ML20127K190
| ML20127K190 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 04/09/1985 |
| From: | Casey Smith, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127K170 | List: |
| References | |
| 50-369-85-09, 50-369-85-9, 50-370-85-10, NUDOCS 8505220066 | |
| Download: ML20127K190 (13) | |
See also: IR 05000369/1985009
Text
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AIUCLEdR REGULATORY COMMISSION ~
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101 IAARIETTA STREET, N.W.
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ATLANTA, GEORGIA 30303
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iReport Nos.: 50-36h/85-09and50-370/85-10
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Licensee: DukeIPowerCompany
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-422 South' Church Street.
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-Charlotte, NC .28242-
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Dockst"Nosl: ~50-369'and 50-370
License Nos.: NPF-9 and NPF-17
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- Facility Name: McGuire'l_and 2
- Inspection Conducted
- March 4-8,-1985
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LInspector: [h A,N
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_ C. F.%V
Date/ Signed
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/ Accompanying. Personnel':
=R. M. Latta, Region II
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Appro'ved by:
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C. M. Upr.ight/,JSect)g6 Chief
D'te Signed.
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' SUMMARY
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Y Scope: This routine, unannounced inspection entailed-70 inspector-hours
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- on -: site and at' Duke Corporate offices in .the areas'of design control, tests a'nd
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experiments, and. licensee action on previously identified inspection findings.
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~Results:
One violation was identified
. Failure _ to Specify Post Modification .
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iTesting Requirements.and. Acceptance Criteria.
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8505220066 850423
ADOCK 0500
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' REPORT DETAILS
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-Persons Contacted
l Licensee - Employees
- J. Barber,' Quality' Assurance Manager, Operations, Quality Assurance
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- A. Batts, Quality Assurance Engineer, Quality Assurance-
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- Ei Brafford, Project Engineer,. Design Engineering-
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- G. Cage, Superintendent Operations, Nuclear _ Production Department
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- E. Estep, Project Services Engineer, Nuclear Production Department
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- C. Fish; Contract Coordinator, Nuclear Production Department-
D. Franks, Quality-Assurance-Surveillance _ Supervisor, Quality Assurance
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~ *G. Grier, Corporate Quality Assurance Manager,. Quality Assurance
- P.;Herran, Supervising Design Engineer, Design Engineering,, Mechanical /
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Nuclear
W.. Houston,. Senior Engineer, Project. Management Division, Design ~ Engineering
J. Keirnan~ Project Engineer, Design Engineering / Electrical Project
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. Management Division
.T. : Ledford, Supervising Design Engineer, Design _ Engineering / Electrical
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D. . Marquis, Performance Engineer, Nuclear Production Department-
- T.' McConnell, Station Manager, Nuclear Production Department-
- N. McGraw,. Compliance Engineer, Nuclear Production Department
S. McInnis,-Associate Engineer, Compliance Group, Nuclear Production
Department
- R. Medlin,' Quality Assurance
- D. Mendezoff, Engineering Specialist, Compliance Group, Nuclear Production
- Department
D. Murdock,LPrincipal Engineer,-Design Engineering / Electrical
- P.;Nardoci, Licensing Engineer, Nuclear Production Department
-B.-Peele,1 Design Engineer, Design Engineering, Mechanical / Nuclear
- D. Rains, Superintendent of Maintenance, Nuclear Production Department
R.. Revels,. Design Engineer II,- Design Engineering Mechanical / Nuclear
- T._ Roberts, Quality Assurance
R.: Ruth, Site Quality Assurance Supervisor
- B. Travis,: Superintendent Integrated Scheduling
M..Tully, Design Engineer II, Research and Projects
D. Vass, Design Engineer II, Design Engineering / Electrical
- R. Webar, Director of Nuclear Projects-
NRC Resident Inspectors
- *W. Orders, Senior Resident Inspector
- P. Skinner, Visiting Senior Resident-Inspector
- Attended exit interview
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Exit-Interview
The inspection scope and findings were summarized on March 7,1985, with :
those persons . indicated in paragraph 1 above.
The inspector described the
areas inspected. and discussed in detail the inspection findings listed
below. . The licensee did not identify as' proprietary any of the materials
,provided to or reviewed by the. inspector during this inspection.
~Vio14 tion, Failure : to Specify. Post Modification Testing Requirements
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and Acceptance Criteria, Paragraph 4.a.
Dissenting comments were received from licensee management concerning
this violation.
Licensee. management stated that this responsibility
has been assigned to the Nuclear Production Department by Duke Power
Company.
Violation, Failure to Establish Measures for Reporting to the - NRC
pursuant to 10 CFR 50.59
Subsequent review by Regional Management verified that guidance for
reporting' design changes to the NRC in accordance with 10 CFR 50.59 is
delineated in _the : regulations.
This violation was withdrawn and
licensee management was. informed of this action in a telephone
conversation on March 14, 1985.
Inspector Followup Item, Revision to Exempt Change Program, paragraph
4.b.
Inspector Followup Item, Revision to Nuclear Safety Evaluation Check-
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list,' paragraph 4.c.
Inspector. Followup Item, Preparation of Working Level Procedures for
Technical Services Staff, Paragraph 4.d.
Inspector Followup Item, Revision to Design Engineering Department
Procedure PR-160, paragraph 4.e.
3.
Licensee Action on Previous Enforcement Matters
.This subject was not addressed in the inspection.
4.
Design Program (37702)
References:
(a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear . Power Plants and Fuel Reprocessing Plants,
Criterion III
(b) Regulatory Guide 1.64, Quality Assurance Requirements
for the Design of Nuclear Power Plants, Revision 2
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(c) ANSI N45.2.11-1974, Quality Assurance Requirements for
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the Design of Nuclear: Power Plants
(d) Regulatory Guide 1.33,- Quality Assurance Requirements
(Operations) November 1972
-(e) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
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(f)
10 CFR Part 50.59, Changes, Tests and Experiments
(g) . Technical Specifications Section 6.5, Review and Audit
The inspector reviewed the licensee design' change program required by
. references (a) through (g) to verify.that these activities were conducted in
accordance with regulatory requirements, industry guides and standards, and
Technical Specifications.
The fc110 wing criteria were used during the
review to assess the overall acceptability of the established program:
Procedures have been established to control design changes which
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include assurance that a proposed change does not involve an unreviewed
safety question or a change in technical specifications as required by
Procedures and responsibilities for design control have been estab-
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lished including responsibilities and methods for conducting safety
evaluations.
Administrative controls for design document control have betn estab-
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lished for the following:
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Controlling changes to approved design change documents
Controlling or recalling obsolete design change documents such as
revised drawings and modification procedures
Release distribution of approved design change documents
Administrative controls and responsibilities have been established
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commensurate with the time frame for implementation to assure that
design changes will be incorporated into:
Plant procedures
Operator training programs
Plant drawings to reflect implemented design changes and modif t-
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Design controls require that implementation will be in accordance with
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approved procedures.
Design controls require assigning responsibility for identifying
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post-modification testing _ requirements and acceptance criteria in
approved. test procedures and for evaluation of test results.
Procedures assign responsibility and delineate the method for reporting
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design _ changes to the NRC in accordance with 10 CFR 50.59.
-Controls require review and approval of temporary modifications in
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accordance with Section 6 of the Technical Specifications and 10 CFR 50.59.
The documents listed below were reviewed to verify that these criteria had
been incorporated into the licensee design program:
' Duke Power Company Topical Report, Quality Assurance Program, Duke-1
Section 17.2.3, Revision 8
Duke Power Company, Quality Assurance Manual, Design Engineering
Department
Section DEQAP, Department Quality Assurance Plan, Revision 15
Section PR-160, Nuclear Station Modification, Revision 6
Section PR-170, Design Specifications, Revision 4
Section PR-201, Variation Notice, Revision 22
Section PR-202, Design Nonconformance, Revision 7
Section PR-220, Nonconforming Item Report, Revision 15
Section PR-260, Nuclear Station Problem Report, Revision 6
Section PR-290, Nuclear Regulatory Commission Reporting Require-
ments, 9evision 11
Section PR-400, Quality Assurance Program for Client Projects,-
Revision 1
Section PR-931, Design Quality Assurance Records Review, Approval
and Storage, Revision 8
Design Engineering Department Manual
Section II.4.2, Station Modifications, Revised 10-01-84
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Section II.4.3, Station Modification Interim Procedure for McGuire
1, Revised 10-01-84-
Section 11.5.1, Design Criteria Documentation, Revised 10-01-84
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Electrical Division Procedure 9.0.1, Design Process Summary, Revision 0.
Electrical Design Manual, Revision 17
Nuclear Station Modification Manual
Section 4.2, Design Engineering Designed Modifications, Revision 0
.Section 4.3, Station Designed Modifications, Revision 0
Section 4.4, Exempt Changes, Revision 0
Section 7.0, Administration of Nuclear Station Modifications,
Revision 0
Section.7.6, Design,. Revision 0
Section 7.7, Drawing Control, Revision 0
Section
8.0,
Administration of Major Construction Projects,
Revision 0
Section 9.0, Administration of Exempt and Temporary Changes,
Revision 0
Station Directives Manual, Revised 02-20-85
Section 4.4, Modification
The inspector interviewed licensee onsite QA staff to determine the degree
of involvement of QA staff members in the performance of surveillance in the
functional area of plant modifications. The following surveillance reports
were reviewed by the inspector:
Surveillance Report MC-84-71, Nuclear Station Modifications dated
January 10, 1985. No deficiencies were identified by this surveil-
lance.
The surveillance summary states that in October 1984 the
nuclear station modification program was changed to improve the
modification program system.
A Nuclear Station Modification Manual
which clearly delegates responsibilities and introduces new forms into
the program had also been prepared. Because of the " newness" of this
program change, this surveillance was performed on nuclear station
modifications performed prior to October 1984.
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Surveillance
Report
MC-84-39,
Station
Modifications,
dated
September 14, 1984.
This surveillance identified two deficiencies in
connection with procedural non-compliance. The deficiencies were noted
as having been corrected.
Surveillance
Report MC-84-62,
Station Modifications,
Temporary
Modifications and Lead Shielding, dated March 27, 1984.
No deficien-
cies or nonconforming items were identified by this surveillance.
Surveillance
Report MC-84-12,
Station Modifications,
Temporary
Modifications.
This surveillance identified one deficiency in
connection with the independent ~ verification for restoration of
This deficiency is listed as having been
corrected. One deficiency was identified and noted as not having been
corrected. This concerned the determination of seismic classifications
of system piping by a qualified reviewer, who is required to be a
Safety Review Committee (SRC) member. Station Directive 2.10.12 was
subsequently revised to delegate responsibility for determination of
seismic requirements to non-SRC reviewers.
The inspector intery,ewed licensee management in the Engineering Design
Department to verify that a quality assurance program for design had been
established and documented to comply with the requirements of ANSI
N45.2.11-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.11-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
In October 1984 the nuclear station modification program was revised. This
resulted in the preparation of a Nuclear Station Modification Manual which
specifies the appropriate requirements which shall be met to implement a
modification at an operational nuclear station.
Additionally, the Design Engineering Department Manual was reformatted,
revised, divided into two volumes, and reissued to allow a better under-
standing and handling of the Department Manual procedures. The licensee has
established a Design Engineering Department Manual
Review Committee
consisting of representatives from each Division.
This committee meets
monthly for reviewing any proposed changes to the Department Manual for
merit and for assuring appropriate interdepartmental review.
Procedures
have been established to assure that design activities performed by Design
Engineering are carried out in a planned, controlled, orderly, and correct
manner.
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Specific types of modifications can be designed by the Nuclear Production
Department following concurrence from Design Engineering.
Nuclear Station
Modification Manual Section 7.6, Design, delineates the administrative
controls applicable to both Design Engineering Designed Modifications (DDMs)
and Station Designed Modifications (SDMs). Additional requirements for the
processing of Nuclear Station Modifications are delineated in Station
Directive Section 4.4.
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Nuclear Safety. Evaluations are performed for DDMs and'SDMs to assure that a
. proposed change does' not involve an 'unreviewed safety- question or. a change
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- in -the Technical . Specifications (TS) as required.by 10. CFR 50.59. . Addi-
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tionally, measures.have been established to control temporary modifications
including the performance of a~ Nuclear: Safety Evaluation - for determination
.'of an unreviewed ~ safety question in accordance with 10 CFR 50.59. Station
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~ Directive .(SD) '4.4.2 Revision 5 delineates the ' administrative controls '
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., applicable - to the - control of - temporary modifications.
The inspector
reviewed 'a draft copy. (revision 6) of SD -4.4.2 which .is being revised -to
include a ; Temporary ~ Modification Evaluation Checklist in addition. to
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providing more prescriptive' guidance for the controls of temporary .modif t-
cations.-
Jithin this area, one violation and four inspector . followup items were
fidentified and they.are discussed in the following paragraphs,
a.
Failure to:Specify Post Modification Test- Requirements and Acceptance
Criteria
-The ' Nuclear Station. Modification Manual Section 7.6 states that the
design of modifications is normally the responsibility.of the Design
Engineering Department. .Section 7.6.1, Design Engineering ~ Designed
Modification (DDMs)',
further states that modifications designed by
' Design Engineering .should be' processed 'in accordance with Design
Engineering Department Quality Assurance Manual Procedure PR-160 and
Design Engineering Department Manual Procedure VI.E.2.
Licensee accepted QA program endorses Regulatory Guide 1.64 Revision 2
and ANSI N45.2.11-1974. Regulatory guide 1.64 paragraph C, Regulatory
position and ANSI N45.2.11 Section 3.2.20 requires that test require-
ments including in plant test and the conditions under which they will
be performed be specified as design inputs.
The administrative controls delineated in procedure PR-160 do not
address the requirements of ANSI N45.2.11-1974 Section 3.2.20 in that
test requirements including in plant tests and the conditions under
which they will be performed are not provided as design inputs for
station modifications designed by Design Engineering.
Additionally, licensee lower tier document Design Engineering Depart-
- ment Manual Section II.4.2, Station Modifications, revised October 1,
1984, does not address requirements for post modification tests and
post modification test acceptance criteria.
This failure to establish measures required by the accepted QA program
section
17.2.3
is
identified as
violation
369/85-09-01
and
370/85-10-01.
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- Revision to Exempt Change Program
-Exempt changes . are . defined 1 as a change to. a structure, system, or__
component that ~f s exempt-from .the requirements' of Section 7.0 of the
Nuclear Station' Modification. Manual. Exempt changes are intended to be
' changes to structures, systems, or ' components that do not require the
same 1evel of- approvals, reviews, and documentation as a . station .
designed modification (SDM) or a Design Engineering designed modiff-
cation (DOM).
Nuclearf Station Modifica' tion Manual Sectioni 9.0, 4 Administration of
Exempt 'and _ Temporary Changes, delineates the ' requirements for changes
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conducted under.the Exempt Change Program and provides typical examples
of. changes that may be performed in paragraph 9.2.1.
The inspector
. expressed a concern at the . lack of specificity contained in the program
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for activities that'may be performed as exempt changes. Additionally,
- the inspector stated in a telephone conversation to licensee management
on March 13,~1985,~that all changes to QA Condition 1 Systems (Nuclear
Safety Related) must be conducted within the controls of the nuclear
station modification program as required by licensee commitments
delineated in the accepted QA Program.
Licensee management stated in the telephone conversation _that not all
controls of the nuclear station modification program would be applic-
able to some activities performed on QA Condition. I system as exempt
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changes. -Licensee management expressed concern regarding the use.of
resources and the . documentation requirement for changes of this type.
The licensee has previously identified the need to revise the require-
ments of the Exempt-Change program to provide prescriptive guidance for
activities . to be conducted under_ this program.
Until the program
description 'has been delineated in appropriate documents, this is
identified as Inspector Followup Item 369/85-09-02 and 370/85-10-02.
c.
Revision to Nuclear Safety Evaluation Checklist
Station Designed Modifications 1(SDMs) are performed by qualified
designers and checked by. qualified design verifiers in the Nuclear
Production Department. A safety evaluation is required to be performed
for determination of an unreviewed safety question in accordance with
10 CFR 50.59. A qualified designer in the Nuclear Production Depart-
ment originates a . Nuclear Safety Evaluation Checklist form for each
SDM. The checklist documents the safety evaluation for the modifica-
tion including the reviews of the FSAR, Technical Specifications (TS),
all appendices to the TS, and potential unreviewed safety questions.
.The checklist is independently reviewed by a qualified design reviewer.
The inspector expressed concern that the Nuclear Safety Evaluation
Checklist does' not provide a basis for the decisions reached.
The
checklist documents the decision that an unreviewed safety question
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does' not'. exist without: documenting the specific reviews and actions
taken.to arrive at this conclusion.
- The' . licensee . concurred. with. the inspector's observations and stated
-.that the Nuclear Safety Evaluation Checklist will be revised to' provide-
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substantiating information for the decision documented. The final form
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for this checklist has not been completed. The. inspector. understands
that a narrative description of the justification for responses 'to
questions : delineated in . Parts A, B, and C of the Nuclear Safety
- Evaluation Checklist Form will be provided.
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Until the licensee has revised the Nuclear Safety Evaluation Checklist
to1 incorporate justification for the decisions documented, this is
' dentified as. Inspector Followup Item 369/85-09-03 and 370/85-10-03.
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Preparation- of Working Level: Procedures-for Technical Services Depart-
. ment Staff
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The inspector determined that the licensee has identified a need for
-working . . level instructions for staff- members within the Technical
Services Department. The inspector reviewed a draft copy of a table of
contents of a proposed manual which addresses appropriate activities
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performed by this group.
Until the licensee has developed working level instructions for the
Technical Services Department, this is identified as Inspector Followup
Item 369/85-09-04, 370/85-10-04.
- e.
Revision to Design Engineering Department Procedure PR-160.
The ' inspector determined that the' licensee has identified a -need to
revise engineering department procedure PR-160. This is the control-
ling QA procedure for Nuclear Station Modifications performed by Design
Engineering and delineates requirements for processing, controlling,.
approving, and clearing nuclear station modifications within Design
Engineering.
The changes to PR-160 is intended to address the reorganization of the
Safety Review and Licensing (SRAL) group which is assigned respon-
sibility for performing the Nuclear Safety Evaluations for DOMS.
Additionally, other changes brought about by the reformatting and
reorganization of the nuclear station modification program will be
incorporated into the procedure.
Until the Licensee completes the revision to Design Engineering
Department procedure PR-160, this is identified as Inspector Followup
Item 369/85-09-05, 370/85-10-05.
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Tests'and Experiments (37703)
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References:
(a)1 Appendix;B to 10 CFR 50 - Qualits Assurance Criteria-for
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Nuclear-Power Plants and Fuel' Reprocessing Plants
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(b)
10 CFR 50.59 - Changes, Tests and Experiments
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1(c) Duke . Power Company . Topical--Report, Quality Assurance .
Program, Duke-1-A,' Section'17.2.11, Revision 7
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(d) Technical Specification, Section'6.5, Review and Audit-
(e) Regulatory Guide 1.33, Quality Assurance - Requirements
(Operations)' November 1972
(f) - ANSI ' N18.7-1976, Administrative Controls and ' Quality
Assurance for the Operational Phase of Nuclear Power
Plants
'The : inspector reviewed the licensee's test 'and experiment program required
by references (a) through (f) to verify that the program was:in conformance
- with regulatory requirements, commitments in the application, and industry
^ guides and standards. The following criteria were used during this . review.
Lto assess the overall-acceptability of the established program:
A formal method has been established to handle all- requests .or
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' proposals for conducting plant tests involving safety related compon-
ents.
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Provisions have been made to assure that all tests will be performed in
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accordance with approved written procedures.
Responsibilities. have been assigned for reviewing and approving test
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procedures.
A' formal system, including assignment of responsibility, has been
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established to assure that all uroposed tests will be reviewed to -
' determine whether they are as described in the FSAR.
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Responsibilities have been assigned to assure' that a written safety
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evaluation. required by 10 CFR 50.59 will.be developed for each test to
-assure that it does not -involve an unreviewed safety question .or a
change in Technical Specifications (TS).
The documents listed below were reviewed .to verify' that the previously
listed criteria had been incorporated into the licensee's tests and experi-
ments program.
Administrative Policy Manual for Nuclear Power Station
Section 3.2.3, Special Testing, Revision 21
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.Section'4.8, Safety Related Analyses, Revision 21
Station Directives Manual, Revised 02-20-85
Section '3.2.1, Identifying,- Scheduling, and Performance of Plant
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~ Testing, Revision 13 (draftLcopy)
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Section 4.2.1, Handling of-Station-Procedures
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4 The inspector reviewed licensee , test 'and experiment -program documents' to
determine the program scope and content. The inspector determined that:a
test program hast been established.to assure that all testing required to
.. demonstrate satisfactory operation in service - of structures, systems, and
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components has been identified. Additionally, all . testing is performed in
accordance with approved written procedures.
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The inspector' verified that written safety evaluations required by 10 CFR'
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50.59 are . developed for special tests to assure that ~ unreviewed safety-
- questions" or ~ changes to . the - TS ? do . not. exist.
The inspector expressed
concern - regarding the NuclearL Safety Evaluation Checklist used. for docu-
. menting nuclear: safety evaluations. This concern is addressed in paragraph
4.c where .an Inspector . Followup -Item was identified to monitor licensee
corrective action.
- The inspector - reviewed the following special tests to verify conformance
with licensee documented program:
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ID No: TT/1/A/9100/73, Procedure Title: Power Operation with Increased
.Tave,' dates performed 11/1/83 thru 11/3/83.
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ID No: TT/1/A/9100/82, Procedure Title:
Dropped Rod Check, date
performed 5/3/84
ID No: TT/1/A/9100/68,. Procedure Title: Turbine Governor Valves Wide
Open Test, date performed 8/10/83.
- The inspector reviewed the nuclear safety evaluation of special test number
9100/73.
The inspector determined that the basis for the decision docu-
mented in Part C of.the Nuclear Safety Evaluation Checklist did not specifi-
cally address requirements of TS Section 2.0, Safety Limits and Limiting
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Safety System Settings. Section 2.1, Safety Limits, specifically delineates
the safety limits for the combination of thermal power, pressurizer
pressure,-and the highest operating loop coolant temperature (Tavg).
The special test involved variation of two of the parameters delineated in
TS Section 2.1 which were the highest operating loop coolant- temperature
Tavg.and thermal power. Thermal ~ power was estimated during the test because
of inaccuracies in the power range detectors due to increased downcomer
-temperature. The third parameter, pressurizer pressure, was not documented
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as a variable ~ to be monitored during the . test performance. Section'8.0 of
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-the special test procedure stated that, as a' prerequisite system condition,
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the- pressurizer pressure control.-is in the auto. mode. The . inspector _ wa's
linformed :- that.~ pressurizer; pressure during the' performance 'of the special
- test was as shown in TS Table 3.2-1 (DNB Parameters),
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The inspector reviewed the nuclear safety evaluation for special test number
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- 9100/82., The iinspector could not~ determine the' basis for the decision
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documented sin: Part'CLof the Nuclear Safety . Evaluation Check 11st in that
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Jreferences were not';provided:in the writeup. This' example along with:the
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one;that preceds it;is indicative of the inspector's concern regarding the
adequacy of the ' Nuclear Safety Evaluation tas -documented on' the Nuclear
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Safety Evaluation Checklist.
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.The. inspector _ interviewed licensee management concerning actions taken upon
determination
that- an u unreviewed safety - question exists. The. inspector
determined that once. station testing personnel decide - that an unreviewed
safety question exists, the special test requirements .are forwarded for -
review ;to Nuclear Production Department, Nuclear Safety Analysis : Group. .
.Special tests are not conducted until the unreviewed safety question
determination has been resolved.
Within this . area, no violations or deviations.were identified.
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. Licensee Action on Previously Identified Inspection Findings. (92701).
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(Closed)- Inspector Followup Item 369/82-34-01 and 370/82-29-01, Audited
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Organization Not Responding to Audit Finding in-the Required Time Interval
The ' inspector reviewed biannual report periodic assessment of QA Audit
results,~ dated 10-15-84. Examination of the objective evidence contained in
this document indicates that the: licensee is providing responses to audit
findings within the prescribed time frame.
(Closed) Ins'pector Followup Item 369/84-33-02 and 370/84-30-02, Two year
Periodic-Review of I&E Periodic Test Procedures.
The ~ inspector reviewed McGuire action item completion documentation -
sequence No.~ 2401-030BC, dated 2-1-85, and verified that corrective actions
for. completion of the two year review of I&E periodic test procedures were
completed on 1-7-85 using PT/0/B/4700/04A.-