ML20079K088

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Forwards,For Review for Closure of NIR-0012,QA Requests QAR-RS-00106 & QAR-RS-00109 Re Deficiencies at Stations 8 & 10,respectively
ML20079K088
Person / Time
Site: Midland
Issue date: 01/17/1984
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
STONE & WEBSTER, INC.
References
CSC-7173, NUDOCS 8401240509
Download: ML20079K088 (23)


Text

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CONSUMERS POWER COMPANY MIDLAND ENERGY CENTER

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Transmittal Non, CSC-7173 b

Date: January 17, 1984 To:

Stone & Webster P O Box 1963 Midland, MI '46640 FF v Qg T,/,,,\\ W P Attached To:

Partial Response To

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[ Complete Response T f 0 56A 4L For Your Information

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Description:==

In response to NIR-0012, QAR-RS-00106 and QAR-RS-00109 were issued by WQAD and have been closed. Appropriate corrective action has been taken. The referenced QAR's are attached for your review for closure of NIR-0012.

Signature: i

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cc:

JGKeppler., NRC Region III w/a.;

JJHarrison, NRC Region III w/a RJCook, NRC Site w/a RAWells, MPQAD w/a BHPAck, MEC w/a f

NIReichel, MEC w/a l l I

DDJohnson, MEC w/a

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MIDUUID PROJECT C

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RS-00106 QUALM ASSURANCE DEPARTMENT

.OU ALITY A9 IIUn RECU EST 7.

DATEISSuledt'h/s4a Rev*.

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4 1/5/84 y-i REWIREMENT:

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PAEE 1 0F / ll Sza attached page 2 of 2 for description of requirements 10 ASME RELATED aescciated with this QAR.

O TES EB =0 2.

DEFICIENCY:

Sss attached page 2 of 2 for description of deficiencies found at stations MPQAD Sta. 8; l

FSO Sta. 10 and' BOP Standish Sta. 13.

'11.

POTENTIAL p.55(e)

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QAR BY:

4.

DISCIPLINE / DIVISION /SECTION 5.

RESPONSE DUE DATE

12..REPor.TED TO MPQA I

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  • M4 NAGER:

MPQAD - Soils QA 1/6/84 DATE N/A h13. ACTION ITEM NO:

15. ITDI PRIORITY:
17. S/U CODE:
19. ACTION ORGANIZATION ' 20 QAR REVIEWED BY:

U-00508 01 PCMOR W

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14. DISCIPLINE:
16. TREND CODE:
18. RESB CODE:

Dochment Control

21. DATE: '

Q BPA - Field Doc. Control G-5, R-5, G-9 BFSOC

22. CAUSE:

23 PROPCSED CORRECTIVE ACTION:

1.

Clerical error.

None - See Block #27.

t 2.

Issuance of FDDL for audit prior to i

verification that all com: rents and changee were incorporated.

3.

FDDL did nct reflect the voiding of a echtrolled ccpy by.FSO..

24 RESPONSIBLE ORGANIZATION / PERSON:

25. PROPOSED COMPLETION DATE FSO/BCP Ccnstruction.

January 6,1984.

l~26 DISPOSIT ON CONCURRENCE:

J EAL

\\ Met ah QAR REVIEWER DATE PQAE (ASME ONLY)

DATE l

27. DISPOSTION ACTION TAKEN:

CORRECTIVE ACTION TAKEN:

Soo attached response.

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2S. METHOD OF DISPOSITION VERIFICATION

29. QAR CLOSED BY Sn eg I l e6 I \\

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MPQAD DATE k

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DATE UNACCEPTABLE hSUPERCEDING QAR b - OOI@

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y,/ef "M Miditnd Projcet QAR No. RS-00106 Quality Assurcacs D:pt.

QUALITY ACTION REQUEST Datat -1/5/"' Rev. / l l[7/6[

CONTINUATION SHEET Page 2 of Et(

gas i-7.W The following conterns have been identified by Stone and Webster (CIO) during

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an audit of the following document control stations: MPQAD Station 8. FSO Station 10, and BOP Standish Station 13. These concerns are addressed by CIO on NIR number 012, dated January 2, 1984 A.

The FSK Change Notice Composite Register shows FSK CA-1060 Sheet 7 requiring FCR 6704 FSK CA-1062 Sheet 6 requiring FCR 6053 and 6704, and FSK CA-2257 Sheet 5 requiring FCN 3743 and FCR 6890 to be attached.

Contrary to this composite register FSK's CA-1060 Sheet 7. CA-1062 Sheet 6 and CA-2257 Sheet 5 do not' exist.

Also FSK CA-1060 is shown in'the Register as "FSK CA-1060 sheet 7" however it should indicate FSK CA-1060 Revision 7 with only one sheet and 'FSK CA-1062 is shown in the Register as (fA "FSK CA-1062 sheet 6 revision 4," however it should indicate FSK CA-1060 revision 6 with only one sheet. (This was a generic problem with the lb FSK's sampled by CIO).-

B.

The FDDL provides the following information; Stations that receive documents, number of, and description of documents distributed. Contrary to the above, the number of Design Drawings and Specifications at Station 10 did not agree with the FDDL.

1)

Specificat, ions C-195, C-197, C-198, C-200.

Design Drawings C-1492 C-1493-1, C-97, C-8 and C-2031.

2) All vendor controlled drawings have one copy in their' station that is voided. These voided documents could not be counted in the required number of documents per the FDDL. Therefore all vendor controlled drawings were one short of the required amount.

3)

Spencer-White and Prentice had the following Design Drawings missing from station 10, one copy (sepia) of C-8 and one copy (sepia) of C-97.

Two sepia were issued for each drawing per the FDDL.

C.

The Change Notice Composite Registers list the applicable change notice attachments to drawings and specifications. Contrary to this requirement, 1.

Station 10 had the following discrepancies:

- (a) Drawing C-2031-19 revision 1 did not have FCR 6974 attached to the Design Drawing.

(b) Design Drawing C-2036 revision 5 should have had DCN-2 attached to the drawing.The drawing indicated it was pulled-back, the Composite Register did not.

(c) FCR C-6053 was attached to the Mergentime FSK CA 1062 Revision 6 l

, blue-line but was not attached to the sepia.

2.

Station 13 had the following discrepancy:

(a) Specification C-306 had referenced FCR C-4854 but it was not attached to the specification.

D.

The Civil One Time Deviation Register lists the drawings and specifications that require a R symbol. Contrary to this requirement:

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1.

Station 10 had the following discrepancy:

,(a) Specification C-305 located in station 10 Mergentime was missing thesymbol@toindicatethatthereisaretireddocumentagainst i

this specification.

2.

Station 13 had the following discrepancies:

(a) Drawing C 482-1 outstanding attachment stamp could not be read.

Also a @ symbol was located on the drawing.while the Composite Register'had it voided.

Q A k RS.-oo n o6 fy 3+ 11 RESPONSE TO QAR #RS-00106 Continuation of Block #27 Corrective Action Taken ITEM A Statement The FSK Cha'nge Notice Composite Register shows FSK CA-1060, Sheet 7 requiring FCR 6704, FSK CA-1062, Sheet 6 requiring FCR 6053 and 6704, and FSK CA-2257, Sheet 5 requiring FCN 3743 and FCR 6890 to be attached.

Contrary to this composite register, FSK's CA-1060 Sheet 7. CA-1062, Sheet-6 and CA-2257, Sheet 5 do not exist. Also FSK CA-1060 is shewn in the Register as "FSK CA-1060, Sheet 7", however, it should indicate FSK CA-1060, Revision 7 with only one sheet and'FSK CA-1062 is shown in the Register as'"FSK CA-1062 Sheet 6 Revision 4",

however, it should indicate FSK CA-1060, Revision 6, with only one sheet.

(This was a generic problem with the FSK's sampled by CIO.

Response

This item is attributable to Document Control clerk error, concerning input into the computer.

These were drawing revision numbers which belonged in the next column of the register. The normal proof reading operation. failed to pick up this error.

The entire FSK/ Civil change notice composite register has been reviewed.

Seven additional errors were found. A marked-up register has been resubmitted to computer operators for input.

ITEM B

' Statement The Field Document Distribution List (FDDL) provides the following

'information; stations that receive documents, number of and description of documents distributed.

Contrary to the above, the number of Design Drawings and Specifications at Station 10 did not agree with the FDDL.

1.

Specifications C-195, C-197, C-198, C-200.

Design Drawings C-1492, C-1493-1, C-97, C-8 and C-2031.

2.

All vendor controlled drawings have one copy in their station that is voided.

These voided documents could not be count.ed in the required number of documents per the FDDL.

Therefore, all vendor controlled drawings were one short of the required amount.'

3.' Spencer, White & Prentis had the following Design Drawings missing from station 10 one copy (sepia) of C-8 and one copy (sepia) of C-97.

Two sepia were issued for each drawing per the FDDL.

QM. RS-oolo6

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Pa.ge. +sy n Page 2

Response

Item 1 The FDDL issued on Friday, December 30, 1993 did not agree with the actual quantity in station 10 for the documents listed. The FDDL had been reviewed by Area 10 personnel prior to the December 30, 1983 issue, and distribution change sheets-had been prepared:and submitted to correct the FDDL, according to established procedures. The Document Control computer input to the FDDL had not yet caught up to these change sheets.

The auditors received copies of the change sheets for the documents listed, and agreed that the count at Station 10, was the same as that indicated on the submitted change sheets. The FDDL has now been updated to include all submitted change sheets, and the FDDL and the actual quantity at Station 10 now agree.

Item 2 This statement is accurate only for those Subcontracts administered by the Field Soils Organization (FS0), not for all vendor documents. The Field Soils Organization (Area 10) received three controlled copies of all approved subcontractor documents for Subcontract Numbers C-194, C-195 and FSC-436.

In addition, the FSO received three controlled copies of all approved shop drawings for Purchase Order No. F55739 (under Specification C-233).

For historical and commercial reasons, the FSO maintains a filing system of the subcontractor and vendor documents noted in the above paragraph.

The intent was to track documents as submitted, and the documents as approved and returned to these vendors. Therefore, one of the three controlled copies of the vendor documente listed was marked " Void" upon receipt from Document Control, and was placed in the appropriate file in the FSO offices.

The reason these documents were marked void is because FPD-1.000 prevents the FSO from maintaining controlled and uncontrolled documents in the same files. 'The FSO has now discontinued the use of controlled copies for this purpose, and have substituted uncontrolled copies. The FDDL has been changed to reflect this decrease in controlled copies.

Item 3 When Spencer, White & Prentis'first mobilized on site, they h,ad no reproduction capability, and received no sepias in their original distribution. The original distribution list identified 19 drawings, among which were Drawings C-8 and C-97.

After Spencer, White & Prentis obtained reproduction capability, the FDDL was changed to read ons sepia and one controlled copy instead of two controlled copies, but the FSO did not retrofit the sepias for the original distribution. Most of the original 19. drawings have been revised, and sepias were part of normal distribution, but C-8 and C-97 were not revised and, therefore, did not match the revised FDDL. A complete review of all drawings was performed and t'vo additional drawings with this problem were found. All have been corrected, and the count of sepias in the field agrees with the count in the FDDL.

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kg sg u Page 3 ITEM C Statement The Change No,tice Composite Registers list the applicable change notice attachments to drawings and specifications. Contrary to this requirement, 1.

Station 10 had the following discrepancies:

(a) Drawing C-2031-19 Revision 1 did not'have FCR 6974 attached to the Design Drawing.

(b) Design Drawing C-2036 Revision 5 should have had DCN-2 attached to the drawing. The drawing indicated it was pulled-back, the Composite Register did not.

(c) FC,R C-6053 was attached to the Mergentime FSK CA 1062 Revision 6 blue-line but was not attached to the sepia.

2.

Station 13 had the following discrepancy:

(a) Specification C-306 had reference FCR C-4854 but it was not attached to the specification.

Response

Item 1 (a) and (b)

This occurred in the Spencer, White & Prentis office, a'nd was caused by Document Control Clerk error. The clerk misread the latest Change Notice Composite Register for~these two drawings.

These items were corrected and a complete review of all documents maintained by Spencer, White & Prent4s was performed for proper attachments. No other errors were found.

. Item 1 (c)

This occurred in the Mergent'ime office and is also attributable to-Document Control Clerk error. The FCR was attached to the blue-line and noted on the front. The FCR was also in the book of FCR's that goes with the sepias, but was not noted in the addenda block on this sepia. This item was corrected, and a complete revi.ew of all documents maintained by Mergentime was performed for proper attachments. No other errors were found.

Item 2 (a)

This occurred in the Standish Fabrication Facility, and is attributable to Document Control clerk error. This FCR should not have been attached to Specification C-306, and was correctly removed, but was not crossed off in the addenda block.

This item was corrected, and a complete review of all documents maintained by Standish was performe.d for proper attachments. No other errors were found.

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M R. R.s-ooio6 Page Go{ Il Page 4 ITEM D Statement The Civil One Time Deviation Register lists the drawings and specifications that require a R symbol.

Contrary to this requirement:

1.

Station 10 had the following discrepancy:

(a) Specification C-305 located in Station 10 Mergentime was missing the symbol dD to indicate that there is a retired document against this specification.

2.

Station 13 had the following discrepancies:

(a) Drawing C-482-1 outstanding attachment stamp could not be read. Also, a QD symbol was located on the drawing while the Composite Register had it voided.

Response

Item 1 (a)

This item is attributable to Document Control Clerk error.

It was corrected, and a complete review of all documents maintained by Mergentime was performed for proper retirement symbols. No other errors were found.

, Ire = 2 (a)

Drawing C-482-1 was difficult to read due to reproduction quality, and was replaced.

Other doc'iments maintained by Standish were reviewed for clarity and legibility, and were replaced where appropriate.

A complete review of all documents maintained by Standish was also performed for proper retirement symbols. Drawing C-482-1 has been replaced, and no other errors were found.

Additional Corrective Action Taken On Wednesday and Thursday, January 4 and 5,1984, instruction sessions were held for all appropriate Document Control personnel concerning how to read and

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use the various registers published by Document Control, and on auditing methods and processes.

See Attachments 1 and 2 for detailed descriptions of these sessions and the attendance records.

'V' Signature pignature BOP FSO FTR/ WORK 6

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Pap 94 n MEMO FOR THE RECORD Date: January 4, 1984 From:

Ralph Bradford

Subject:

Document Control Instruction Session

Enclosure:

(1)

Instruction Session Attendance Record On Wednesday,' January 4, 1984, the undersigned held an instruction session for Bechtel FSO, Mergentime and Spencer, White & Prentis Document Control personnel, including supervisory personnel responsible for document control. The session began at 8:00 a.m. and lasted approximately 45 minut,es. Subjects covered vera document control processing methods, procedures, and auditing methods, including appropriate logs and registers.

The undersigned pre'sented a detailed, step-by-step review of the methods for conducting a document control audit, and how to read and use the various logs and registers published by Document Control. The purpose of the session was to ensure that all Document Control personnel, including supervisory, have a thorough knowledge of auditing practices and to ensure that all personnel are working from che same basic information.

All personnel were instructed to return to their respective areas and again perform a 100% audit of the entire Document Control stations. This audit is to be complete by close of business Wednesday, January 4, 1984, and'ill w

include all specifications, design drawings, procedures and subcontractor / vendor shop drawings for the Civil discipline. All questions were answered and problems resolved, and all attendees confirmed that they understood the information covered.

Ralph Bradford Senior Contracts Administrator RB/nj cc:

D. H. Lavelle J. F. Fisher R. Bradford All Attendees - See Enclosure (1)

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-Quality Accurtnes D2pt.

QUALITY ACTION REQUEST D:ts: 01-07-84 CONTINUATION SHEET-Page 11 of 11 Block 28.

Method of Disposition Verification (Continued from page 1)

A.

All controlled Civil Specifications were reviewed at stations 10 (FSO including Mergentime and Spencer, White & Prent' ice) and 13 (BOP-Standish).

f Thi r view gesulted in satisfactory results.

N Y N. All wer7 reviewed at stations 8 (MPQAD-Soils), 10 (FSO including B

Mergentime and Spencer, White & Prentice), 24 (MPQAD-Receiving did not have any FSK's) and 64 (Subcontractors-FSK's sent to supplier, only card system was reviewed). FSK-CA-1062 had a h on the stick drawing at Station 13 (Standish) which should have been removed as it had been removed on the three other copies at this location. A FCR at Station 8 did not have a " CONTROLLED" stamp on it.

Because all. controlled Civil FSK's were reviewed as stated above and the problems abcve were corrected, no further action is required.

C.

A sample of Controlled Bechtel Civil Drawings was reviewed at stations 10 (FSO including Mergentime and S. pencer, White & Prentice) and 13 (BOP-Standish).

All Controlled Bechtel Civil Drawings requiring the h symbol at station 13 (BOP-Standish) were reviewed for the @ symbol.

The only problem found was at Station 13 (BOP-Standish) where drawing C-436 Revision 4 had a @ symbol which was not required.

Because of this problem and the problem at Station 13 (BOP-Standish) identified in B above, the corrective action taken to resolve the problems,of R symbols on documents at Standish is unacceptable.

Refer to QAR RS-00109 for further corrective action.

D.

A sample of Controlled Civil Vendor Drawings at stations 10 (FSO including Mergentime and Spencer, White & Prentice) and 13 (BOP-Standish).

The only problems identified in this review were found at Mergentime and are as follows:

1.

Vendor Drawing C233A-F55739-80-4 had an addenda change block on the front o,f 1, drawing and 1 sepia indicating FCR C6868 was attached.

FCR C6868 was not attached and was,not required to be attached. This problem was corrected at the time of the QAR RS-00106 corrective action

. verification review.

2.

Vendor Drawing C233A-F55739-58-4 did not indicate FCR C6466 in the addenda change block on the front of I drawing and 1 sepia.

FCR C6466 was attached to the drawing and was required to be attached.

This problem was corrected at the time of the OAR RS-00196 corrective action verification review.

~ 3.

Vendor Drawing C233A-F55739-70-3 and C233A-F55739-82-3 did not have

'an addenda change block indicating the applicable FCR on the front of 1 drawing and 1 sepia.

However, the applicable FCR was attached to each of the drawings.

4.

Vendor Drawing C233A-F55739-78-4 did not indicate FCR C6756 in the addenda change block on 1 drawing and 1 sepia and it was not attached to the drawing.

It should be noted that item 1 and 2 above were found in the first sample selection and 3 and 4 were found in the increased sample selection.

Based on the problems identified at Mergentime, the corrective action taken by Mergentime to resolve the problems identified in this QAR is unacceptable.

Refer to QAR RS-00109 for further corrective action.

E.

Reviewed instruction documentation attached to this QAR.

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PAGE 1 0F g fY See attached page 2 of 2 for description of requirements 10 M REMTED associated with this QAR.

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DEFICIENCY:

--See attached page 2 of 2 for description of deficiencies found at Station 10(FS0-Mer'gentime) and Station 13 (BOP-Standish)

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Midland Project-QAR No. RS-00109 Quality Assurance Dept.

QUALITY ACTION REQUEST

~ Date: 01/07/84 REV. O CONTINUATION,S,HEET Page 2 OfIf /

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1.. Requirement (Continued from page 1)

QAR-RS-OO106 identified document control problems at station 8 (MPQAD-Soils),

10 (FSO) and'13 (BOP-Standish).per Stone & Webster CIO's NIR 012.

Corrective action was taken, as stated in QAR RS-00106, to correct the problems ident-ified.

4 2.

Deficiency (Continued from page 3)

Contrary to the corrective action taken on QAR RS-00lO6 the following problems

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were,identifled at Mergentime, but found satisfactory at FSO.

It should be noted tha'c iters A and B below were found in the first sample selection and C and D were found in the increased sample selection.

A.

' Vendor Drawing C233A-F55739-80-4 had an addenda change block on the front of I drawing and 1 sepia indicating FCR C6868 was attached.

FCR C6868 was'not attached and was not required to be attached.

This

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problem was corrected at the time of the QAR RS-00106 corrective action' verification review.

B.

Vendor Drawing C233A-F55739-58-4 did not indicate FCR C6466 in the addenda change block on the front of 1 drawing and 1 sepia. FCK C6466 was attached to the drawing and was required to be attached. This problem was corrected at the time of the QAR RS-00106 corrective action, verification review.

C.

Vendor Drawings C233A-F55739-70-3 and C233A-F55739-82-3 did not have an addenda change. block indicating the' applicable FCR on the front of 1 drawing and 1 sepia. However, the applicable FCR was attached to each of the drawings.

D.

Vendor Drawing C233A-F55739-7'8-4 did not indicate FCR C6756 in the addenda, change block on 1 drawing and 1 sepia and it was not attached to the drawing.

Also contrary to the correc' ive action'taken on OAR RS-00106 the followi-ng t

problems were, identified at Standish.

A.

Drawing FSK-CA-1062 Revision 6 had a (k)symbolonthestickdrawing which should have been removed as it had been removed on the three other copies of the same drawing at this location.

B.

Bechtel Civil Drawing C-436 Revision 9 had a (() symbol which was not required.

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QU ALITY ACTION REQUEST cn;:

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CONTINU ATION SHEET l

PA E 1 CF M / ) M '/#/A ELCCK 22 (CONT. ) -

Cause :

Improcer implementation of-Design Document Control Procedures, due to clerical errors.

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Corrective Action:

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1.

All deficiencies noted on Pace 2 of 3 have been corrected, (1/7/84).

2.

A 100 cercent re-audit will be performed by the F.S.O. D.C.

section at Standish's and Mergentime's Document Control centers on 1/9/84. to verify conformance to the orogram.

3.

All Documument Control oersonnel in Stations 10 and 13 will be retrained by the F.S.O. D.C. sueervisor in the recuirements of the crocram.

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