ML19323D383
| ML19323D383 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 05/06/1980 |
| From: | Mcgaughy J MISSISSIPPI POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| MAEC-80-80, NUDOCS 8005210515 | |
| Download: ML19323D383 (12) | |
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MISSISSIPPI POWER & LIGHT COMPANY Helping Build Mississippi
- ' " ' ="
P. O. 9 0 X 18 4 0. J A C K S O N, MISSISSIPPI 39205
==o ouction os arv e~r May 6, 1980 Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region II i
101 Marietta Street, NW duite 3100 Atlanta, Georgia 30303
)
Attention:
Mr. J. P. O'Reilly, Director
Dear Mr. O'Reilly:
SUBJECT:
Grand Gulf Nuclear Station File 0260/0490/15521 RII: MJG 50-416, 50-417/80-02 Response to NRC Site Inspection 80/02
Reference:
MAEC-80/80 AECM-80/ 93 Your Mr. M. J. Gouge performed an inspection at the Grand Gulf construction site on March 4-7, 1980.
Mr. Gouge 's report was issued by your letter of April 14, 1980. On May 2,1980, MP&L management met with you and members of your staff to discuss the MP&L response to the Nuclear Regulatory Commission report and the enclosed Notice of Violation.
1 Attached you will find the MP&L response to your letter of April 14, 1980, and the Notice of Violation. It is hoped that this response, the
{
management meeting held on May 2,1980 and MP&L's past history of reporting will renew your confidence in the MP&L Quality Assurance Program.
Yours truly, M J. P. McGaughy, Jr.
Director of Power Production TER/ WEE:mt Attachments:
(A) MP&L Response to MAEC-80/80 lg 00; (3) MP&L Response to Notice of Violation J
.5 cc:
Mr. N. L. S ta:t 71ey
/
Mr. R. 3. McGehee f/[
Mr. T. 3. Conner Mr. Victor Stallo, Director 4 f,HS CO8V mg Division of Inspection & Enforcement U. S. Nuclear Regulatory Commission 1
Washington, D.C.
20535 8005210p F Member Middle South Utilities System
Attachment A to AECM-80/95 Page 1 of 6 MPSL RESPONSE TO MAEC-80/80 A.
Nuclear Regulatory Commission (NRC) Letter of April 14, 1980 indicated to MPSL that the NRC was " concerned with the adequacy of your manage-ment systems for identification and reporting of 10CFR50.55(e) deficiencies." Further quotingsfrom the report: "This concern was pre-sented to your prior to this inspection by F. S. Cantrell on January 24, 1980...."
Within one week after Mr. Cantrell's visit we had established and now have in place a visual status board to ensure ti'..ely responses. Since that visit no interin 30 day reports have exceeded the time requirement.
Consequently we feel appropriate actions were taken to correct timeliness as a result of Mr. Cantrell having brought this matter to our attention.
3.
The NRC letter of April 14, 1980 stated in part:
"During the current inspection, three significant deficiencies were identified by our inspector which had been reviewed by MPSL but were not reported for the following reasons:
a.
Your analysis indicated that the item would have been dis-covered during functional testing, thus coulc not nave remained undetected, b.
Your analysis determined that since an item was in a rMundant i
system, its failure could not have been detrimental to the plant.
c.
Your analysis determined that since an item could be repaired for less than $50,000 it was not significant."
It appears that your conclusions are not supported by the regulation.
Ccnsequently, in your reply, you should describe in particular those actions taken or planned to insure that safety-related deficiencies identified during const:uction of the Grand Gulf facility are prcmptly reported to the NPC."
As stated in the May 2,1980 meetin; with the NRC: MPSL has always maintained that the corrective actions shculd be taken because of the identification of a problem and not because that the p,roblem is recortable under a regulation. The NRC Inspector M. Gouge on Page 5 c: the inspection report Details under Item 5 states: "Although these items were not properly reported to the NRC, no deficiencies were identified in the corrective action by the licensee."
10CFR50.55(e) defines repor-ing recuirements. We feel that a " reportable deficiency" is a defined term in the regulaticn, i.e. :
Attachment A to AEC4-80/93 page 2 of 6
".... deficiency found in design and constniction, which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the-expected lifetime of the plant, and which represents:"
(1), and (i), or (ii), or (iii) or (iv).)
MPSL has in the past strived andwill do everything possible in the future to "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notify the appropriate Nuclear Regulatory Comission Inspection and Enforcement Regional Office of each reportable deficiency.".
There is, however, another type or class of deficiency which the NRC has requested that they be infomed of (i.e. those which have a potential for becoming reportable). We have complied with this request within our j
understanding of what was needed. To address this requirement for prompt l
reporting of deficiencies which do not in the early stages meet all of the criteria of reportability, MP5L will formalize the following:
The Bechtel QA Manager will notify the MP5L Manager of QA within one working day of his becoming aware of each potentially reportable deficiency.
The MP5L Manager of QA will notify the NRC within one working day of his becommg aware of each potentially reportable deficiency.
NCITE: During the meeting of May 2,1980 your Mr. C. E. 41rphy agreed that this reporting time as stated was acceptable.
The three reasons indicated in your report as conclusions "not supported by regulation" are described below. MPSL requested at the May 2, 1980 meeting that the NRC provide the rationale or requirement in regulation or interpretation which states that later activities (including functional tests, QC and QA actions) and redundancy are not acceptable for this type evaluation. The rationale in the " time frame" used should be considered. hhile MPSL does not condone the use of the rationale in 1980, it does this because of verbal h3C direction not regulation. The extensive definition of $50,000 was placed in MP5L procedures at an NRC inspector direction and has been "de facto" accepted since 1976. As your staff suggested during the May 2, 1980 Meeting we will address these interpretaticns to the" General Counsel."
C.
The NRC Inspection Report in Section 5 Licensee Comoliance with 10CpR 50.55(e) (Lhits 1 and 2) outlined inadequacies m Policies /Procecures anc improper evaluation rationale. These are addressed as follows:
1.
precedural Inadecuacies a.
(1)
NRC Inspecticn Report Section 5.a states:
"paragnphs 3.2 and 3.6 of Bechtel QA Manual policy No.
Attachment A to AECM-80/93 Page 3 of 6 1.
Procedural Inadecuacies - Continued QGG-16.2 is unclear about how the licensee will meet the 24-hour reporting requirement of 10CFR50.55(e).
This information required by 10CFR50.55(e) must be reported to Region II within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of detection of a reportable deficiency in design or constmetion. Bechtel Power Corporation is the Architect Engineer for Grand Gulf Nuclear Station and acts as >PSL's agent.
Therefore, if a responsible employee of Bechtel is aware of a reportable deficiency, it must be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC. This item is discussed further below."
a.
(2) Response Paragraph 3.2 of QGG-16.2, Rev. 3 indicates that
"....it is incumbent upon Eechtel to notify 3PSL of such deficiencies for which Bechtel has responsibility in sufficient time to satisfy the 10CFR50.55(e) requirements. >PSL is responsible to notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after they decide that the condition is reportable..."
Furthemore, paragraph 5.1.5 required QA to make verbal notification to MPSL of such a condition.
This policy statement established the awareness and re-quirement for expeditious reporting of potential significant condtions adverse to quality.
The implementingBechtel QA Procedure, QADP 16.1-1,paracraph 4.4.3 requires the PQAM to " verbally notify'the 3echtel Project Manager, the Division QA Manager and the >P5L Manager of Quality Assurance of the problem."
These requiements were considered adequate on the part of 3echtel to notify.\\PSL as soon as a ccnditicnis determined pot-entially repo m ble. However, the policy will be revised to reflect comitments as described in Atach=ent 3 of this letter.
Attachment A to AEO!-80/93 Page 4 of 6 b.
(1) NRC Inspection Report Section 5.6 states:
" Paragraph 3.4 of Bechtel QA Manual Policy No. QGG-16.2 is unclear.
Specifically the planned test sequence intended to verify design adequacy is never defined.
If the test sequence is limited to only preliminary design activities and does not include constmetion testing this test may not be adequate to detect a discrepancy in final construction."
b.
(2) Response The revision to QGG-16.2 will delete the contents of paragraph 3.4.
c.
(1) NRC Inspection Report Section 5.c states:
" Paragraph 3.5' of Bechtel QA Manual Policy No. QGL-16.2 provides guidance to be used in determining if a deficiency is reportable. The guidance in paragraph 3.5.1 appears less conservative than 10CFR50.55(c)."
c.
(2) Response The criteria in the revision of QGG-16.2 are being quoted from 10CFR50.55(e) to assure no lessening of these re~
quirements.
d.
(1) NRC Inspection Report Section 5.d states:
"MPSL Quality Assurance Procedure 16.20 defines extensive as any evaluation, redesign, repair or combination thereof which will require the ex-penditure of fifty thousand dollars or more.
Evaluations, redesigns or repairs that cost less tMn fifty thousand dollars are not reportable.
Thi's threshold of reportability allows MPSL to not report failures of inexpensive items (springs, switches, etc.)
that could be generic in nature and affect the safety of operations of Grand Gulf Nuclear plant. A dollar limit on the definition of extensive cculd arbitrarily sc een very significant deficiencies.
Each deficiency must be evaluated on its own basis and for the effect it could have en the safety of operatiens of the plant.
l i
~
Attachment A to AEC4-80/93 Page 5 of 6 d.
(2) Response This definition of " extensive" in MPSL Quality Assurance Procedure 16.20 is being deleted in the revision under preparation. Tnis definition is not being used in current 10CFR50.55(e) evaluations.
e.
(1) NRC Inspection Report Section 5.e states:
MPSL Quality Assurance Procedure 16.20 provides for 24-hour notification to the NRC after a deficiency is determined i
reportable. MPSL requires an evaluation of the effect 1
the deficiency could have an the safety of operations of Grand Gulf Nuclear Plant prior to informing the NRC. This evaluation could take days, weeks or months depending on the complexity of the deficiency. The 24-hour reporting requiement of 10CFR50.55(e) (2) was established for prompt notification. MP5L and its agents should conclude that a deficiency which meets one or more of the conditions of 50.55(e) (1) (i-iv) and has the potential to (could) affect the safety of operations of Grand Gulf Nuclear Station is reportable. The NRC should be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to enable dissemmation of generic deficiencies and immediate Regional review of significant deficiencies.
If a subsequent evaluation completed within 30 days shows l
the deficiency to be not reportable, a 30-day written report would not be required if the NRC is informed of this finding.
e.
(2) Response Refer to Item III.2 under Attachment B.
~
trachment A to AEC4-80/93 Page 6 of 6 2.
Imoroper Evaluation Rationale The MPSL response to the SRC Inspection Report Section 5.a through c (Pages 4 and 5 of the Report) is given under Item B above. Bechtel Project Engineering was informed by Bechtel Management Corrective Action Report (MCAR) Number 77 issued April 30, 1980, that improper rationale had been used for MCARs 26 and 41 and that reevaluation on these ari other MCARs j
shall be performed.
. to AEOf-80/93 Page 1 of 5 MPSL RESPONSE TO NCTTICE OF VIOLATION AFFENDIX A I.
The Notice of Violation stated as a deficiency the following:
"As required by 10CFR50.55(e), the holder of a construction pemit shall notif'f the Comission within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of each deficiency found in design or construction which could adversely affect the safe operation of the nuclear power plant at any time during the life of the plant and submit a written report to the Comission within 30 days.
Contrary to the above, MCAR 49 dated April 13, 1979 identified nonconforming piping elbows delivered to the site for use in safety-related piping. The Project QA Manager for the architect engineer for the Grand Gulf facility had been notified of the deficiency by the vendor April 4,1979. The NRC was notified of the deficiency appronmately 13 days after a responsible licensee agent was infomed of the deficiency and the written report was submitted an additional 33 days later."
II.
Chronology The following chrcnology is offered to describe the extenuating circumstances surrounding the reportable deficiency.
Thursday April 4, 1979 - (1) Liberty Equipment and Supply Ccmpany notified the NRC that possible I
defective material had been supplied to them by Tube Turns. Quoting from Liberty's letter to the NRC "The possible defect consists of a carbon content beyond the range allowable by ASDi SA 234 h?B, possibly causing cracks to appear upon welding".
See Attached Liberty letter of April 4, 1979.
It should-be noted that Liberty notified the NRC of possible defective material not of a " Defect" as defined by Part 21.
(2) Liberty also notified Bechtel QA yanager; this is the first time "a responsible employee of 3echtel" became aware of the possible defect.
Attachment B to AEO!-80/93 Page 2 of 5 (2) Continued The Bechtel Manager notified the MPSL QA Manager of the possible defect.
Collectively the decision was made not to notify NRC Region II until confirmation of the possible defect. This decision was based-upon the following:
a.
Both Bechtel's and MPSL's QA Manager were aware that the h7C had been notified by Liberty Equipment 6 Supply Company.
- b. It was known that approximately 27,000 fittings had been manufactured from Heat Number W6719, and of the 1
total approximately 270 were fomed from material having a suspected high carbon content.
Reference Tube Turns Division letter to Liberty Equipment which states:
"We cannot determ1ne which of the products nor the exact number of pieces that were produced frcm high carbon steel, but we do know the number of discrepant fittings in properation to the tota 1 number of fittings produced is minimal."
"Our records indicate that certain of these fittings may have been shipped to you."
- c. Bechtel had received no evidence f cm their field forces of any fitting which had been fcund to be nonweldable or to have cracked during the welding process.
SUIE:
Liberty confimed by telephone 4/28/80 that only 46 high carben fittings have been found as of that date.
l Attachment B to AEOf-80/93 Page 3 of 5 Therefore, the potential of GGNS having received any of the defective fitting was low.
~(3) MPSL and Bechtel concluded that a detemination shculd be made prior to notification of the NRC of:
a.
Did GGNS have any fittings of the potentially defective material destined for safety related services.
b.
Were any of these fittings installed for safety related services.
(4) Issued NCR No. 3507 on Liberty supplied items.
Thursday April 5, 1979 - (1) Bechtel issued MCAR No. 49 requesting i
the extent of the problem be determined and safety impact be detennined. As a minor note the April 13 date listed in j
the Notice of Violation must be a typo-graphical mistake. MCAR No. 49 was initiated April 4, 1979.
Friday April 13, 1979 -
(1) Bechtel, QA Manager notified MPSL QA Manager by letter of potential report-ability of this item.
It had been dete mined during the time interval between April 4-13, 1979, that at least ene of the suspected high carbon fittings was on site in storage at the Bechtel warehouse. At *Jtis time it was not kncwn if any of the pctentially defective heat was actually installed in a safety related system.
While the record is not clear, in all probability the Bechtel QA Manager notified the MPSL QA Manager that the item was potentially reportable.
Our nomal response would have been to notify the NRC no later than within cne working day. However, the City of Jackson
Attachment B to AECM-80/93 Page 4 of 5 experienced the worst flood in its
- history the night of April 13, 1979.
During the week of April 16,1979 nuch of the downtown section of Jackscn was inundated and the city closed downtown streets to all but essential services.
During this week hPSL drew on the General Office Staff to assist in protecting the one remaining sub-station sernng down town Jackson.
Wednesday April 18,1979-(1)hPSL reported the high carbon content fittings to Mr. J. K. Rausch as a potentially reportable deficiency.
Monday May 21, 1979 -
(1) Interim Report was submitted to hE Region II.
It is acknowledged that the report was due Friday 18, 1979, and was not mailed until after the weekend.
Final Report was stated for August 25, 1979.
Tuesday June 25, 1979 -
(1)hE released IE Circular No. 79-10
)
concerning unacceptable material supplied I
by Tube Tums.
Wednesday Aug. 25,1979 -(1)Second Interim Report submitted to hE Region II, final report stated for i
November 30, 1979.
1 Tuesday Sept. 18,1979 - (1) Final R> port submitted to hE stating that the deficiency was reportable.
1 III.
Resuonse l
l 1.
Corrective Steos Taken and Results Achieved As described during the May 2,1980, meeting in your offices we have completed a review of all Reportable Deficiencies frem January 1, 1979 to date.
Our records reveal that for the year 1979, MPSL notified the NE, Region II, of nineteen Potentially Reponable Deficiencies. With the exceptien of the one referenced in the Notice of Violation, all were reported within one working day; welve were repor ed the same day as MPSL's receipt of notif,ication, and an additional six were reported within twenty Iour nours.
~
4ttachment 3 to AEO!-80/93 Page 5 of 5 III.
Rescense - Continued For the year 1980, MP5L notified the NRC Region II of 23 reportable deficiencies; 17 were reported the same day MPSL received notif-ication and one (1) was reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; 4 were considered to be not reportable but the NRC rejected MPSL's conclusions; and one (1) was reported receiving NRC pemission to investigate the condition.
2.
Corrective Steos hhich Will be Taken to Avoid Further Noncomoliance Appropirate changes have been drafted for both the Bechtel and MPSL QA Policy / Procedures. We anticipate issue of final drafts.no later than June 1, 1980. The policies / procedures will inact the following:
The Bechtel QA Manager has been designated as the responsible a.
Bechtel employee b.
The Bechtel QA Manager will notify the MPSL QA Manager in sufficient time that the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting time per 10CFR50.55(e) for all Reportable Deficiencies can be met.
For all deficiencies detemied to be potentially reportable c.
the Bechtel QA Manager will notify the MP5L Manager of QA within one working day of his becoming aware of the item.
d.
For all potentially reportable deficiencies the MPSL Manager of QA will notify the NRC within one working day of his be-cc=ing aware of the item.
For all Items reported under Part 21 by a GGNS supplier MPSL e.
will notify the NRC within one working day of the Manager of QA being made aware.
These ccamitments have already been implemented at the direction of the MPSL Manager of Quality Assurance until revision to appropriate Policies /
Procedures.
3.
The Date hhen Full Comoliance Will Be Achieved Full compliance has been achieved. Appropriate Bechtel and MPSL Quality Assurance Policies / Procedures will be revised by June 16, 1980.
We recuest your reconsideration of this Notice of Violatien in light of the abcVe extenuating circumstances.
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- 610 E. BRUNE AU e P.O DR AWER "S" O
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- KENNEWICK, WA 99336 EQUIIMt ENT N SUPPLY CO.
1 (509)586 1166
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A Olve$ SON 08 alv 'NOUSTmets NUCLEAR 4 April 1979
.c DIVISION Director Office of Inspection and Enforcement U.
S.
Nuclear Regulatory Commission 1717 "H"
Street N.
W.
Washington, D. C.
20555 Gentlemen:
In compliance with 10 CFR, Part 21 (Paragraph 21.1), we are reporting an instance of possible defective material shipment to Grand Gulf Nuclear Power Station.
Notification was received by Liberty Equipment on 2 April, 1979 (copy enclosed).
The material, possibly defective, consists of:
12 pcs.
4" Sch. 40 LRu90 Degree Elbows, SA234 WPB,Section III, Class 2, 1974 Edition, Summer 1975 Addenda, Manufactured by Tube Turns, Louis-ville, Kentucky 40232 Heat Code - W6719 The possible defect consists of a carbon content, beyond the range allowed by ASME SA234 WP3, possibly causing cracks to appear upon welding.
This material was purchased from Tube Turrs by Liberty, on our Purchase Order 70005TR, and purchased from Liberty by Bechtel Power, Grand Gulf, on their Purchase Order 9645-F-
'4148, and shipped direct from Louisville to the jobsite,
.at Port Gibson, Mississippi.
4 i
D.
LIE.NRTY n
" " ^ "
4 a.pril 1979 DIVISION Bechtel Power has been notified of the possible defect:
~
Ron Barnett, Purchasing, Telecon 4-2-79 Jerry Calvey, Expediting, Telecon 4-2-79 R. L. Scott, Q/A, Telecon 4-4-79 It is our understanding, that Bechtel has instituted appro-priate action, and thati an evaluation of the possible defect will be made in the very near future.
Yours Very Truly, b bO N.
S.
Michael K. Reilly General Manager Nuclear Division MKR/pim
Enclosures:
Tube Turns Recall Notice (3-30-79) cc:
Bechtel Power Corporation i
P.
O. Box 41 Port Gibson, Mississippi 39150 Attn:
Ron Barnett J. Calvey R. Scott-I Liberty Equipment Attn:
H.
Lipsett, President R. Bainbridge, G/M Corp.
i
- 3. Roy, Critical Products Manager l
D. Grazzini,-Q/C Manager Tube Turns Box 32160 Louisville, Kentu:.y 40232 l
Attn:
H.
- George, P. Engineering s
i S. Wood l
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TubeTurnsDivision c ~ n.. ::.
Box 32160. Louisvale. Kemu:ky 40222 Telegnene 502 774 6011 RICALL NOTICE March 30, 1979 Liberty Equipment & Supply Co.
P.O. Drawer S Kennewick, WA 99336 Attn: Mr. Mike Reilly It has just come to our actedtion that so=e Tube Turns Welding Fittings
~ hipped to you during the period of February 1, 1978 through March 21, s
1979 may have been produced from a very high carbon steel.
It has been determined that our steel supplier erroneously identified high carbon steel with the same =arking as our regular =aterial and mixed it with our regular material for these products prior to delivery to us.
All products in question bear our Lot Number W6719.
We cannot determine which of the products nor the exact number of pieces that were produced from the high carbon steel but we do know the nu=ber of discrepan fittings in proportion to the total nu=ber of fittings produced is minimal.
The high carbon material is classified as nonweld-able and cracks should occur when welding'is attempted.
- dovever, it is conceivable that cracks could go undetected.
i Our records indicate that certain of these fittings may have been shipped to you.
These shipments are listed on tha attached.
Those shipments refer-encing ASFE Section III Nuclear Power Plant Components and thos,e that involve Title 10CFR Part 21 are identified.
In view of the circumstances you (and each of your customers, if the products have been resold) are advised to pro =ptly return to us any loose fittings bearing our identification nu=ber W6719.
You are urged to pro =r:ly notify your custo=ers of thi. coc=unication.
Credit for =aterial returned by you or your custo=er vill be issued for the invoice value of the fittings or the fittings will be replaced as provided for in our General Terms and Conditions of Sah, at your discretion.
Return shipments should be directed o:
Tube Turns Division 718 South 28th Street Louisville, Kentucky 40211 Attention:
Receiving Inspection Tag:
C-4 042 N.N
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l, 50.'. 3 U IOS L. '.*f*'50 0 m
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i P2 CALL NOTICI 3
Should the caterial be returned by a third party, please have them iden-tify the shipment with your order number.
Regarding products that have been installed, please advise the quantity, product, geographical location, accessibility, phone number and individual's name acquainted with location of the material and action vill be taken to determine disposition of this =aterial.
We request all infor=ation and/or inquiries pertaining to this Lot Number
, be ref erred, preferably in writing, to:
, Mr. Sam Wood Tube Turns Division P.O. Box 32160 Louisville, Ky.
40232 Phone (502) 774-6457 (After 4/4/79)
Prior to 4/4/79 phone (502) 774-6252 Tube Turns regrets this unfortunate occurence. However, there was no practical way to detect the mixed steel.
We appreciate your assistance s
in helping us resolve this problem.
89
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Very truly yours, f"',
y-/, y l 7yj,6 ru&n s Aa TU3E TURNS f,yy{ p {-
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H.H. George Vice President, Engineering 6.,pff js P.S.
Those products identified as ASME See:1on III Nuclear Power Plant Co=ponents and those involving Ti:le 10CFR Part 21 are to be tagged C-4042-N.
All
'others are to be tagged C-4042 as indicated on page 1 of this letter.
cc:
Mr. Harry Lipsett, Pres.
Liberty Equipment & Supply Co.
P.O. sox 24848 0**]D
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Seattle, WA 98134 e e jg eMUSUN m
Ett IvrP5 Chr$&. h'.t'ntt' 4.0M.E'.'.3 GI.M
- Ce;.any Ly:1,m 1: 0.h;f.e!, i,0.