ML19325C530
| ML19325C530 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/06/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19325C528 | List: |
| References | |
| NUDOCS 8910170010 | |
| Download: ML19325C530 (17) | |
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' EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO SAFETV AND PERFORMANCE IMPROVEMENT PROGRAM PROGRAPMATIC AUDIT l
METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR CORPORATION THREE MILE !$ LAND. UNIT 1 DOCKET N0. 50-P89 1.0 SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM AUDIT l
1.1 Introduction 1
During the week of July 31 - August 3,1989, the Nuclear Regulatory Comission (NRC): staff conducted a programatic audit of General Public Utilities Nuclear (GPUN)SafetyandPerformanceImprovementProgram(SP!P)foritsThreeMile Island, Unit 1(TN!-1).
l The Babcock and'Wilcox Owners Group (BWOG). developed the SP!P program in order to reduce both the frequency of reactor trips and the complexity of post-trip-responses. The purpose of this audit was to evaluate GPUN's SPIP program for TMI-1.
1.2 Background
AftertheaccidentatThreeMileIsland, Unit 2(TMI-2),nuclearpowerplant l
owners made a number of improvements to their nuclear facilities. Despite l.
these improvements, the U.S. Nuclear Regulatory Comission (NRC) staff was concerned that the number and complexity of events at Babcock & Wilcox (B&W) nuclear plants had not decreased as expected. This concern was reinforced by the total-loss-of-feedwater event at Davis-Besse Nuclear Power Station on June 9, 1985, and the overcooling transient at Rancho Seco Nuclear Generating Station On December 26,-1985.
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- By letter dated January, 24, 1986, the NRC Executive Director for Operations (ED0) informed the Chairman of the BWOG that a nun 6er of recent events at i
B&W-designed reactors should be reexamined.
In its February 13, 1986, response to the ED0's letter, the BWOG committed to lead an effort to define concerns relative to reducing frequency of reactor trip and the couplexity of post-trip response in B&W plants. The BW0G submitted a description of the program entitled " Safety and Perfomance Improvement Program" (BAW-1919) on May 15, 1986. Five revisions to BAW-1919 have been submitted.
Included in BAW 1919 were specific tasks to be completed by each utility under a SPIP.
The NRC staff reviewed BAW.1919 and its five revisions and presented its
- evaluation in NUREG-1231, dated Novem6er 1987, and in Supplement No.1 to NUREG-1231 The NRC staff has previously perfomed an audit oftheBW0d'datedMarch1988.
i s disposition of the technical reconenendations (TRs) that were developed by various BWOG connittees and task groups. The results of that I
audit, which were favorable, were reported in NRC Irspection Report 99900400/87/01. However, the staff determined that an NRC audit program to l
ensure the quality of each utility's program used to control the disposition and implementation of TRs is necessary since the majority of the r
t recommendations developed by the BWOG did not provide specific design details.
Initially, a programmatic audit would be conducted to evaluate the adequacy of the SPIP progransnatic process and TR disposition. This would be followed by an implemertation audit to evaluate the adequacy of the TR inplementation process.
ThescopeoftheSPIPprogramaticauditincludesanevaluationof(1)the commitment and involvement of corporate management in the SPIP process (2)(3) the commitment and involvement of site organizations in the SPIP process, and the SPIP process for dispositior, of TRs. The SPIP programatic audit also included a review of the disposition of 34 selected TRs to determine the acceptability of the decisions regarding TR applicability and the evaluation for TR implementation. The acceptability of the TR implementation will be evaluated later during the SPIP implementation audit.
1.3 BWOG Reconundendation Categories All BWOG recommendations are to be tracked through closure. The following categories have been selected as the " bins" to be used by the utility when I
assigning. tracking status. These categories, as well as the explanatory notes, are addressed in the BWOG Recommendation Tracking System (RTS), in BAW-1919, and in NUREG-1231.
Evaluating for Applicability (E/A) l The recomendation is being evaluated by the utility for applicability to their particular plant. The evaluation may conclude that the recomendation (a) is not applicable, (b) was implemented previously and is operable,ld beor (c) if ap licable, requires further evaluation to determine if it shou im lemented.
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3 Based on the initial screening process, the EP assigns an RP to evaluate the basis of the TR for applicability to TMI-1. The RP evaluates the TR for i
applicability, and eitter assigns a status of Closed /Not Applicable (C/NA),
Closed / Rejected (C/R)Idered for implementation at TN!-1.orClosed/0perable(C the TR should be cons The RP submits an 1
applicability close-out Memo with recommendations to the Review Board for approval.
The purpose of the Review Board approval is to assure that all aspects of each TR are considered during the evaluation phase.
If the Review Board disagrees with the conclusions in the Close-out Memo, the RP is directed to reevaluate the TR or to clarify the conclusions in the Close-odt Memo. Clarification may require reevaluation, or may be obtained through a presentation of the findings by the RP at a Review Board meeting.
j Evaluating for Implementation (E/I)
An evaluation of the recommendation for applicability has been completed, and the recommendation is now being evaluated to determine if it should be implemented.
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Implementing (I)
Utility evaluation is complete and the need for software / hardware changes to meet the intent of the recommendation has been identified.
Software changes have been assigned to appropriate organization and are scheduled and budgeted. Hardware changes have been assigned to appropriate organization for implementation, funding is approved, and the changes are included in a corporate plan for implementation.
Additional cooments on implementation status or method of implementation are appropriate.
Closed /0perable(C/0)
Utility meets the intent of the recomendation, and iiaplementation is complete.
Review of existing plant sof tware or hardware results in conclusion that intent l
of recommendation is alre6dy met.
If software changes were required, new/
revised procedures, traininil plans, etc. are approved and issued. Personnel are trained and procedures dssued.
Closed /Not Applicable (C/NA) s l
Utility evaluation determines that the recomendation does not apply to plant-l specific configuration; no past experience of underlying problems has occurred.
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. Software / hardware of concern does not exist, and existing software / hardware is such that a similar problem could not develop at their plant.
Additional comments on why it is not applicable are required.
Additional comments on why it is rejected are required, f
2.0 GENERAL PUBLIC UTILITY NUCLEAR - SP!P TECHNICAL REC 0pmENDAT10N AND IMPLLRLRTATION PROCE55 GPUN and TMI-1 established a formal, procedura11 red SPIP process to control TR disposition. -The following description of the GPUN organizational structure andSPIPproceduresandpoliciesisbasedonwritteninformation[GPUNProject EngineeringGuides(PEG)No.30(Rev.1)]andflowcharts(seeAppendixA) l provided by GPUN. Additional information was obtained during interviews with GPUN and TMI-1 personnel.
2.1 Organizattoral Structure TheGPUNisadministeredbytheGPUN$PIPReviewBoard(ReviewBoard)which BoardMembers(twoexofficio)gineeringandDesign(theBoardChairman),six consists of the Director of En and five alterhete board members. The Board members are Directors within the GPUN and/or TMI-1 organizations or a designee acting for their Director.
The Review Board meets periodically to review specific requirements associated with unresolved TRs and identify actions necessary to resolve difficulties in implementation or to redirect implementation plans to ensure the TRs are satisfactorily implemented.
In addition, the board reviews the TR disposition and implementation decisions and either approves the implementation plan or request additional information from the Responsible Person (RP). The board also assesses the overall status and progress of GPUN work on SPIP TRs to assure that necessary actions are taken to satisfactorily implement the TRs in a timely and cost effective manner.
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TheDirector,EngineeringProjects(EP)actsastheliaisonbetweentheBWOG and GPUN and is a member of the Review Board.
In addition the EP screens each TR received from the BWOG, establishes a TR tracking file for subsequent engineering analysis and results, and selects the Responsible Party (RP) for each TR.
P The RP evaluates the TRs for applicability and implementation, develops the budget and schedule for TR implementation, and coordinates the efforts of site organizations in the TR implementation phase.
2.2 Processing of BWOG Technical Recomendations
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5 A flow chart of the GPUN $ PIP Implementation process is shown in Appendix A, Figures 1 and 2.
This section provides an explanation of each of the flow l
chart functions.
l The Director, Engineering Projects (EP), who is a member of the Review Board, screens each TR received from the BWOG and establishes a tracking file for subsequent engineering analyses and results. The tracking is performed using the GPUN TMI-1 Project 2 scheduling system. The documentation related to each TR evaluation and implementation is placed in a dedicated file, along with supporting documentation when appropriate.
Closed / Rejected (C/R)
Utility evaluation determines software / hardware changes meeting the intent of the reconnendation are unacceptable and will not be implemented.
Recommendations may be unacceptable because:
(1) Implementation would not result in an overall improvement in plant safety or performance.
l (2)
Implementation of recommendation as described would not effectively resolve problem of concern.
l (3) Resources required for implementation are excessive for expected plant t
improvement or benefit.
If the Review Board accepts the Close-out Memo, the TR file and memo are
- forwarded to the EP for additional processing.
If the TR is not applicable to TMI-1 is already in place at TMI-1, or is rejected due to questionable benefit, the TR is. closed and filed for future reference.
If additional action is required to resolve a particular TR issue, the Review Board adds a request for additional information or additional planning requirements to a list of open action items. When an open action item is resolved before the next scheduled Review Board meeting, the open action item is closed and removed from the list. The open action items list is only maintained as part of the Review Board meeting minutes, and is usually not included in the Project 2 tracking system or the TR document file.
If it is determined that the TR should be im>1emented at TMI-1, the process of implementing the TR depends on the type of c1anges recomended by the TR and accepted by the Review Board.
If the TR is to be implemented with a software change, the RP prepares the new or revised procedure, training, or sof tware change and submits the documentation of completion to the EP.
If the TR implementation requires hardware changes, the RP establishes a capital project, mini-modification, or job ticket scope, budget, and schedule.
In either case, the RP submits the schedule to the EP who changes the B&WOG status from Evaluating for Applicability / Implementation to Implementing.
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6 Following completion of the implementation process, the RP submits documentation to the EP describing how and when the TR was implemented and l
releases the affected system to plant operations. The EP adds the com)1etion document to the TR file, updates the Project 2 system record (s), and ciangut i
the TR status to Closed / Operable.
If a TR is revised due to a BWOG recomendation, additional information is
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received, or a plant experience is applicable that justifies reopening a TR for additional evaluation, the EP retrieves the TR file, and assigns the TR to the appropriate RP for reevaluation, e
3.0 REVIEW 0F SELECTED RECOMENDATIONS 3.1 Selection criteria t
In order to have an in-depth understarEn process, the staff reviewed 34 TR files (g of GPUN's SPIP TR disposition see Appendix B) and evaluated the timeliness and acceptability of TR disposition. These TRs were selected based on NUREG-1231, " Safety Evaluation Report Related so Babce.k and Wilcox Owners Group Plant Reassessment Program," and on the most recent Recommendation Tracking System (RTS) report. A broad spectrum of TRs were selected so that I
representative TRs from the following categories were reviewed:
1)TRs
= designated ' key" by the BWOG and also TRs which were considered high priority by the NRC although not designated key; 2) TRs associated with eac1 of the plant systems (see Appendix B) having a bearing on the SPIP goal of reducing the nunter of reactor trips and the complexity of post trip responses: 3)TRs at each point in the disposition process (i.e., C/0, C/R, C/NA, E/A, E/I, and I).
3.2 Results of Staff Review The staff found evidence of adequate corporate and site management comitment and involvement in the SPIP process. The staff also found that GPUN used a.
formal, documented, procedure controlled, systematic process to evaluate SPIP TRs for disposition.
In addition, the staff found that GPUN and TMI-1 personnel (i.e., members of GPUN SPIP Review Board the Director, Engineering Projects,theResponsibleParties,andsupportstaffinvolvedintheSPIP i
processes) were knowledgeable with respect to their duties and responsibili-ties and that good comununication channels existed among these personnel. Also, the documentation contained in the TR packages reviewed was in most cases complete and was always retrievable and auditfole.
In addition the documenta-tionmaintainedthroughouttheSPIPTRdispositionprocessprovldedadequate information regarding TR disposition decisions.
Furthermore, the recommended actions necessary to implement a TR appeared to adequately address the intent and basis for the TR. The engineering analysis for rejecting a TR or portions of a TR were also found to be adequate.
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The staff found that the Review Board satisfactorily evaluated the adequacy of disposition decisions related to all TRs categorized as Closed / Operable prior to June 1987. For those TRs dispositioned subsequent to June, 1987, the i
adequacy of TR disposition was reviewed periodically during the Review Board meetings. The meeting date that a specific TR was reviewed is noted on the Project 2 84W Owners Group Recommendations Disposition Schedule Summary Sheets. Yhe meeting minutes are formally maintained in accordance with GPUN guidelines.
In addition the staff found that the open action items (i.e., modifications that are stIll being implemented, procedures that are still being reviewed and I
upgraded, maintenance packages that are still being upgraded, etc.) associated with TRs categorized s Closed /0perable were adequately tracked and monitored in the Review Board meeting minutes. Even though categorizing a TR as Closed /
Operable with open action items is not exactly in keeping with the BWOG Closed /
Operable definition, GPUN and TMI-1 satisfactorily track and close out these 1
items in accordance with plant and corporate policies and procedures.
The staff found that 15 TRs were reopened for evaluation based on BWOG Steering Committee recome ndations following the Arkansas Nuclear One, Unit 1, and Oconee Nuclear Station events, and that the reevaluation and clnsure were performed in a satisfactory manner.
The staff found that Closeout Memorandums contained in the TR files adequately documented the determination of TR intent the associated engineering analysis, the conclusions formulated during the evaluation of applicability, and the evaluation for implementation phases.
In addition, the staff found that when additional information or feedback was required to resolve differences of opinions in the TR disposition process, the information appeared to be well documented and sufficiently detailed to support final TR disposition conclusions.
The staff found that if schedular slippage occurred during any phase of TR disposition, it was adequately tracked on a punch list of Responsible Persons (RPs) behind schedule and was reviewed monthly by management, during the SPIP Status Sunnary and Overview meetings.
The staff found that cross check provisions were included in the SPIP process to assure that all EP decisions on TR applicability were confirmed or denied by the RP and, that all decisions on TR applicability and/or implementation were confirmed adequate or denied by the Review Board. The staff also found that GPUN adequately reviewed the TR disposition decisions of other B&W facilities to aid them in their final TR disposition decisions.
The staff also found that TRs were receiving adequate prioritization which assured that final disposition and implementation was being performed in a timely and cost effective manner.
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1 The staff found that only 16 (see Appendix B) of the approximately 222 TRs were still in the E/I or I phase (i.e., 1 TR was in the E/I phase, 4 TRs were in the I phase which required a procedure or training change, and the 11 additional TRs in the I phase required plant modifications).
i GPUN and TMI 1 plan to have all but two applicable TRs implemented by the end of the 1990 Refuel Outage #8. TR-126-IAS will be implemented during the Refuel Outage #8 cycle and TR-158-0PS will be implemented by the end of the mid-1991 Refuel Outage #9.
In addition 22 BWOG SPIP TRs requiring plant modifications were implemented during the ReYuel Outage #7 cycle in 1988.
Based on the minutes of the SPIP Review Board Meeting held at TMI-I on May 24, 1989, the staff found that 14 of 164 TRs categorized as closed operable had open action items associated with them. These open action items (e.g., plant modifications (TR-155-EFW), maintenance packages review and update (TR-109-MSS), follow-upactionstostudies(TR-177-0TS),andcloseoutsummaries (TR-034-ADM), etc.) must be completed to fully implement the TRs. The staff also found that six of these TRs required a closeout summary whereas the remaining eight of the TRs required slightly more detailed efforts to close out the open action items. The staff found that neither the P-2 tracking system "B&W Owners Group Recomendations Disposition Schedule" nor the TR files sumarized the open action items associated with a specific TR. However, the open action items were satisfactorily tracked in the GPUN SPIP Review Board i
meeting minutes and were being completed in a timely manner.
During the staff's review of the 34 selected TR files, some documentation deficiencies were found. They are documented in Appendix D.
The staff also found that GPUN and TMI-1 had 1) noted similar file deficiencies during an 1989, SPIP Revlow) Board meeting, and 3) developed guidelines for " Closeout of internal audit 2 discussed a means to update the TR files in the May 24, SPIP Recomendations" with a " Closeout Sumary" form to be completed for each l
TR. The guidelines and associated form are being implemented into the SPIP process. The staff agrees with the utility in that proper implementation and use of the closeout sumary guidelines and form should correct the TR file deficiencies.
The staff found that even though file documentation was sometimes incomplete, adequate information was available in other GPUN and TNI-1 records and was provided in a timely manner.
4.0 CONCLUSION
S - SPIP PROGRAMMATIC AUDIT The staff found that GPUN had established a formal process, governed by GPUN and TNI-1 policies and procedures, that adequately controls the disposition of BWOGTRsfromidentificationontheBWOGRecommendationTrackingSystem(RTS) through final disposition. The staff also found that corporate and site management and site organizations were adequately involved in the SPIP process and were comitted to ensuring that the process effectively controls TR disposition. The personnel involved in the SPIP process appeared to be knowledgeable with respect to their SPIP duties and tesponsibilities.
In addition, the staff found that good comunication channels existed between L
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organizations and that TRs were receiving adequate prioritization for disposition.and/or modification. The staff found that TRs were being closed out in a timely manner even though some TRs were categorized as Closed / Operable with open action items still outstanding. The staff also found that the open action items were adequately tracked in the Review Board meetings minutes notes and were being satisfactorily completed in accordance with GPUN and TMI-1 policies and procedures.
In addition, the staff found that the documentation presented in the TR files was complete in most cases, was adequate, in most cases complete, and contained only a few minor deficiencies. The TR documenta-tion was auditable and adequately supported the decisions regarding TR dispost-E tion.
The staff reviewed 34 selected TRs and found that 29 were categorized as C/0 (twoofwhichhadopenactionitemsthatwereaddressedintheReviewBoard meeting notes), one was categorized as C/NA, another one was categorized as C/k, and three were being implemented.
Based on the above, a review of SPIP and TR documents, a review of GPUN and TMI-1 policies and procedures, and discussions with GPUN and TMI-1 personnel, the staff determined that the GPUN SPIP program used at the THI-1 satis-factorily controls TR disposition and is, therefore, acceptable.
The adequacy of TR implementation will be evaluated later by the staff during the implementation audit.
DATED:
October 6, 1989 Principal Contributor: Y. Hsii L
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Flow chart of the GPUN SPIP TR implementation process (continued from Figure 1)..
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Appendix 8 I
SAFETY AND PERFORMANCE IMPROVEMENT PROGRAM THREE MILE ISLAND, UNIT 1 PROGRAMATIC AUDIT SELECTED PLANT SYSTEMS, TRS REVIEWED, AND TR STATUS Integrated Control S MainFeedwater(MFW)ystem(ICS)
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-Administrative (ADM) l
-MainSteamSystem(MSS)
Operations (0PS)
L PlantElectricalSystem(PES)
Instrument Air System (! 5)
Emergency Feedwater (EFW Primary Relief Valves (P V) j Main Turbine System (MTS STATUS from March, 1989 RTS TR-001-ICS Replace RC flow signal input to ICS with RC pump status.
C/0 09/88 TR-008-!CS Restore high pressure reactor trip set mint, change'ULD setpoint and L
runi>ack rate for loss of one MFWP.
C/0 01/89 1
L TR-013-!CS Prevent Loss of power to ICS or NNI.
C/NA 01/88 I
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I TR-014-MFW Install a monitoring system in the NFWP trip circuitry.
03/90 i
TR-015-MFW Determine if a Low MFW pump suction pressure is needed.
C/0 09/87 L
L TR-020-MFW Establish procedures for shifting l
MFWP oil supply.
C/0 01/87 TR-034-ADM Review of training records - assure Loss of ICS power is addressed.
C/0 06/89 l
TR-038-!CS Develop and implement a preventive i
maintenance program for the ICS/NN!
(this includes revisions). Rev. 3.
C/0 07/89 l
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TR-066-MFW Ensure that a single electrical failure will not cause a loss of both feedwater trains.
C/0 01/89 TR-067-MFW Evaluate setpoints and functions of automatic MFWP trips.
C/0 03/88 TR-071-MFW Install valve position indication for the startup and MFW regulating valves.
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TR-096-MSS Minimize / Mitigate overcooling via control of TBVs and ADVs.
C/0 11/87 TP.-099-0PS Include guidance on excessive MFW, l
throttling AFW and throttling HPI in plant procedures.
CO 10/87 TR-104-!CS Incorporate automatic selection of valid input signals to ICS/NNI.
C/0 09/88 TR-105-ICS Perform field verification of ICS/NNI drawings.
C/0 01/88 TR-107-ICS Improve maintenance and tuning of 105.
Rev.4.(5-31-89 completion)
C/0 05/89 TR-119-PES Implement preventive maintenance for electrical buses.
C/0 03/88 1R-122-IAS Instrument air should be systematically inspected for leaks.
C/0 03/88 l
TR-128-IAS Review training and loss of air response procedures for instrument air system.
C/0 06/88 l
TR-144-IAS Develop an Instrument Air loss of air l
Emergency Procedure.
(SeeTR-128)
C/0 06/88 TR-153-IAS A plant specific air system failure evaluation should be made.
C/0 03/88 i
TR-157-0PS Validate E0Ps to detemine if adequats I
staffing and prioritization exist.
C/0 12/87 TR-159-0PS Evaluate secondary stem controls to achieve remote manua control in the Main Control Room of all post-trip steam flow paths, MFW, and EFW.
Rev. 2.
I 01/90 TR-163-EFW Review of Emergency Feedwater surveillance and periodic test procedures.
C/0 03/88
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TR-174-MSS Response time improvement for TBVs and ADVs.
(See TR-048)
C/0 09/88 TR-175-PRV Ensure the PORY block valve functions as designed under transient conditions.
C/0 12/87 TR-178-ICS Ensure plant goes to a known safe state on loss of IC5/NNI power.
C/0 09/88 2
TR-179-MFW Identify areas to enhance the reliability of main feedwatar and condensate control.
C/0 03/31/89 TR-181-0PS Verify adequacy of instrumentation and displays used to assess and control the AT06 stability parameters.
C/0 01/89 TR-190-ICS Develop backup manual or automatic control for pressurizer level and pressure control.
C/0 09/88 TR-2004TS Install EHC oil system time delay or orifice to limit ARTS sensing line predications. Rev. 1.
C/R 03/89 TR-201-MTS Review EHC overspead and fast control and intercept valve circuits.
C/0 06/88 TR-203-PES Establish preventive maintenance to increase reliability of inverters.
C/0 03/89
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Appendix C BWOG SP!P TRs CATEGORIZED AS E! OR I P-2 STATUS OF 19 JULY 89 GPUN/TNI-1 1R_
$TATUS TR-007-ICS Implementation by Modification
-014-MFW
-019-MrW
-025-MTS
-017-MFW
-114-PES -
-126-IAS
-143-IAS
-158-0PS
-159-0PS
-171-0PS 1
TR-125-IA$
Implementation by Procedure / Training
-127-IAS
-165-EFW-
-217-EFW TR-176-POV Evaluating for Implementation L
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Appendix D j
BWOG $ PIP TR FILE DEFICIENCIES IDENTIFIED DURING THE AUDIT OF GPUN/TMI-1 j
1 TR BRIEF DESCRIPTION OF DEFICIENCY TR-034-ADM Documentation to support closure was not in file.
TR-101-MTS TR-107-!CE t
TR.11g-PES i
TR-203-PES i
TR-038-ICS P-2 dates do not agree with dates in TR files and/or TR-071-MFW Review Board meeting minutes.
TR-104-ICS SPIP Review Board approval of TR disposition was.not TR-153-IAS in the meeting minutes.
TR-105-ICS Documentation explaining why the TR was initially l
rejected, then re-opened was not in file.
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I Appendix E LIST OF ATTENDEES AT ENTRANCE AND EXIT PEETINGS FOR THE-THREE MILE ISLAND, UNIT 1. PROGRAMATIC AUDIT f
Attendee organization Entrance Exit 1
Jim Langenbach GPUN X
Michael E. Waterman INEL/NRC X
X Don Grace GPUN X
X' John M. Fehringer INEL/NRC X
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E. Wayne Roberts INEL/NRC X
X Y. Gene Hsii NRC/NRR X
X' Dave $1 ear GPUN X
1 Don Croneberger GPUN X
X Gordon Bond GPUN X
X Raymond S. Markowski GPUN X
l Chester Shorts GPUK X
X-Ed Pagan GPUN X
X John Mateychick GPUN X
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