ML20035A946

Staff Requirements Memo Re 930316 Discussion in Rockville, MD W/Several Public Interest Groups,Licensee & NRC on Issuance of Full Power OL for Facility

ML20035A946
Person / Time
Site:	Comanche Peak
Issue date:	03/24/1993
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
REF-10CFR9.7 M930316, NUDOCS 9303300269
Download: ML20035A946 (2)

Text

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'o UNITED STATES

^g NUCLEAR REGULATORY COMMISSION n

wAsmNcTon, o. c.20sss

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March 18, 1993 Sn - M 3 The Honorable Joseph Lieberman, Chairman 50 - 94 i Subcomittee on Clean Air and Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, DC 20510

Dear Mr. Chairman:

I am responding to your letter of February 16, 1993, in which you referred to a televised report by WSSB-TV (CBS), Hartford, Connecticut, concerning faulty equipment imported from China and used at the Seabrook Station, Seabrook, New Hampshire.

You also requested a reply that addressed our analysis of this issue and its effects on all U.S. Nuclear Regulatory Commission (NRC) licensees, our coordination of this issue with other Federal and State agencies, other NRC licensees that reported having flanges that could be substandard, and the steps we are taking to address any safety issues.

On December 7,1992, Mr. Cole of WSSB-TV contacted the NRC and inquired about the NRC's actions regarding China flanges at the Seabrook Station. Mr. Cole was provided a verbal overview of the NRC's actions regarding the flange issue, as well as specifics on NRC follow-up activities at Seabrook.

On September 10, 1992, the NRC' issued Information Notice (IN) 92-68, "Potentially Substandard Slip-On, Welding Neck, and Blind Flanges" (copy enclosed), to all power reactor licensees, with copies provided to all non-power reactor licensees, agreement states, and major vendors supplying the nuclear industry. Additional NRC licensees will be notified of the flange problem if it is found to be appropriate during the mrse of our ongoing review. The IN alerted recipients to problems that could result from substandard flanges imported from the People's Republic of China and enclosed an analysis of this issue.

Power reacto_r lit.ensees use the largest number of flanged assemblies in applications with the greatest safety significance.

In this IN, the NRC stated that the National Board of Boiler and Pressure Vessel Inspectors (Board) of Columbus, Ohio, received numerous reports of flanges marked " China" that contained ' cracks, inclusions, and slugged weld repairs, and that were constructed from two pieces of material. The suspect flanges were marked as steel forgings that comply with the American Society for Testing and Materials (ASTM) Standard A-105, " Specifications for Forgings, Carbon Steel, for Piping Components,* and the American National Standards Institute (ANSI) Standard 816.5, " Dimensional Standards for Steel Pipe Flanges and Flanged Fittings."

When the IN was issued, the NRC did not have evidence that any suspect China flanges had been installed in U.S. naclec. power plants. However, since that IN was issued, the licensees listed in the enclosure have verbally advised the NRC of finding suspect China flanges in uninstalled piping assemblies for use in planned modifications or installed in nonsafety systems.

Because ins do 1

9303300269 930324

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PDR 10CFR PT9.7 PDR i

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Letter to Senator Lieberman dated March 18, 1993 Distribution:

JTaylor JSniezek HThompson JBlaha JKnubel HDenton JScinto CKammerer TTMartin, RI CERossi RZimmerman SECY OCA TMurley FMiraglia WRussell JPartlow AGody, Sr.

si DMCrutchfield 1

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NRP. Mailroom (Green Ticket No. 0008598)

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Central Files (w/ incoming)

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EDO R/F 0008598 PDR (w/ incoming) dvfp g

DRIL R/F y,>8 /. l 4A Tech Editor's comments have been incorporated VIB R/F

• See previous concurrence

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Senator Lieberman.

not require licensees to take specific action or respond in writing, this list may not bound the extent of the problem but our inspection experience has been that licensees take the actions necessary to address the safety issue.

Properly implemented, NRC-required, quality assurance programs should minimize the possibility that licensees have installed China flanges in safety systems.

Only the licensee for the Seabrook Station reported finding flanges in a safety ;ystem (si>. 4-inch welding neck flanges installed in the control rcom ventilation) that could be substandard because they were stamped " China."

The licensee performed insitu evaluations of the flanges installed at the Seabrook Station to assess their quality, integrity, and ability to perform their safety function in a ventilation system. The licensee deter;nined that the China flanges were acceptable for this particular installation. The licensee's actions have not identified China flanges installed in any other safety system. As documented in NRC Inspection Report 50-443/92-25, the NRC resident inspector determined that the licensee was taking sufficient actions to address the issue, including the inspection of about 20 China flanges installed in nonsafety systems. The resident inspector will be reviewing the final results of the licensee action plan upon completion.

During a meeting on August 19, 1992, of the Interagency Working Group for Problem Parts and Suppliers, the NRC's representative discussed the issue of flanges marked " China" that could be substandard.

IN 92-68 was issued through the Government-Industry Data Exchange Program (GIDEP) to its members in Agency Action Notice AAN-U-92-115. September 24, 1992. The Board, through its 1992 Special Edition of the Bulletin, Volume 48, Number 2, alerted its membership (state jurisdictional officials) and Bulletin subscribers of the results of its investigation of flanges marked " China."

j The NRC and the Board are continuing to review information related to the flange problem.

Further inspections are also planned to assess licensee and vendor actions associated with this issue.

In addition, the NRC is starting i

work on a similar problem recently found by the Federal Trade Comission in which stainless steel flanges.and butt-welded pipe fittings imported from Taiwan could be substandard. The NRC will continue to provide the industry i

information on substandard parts, including an update to IN 92-68, if appropriate.

2 Sincerely, Or}ginal signed by James M. Taylor James M. Taylor i

Executive Director for Operations

Enclosures:

1.

NRC Licensees Reporting China Flanges 2.

Information Notice 92-68 cc: Senator Alan K. Simpson

• Distribution and concurrence see next page

~.

ENCLOSURE 1 i

I NRC LICENSEES REPORTING CmNA FLANGES i

1.

Virginia Electric and Power Co. (North Anna Power Station /Surry Power Station) t' 2.

Wolf Creek Nuclear Operating Corp. (Wolf Creek Generating i

Station) 3.

Pennsylvania Power & Light Co. (Susquehanna Steam Electric Station)

[

4.

Arizona Public Service Co. (Palo Verde) a 5.

Southern California Edison Co. (San Onofre Nuclear Generating Station) 6.

Omaha Public Power District (Fort Calhoun Station) 7.

Pacific Gas & Electric Co. (Diablo Canyon Nuclear Power Plant) 8.

Texas Utilities Electric Co. (Comanche Peak Steam Electric Station) 9.

Houston Lighting & Power C3 (South Texas Project) 10.

North Atlantic Energy Service Corp. (Seabrook Station) h 7

i t

i l

s l

ENCLOSURE ;

UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 September 10, 1992 NRC INFORMATION NOTICE 92-68:

POTENTIALLY SUBSTANDARD SLIP-ON, WELDING NECK, AND BLIND FLANGES A~Jressees All holders of operating licenses or construction permits for nuclear power reactors.

Purocse The U.S. Nuclear Regulatory Commission (NRC) is issuing this information I

notice to alert licensees to problems with potentialTy' substandard slip-on, welding neck, and blind flanges.

It is expected that recipients will review this information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems.

However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response is required.

Description of Circumstances On July 9, 1992, the NRC staff met with a representative of The National Board of Boiler and Pressure Vessel Inspectors (Board) to discuss the Board's investigation of problems associated with flanges that originated from the People's Republic of China. The Board has received numerous reports of flanges marked " China" that contain cracks, inclusions, and slugged weld repairs, and that were constructed from two pieces of material.

The suspect China flanges were sold to U.S. suppliers through several trading companies. Three of the trading companies identified were:

Billiongold Company Limited of Hong Kong, Tain Gong Company, and Shanxi Province Overseas Trading Corporation.

The suspect flanges were marked as forgings that complied with the requirements of the American Society for Testing and Materials (ASTM) Standard A-105, " Specification for Forgings, Carbon Steel, for Piping Components," nd the American National Standards Institute (ANSI)

Standard B16.5, " Dimensional Standards for Steel Pipe Flanges and Flanged Fittings." However, the suspect flanges were manufactured with ring-inserts welded to the inside diameter of the flange and the outer surfaces were machined.

Consequently, a visual inspection would not detect either the welding or the two-piece construction. Other flanges were found with slugged weld repairs to the flange hub and still others failed to meet the material specification requirements for thermal treatment, mechanical properties, or chemistry.

- 9209030274 i

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IN 92-68 September 10, 1992 Page 2 of 2 Discussion The Board determined that one Chinese flange manufacturer, of the saveral known factories that supply the U.S., shipped more than 110 tons of ASTM A-105, ANSI B16, China flanges to this country.

The Board stated that over 7,000 flanges are being removed from refineries and petro-chemical plants as a result of failures that occurred during welding, bolting, and hydrostatic and pre-operational testing. The Virginia Electric and Power Company informed NRC staff that China flanges are installed in two of its fossil power plants and others are in its warehouse. At the time of discussion, Virginia Power had not determined whether any suspect China flanges are installed in its nuclear power plants.

The NRC does not hate evidence that any suspect China flanges have bean installed in U.S. nuclear power plants. However, specific examples and discussions of the problems are attached for information.

l A potentially substandard " China" flange can pass between two or more distributors before reaching the end-user facility. A nuclear power plant j

could buy a commercial grade China flange from a distributor to dedicate the flange for safety-related use, or safety-related components or subassemblies that contain China flanges could be supplied by licensee-approved manufacturers or fabricators.

Establishing and verifying procedures to trace procured equipment and material tc the original manufacturer or mill is an l

important prerequisite to inspecting and testing during the dedication It is possible for a licensee to install potentially substandard or i

process.

defective equipment or material if it does not adequately verify that the product can be traced to the original manufacturer.

If This information notice requires no specific action or written response.

you have any questions about this matter, please contact the technical contact listed below, one of the Board representatives listed on the attachments, or the appropriate Nuclear Reactor Regulation (NRR) project manager.

J t

{ Charles [. Ro.R k: -M 7 i

rd ~

ssi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation t

i Technical contact: Steven M. Matthews, NRR (301) 504-3191 l

i t

Attachments-1.

1992 Board article, " Failure Analysis of a Slip-On Flange."

~

2.

Sei2cted 1992 Board "NBB!nfoletters."

3.

List of Recently issued NRC Information Notices

Attachment'l -

i IN 92-68 l

September 10, 1992 Page 1 of 3 o

l Theinstallation ofa 14 ~ slip-on pange in a pipeline was recently

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_j witnessed by AlJustin. chief inspectorfor the state ofMinne-y( b;,;.:'.a'.)?

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sota. Theflange originally had a

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14-3/4" inside diameter, which 1

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was reduced by w-iding a 3/4"

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ring and inachine welding. The '

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ring.however, separatedfrom the FAlLURE 9""E E'"'"8 'hPpearance ofa crack. Thefange ss reported to A N A LYS l S have been manufactured in the People's Republic of China.

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OF A several suchpanges have been reported in Ihefield. s!! individuals in Ihe.

SLlP-ON i"d"s"v 'ho"!d b' 0" 'h'10"hes'9""8-

i FLANGE Thelo!!owing is a report by columbus uciallurgical services. inc. on failure analysis ofa slip-onpange.

A " cracked" 14* diameter slip-on flange was non-destructively inspected by uung magnetic particle dye penetrant and ultrasonic test methods. The flange was also checked for material chemical analysis and macro and microstructure. On the basis of the results and observations reported, the following conc'usion is drawn: '

i The subject slip-on flange is not an integral forging or a casting. It has been fabrxated by welding and machining a ring insert within a large diameter flange. The flange " cracked *' because the welds between the flange and the insert were inadequate to withstand the bolting pressures.

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r. y' q The " cracked" slip-on flange was received by Columbus Metallurpcal i

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Services,Inc. in one piece. It had two diametrically opposite cracks located on pipe and gasket sides. It has been reported that e cral

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A such flanges are in the field. The subject flange has the folkm ing l

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engraved markings on the outside diameter (OD):

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,5 [; [...

g"R" 'g

~14 300 SO RF B16.5 A105 848 CHINA 02F" i

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To identify the cause of the failure it was planned to perform Jie

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penetrant. d ry magnetic particle. ultrasonic and radiographic te-:- en j

Figu*e 2 A close-vD of the the subject flange.

Qosket sCe showeg fSe

'Crocu' nc cotion.

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IN 92-6B September 10, 1992 Page 2 of 3 NON DESTRUCTIVE TESTS l

First, the flange was UT tested from the

_,, _, 3 OD. The mdicatinns were rather W?

puzzling because the reflections were k V.

3 consistently from a cylindrical surface I

,fif "

4 about 3.75 from the OD. A dry mag-netic particle examination conf rmed

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r that the cracks extended more or less 4-3 continuously in a circular path. The NDT exammation was concluded with D

dye penetrant tests as shown in the

' e M*' "

• F ure 3. Poe sece of nonge.

photographs in Figures 1 through 4. It 9

was quite evident that the flange was not a single piece component. A large inside diameter (ID) flange was reduced to a 14' i

ID unit by welding a 0.75 thick ring. The welding faces had been machmed.

CHEMICAL ANALYSES AND METALLOGRAPHY The flange was sectioned into four pieces to obtain specimens for chemistry, as well as for macro and microscopic examination. The original engraved markings has e been retamed on one of the segments. The chemical analyses are as follows:

C Mn P

S Si Cu Sn Ni Cr Mo Al V

l Mam Range Steel

.23

.62 424 E38

.24

.27 416 M4

.079 E26 4 06.003 1

Welded Insert Steel

.26 1.02

.017

.039

.28

.063

.003

.050 S 46

.032

.006.000 t

ANSI / ASTM A 105

.35

.60 1.05 D&D

.050 35 (listed for reference only)

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showing RNE'L N N teneo7 o-h M [5 ' 2 $ - S b

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IN 92-6B September 10, 1992 Page 3 of 3 F

Figure 5 shows the tadial macro section 3, -g. -

g.fm

p'.c =

k.h of the flange. Note the insert ring

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4 welded to the main flange. When E4@!

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y;.,,?p,b;;*g'.,_p:_.

another similar piece was further sec-

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tioned to retrieve specimens for L-!

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mounnng and pohshing, the insert if 'g.

. gh..;,..f;

.gf; p }- i e.

separated from the main flange. The p

general microstructure (ferntic pearlitic) g..p.

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at 25X (Nital etch) is shown in Figure 6.

ROCKWEL.L HARDNESS TEST Y.

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• t:RSGS Main Flange: 72.69.70 HRB Ave =

F gure 6: Photo snowing genero!

70 HRB micros *ructure e me main tionge power Insert:

76,78,80 HRB Ave =

half). esert (vocer notf) one weto mefoi (left 78 HRB ecce).25X Nitot etch.

No further work was deemed necessary+

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mg IN 92-68 t

September 10, 1992 l

Page 1 of 4 7

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s Alert Continues for Flanges from China The Winter 1992 National Bamf Bu!Irtis quired by the ANSI B16 specification, included an article regarding a serious

~although they do bear the B16 mark.

problem found to exist on 14" slip on, raised-face flanges.

NBB! advises double-checkins all flanges l

with the marking China /'especaUy l

Since publication, NBBI has leamed the before these flanges are placed in service.

problem described is onlyone of many j

associsted with flanges from the Peoples,

Certainly, flanges tha t have visible surface l

Republicof China.

discontinuities or incomplete rnarkings may be easy to see. But the machined NBBI has been provided with a lab report surfaces of welded flanges can only be i

for a 4" weld neck flange SA 105N B16 5 detected through a volumetric form of

-i with a BHN (Brinell Hardness Number) of NDE. The failure to meet heat treat, i

up to 500. Also, normaHzing and chemis-mechanical or chemical requirements of try requirements do not meet SA 105 the sped 6 cations can only be venfied j

requirements.

throu5 metallurgieexamination..

h l

'Ihese flanges have been reported to have This update is being distntuted in the i

cracks and other surface discontinuities interest of public safety. Future updates i

that might make them un6t for semce. In will be published as more facts are teamed. ~j addition, there have been reports that f

j

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some flanges do not meet thickness Further questions or concems should be requirements. NBBI also has been advised directed to A.M.* Doc"Matthews.Jr.or l

through reinspection reports that some R.D. Schueler, Jr. at Na tional Boa rd head-flanges rnay not bear the markings re-quarters.

l r

i 2.

Attcchment 2-IN 91-68 September 10, 1992 I

Page 2 of 4 '

l NBBinble::euvotuwe : - Nuwer= iv -.ans:

i 1

i Number of Suspect Flanges Growing at Alarming Rate The National Board continues to receive Inspections John McLouglin, late in May reports of several different types of in Bejing to discuss the problem.

flanges, ranging in sizes from 2 ' to 20"

. ~ and marked ' China,* that do not appear NBBI continues to advise double <hecking j

to bein accordance with ANSI B16 as-all flanges with the marking *Ouna,"

markmgs.

espedaily before these flanges are placed -

l in service.

t As the number of suspect flanges contin-ues to grow, so does the different types of - Flanges that have visible surface j

problems related to these flanges.

discontinuities or incomplete markings

[

maybe easy to see. But the machined l

To date, over 7,000 have been..i.e.J.

surfaces of welded flanges can only be -

from service, including 1,600 recently detected through a volumetric form of j

disccm.J in a newly 4nstalled pipeline.

NDE. The failure to meet heat treat, i

An injunction has been ordered to cease -

mechanical or chemical requirements of work on the pipeline until the flange the specifications can only be venhed

.j problem has been resolved. The remain.'

through metallurgic examination.

j ing 5,200+ flanges have been found mostlyin refineries.

NBBI will continue to publish updates as -

(

information is learned. This update is j

The president of the China Association of distributed in the interest of public safety.

e Boiler and Pressure Vessel Inspection, Center of Boiler & Pressure VesselInspec-Further questions or concems should be j

tion & Research of the Ministry of Labour, directed to A.M.*' Doc"Maethews,Jr.or P.R.C., Wang Hannuo, has agreed to meet R.D. Schueler, Jr. at Na tional Board.

l with National Board Assistant Director of headquarters.O l

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IN 92-68 l

1 September 10, 1992 1

Page 3 of 4 9 c l7 3 t

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i.WAVvvV VOLUut 1 - 9fuutte 18 - Juwt 1992 i

\\\\1 Flange Update: McLoughlin Meets Chinese.

Boiler / Pressure Vessel Officials John D. McLoughlin, assistant director of Metoughlin by Mr. Su Rung Ji, vice premier inspectons,metwithseveralagencsesof the ' of Oiina. Mr. Metaushlin art with Mr.

Chinese government during his recent visit Zheng You Mei, director of the Recepean j to the Peoples Republic of China. The visit Surosu, State CouncG, PJLC, Ma. Fan Jim was to discuss problems with Aanges manu.. Nian,assistantdimeterof theRecepsonSu-factured in China (and distnbuted m the usu, and several snembers of the Center of U.SJ, SoDer and Pmasure Vessel Inspecton and. i Research (representing the Ministry of La ~ !

Two meetings were held in Beijing.

bor). C3PVIR has been assisting the Na. !

tional Board initsinvestigation.

j On May 28,1992, McLougNin met with t

offidals of the Center of Bouer and Pressure The director of the Reception Burusu was 3 4

Vessel Inspection and Research, as well as given copies ofinformation accumulated dur'.

representatives of Sharud Province Over-ing the murse of Mr. McLoughlin's investi-i seas Trading Corpora tion,Tian Cong Com-go t on and provided with a briefexplana tion j

i pany and Dine Xinane Nan XI U Florige of the documents and the signincance of l

Company.

each.

j Mr.McLoughlin learned that Ding Xinang. Mr. Zheng You Mei reported that Mr._ Su 'l Nan XI U has shipped seven to eight con-Rung Ji has a great interest in the flange tainers (each with 17 tons of various types situation.He said the govemment appreci-and. sizes of flanges) to the U.S. thmuSb aged the information provided by the Na-what is believed to be lacksonvi!!e. F3odda. tional Board. Mr.Zheng You Mei also mid l

Shipping was reportedly provided bySharud that a complete nrport of the meeting would Province, Tian Cong and Bi!!iongold (a be provided to Mr.Su Rung Jt. -

Hong Kong trader with Beijing offices).

Demeetmgconcludedafte:Mr.Metou5hlin Mr. Yang U Min of Sharud Province Over-provided Mr. Zheng You Mei with recom-seas Trading Corporation reported that the unendations on steps the government could t

base material for these Aanges was 2S MN take to assure that steel mills and forging i

and possibly 16 MN (both Chinese forging makers produce material and flanges that specifications) and not the A105 identified meet ASTM and ANSI specificatiors. Se i

on both the flanges a nd ma terial test reporta. National Board will be advised when or if these.htionswillbeimplemented.

l It was stated by Mr. Yang U Min that manu-facturing identification on the flanges was Upoa his retum to the U.S Mr. Met.oughlin j

speofied by Bi!!iongold {the Hong Kong sceived thelabora tory results of blind na nge trader) and not the Aange manufactumr.

and slip on flange tests that were ordered j

prior to his departure. Results of these tests A second meeting was arranged for Mr. are as follows: -

j l

'l

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Attcchment 2 '

IN 92 -t september 10, 1992--

I Page 4 of 4 l

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i N B Binfokser e vowwe i.'wu;..e. is..,u,,,,,,, -

3 l

i Flanges sentkued

1. Blind flange with an identiner of "FF" and marked A1051.s reported to be a plate mate-i nal.

t 251ip on flange with an identiner of USC or t

USIO and a heat FI 406 contains shagged weld repairs. % W weld repair indicator regared by A105 is not stamped on the flange. h chemistry does not meet A105.

i The mill report does not indiente any type of heat treet even though the flange is snarked '

, A105N and has abo been

• weld repaired."

[h l

FinaDy, photo micrographs indicate plate matarial. W Aange makars name in Shou I

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Gang Machinery 4% Conyaay.

WNSEMis pah een%

'f According to Mr. Mel.oughhn: "This of6ce has probably accomP shed aU it can at this

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Vennet

- a..,1015 Crupper Avenue, l

Cahambus,Chio 43229,(61o sase2D pon with the rumources availabk N -

National Bead win publish a special edition

}

7 ef The National Soerd Sufleth that will ad-D.J. Mcdonald, dross this problee Hopefully, we will be ga m e m O m eese A.M. W Manhrws, Jr, j

able to report steps the Chinese government Asaisamut Esmever De are taMng to insure that their 8ange prod-p.D.Bsenaan APR.

j ucts sneet spea6 cation,-

Dmrter of Cm==wesisse i

The National Board wiD be providing vari-l ous appropriate agencies of the US. govem-snent with information it has acquired l

through theinvestigation procesaD l

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9 l

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O IN 92-68 September 10, 1992 Page 1 of 1 LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES Information Date of Notice No.

Subject Issuance Issued to 92-67 Deficiency in Design 09/10/92 All holders of Ols or cps Modifications to Ad-for nuclear power reactors.

dress Failures of Hiller Actuators Upon A Graoual Loss of Air Pressure 92-66

' Access Denied to NRC 09/01/92 All holders of OLs or cps Inspectors at Five Star for nuclear power reactors Products, Inc. and and all recipients of Construction Products NUREG-0040, " Licensee, Con-Research, Fairfield, tractor and Vendor Inspec-Connecticut tion Status Report" (White Book).

92-65 Safety System Problems 09/03/92 All holders of OLs or cps Caused by Modifications for nuclear power reactors.

That Were Not Adequately Reviewed and Tested 92-64 Nozzle Ring Settings 08/28/92 All holders of OLs or cps on Low Pressure Water-for nuclear power reactors.

Relief Valves 92-63 Cracked Insulators in 08/26/92 All holders of Ols or cps ASL Dry Type Transformers for nuclear power reactors.

Manufactured by Westing-house Electric Corporation 92-62 Emergency Response 08/24/92 All U.S. Nuclear Regulatory Information Require-Commission licensees.

ments for Radioactive Material Shipments 92-61 Loss of High Head 08/20/92 All holders of OLs or cps Safety injection for nuclear power reactors.

92-60 Valve Stem failure 08/20/92 All holders of OLs or cps Caused by Embrittlement for pressurized water reactors (PWRs).

OL = Operating License CP = Construction Permit