IR 05000445/1987024

Insp Repts 50-445/87-24 & 50-446/87-18 on 871007-1103.No Violations or Deviations Noted.Major Areas Inspected:Items of Noncompliance/Deviations,Review of Allegations,Technical Audit Program & General Plant Areas

ML20236Q589
Person / Time
Site:	Comanche Peak
Issue date:	11/12/1987
From:	Barnes I, Hale C NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20236Q581	List: IR 05000445/1987024 ML20236Q580
References
50-445-87-24, 50-446-87-18, NUDOCS 8711200158
Download: ML20236Q589 (14)

Text

'

l

. ,

l l

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS NRC Inspection Report: 50-445/87-24 Permits: CPPR-126

,

50-446/87-18 CPPR-127 i

.1 Dockets: 50-445 Category: A2 50-446 Construction Permit ,

.

Expiration Dates: I l

Unit 1: August 1, 1988  !

Unit 2: Extension request l

submitte l Applicant: TU Electric )

Skyway Tower i 400 North Olive Street

' Lock Box 81 Dallas, Texas 75201 Facility Name: Comanche Peak Steam Electric Station (CPSES),

Units 1 & 2 Inspection At: Comanche Peak Site, Glen Rose, Texas Inspection Conducted: October 7 through November 3, 1987 Inspector: / II 19 C. J.(Hkle, Reactor Inspector D' ate Consultants: EG&G - V. Wenczel (paragraph 3.a)

. Parameter - J. Birmingham (paragraphs 2, 4, and 5)

Reviewed by: [O wwh [W HbZb7 Barnes, Senior Project Inspector Dat6 8711200158 871112 PDR ADOCK 05000445 G PDR

_ _ _ _ _ _ _ -_-

. .

-. !

Inspection Summary:

Inspection Conducted: October'7 through November 3,~1987 (Report 50-445/87-24; 50-446/87-18) ,

a Areas Inspected: Nonroutine, unannounced ~~ inspection of' follow-up on

-

I items of noncompliance / deviations, review of allegations, technical

.

audit program,, and general plant areas (tours).

Results: Within the four areas inspected, no violations.~~or j deviations were identified, i

l l

1

!

i

l 1 i

i l  !

l

)

!

l

,

l

.

_ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - - - _ _ _ _ _ _ - - . _ _ - _ _ - _ _ _ _ _ _ _ - _ _ _ - - _ _ . _ - _ . _ _ _ _ _ _ _ - - _ _ _ .

- _ _ _ _ _ _ _ _ _ _ - . .

I

3 1 DETAILS Persons Contacted j

• R. W. Ackley, Project Manager, Stone & Webster Engineering Corporation (SWEC)

• R. P. Baker, Engineering Assurance (EA) Regulatory Compliance Manager, TU Electric

• J. L. Barker, Manager, EA, TU Electric

• W. H. Benkert, Staff Assistant, Manager Operations Quality ,

Assurance (QA), TU Electric l '

• R. D. Best, Nuclear Operations Inspection Report Item Coordinator, TU Electric

• R. C. Byrd, Quality Engineering (QE) Supervisor, TU' Electric l l *R. D. Delano, Licensing Engineer, TU Electric .

l l *D. E. Deviney, Manager, Operations QA, TU Electric

• T. L. Heatherly, EA Regulatory Compliance Engineer, ,

TU Electric I C. R. Hooten, Civil Engineering Manager, TU Electric

• J. J. Kelley, Manager, Plant Operations, TU Electric l *0. W. Lowe, Director of Engineering, TU Electric j

'

• D. M. McAfee, Manager, QA, TU Electric

• L. D. Nace, Vice President, Engineering & Construction, )

l l

TU Electric

'

• D. E. Noss, QA Issue Interface Coordinator, TU Electric

• D. M. Reynerson, Director of Construc'clon, TU Electric

• M. J. Riggs, Plant Evaluation Manager, Operations, TU Electric

• A. B. Scott, Vice President, Nuclear Operations, TU Electric

• C. E. Scott, Manager, Startup, TU Electric

• J. C. Smith, Plant Operations Staff, TU Electric

• M. R. Steelman, Comanche Peak Response Team (CPRT), i TU Electric l *P. B. Stevens, Manager, Electrical Engineering, TU Electric

• J. F. Streeter, Director, QA, TU Electric l *T. G. Tyler, Director, Projects, TU Electric l

W. G. Westhoff, Supervisor, Technical Audit Program,

,

TU Electric l

The NRC inspectors also interviewed other applicant employees during this inspection period.

l * Denotes personnel present at the November 3, 1987, exit intervie . Follow-up on Items of Noncompliance / Deviations (92702) (Closed) Deviation (445/8626-D-03; 446/8622-D-01): The ,

Issue-Specific Action Plan (ISAP) I.d.3 Results Report j did not provide to TU Electric a recommendation that the l Bahnson Service Company (BSC) Procedure QCI-CPSES-013, -l

" Indoctrination and Training of Personnel," be revised to I

i i

__.._m . _ _ __ . .

4 I assure that craft personnel were trained to procedural .]

!

revision The applicant's response for this Notice of Deviation y indicated the following: (1) BSc is no longer performing  ;

work at CPSES, (2) HVAC construction work activity j formerly performed by BSC is currently performed by Fluor Daniel, and (3) training of the. Fluor Daniel personnel is controlled by TU Electric Procedure ECC-1.16-1, " Orientation, Indoctrination, and Training'of

_ ]

Fluor Daniel Project Personnel."

The NRC inspector verified this response was accurat j Further, the NRC inspector reviewed Procedure ECC-1.16-1, Revision 1, and verified that it included requirements i I for the training of Fluor Daniel project personnel and that it specifically required training to be performed after a procedural revision takes place. The NRC inspector determined that the procedure addresses the concerns for training of HVAC construction personne This item is close '

b. (Closed) Deviation (445/8626-D-04; 446/8622-D-02): This deviation concerned substantive changes to ISAP I. which were implemented prior to receiving approval from the Senior Review Team (SRT).

Corrective actions taken for this deviation included:

l (1) CPRT Procedure PAG-01, " General Policy for Conduct of Action Plans," was revised to require SRT approval of I

substantive changes to ISAPs' prior to implementation of l the change; (2) all ISAP I.d.3 action plan changes were l documented on Action Plan Change Requests; and (3) the SRT will formally approve all substantive changes to i ISAP The NRC inspector reviewed Revision 1 of PAG-Ol'and verified that it required SRT approval of substantive changes to ISAPs prior to implementation-of those change PAG-01 provides for the documentation of SRT approval of substantive changes to ISAPs by the SRT chairman's signature on the cover sheet of the~ revised Action Plan, or on an Action Plan Change Reques The i NRC inspector then reviewed the ISAP I.d.3 file. The review was performed to verify that the substantive changes to the ISAP I.d.3 Action Plan had been reviewed and approved by the SRT and documented as required by PAG-01. The following documents were reviewed for thi verification: (1) Action Plan Change Request, I. CRl/APCR; (2) Action Plan Wording Change Request, I. WCR/APCR; (3) ISAP I.d.3, Revision 0; (4) ISAP I.d.3,

_ _ - _ _ - _ _ _ _ _ _ _ - _ -

'l l

. . j

1

Revision 1; and (5) ISAP I.d.3 Results Report, Revisio l

'

(Revision 1 is.the SRT approved revision)..

The NRC inspector's review found.that the SRT had been s informed of the past substantive changes to the j

'

ISAP I.d.3 Action Plan and h?.d approved the changes albeit the approval was, in some cases, after  ;

implementation of the change. The NRC inspector ]

performed a similar review for ISAPs I.d.2 and VII. Based on these reviews, the NRC, inspector determined that 1 the corrective actions for'this deviation had been )

implemente Adherence to.the requirements of PAG-01 I

.

'

should preclude repetition of.the deviation. This item is close . Review of Allegations (99014)

l l

l (Open) Allegation (OSP-87-A-0038): An allegation was received that contained three concerns for assessment by ,

the NRC, During this reporting period, two concerns were !

assessed as documented below and are considered to be closed. The third concern will be. assessed in a subsequent NRC inspection repor Concern No. 1

!

I Vertical members (columns)'of the cable tray supports in l Unit 1 cable spreading room contain visible material defects. One of two columns was stated to have exhibited flange to web separation, for which a nonconformance report (NCR) was issued. The individual believed one l column was subsequently removed, but stated other columns were still present which exhibit'these defect Review The NRC inspector reviewed the NCRs addressing this issue; reviewed the significant deficiency analysis report (SDAR 125) with associated documentation related to this concern; and performed a visual inspection of the columns identified in those reports. The NRC inspector determined the following:

(1) NCRs, QC inspection reports, and engineering correspondence, all stated that certain vertical columns for cable tray supports in Unit 1 contained visible material defects. These columns were fabricated by Northwestern Steel and Wire Company and were from the same heat number (70763). Two columns were removed and replaced. .The documentation further stated that other columns with visual defects still remain in the cable spreading

_ _ _ _ . _ - _ -

,__ _

_--

. . .

room; however, reviewed documentation did not indicate any flange to web separation, as alleged, even in the columns remove (2) SDAR 125 (QA file CP-84-01) was initiated by the applicant to determine if the identified defects were reportable under 10 CFR Part 50.55(e) i requirements. The applicant reported that the two worst case columns were-removed and cut into test specimens which were subject to tension loading (pull testing). The testing was to determine the effect of the defects in the material's load ,

carrying capabilities. When tested to failure, the l specimens exceeded design loading requirements.

'

Accordingly, the defects were determined by the applicant to be not reportable under 10 CFR Part 50.55(e).

(3) A visual inspection by the NRC inspector of 12 of the remaining columns in the Unit 1 cable spreading 3 room did not identify any further surface defects; '

however, all surfaces were painte (A total of 39 columns remain installed in the plant from heat No. 70763.)

Conclusion This concern was substantiated with.the exception that flange to web separation was not identified by either the NRC or the applicant inspection efforts. The applicant has documented and assessed the defects found in the cable tray support columns in the Unit 1 spread roo An analysis (SDAR-125) was1 performed concluding that the l identified condition was not reportabl On October 22, 1987, the NRC met with the applicant's personnel concerning this matter. The applicant's actions taken concerning these columns were discussed in detai The NRC concluded that the applicant's actions were proper, conservative, and on the side of safet Since the column defects may not have been a function of the material heat number, the NRC requested that the applicant identify all other safety-related applications of columns procured from Northwestern Steel and Wire Company. When this information is obtained, the NRC will complete their evaluation of this matter (445/8724-0-01;-

l 446/8718-0-01).

Apart from follow-up of this open item, this concern is-closed.

i L____._____

_ __

'O f O 7 I l

!

Concern 2 Embedded supports for Units 1 and 2 were not seismically

~

designed or installed as safety-related items for:

(1) 6.9kv switchgear-in Room 83, elevation 810',.

safeguards building; (2)' control panels and associated i members in both control rooms; (3) Train-A.and B switchgear and transformers; and (4) the diesel generator ;

skids and control panels. Furthermore, drawings used for installing embeds and pouring floors were alleged to ,

substantiate these: conditions.

'

- Review This review was to determine if:the embeds identified l above were properly classified on drawings as safety-related and seismically designed. Records for the installation of the embeds and placement of. concrete surrounding these embeds were reviewed to verify that th embed installation and concrete placement conformed to design requirements. The NRC inspector found the following:

(1) Drawing classification for embeds - The drawings describing the design and installation of embeds for Unit 1 and 2 diesel generators with associated electrical control panels (2323-S1-0657 and 2323-Al-0501), 6.9kv'switchgear (2323-S1-0633),

Train A and B switchgear and transformers

.

(2323-S1-0605);-and control room panels and l associated members (2323-S-0709) were found to be identified as Class I in every case. TU. Electric procedure ECE-DC-1, Revision 5, " Design Control General Requirements," defines Class I as nuclear safety-related and seismic Category I systems, structures, or components. The review by the NRC inspector of seismic qualification records disclosed that embeds for the equipment in question'had seismic analyses performed and that the embed design conformed to seismic. requirement (2) Setting of embeds and concrete placement - The NR inspector reviewed the inspection records for the installation (setting) of embeds and concrete placement for the equipment in question. This review confirmed that embed installation'and concrete placement was accomplished and inspected by the applicant in conformance with the. safety-related drawings reference __ _

-_-

. . .

Conclusion Based on the review of design documentation, seismic analysis, embed installation, and concrete placement records, concern 2 was not substantiated. Drawings were-determined to identify embeds as safety related and seismically qualified. . Embed installation and concrete placement was performed and inspected by the applicant to

_

Class I drawings. This-concern is close b. (Closed) Allegation (OSP-87-A-0081): On August 26, 1987, an individual (Individual-A)'came to the onsite OSP offices to express a concern regarding the qualifications of an electrical QC inspector (Individual B). Earlier this same day,. Individual A had expressed these-concerns to the SAFETEA Concern Based on observations and information obtained from l others (not identified), Individual A believed that .

Individual B had falsified pre-employment information in order to obtain the position of electrical =QC inspector.

i Review l 1 The NRC inspector's approach to the evaluation of this I concern was to: (1) determine the requirements for the electrical QC inspector position, (2) verify that Individual B's previous. education and experience met position requirements, and (3) determine that the previous education and experience was verifie Since the SAFETEAM was evaluating this concern, the NRC inspector elected to begin his inspection when the SAFETEAM evaluation was completed. On October 5, 1987, the SAFETEAM notified the NRC that their evaluation was complete The NRC inspector reviewed the SAFETEAM file relating'to this concern. This concern was closed based on a memorandum from the site manager of QC, CQA-0228 dated October 1, ILd7. In substance, the memorandum stated that the site manager of'QC knew of no. previous supervisors that had questioned the qualifications or capability of Individual B. The manager of QC further stated that a review of the personnel qualifications of all current QC inspectors by an independent organization (i.e., the CPRT in conducting ISAP I.d.1) did not identify any concern regarding Individual B's qualification _ _ ____a

-- _,

. . .

{

The NRC inspector contacted the issue coordinator for ISAP I.d.1 to review the results of their evaluation of Individual B's qualifications. The issue coordinator stated that their review of current-QC inspectors only cor.sidered those on site as of March 1985, and Individual B was not included in that. revie (Individual B was first on site in October 1985.) The'

NRC inspector advised both the SAFETEAM and the manager of QC of the apparent error in the CQA-0228 memorandu The manager of QC amended CQA-0228 on October 29, 1987, !

by deleting the reference to the CPRT effor ')

The NRC inspector conducted the following inspection of j the training and certification files, which was very similar to the type of review performed by the CPRT in ISAP I. i To determine the requirements for the electrical QC inspector position, the NRC inspector reviewed TU Electric Procedure NQA-1.16-2.02, " Training, Qualification and certification of Quality Control Inspection Personnel," Revision 0. This procedure establishes the minimum education and experience requirements for Level.I, II, and III inspection personnel and is consistent with the requirements of ANSI N45.2.6-1978. The NRC. inspector also reviewed the resume of Individual B and compared the education'and work experience to the requirements of NOA-1.16-2.0 In October 1985, Individual B began work at the site as an electrical QC inspector, Level II. At that time Individual B met the NQA-1.16-2.02 Level II requirements of "High school education or GED plus three years of related experience in equivalent inspections . . . . "

Individual B's resume claimed.a GED, 2 years and 9 months as an inspector (nuclear, part as a Level II equivalent),

.

and in excess of 12 years of related experience. The NRC l

inspector reviewed the certification file for Individual B and found documented evidence that the claimed education and experience had been verified, as required by NQA-1.16-2.0 In January 1987, Individual B was promoted to Level III and functioned for a time as a Quality Engineer. Again, Individual B met the Level III. requirements of NQA-1.16-2.0 The NRC inspector interviewed two of Individual B's former supervisors. While both had criticism of Individual B's work habits, neither identified any problem with the individual's ability or capability of functioning as a QC inspector, Level I _ _ _ _ _

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. . .

conclusion The allegation was not substantiate Evidence was found that the pre-employment information provided by Individual B had been verified as correct and that inspector certifications were made in accordance with procedures and ANSI N45.2.6-197 . Technical Audit Program (35060)

TU Electric has instituted a technical audit program (TAP) to provide timely and effective audit coverage of the implementation of those recommendations and commitments resulting from performance of.the CPRT ISAPs. The. TAP was also instituted to provide technical audit coverage of the design related corrective action programs (CAPS). .The TAP l provides supplemental technically based audits in addition to ,

the normal or routine, TU Electric internal. audit progra During this report period, the NRC inspector reviewed this l l

,

program and its implementation.

l The objectives of the TAP program are provided in Nuclear Engineering and Operations (NEO) QA Department Procedure l NQA 3.07-1.01, " Technical Audit Program." These objectives are: (1) to assure the technical and programmatic .

effectiveness of the CAP, and (2) to provide oversight of

, those project actions performed in response to recommendations I made by the CPRT and of those commitments made by the project

'

to the CPRT as a result of the conduct of the CPRT ISAPs.

l To assess the TAP, the NRC inspector: (1) evaluated Procedure NQA 3.07-1.01, (2) reviewed the qualifications of the audit personnel, and (3) inspected in detail the records of four TAP audit The NRC inspector's review determined that NEO I Procedure NQA 3.07-1.01, Revision 0, provides: (1) a l description of the program and its objectives; (2) the responsibilities of. management and audit personnel in accomplishing these objectives; and (3) the methodology for accomplishing training and certification of personnel, audit scheduling, audit performance, audit reporting, and follow up of audit deficiencie The procedure identifies that the TAP covers two areas of activity, the CAP and the implementation of CPRT ISAP recommendation / commitments. For the CAP, the procedure details the design validation elements to be audited; such as, (1) resolution of third-party discrepancy issue reports; (2) reflection of generic technical issues in design validation packages; and (3) identification, preparation and implementation of design modifications and changes required as

_ _ - _ _ _ - _ _ _ _ _ _ _ _ _ ._______ ___ _ . _ _

- ___ - __ _

=

. ..

l a result of the design validation effort. For the implementation of ISAP recommendations / commitments, the procedure provides assurance that: (1) the responsible party has captured the item in a formal control system; (2) the resolution actions as approved by the CPRT are effectively implemented; and (3) the corrective actions have been completed and documente The NRC inspector determined from the above review that the i controlling procedure for performance of the TAP.provided or referenced adequate instructions, which if properly implemented, would assure effective audit coverage of the design related CAPS, and those project actions taken as a result of the CPRT ISAP To assess the adequacy of the TAP staffing, the NRC iiipector reviewed the organization chart for the TAP and inspected the personnel file documentation. The audit staff was found to 4 consist of approximately 30 technical specialists and auditors and to be supported by 10 additional management and administrative personnel. A review of the qualification files for ten of the audit personnel showed that the training and examination required by NQA 1.16-1.01, " Indoctrination, Training, and Certification of Auditor's," had been performe Records that previous experience and education had been verified were also in the files for lead auditors or lead auditor candidates, unless the individual was supplied by a vendor on the TU Electric approved vendor's list in which case the vendor maintained those record The NRC inspector reviewed Revision 3 of the 1987 TU Electric Internal Audit Plan / Schedule which included the TAP audit The audit schedule showed that for 1987, 63 audits are planned to be performed by the TAP. As explained by the audit schedules' cover letter (QIA-7170), TAP audits had been added to the schedule and additional TAP audit staff was provided to meet the increased work loa The NRC inspector discussed these schedule and staffing changes with the TAP supervisor who stated that the changes were taken to achieve more timely and in depth audits. This was accomplished by performing more audits of a more narrow, but more comprehensive scope for each issue, and by scheduling audits for the initial, middle, and-late stages of the CAP. These actions are deemed appropriate by the NRC inspector, since performance of audits in the first two quarters of 1987 indicated a need for more timely audits of ongoing CAP activitie To assess audit performance and follow-up of identified deficiencies, the NRC inspector reviewed the audit reports, the audit checklists, and the follow-up actions for four TAP audits. The objective of two of these audits, ATP-87-22 and ATP-87-41, was to provide assurance that a review of CPSES L_

,-- - - _ _ . .

l

. . ,

! l

'

L equipment qualifications, performed by Impell corporation, was q being adequately and effectively conducted. The NRC

'

inspector's review of the checklists for these two audits i showed that they were based on the procedural requirements of the Impell program, which implemented FSAR commitments to national standards for equipment qualifications such as IEEE 323'and 383. The' completed checklists showed that the 1 TAP auditors had recorded the evidence observed for each checklist item and had made a determination that the item was either satisfactory or unsatisfactor The audit files of ATP-87-22 and'ATP-87-41 were reviewe' These files contained documents; such as, the attendance lists of the pre- and post-audit meetings, the completed audit )

checklists, the audit report, and.the correspondence pertaining to the follow-up on cor'rective actions. The audit ,

report was found to provide an executive summary of the audit I and its scope, the details of identified deficiencies and ,

observations, a definition of response requirements, and a i listing of the references and acceptance criteria used for the audit. The identified deficiencies and observations properly reflected the findings documented in the audit report. .The correspondence regarding the follow-up of the audit findings was found to meet the time requirements of.NQA 3.07-1.01 and to address the audit findings properl The NRC inspector noted that some checklist items were not !

completed. The incomplete checklist items were discussed with ,

the TAP supervisor who stated that further audits of the j Impell review of equipment qualifications were scheduled and '

that any checklist items not completed in a previous audit must be completed in subsequent audits, as required by Procedure NQA 3.07-1.0 The other audits reviewed by the NRC inspector, ATP-87-514 and ATP-87-520, concerned applicant actions resulting from ISAP I.d.3, " Craft Training," and ISAP VII.a.2,

"Nonconformance and Corrective Action Systems." The NRC inspector found that the scope of audit ATP-87-520 covered all the recommendations and commitments identified in ISAP VII.a.2, while ISAP I.d.3 had no recommendations and related only to craft' training of BSC and Brown & Root, In (B&R) personnel. Audit ATP-87-514 broadened the scope of ISAP I.d.3 by inspecting craft training for B&R; Grinnell Fire Protection System Company, Inc.; Brand Industrial Services, Inc. (BISCO); Fluor Daniel; and the TU Electric Operations & i Maintenance Department ,

The NRC inspector reviewed the audit files for ATP-87-514 and ,

ATP-87-520, and found that the contents were consistent with the audit files of ATP-87-22 and ATP-87-41. The NRC inspector determined that the audit' checklists were structured to verify i

- _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _

e a .

'

whether the CPRT recommendations / commitments were implemented and that actions taken were proper. The completed audit checklist provided the evidence observed and whether each checklist item was satisfactory or unsatisfactory. The NRC inspector found that audit ATP-87-514 had been recently completed (September 25, 1987) and the response from the '

.

audited organizations was not due. The correspondence for ATP-87-520 was found to be timely and to properly address the audit findings. Although most of the corrective actions wer not yet due or fully implemented, the NRC inspector considers audits ATP-87-514 and ATP-87-520 to have been implemented in accordance with procedure i The following standards, to which TU Electric is committed in 1 the CPSES FSAR, were used during the NRC inspector's review of the TAP: ANSI N45.2.12, Draft 3, Revision 0, dated May 2, 1973, for the require:nents of establishing and implementing a system of controlled audits; ANSI N45.2.23-1978 for the qualification criteria of audit personnel; and ANSI N45.2.9-1974 for the accumulation of record i No NRC violations or deviations were identified. Further NRC i inspection of the TAP is planned and will be reported in subsequent report . Plant Tours (92700)

The NRC inspectors made frequent tours of the Unit 1, Unit 2, and common areas of the facility to observe items such as housekeeping, equipment protection, and in-process work activities. No items of significance were observe . Open Items open items are matters which have been discussed with the applicant, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or i applicant or both. One open item disclosed during the inspection is discussed in paragraph . Exit Interview (30703)

An exit interview was conducted November 3, 1987, with the applicant's representatives identified in paragraph 1 of this report. During this interview, the NRC inspector summarized the scope and findings of the inspection. The applicant acknowledged the finding ;!

-J

,

. ~y DISTRIBUTION:

.

MYI5EEEEESEf1E5l[($0 Mis 7"iUM

~ NRC PDR""""""~~~"""" * " ~ ~'"

LPDR-- -

OSP Reading-I CPPD-LA CPPD Reading (HQ) j

• Site Reading  ;

• CPRT Grou i

• SRI-OPS  ;

• SRI-CONST l AD for, Projects j

• MIS System, RIV 4

• RSTS Operator, RIV-  !

RPB,.RIV RIV Docket File

'*DWeiss, RM/ALF JTaylor ..

JKeppler/JAxelrad l CIGrimes -;

PFMcKee

'

JLyons y AVietti-Cook MMalloy i JMoore, OGC I

JGilliland, RIV ,

l FMiraglia

'

EJordan JPartlow  ;

BHayes

• w/766 l

j

__--_-._2__