an (86-08)

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Severity Level V violation for failure to pr ide training to a key member of the Emergency Organizati

" Fission Product Barrier Approach" to eve regarding the (86-05) classification.

2. Conclusion Category: 2 3.

Board Recornmendation No change in NRC inspection activ y is recommended.

G.

Security and Safeguards 1. Analysis During the evaluation pe resident and regional od, inspections were performed by the staffs. A Regulatory Effectiveness Review (RER) was cond ted in March 1986.

Secority force sta plants of similar size.ing was adequate and consistent with that of perform require duties. The security staff had been trained to innovative wit The training program was extensive and classroom in a well balanced mixture of hands on and motivated ruction which resulted in a highly capable and curity force.

activitie Observation of security force training programduringandperiods a commitmentof inspection verified a quality members of the security force. to excellence by individual S'i t management un exhibited an excellent knowledge and o the security program.estanding of security requirements and de

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The RER team visited the site and found no safeguards vulnerabilities.

p cp inadequacies and Although not considered requirements, several immediate corrective weaknesses action by were identified and received the licensee.

/ identified strengths in the areas as barriers, maintenance program, deployment of the security force.

The RER ceam Summer security program, in training and tactical l

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17 REVISION Three violations were identified and as indicated above were not indicative of a programmatic deficiency:

a. Severity Level IV violation for an inadequate procedure defining , notification of offsite authorities of an emergency. (86-08)

b. Severity Level V violation for failure to provide traini.ig to a key member of the Emergency Organization regarding the

" Fission Product Barrier Approach" to event classification.

(86-05)

c. Severity Level V violation for failure to promptly evaluate and classify reactor coolant system pressure boundary leakage as an Unusual Event. (87-14)

2. Conclusion Category: 2 3. Board Recommendation No change in NRC inspection activity is recommended.

G. Security and Safeguards 1. Analysis During the evaluation period, inspections were performed by the resident and regional staffs. A Regulatory Effectiveness Review (RER) was conducted in March 1986.

Security force staffing was adequate and consistent with that of plants of similar size. The security staff had been trained to e perform required duties. The training program was extensive and innovative with a well balanced mixture of hands-on and classroom instruction which resulted in a highly capable and motivated security force. Observation of security force activities during periods of inspection verified a quality training program and a commitment to excellence by individual members of the security force.

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Site management exhibited an excellent knowledge and understanding of security requirements and demonstrated support of the security program.

The RER team visited the site and found no safeguards vulnerabilities. Although not considered requirements, several inadequacies and weaknesses were identified and received I immediate corrective action by the licensee. The RER team i

identified strengths in the Summer security program, in such areas as barriers, maintenance program, training and tactical deployment of the security force.

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18-The licensee recently installed a new security computer '

enhance the effectiveness of the security program. Funct nal operability of the. computer and associated systems is p ding completion addition, of testing and acceptance of the systems In relocation of the affected protected area fencing nethe essitated by the new access control facility, installation o additional closed circuit television (CCTV) cameras and an banced alarm system is indicative of an ongoing management mmitment to a quality security program. The security equip nt and enhancements clearly add to the effectiveness and operational facility capabilities of the security organization.

One violation was identified. The licen ee had identified the violation and provided prompt and effec ve corrective action.

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Severity Level IV violation f floor grating. (87-12) an unsecured vital area 2. Conclusion Category: 1 3.

Board Recommendation A reduced NRC inspecti activity is recommended.

H. Outages 1. Analysis During refueling theo aage.

essment period the unit underwent a 95 day operations The resident Resident and regionalinspectors observed based inspectors refueling observed outage ac ivities.

The acti th rd refueling outage was completed on June 9, 1987. Major the ties accomplished during this outage included: refueling; e y peening, stress relieving, tube plugging, tube removal and current testing of steam generator tubes; five year erbaul on diesel generator B; overhaul of reactor coolant pump A motor; seal replacement on reactor coolant pumps A and B; gD reactor vessel inservice inspection; reactor baf fle inspection cp for jet impingement; inspection of the service water system for microbiological induced corrosion and corbicula infestation;

/. inspection of Teedwater piping as related to the Surry steam line break and completion of design changes and modifications.

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18 REVISION j The licensee recently installed a new security computer to enhance the effectiveness of the security program. Functional operability of the computer and associated systems is pending completion of testing and acceptance of the systems. In addition, the construction of' a new access control facility, relocation of the affected protected area fencing necessitated by the new access centrol facility, installation of additional closed circuit television (CCTV) cameras and an enhanced alarm system is indicative of an ongoing management commitment to a quality security program. The security equipment and facility enhancements clearly add to the effectiveness and operational capabilities of the security organization.

One violation was identified. The licensee had identified the violation and provided prompt and effective corrective action.

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Severity Level IV violation for an unsecured vital area floor grating. (87-12)

2. Conclusion Category: 1 3. Board Recommendation

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A reduced NRC inspection activity is recommended.

H. Outages 1. Analysis ~

During the assessment period the unit underwent a 95 day refueling outage. The resident inspectors observed refueling operations. Resident and regional based inspectors observed e outage activities.

The third refueling outage was completed on June 9,1987. Major activities accomplished during this outage included: refueling; shot peening, stress relieving, tube plugging, tube plug removal and eddy current testing of steam generator tubes; five year overhaul on diesel generator B; overhaul of reactor coolant pump A motor; seal replacement on reactor coolant pumps A and B; reactor vessel inservice inspection; reactor baffle inspection for jet impingement; inspection of the service water system for microbiological induced corrosion and corbicula infestation; inspection of feedwater piping as related to the Surry steam line break and completion of design changes and modifications.

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. 29 I c. Severity Level III problem for fire protectioE requirements - Appendix R.

each. This matter was discussed inTwo violationSA with the previous LPtwo ex oples report. (Issued: March 11, 1987; 85E039).

2.

Actions without Civil Penalties

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Severity Level III problem with two violat ns, for hand overexposure.

matter. The licensee is currently ppealing this (Issued: March 10, 1987; 86E05 .

3. Orders Order imposing $50,000 Civil Penalty was issued on September 19, 1986, for the Severity Level III pr lem on the Component Cooling Water trains inoperability. e Civil Penalty was paid on October 17, 1986.

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Enforcement Conferences Held During A raisal Period 1.

An enforcement conference wa held in the Region II office on February 28, 1986, to disc s the Cooling Water trains. inoperability of Component 2.

An enforcement conferen e was held in the Region II office on July 3, 1986, to discu s the misalignment of the Charging Pumps.

3. An enforcement con

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December 16, 1986 rence was held in the Region II office on I to discuss the hand overexposure issue.

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Confirmation of Act n Letters ~~

l None H. Licensee Even Report During the valuation period, 25 of 37 LERs submitted by the licensee were revieweval ated by the NRC staff to determine the event cause and se content.

in the Summary of comments provided to the licensee are icensing Activities section of this report. The distribution of tF se events were as follows:

Cause Number A

Component Failure Design 5

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/ Construction, Fabrication, or Installation Personnel

- Operating Activity

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29 REVISION 2. Actions without Civil Penalties a. Severity Level III problem with two violations, for hand overexposure. The licensee is currently appealing this matter. (Issued: March 10, 1987; 8CE055).

b. Severity Level III problem for fire protection requirements - Appendix R. Two violation with two examples each. This matter was discussed in the previous SALP report. (Issued: March 11, 1987; 85E039).

3. Orders Order imposing $50,000 Civil Penalty was issued on September 19, 1986, for the Severity Level III problem on the Component Cooling Water trains inoperability. The Civil Penalty was paid on October 17, 1986.

F. Enforcement Conferences Heid During Appraisal Period 1. An enforcement conference was held in the Region II office on February 28, 1986, to discuss the inoperability of Component Cooling Water trains.

2. An enforcement conference was held in the Region II office on

, July 3, 1986, to discuss the misalignment of the Charging Pumps.

3. An enforcement conference was held in the Region II office on December 16, 1986, to discuss the hand overexposure issue.

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G. Confirmation of Action Letters None H. Licensee Event Report During the evaluation period, 25 of 37 LERs submitted by the licensee were evaluated by the NRC staf f to determine the event cause and review the content. Summary of comments provided to the licensee are in the Licensing Activities section of this report. The distribution of these events were as follows:

Cause Number Component Failure 5 Design 1 Construction, Fabrication, or Installation 2 Personnel

- Operating Activity 6

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- Test / Calibration Activity 6

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Out of Calibration 0 Other

Total 25

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2. 10 CFR Part 21 Reports

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Anchor Darling Check Valves, February , 1986, discussed in LER 86-01

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ESF Load Sequencer, June 5,1987, scussed in LER 87-10.

I. Enforcement Activity A summary of violations tabulated pe SALP functional areas are shown in the following table.

FUNCTIONAL AREA NUWER OF DEVIATIONS AND VIOLATIONS

/ IN EACH SEVERITY LEVEL V IV III II I Plant Operations 1 1 2 Radiological Control 1 3 1 Maintenance Surveillance 1 Fire Protection 2 l'

Emergency Preparedness 1 1 Security

Outages 1 1 Quality Programs nd 2 1 Administrative Controls Affecting-Q 11ty Licensing Ac ivities Training a Qualifications Effecti eness -

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30 REVISION

- Maintenance Activity 2

- Test / Calibration Activity 6

- Other 1 Out of Calibration 0 l Other 2 Total 25 2. 10 CFR Part 21 Reports

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Anchor Darling Check Valves, February 19, 1986, discussed in LER 86-01

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ESF Load Sequencer, June 5,1987, discussed in LER 87-10.

I. Enforcement Activity A summary of violations tabulated per SALP functional areas are shown in the following table.

FUNCTIONAL NUMBER OF DEVIATIONS AND VIOLATIONS l

AREA IN EACH SEVERITY LEVEL D V IV III II I Plant Operations 1 1 2 Radiological Control 1 3 1 Maintenance Surveillance 1 Fire Protection 2 1" Emergency Preparedness 2 1 Security 1 e

Outages 1 1 Quality Programs and 2 1 Administrative Controls Affecting Quality Licensing Activities Training and Qualifications -

Effectiveness Total -

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December 24, 1987 s

III. Licensee Comments Licensee comments sub.nitted in response to the SALP Board Repert follow.

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November 20, 1987 l :7 ' ' . ' cdO : 20 Dr. J. Nelson Grace Regional Administrator U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323 Subject: Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. HPF-12 Coments on 1987 Systematic Assessment of Licensee Performance

Dear Dr. Grace:

On October 21, 1987, a meeting was held at the Virgil C. Summer Nuclear

' Training Center to discuss the NRC Systematic Assessment of Licensee Performance (SALP) evaluation of South Carolina Electric & Gas Company (SCE&G) for the January 1, 1986 through July 31, 1987 period. This meeting and the SALP report provided for a valuable exchange of information between SCE&G and the NRC. The meeting allowed for an open discussion of topics and concerns relevant to operations at the Virgil C. Summer Nuclear Station which enabled varying perspectives to be viewed by both parties. The October 9, 1987 SALP report was a well written document which accurately reflected improving plant. performance by SCE&G in regards to the operation of its nuclear With respect to the October 9, 1987 report, SCE&G requests several minor corrections be addressed in the final SALP Board package. These corrections are identified below:

1.

On page 10, Item IV.B.1.d should read (87-10) instead of (86-10).

2. On page 17. Item IV.F.1 should indicate a total of three violations instead of the two presently identified. Therefore a new item F.1.c should be added to reflect a severity level V violation for failure to evaluate and classify reactor coolant system leakage (87-14).

3.

On page 18, Item IV.H.1, second paragraph, major activities accomplished during the outage identified " tube removal" which was not performed.

SCE&G did perform a significant amount of work on the steam generators including tube " plug" removal; however, " tube removal" was not attempted.

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e' ? ' Dr. J. Nelson Grace

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November 20, 1987 Page 2

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4.

On page 21. Item IV.I.1, the report indicated that the " site engineering group appeared slightly understaffed to fulfill the increased work load as design work is shifting from the design consultant to plant staff."

While SCE&G does not totally agree with this conclusion, it is understandable how that judgement could be derived if the group is viewed during a particularly busy time.

5. On page 29, Item V.E.1.c is categorized as a Level III problem for which y a civil penalty was assessed. This Level III problem was not assessed a civil penalty due to the unusually prompt and extensive corrective action implemented by SCE&G. Therefore, the item should be listed under Item V.E.2.

6. On page 30, Item V.1, the table should indicate two Level V violations rather than one in the area of Emergency Preparedness; therefore, the total number of Level V violations should be 8 vice 7.

Again in summary, SCE&G considers the report to have been well written and the October 21, 1987 meeting to have provided a forum for an excellent exchange of views between NRC and SCE&G management. The opportunity to provide the above coments to the SALP report is greatly appreciated.

If you have any questions, please advise.

l tr urs, I l 1

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. . Na man AM/ DAN:jez i

c: 0. W. Dixon, Jr./T. C. Nichols, Jr.  !

E. C. Roberts 0. S. Bradham D. R. Moore W. A. Williams, Jr.

Group Managers W. R. Baehr C. A. Price R. B. Clary W.,R. Higgins .

W. T. Frady C. L. Ligon (NSRC)

R. M. Campbell, Jr.

K. E. Nodland J. C. Snelson

' G. O. Percival R. L. Prevatte J. B. Knotts, Jr. -

RTS NPCF File

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