ML15224A395
| ML15224A395 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 04/24/1981 |
| From: | Belisle G, Belisle G, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15224A390 | List: |
| References | |
| 50-269-81-06, 50-269-81-6, 50-270-81-06, 50-270-81-6, 50-287-81-06, 50-287-81-6, NUDOCS 8107240370 | |
| Download: ML15224A395 (15) | |
See also: IR 05000269/1981006
Text
- .
g REGO
UNITED STATES
NUCLEAR REGULATORY COMMISSIO
REGION il
101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGA 30303
Report Nos. 50-269/81-06, 50-270/81-06 and 50-287/81-06
Licensee:
Duke Power Company
422 South Church Street
Charlotte, NC
28242
Facility Name:
Oconee
Docket Nos. 50-269, 50-270 and 50-287
License Nos. DPR-38, DPR-47 and DPR-55
Inspection at Oconee site near Seneca, South Carolina
Inspector:
/
G.
Date Signed
P. E. Fredrickson
Date Signed
P. H. Skinne
ned
Approved by:
Z
z ,
C. M. Uprigh _,9tionX/ief
D~ jge
Engineering In ectio6 -ranch
Date Signed
Engineering and Technical Inspection Division
SUMMARY
Inspected on March 23-27, 1981
Areas Inspected
This routine, announced inspection involved 104 inspector-hours on site in the
areas of licensee action on previous inspection findings, QA annual. review,
personnel qualification program,
tests and experiments,
records,
training,
requalification training, calibration program, test and measurement equipment,
and plant operating procedures.
Results
Of the ten areas inspected, no violations or deviations were identified in six
areas; five violations were found in four areas (Failure to include summary of
50.59 safety evaluations in annual report to the NRC, paragraph 7; Failure to
6107240370 810710
PDR ADOCK 05000269
Q
GPDR
2
take prompt corrective action on record storage problem identified by licensee
audit, paragraph 8.a; Failure to follow training procedure,
paragraph 9.a;
Failure to conduct reviews, paragraph 5.b; and Failure to document QA procedure
reviews, paragraph 5.a.)
REPORT DETAILS
1. Persons ContaCted
Licensee Employees
0. Austin, Training Safety Coordinator
R. Bugert, Senior Instructor
- R. Brackett, Senior QA Engineer
- T. Cribbe, Licensing Engineer
- J. Davis, Superintendent of Maintenance
J. Frye, Senior Sr. Supervisor
L. Hindman, Simulator Instructor
- E. Kelley, Licensing (Clerk)
D. Kelly, Training Supervisor
- H. Lowery, Operations Engineer
- T. Matthews, Licensing Technical Specialist
- J. McIntosh, Superintendent of Administration
R. Nichols, Administrative Coordinator
- T. Owens, Superintendent of Technical Services
M. Roach, Administrative Supervisor
- R. Rogers, Licensing and Projects
S. Scott, Technical Associate
- J. Smith, Station Manager
Other licensee employees contacted included technicians, operators,
and
office personnel.
NRC Resident Inspector
- 0. Myers
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on March 27,
1991 with
those persons indicated in paragraph 1 above. The liceansee was informed of
the inspection results listed in the index of findings, parag-raph 14. The li
censee acknowledged the inspection findings.
3. Licensee Action on Previous Enforcement Matters
The following abbreviations are defined and used throughout this report:
Accepted QA Program
Duke Power Company Topical
Report, Duke-1-A,
Amendment 4 dated June 1978
Administrative Policy Manual
Final Safety Analysis Report
2
Health Physics
NRC Office of Inspection and Enforcement
National Fire Protection Association
NRC
Nuclear Regulatory Commission
ONSD
Oconee Nuclear Station Directive
Quality Assurance
0AP
Duke Power Company Quality Assurance Program
Reactor Operations
a.
(Open)
Unresolved (269,
270,
287/79-10-09):
Inadequate internal/ex
ternal design interfaces and communications.
This item is discussed in
paragraph 3.b.
b.
(Open)
Unresolved (269,
270, 287/79-10-10):
Inadequate design change
procedures. The licensee is currently in process of a revision to the
APM relative to the design modification program.
Numerous internal
correspondence has been generated on this subject.
A proposed amendment 19 to the APM has been submitted, but is still
being reviewed by various company departments.
This proposed amendment
will include the necessary requirements to close items 269,
270,
287/79-10-09
and 79-10-10.
Until this amendment is issued and
reviewed, these items remain open.
c.
(Closed) Unresolved (269, 270, 287/79-10-20): Record protection. The
inspector reviewed the Oconee storage facility including the file room
to verify that records storage findings of Duke Quality Assurance
audits 0-78-04 Item 7 and 0-79-02 Item 2A had been corrected.
This
inspection identified that the records storage problems still exist;
therefore, this item has been closed and a violation is being issued as
discussed in paragraph 8.a.
4. Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia
tions.
New unresolved items identified during this inspection are discussed
in paragraphs 8.b. and 9.b.
5. QA Program Annual Review (35701)
References:
(a) Duke Power Company, Topical Report, Duke-i-A, Amendment
4 dated 6/78
(b) QA-100,
Preparation and Issue of Quality Assurance
Procedures, Revision 4 dated 3/78
(c) QA-101,
Quality Assurance Records Storage Vault, Revi
sion 2 dated 10/80
(d) QA-111, Interdivisional Transfer of QA Records, Revision
1 dated 1/77
3
(e)
QA-112,
Certification of Quality Assurance Analysts,
Revision 1 dated 8/79
(f)
QA-130, Qualification and Training of Lead Auditors,
Revision 5 dated 7/80
(g)
QA-131,
Quality Assurance Training, Revision 2 dated
10/80
(h) QA-140, Quality Control Inspector Training, Revision 1
dated 10/80
(i) QA-150, Trend Analysis, Revision 2 dated 5/78
(j)
QA-160, Performance
of Corporate Quality Assurance
Audits, Revision 0 dated 11/78
(k) QA-500, Operations Division Surveillance Program,
Revision 13 dated 9/79
(1) QA-501, Placing, Reviewing and Verifying Quality Assur
ance Requirements on Station Procedures,
Revision 3
dated 3/78
(m) QA-506,
Quality Assurance Review of Nuclear Station
Modifications/Nuclear Problem Reports, Revision 4 dated
4/79
(n) Duke Power Company Steam Production Department Admini
strative Policy Manual for Nuclear Stations, Revision 18
dated 9/79
The licensee has not submitted any changes to the accepted QA Program since
the last inspection in this area conducted in April 1979.
The inspector
reviewed the previously listed references to verify that they are in con
formance with the accepted QA Program. Based on this review, the inspector
identified two violations and one open item as discussed in paragraphs
5.a. - c.
a. Failure to Record the Results of Reviews
The inspector interviewed two members of the QA staff and was informed
that the Quality Assurance Program procedures were frequently reviewed
to assure that they reflected current methods of conducting work
practices. Many of these procedures do not require revisions; however,
documentation of these reviews could not be produced. This failure to
record the results of QA Program procedure reviews cbnstitutes a
violation (269,
270,
287/81-06-05).
The license e's priactice of
frequent reviews of QA Program procedures is acceptable; only docu
mentation of these reviews is lacking.
b.
Failure to Review APM and Station Directives
The inspector identified that the APM and Station Directives are not
being reviewed as required by the accepted QA Program commitment to
Section 5.2.15.
Examples of procedures not being
reviewed are listed below.
4
Station
Directive No.
Title
Revised
2.1.4
Changes to Alarm Setpoint Manual
02/11/78
2.4.4
Material Delivery
12/29/77
3.1.9
Investigation of Unit Trips
10/23/75
3.1.16
Fuel Handling Equipment Interlocks
05/28/76
3.2.1
Performance of Periodic Testing or Sampling
04/02/76
3.3.1
Safety-Related or Non-Safety-Related
05/04-77
Component or Equipment Repair
This is only a partial list of procedures reviewed and is not intended
to be all inclusive.
During discussions with plant personnel , it was determined that the APM
is
considered a policy manual
vice a procedure manual; however,
Sections 17.2.5 and 17.2.6 of the accepted QA Program refer to the APM
as a procedure manual. This failure to perform reviews of procedures
as required by the licensee's commitment to ANSI 18.7-1976 is a viola
tion (296,
270, 287/81-06-03).
C.
Organizational Structure
Technical Specification 6.1.1.3 states in part that the station organi
zation shall be functionally as shown in Figure 6.1-1.
The APM,
Section 1.4,
Organization,
Figure 1.4-4 does not reflect the same
organizational chart as required by the Technical Specifications. The
licensee gave a target date of July 1, 1981 for revising the APM
organizational structure.
Until this revision is made to the APM this
item is open (50-269,
270, 287/81-06-11).
6. Personnel Qualification Program (36701)
References:
(a) Technical Specifications, Section 6.0
(b) FSAR, Section 12, Conduct of Operations
(c) Accepted Quality Assurance Program
(d) ONSD-2.5.1, Training, revised 9/80
The inspector reviewed the references listed to assure the qualifications of
personnel were as stated in the licensee's commitment t'd ANSI/ANS-3.1-1978
as stated in the Technical Specifications.
The inspectorverified that
administrative controls required that minimum educational,
experience-or
qualifications had been established for the following positions:
principal
operating staff, supervisory positions, engineering staff, plant craftsmen,
plant operators,
NDE testing personnel,
chemistry technicians, warehouse
personnel , and QA personnel
5
The inspector reviewed a total of 89 personnel from the disciplines listed
and verified that their qualifications are as required by the licensee's
commitment to ANSI/ANS-3.1-1978.
Based on this review, no violations or deviations were identified.
7. Tests and Experiments Program (37703)
References:
(a) APM Section 3.2.3, Special Testing, Revision 4 dated
12/74
(b) APM Section 4.2, Administrative Instruction for -Perma
nent Station Procedures, Revision 18 dated 9/79
(c) APM Section 4.3,
Administrative
Instruction
for
Temporary Station Procedures, Revision 17 dated 4/79
(d) APM Section 4.4, Administrative Instruction for Modi
fications, Revision 16 dated 7/78
The inspector verified the following aspects of the test and experiments
program:
-
A
formal
method
has been established to handle all requests or
proposals for conducting special
tests involving safety-related
components
-Special
tests will be performed in accordance with approved procedures
-
Responsibilities have been assigned for reviewing and approving special
test procedures
-
A system, including assignment of responsibility has been established
to assure that special tests will be reviewed
-
Responsibilities have been assigned to assure a written safety evalu
ation required by 10 CFR 50.59 will be developed for any special test
to assure that it does not involve an unreviewed safety evaluation or
change in Technical Specifications.
Based on this review,
one violation was identified.
requires that licensees submit a brief description of change'smade to the
facility pursuant to that section and also provide to the NRC a summary of
the safety evaluation for each change.
The 1979 list of. Oconee facility
changes submitted to the NRC on October 27, 1980 did not contain a summary
of the safety evaluations for the listed modifications.
This failure to
provide a summary of safety evaluations to the NRC is a violation of 50.59
requirements (269,
270, 287/81-06-01).
6
.
8.
Records (39701)
References:
(a) ONSD 2.2.1, Procedure for Records Management, revised
12/80
(b) ONSD 2.1.2, Procedure
for Microfilming
Documents,
revised 5/78
(c) Accepted Quality Assurance Program
The inspector reviewed various station directives to verify that provisions
had been made to maintain various types of quality records, in both perma
nent and temporary storage, and that responsibilities had been assigned to
carry out the records storage requirements.
Records storage procedures were
also reviewed to ensure that they described the storage facilities, the
filing systems used, and methods of receipt, handling and disposal of the
records.
In order to verify implementation of these procedures,
the
inspector selected the following records to verify indexing, retrievability
and storage:
Unit 2 RO Log, November 1, 1980 to January 16, 1981
Recorder Chart 107, Off on November 3, 1980
Purchase Order F25488-73
OP/i/A/1103/02
TT/2/A/811/01
PT OA 1505, 1/31/81
TT/2/A/325/3
Based on this review, one violation, one unresolved item, one open and two
inspector followup items were identified and are discussed in paragraphs
8.a. -
e.
a. Failure to Take Prompt Corrective Action on Records Storage Finding
NRC unresolved item 269, 270, 287/79-10-20 identified a records storage
violation with respect to the Oconee file room.
This item (also
discussed in paragraph 3.c.) was unresolved due to the problem area
being previously identified in two Duke Quality Assurance audit
reports, 0-78-04 Item 7 and 0-79-02 Item 2A.
Both audit reports
addressed the problem of quality records being maintained in the file
room, which does not meet the fire protection standards of-Regulatory
Guide 1.88,
Revision 2.
From the date of the NRC. inspection on
April 6, 1979, to March 27,
1981,
several letters- and responses have
been generated between the Quality Assurance Department and the Steam
Production Department, but the problem still exists.
The file room
stores recorder charts generated from 1972 to the present, such as the
Radiation Monitor Charts, Waste Gas Effluent Flow Charts, Liquid Waste
Flow Charts and Stack Flow Charts.
Also,
the file room contains
certain HP and Chemistry quality records from 1979, in storage for
7
eventual microfilming. This failure to take prompt corrective action
on inadequate storage of records is a violation (269,
170,
287/81
06-02).
b. Use of One-Hour Fire Cabinets For Storage of Quality Records
Several one-hour fire rated record storage file cabinets were in use at
various plant department locations. In discussion with the licensee,
it was determined that the licensee has opted to follow NFPA 232-1975,
as allowed by the accepted QA Program commitment to Regulatory-Guide
1.88, Revision 2. Chapter 5, Section 5242.b of NFPA 232, states that
the degree of protection for Class 1 records may be achieved by housing
them in a standard fire resistive vault or in safes, or record protec
tion equipment having a fire rating comparable with the maximum fire
hazard to which they may be exposed. Sections 542,
543 and 553 of this
fire code provides the guidance on determining what the maximum exposed
fire hazard would be. The licensee has not conducted an analysis for
each file cabinet location to justify the use of the one-hour cabinets.
This matter is unresolved (269,
270, 287/81-06-07) pending the licensee
completing and an NRC review of the analysis in accordance with NFPA
232-1975 for all quality record storage locations using one-hour
cabinets.
c.
Disposition of Non-Permanent Records
Reference (a) identified those records to be maintained for the life of
the plant and those to be maintained for periods of time less than
permanent. Attachment VI of reference (a) lists various recorder
charts that are being destroyed on a two-year cycle.
The method to
control the disposal of any non-permanent records is not included in
reference (a) or the APM. The licensee gave a target date of May 1,
1981 for inclusion of a control method for disposition of non-permanent
records into applicable procedures. Until this area is reviewed by the
NRC, this item is open (269,
270, 287/81-06-10).
d.
Inspect Duplicate Storage Facility at Company Offices
A majority of the quality records generated from Ocon.e are micro
filmed, with the originals being maintained at theaCompanyloffices in
Charlotte, NC and a duplicate copy maintained at the site.
In order to
complete the verification of records storage procedures, controls and
implementation, a review of the Company office records storage proce
dures and facilities will be conducted during a subsequent inspection.
This area is identified as an inspector followup item (269,
270,
287/81-06-13).
8
e. Clarity of Handwritten Exams for Microfilming
During a review of training records, the inspector noted that several
handwritten exams that had been microfilmed were partially illegible.
In most cases, the records reviewer had retained the hard copy, but in
a few cases the hard copy had been discarded. The root cause of this
problem was the use of hard lead pencils on yellow paper. During the
inspection a letter, subject, Oconee Nuclear Station Training Records
Management, dated March 27, 1981, was sent to the Operations Training
Supervisor requesting that the training policy be changed to insure
that training records are capable of being clearly microfilmed.
The
implementation of this change will be inspected during a subsequent
inspection and is identified as an inspector followup item (269, 270,
287/81-06-12).
9. Training (41700)
References:
(a) ANSI N18.1,
Selection and Training of Nuclear Power
Plant Personnel, dated 3/71
(b) Administrative Policy Manual
for Nuclear Stations,
revision 17 dated 4/79
(c) Oconee Nuclear Station Directive 2.5.1(AS),
Training,
revised 9/80
(d) Nuclear Station Training Plan and Program Description,
revised 3/1978
(e) Oconee Nuclear Station Directive 2.5.2(AS), Orientation
for Newly Hired or Transferred Exempt Personnel, revised
9/80
Housekeeping Requirements for
Water-Cooled Nuclear Power Plants, Revision 1
(g) Regulatory Guide 8.13, Instruction Concerning Prenatal
Radiation Exposure, Revision 1 dated 11/75
The inspector reviewed the training program which provides general employee
training for station personnel.
The training program was reviewed to verify
that: the program complies with commitments and requirements (references
(a) through (f)
above); that the program covers training in the areas of
general station administrative control and quality assurance policies and
procedures; radiological health and safety; industrial safety-and first aid;
housekeeping and fire prevention and protection; emergency plan and proce
dures; station security plan and procedures; the use of:protective clothing;
and prenatal radiation exposure training for females and.supervisors. The
inspector reviewed approximately 20 training records of station personnel
and interviewed six individuals (non-licensed).
Based on this review one violation, one unresolved item and two open items
were identified and are discussed in paragraphs 9.a. through d.
9
a. Failure to Follow Procedures
10 CFR
50,
Appendix B, Criterion V requires activities affecting
quality shall be prescribed by documented instructions, procedures or
drawings and shall be accomplished in accordance with these instruc
tions, procedures or drawings. The accepted QA Program Section 17.2.5
states in part that personnel implement the requirements of the Admin
istrative Policy Manual as it pertains to the performance of their
activities. Further Technical Specification 6.4.1 requires that the
station be operated and maintained in accordance with approved proce
dures.
Reference (b) Section 2.5, Qualifications and Training of
Personnel,
paragraph 2.5.5.1 requires periodic evaluations shall be
conducted to assure that effectual training techniques are utilized.
Evaluations have been performed on the training provided by vendor
training programs but no evaluations of the training techniques used by
Oconee Training Department personnel
had been accomplished.
This
failure to follow procedures which require evaluations of the training
techniques is a violation (269,
270, 287/81-06-04).
b.
Lack of Formal QA Indoctrination for General Employees
Reference (b) Section 2.5.5.3 requires training for station personnel
in general station administrative control
and quality assurance
policies and procedures.
A review of training provided in this area
identified that only a non-specific general type quality assurance
training was provided.
Specific training for Oconee administrative and
quality assurance policies and procedures has not been included as part
of the training program. This item is unresolved until such training
is provided and reviewed by the NRC (269,
270, 287/81-06-06).
c.
Definition of Periodic Retraining
Reference (b) Section 2.5.5.1 requires that periodic retraining be
conducted to assure continuing proficiency after- initial training.
Reference (c) identifies the retraining subject matter that is to be
provided each employee. There is no documentation that specifies the
frequency at which the retraining is to be conducted.
The records that
were reviewed by the inspector indicate that this retraining is being
provided annually. The licensee gave a target date of July 1, 1981 for
incorporation of the retraining frequency into applicable procedures.
This item is
open pending the
NRC review and incorporation of
retraining frequencies into training procedures (269,
270,
287/81
06-08).
d. Training of Personnel in Prenatal Radiation Exposure
Reference (g) states that instructions concerning prenatal radiation
exposure should be provided for female workers and those who may
supervise or work with female workers.
Oconee provides a copy of
10
reference (g) and a form for each female employee that states she has
read and understands the information provided in reference (g).
This
subject is not covered in general employee training and is not provided
to supervisors and personnel that may work with females. The licensee
gave a target date of June 1, 1981 for the incorporation of prenatal
radiation exposure training into the general employee training program.
This item is open pending NRC review of action taken to provide
instruction about health protection problems to supervisors and others
that work with female workers (269,
270, 287/81-06-09).
10.
Requalification Training (41701)
References:
(a) 10 CFR 50.55, Appendix A, Requalification Programs for
Licensed Operators of Production and Utilization Facili
ties
(b) Technical Specifications
(c) ANSI N18.1-1971, Selection and Training of Nuclear Power
Plant Personnel, dated 3/71
The requalification training program was reviewed to determine conformance
to references (a) through (c) above. The training records of three licensed
reactor operators, three licensed senior reactor operators and one reactor
operator in training were reviewed.
As a result of this review, no violations or deviations were identified.
11.
Calibration (56700)
References:
(a) Technical Specifications
(b) ONSD 3.2.1, Performance of Periodic Testing and Sampling
dated 4/76
(c) ONSD 3.2.2, Responsibility For and Scheduling of Sur
veillance Requirements, revised 3/81
The inspector reviewed the references listed to insure the licensee's
calibration program was in accordance with the accepted QA Program and ANSI
18.7-1976 as committed to by that Program.
Based on this review, no violations or deviations were identified.
12.
Procedures (42700)
References:
(a) APM, Sections 4.1 - 4.3
(b) Oconee Nuclear Station Directive 4.2.1 (Mgr.), dated
1/81
(c) Oconee Nuclear Station Directive 4.2.2 (TS),
dated 3/76
(d) Oconee Nuclear Station Directive 4.2.4 (TS)
dated 4/79
(e) Oconee Nuclear Station Directive 4.2.6, dated 4/80
11
(f)
ANSI N18.7-1976, Administrative Controls for Nuclear
Power Plants
(g) Technical Specifications
Revision 1, Quality Assurance
Program Requirements (Operation)
(i) Final Safety Analysis Report
The inspector commenced a review of selected plant procedures in accordance
with the guidance and requirements provided in references (a) through (i)
above to ascertain whether overall procedures are in accordance with regu
latory requirements.
The following criteria were used during this review:
-
Required review and approval of procedures and temporary changes had
been performed
-
Overall procedure content is consistent with references (g) and (i)
-
Records of changes in procedures are being maintained
-
Safety reviews pursuant to 10 CFR 50.59 were performed
-
The training department was appraised of changes to procedures
- -
Administrative procedures were observed in the preparation and handling
of procedures
This procedure review was limited to a review of administrative require
ments. . Completion of this review will be performed on a subsequent
inspection.
No violations or deviations were identified.
13.
Test and Measurement Equipment (61724)
References:
(a) APM, Section 2.3, Control of Measuring and Test
Equipment, Revision 18 dated 9/79
(b) APM,
Section 5.1,
Standards and Testing Facility,
Revision 15 dated 12/77
(c) ONSD
2-3-1,
Test and Measuring Equipment Control,
revised 11/79
The inspector reviewed the listed references to insure they met the
requirements of the accepted QA Program and ANSI N45.2.4-1974 as committed
to by that Program.
The inspector verified the following aspects of the
test and measuring equipment program.
-
Criteria
and responsibility for assignment of the calibration/ad
justment frequency have been established.
12
-
An equipment inventory list has been prepared which identifies equip
ment used on safety-related structures,
systems or components and
calibration frequency of each piece of equipment.
-
Requirements exist for marking the latest calibration date on each
piece of equipment.
-
A system has been provided for assuring that equipment is calibrated
before the date required.
-
Requirements have been established which prohibit use of equipment
which has not been calibrated within the prescribed frequency.
-
Calibration controls have been established which require evaluation of
the cause of an out of calibration and the acceptability of items
calibrated.
-
New equipment will be added to the inventory list and calibrated prior
to being placed in service.
During discussions with a resident inspection, it was identified that the
test and measurement program was reviewed as referenced in IE Reports
.
50-269/80-28, 50-270/80-24 and 50-287/80-21, paragraph 12.
Based on this review, no violations or deviations were identified.
13
14.
Index of Findings of Inspection Reports 50-269, 270, 287/81-06
Report
Item Numbers
Item Description
Location
269, 270, 287/81-06
Violations
01
01
01
Failure to Include Summary of Safety
7
Evaluations Required by 50.59
02
02
02
Failure to Take Prompt Corrective Action on
8.a
QA Audit Findings
03
03
03
Failure to Conduct Reviews
5.b
04
04
04
Failure to Follow Training Procedures
9.a
05
05
05
Failure to Document Reviews
5.a
Unresolved Items
06
06
06
Lack of Formal QA Indoctrination for General
9.b
Employees
07
07
07
Use of One-Hour Fire Cabinets for Storage
8.b
of Quality Records
Open Items
08
08
08
Define Periodic Retraining
9.c
09
09
09
Instruct Cognizant Personnel in Effects of
9.d
Prenatal Radiation Exposure
10
10
10
Disposition of Non-Permanent Records,
8.c
11
11
11
Organization Discrepancies Between Technical
5.c
Specifications and APM
Inspector Followup Items
12
12
12
Clarity of Handwritten Exams for Microfilming
8.e
13
13
13
Inspect Duplicate Storage Facility at Company
8.d
Offices.
Inpco0olou tm