ML20127K226
| ML20127K226 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/27/1985 |
| From: | Blake J, Hallstrom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127K213 | List: |
| References | |
| 50-424-85-08, 50-424-85-8, 50-425-85-08, 50-425-85-8, NUDOCS 8505220074 | |
| Download: ML20127K226 (14) | |
See also: IR 05000225/2003001
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET,N.W.
2-
ATLANTA, GEORGI A 30323
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, Report Nos.: 50-424/85-08 and 50-425/85-08
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Licensee: Georgia Power. Company
P. 0. Box 4545
. At1anta, GA ~30302
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D'cket Nos.:
50-424 and 50-425-
License Nos.:
CPPR-108 and CPPR-109
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FacilityLName: Vogtle 1 and 2
Inspection Condu ted: ' February 25 - March 1, 1985
. Inspector:
mM
Jh7!W
G . A..
Ist
Dats Signed
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. Approved b
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J. J.
lake, Section Chief
~ 'Date Signed
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gi eering Branch
iv sion of Reactor Safety
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SUMMARY
. Scope: -This routine, unannounced inspection involved 39 inspector-hours on site
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in ~the areas of licensee action on previous enforcement matters, construction
. progress, safety-related structures, safety-related piping, and licensee identi-
.fied items (50.55(e)).
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.. Results: 'One deviation and two violations were identified
" Deviation of
Commitments to American Welding. Society (AWS) Requirements for Inspection of-
Porosity", " Lack of Materials Control from Instrumentation Satellite Warehouse",
- and ;" Failure of Pipe Support Field Installation and' Fabrication Procedure to
provide.for Control of. Welding Quality".
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8505220074 850411
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ADOCK 05000424
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. REPORT DETAILS
1.
Persons Contacted
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Licensee: Employees
'*C. W. Hayes,.Vogtle Quality: Assurance (QA) Manager
- E. D. Groover, QA Site Manager --Construction
- C.' E.fBelflower,JQA Site Manager - Operations
- B. C. Harbin,' Manager,' Quality Control
- G. A. McCarley, Project Compliance Coordinator..
- C. C. Miller, Superintendent of Plant Engineering and Services
'*J. O. Dorough,, Administration Manager
- S.'D. Haltom,.QA Engineering. Support Supervisor
- J. L. Blocker, Assistant Manager, Quality Control (QC)
'91. W. Swain, Mechanical QC Section Supervisor
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- J.'M. Davis,. Nondestructive Examination-(NDE) Supervisor
'90 : S. Hairstor, Regulatory Compliance Engineer
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- E.fA. Meadows,-. Regulatory Compliance' Plant Engineer
- S'.fJ. Piedra,-QA' Engineer-
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- A..Caudill,-Inservice Inspection (ISI) Plant Engineer
- R..May,-ISI NDE Coordinator
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Otherf11tcensee employees contacted included construc'. ion craftsmen,
technicians, and office personnel.
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'Other Organizations
- D. L. Kinnsch, Project Field Engineer, Bechtel. Power' Company -(BPC)
'*K. W. Caruso, Welding Engineer, BPC
- P.- R. Murphy, Construction Engineer', Oglethorpe Power Company
NRC Resident Inspectors
- J. F. Rogge, Senior Resident Inspector - Operations
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' *R. J. Schepens, Resident Inspector - Construction
- Attended exit interview
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2.
. Exit: Interview
The inspection scope and findings-were summarized:on March 1,1985 with'
those~ persons indicated in paragraph 1 above. The licensee' was- informed of
.the ! inspection . findings . listed below.
The licensee acknowledged the
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. findings'with no dissenting comments.
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-(Open) Deviation 424,- 425/85-08-01, Deviation of Commitments to AWS D1.1
Requirements for Inspection of Porosity
paragraphs 3.b. and 6.b.(1)(a).
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(0 pen) Violation 424, 425/85-08-02, Lack of Material Control from Instru-
mentation Satellite Warehouse
paragraph 5.
(0 pen) Violation 424, 425/85-08-03, Failure of Pipe Support Field Installa--
tion and Fabrication Procedure to Provide for Control of Welding Quality -
paragraph 6.a.(2).
The licensee _ did not identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
a.
(0 pen) Unresolved Item 424, 425/84-17-02, Visual Acceptance Criteria.
This item concerns deviations of visual acceptance criteria from the
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American Welding Society (AWS) D1.1 Structural Welding Code (AWS
D1.1-1975).
Appendix VC, Revs. O thru 8, to Bechtel Specification
X4AJ01, Revision 12, includes several requirements for visual accept-
ance of weldments on Seismic 1 steel structures and supports which are
less stringent than those imposed by AWS D1.1-1975.
The licensee provided proposed engineering justification for all
deviations during an earlier inspection (Report No. 50-424,425/84-36).
The proposed justification (Log:
PFE-3730) had been reviewed and
additional concerns were identified to cognizant licensee personnel.
The licensee had been further informed that the exclusion of porosity
from visual acceptance criteria would be the subject of a separate
unresolved item (424, 425/84-36-09).
Additional - Bechtel-sponsored clarification and engineering justifica-
tion (File:
X4A201; Logs:
855141, BG33246, and PFE-4883) were
reviewed during an early 1985 inspection (Report No. 50-424,425/85-03)
and . the licensee was informed that engineering justification and
clarification were sufficient to resolve all concerns provided adequate
clarification could be obtained regarding the acceptance criteria
incorporated in Specification No. X2AP01, Division C5, Section
No. C5.1, Revision 4,
paragraph C.5.1.5.B.
versus the engineering
justification for category A welds - included in PFE-3730. Cognizant
licensee pe rsonnel informed the inspector that requested clarification
was not yet.available. This item remains open.
b.
(Closed) Unresolved Item 424, 425/84-36-09, Potential Deviation of
Commitments to AWS D1.1 Requirements for Inspection of Porosity.
In
continuation of discussions described above, the licensee had previ-
ously - informed ' the inspector that Appendix VC would be revised to
incorporate Category A porosity limits to Category B welds.
The
licensee had been informed that this change would resolve the concern
regarding exclusion of porosity requirements but would require correc-
tive actions to ensure acceptability of welds previously inspected
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without stipulated porosity limits. The inspector reviewed the latest
corrected acceptance criteria (Revision 9, dated January 23,-1985) and
noted that the revisions to paragraph 3.c. did not impose Category A
limits for Category B welds.
Further, that present wording would not
be . sufficient to reject clustered porosity as discussed in paragraph
- 6.b'.(1)(c) for weld B5 to P201 bottom on rack R0006. Further, that the
pertinent second-tier Pullman Power Product's (PPP) procedure X-18 had
not been revised to impose any requirements for inspection for porosity
for category B welds. The inspector informed the licensee that due to
the above and the . final acceptance of -the deficient B5 to P201 weld,
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- this item was upgraded to Deviation 424, 425/85-08-01, " Deviation of
Commitments to AWS D1.1 Requirements for Inspection of Porosity."
4.
Unresolved Items
Unresolved items.were not identified during this inspection.
5.
Independent Inspection (92706)
Construction Progress (Units 1 and 2)
The inspector conducted a general inspection of the Units 1 and 2 contain-
-ments and the control building to observe construction progress and const-
ruction activities such as welding, material handling and control, house-
' keeping and storage.
During the above inspection, the inspector noted the lack of arrangements
-for physical control of access from the PPP satellite warehouse for-instru-
mentation sub-storage on top of the control building.
Further-that racks
containing code-class piping were directly accessible on entering the area.
Cognizant personnel informed the inspector that no warehousemen were on duty
during second shift and, therefore, no control of access was imposed during
that time frame.
The inspector informed the licensee that this was
considered a . lack of conformance to 10 CFR 50, Appendix B, Criterion VIII,
as implemented by PPP procedure VII-2 and would be identified as Violation
424, 425/85-08-02, " Lack of Material Control from Instrumentation Satellite
Warehouse."
6.
Steel Structures and Supports (Units 1 and 2)
The inspector observed welding work activities and reviewed records for
-steel structures and supports as described below to determine whether
applicable code and procedure requirement.s were being met.
The supports and structures involved were welded by PPP. The applicable
codes are as follows:
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Pipe Racks - AWS-Structural Welding Code D1.1-79.
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Pipe Whip Restraints - AWS Structural Welding Code D1.1-74.
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Pipe Supports and Instrumentation Supports - ASME Boiler and Pressure
Vessel Code,Section III, 1977 edition with addenda through W77.
a.
Welding Procedure Specifications and Quality Assurance Procedures
(551518)
(1) Welding Procedure Specifications (WPS) applicable to the weld
-joints listed in paragraph 6.b.(1), were selected for review and
comparison with the ASME Code as follows:
WPS
Process
IT8-III/I-1-BR-2
SMAW*
34A, 34B
IT12-III/I-1-0B-12
SMAW/GTAW**
45, 34A, 34B,
55A, 55B, 58
- SMAW - Shielded Metal Arc Welding
- GTAW - Gas Tungsten Arc Welding
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The_ above WPSs and their supporting Procedure Qualification
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Records (PQRs) were reviewed to ascertain whether essential,
supplementary and/or nonessential variables, including thermal
treatment, were consistent with Code requirements; whether the-
WPSs were properly qualified and their supporting PQRs were
accurate and retrievable; whether all mechanical tests had been
performed and the results met the minimum requirements; whether
the PQRs had been reviewed and certified by appropriate personnel;
and whether any revisions and/or changes to nonessential variables
were noted.
WPSs are qualified in accordance with ASME
Section IX, the latest edition and addenda at the time of quali-
fication.
(2) The below listed documents were reviewed to ascertain whether the
structural welding program had been approved by the licensee and
-whether adequate plans and procedures had been established to
assure that welding would be controlled and accomplished consis-
tent with commitments and regulatory requirements.
Document No.
Title
PPP-III-4, dated 10/11/84
" Drawing and Design Control-
Procedure"
PPP-VII-2, dated 10/3/84
" Material Control"
PPP-IX-40, dated 11/30/84
" Instrumentation Installation,
Inspection, and Testing"
PPP-IX-50, dated 8/30/84
" Pipe Support Field Installa-
tion and Fabrication Procedure"
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PPP-IX-65, dated 10/18/84
" Installation and Inspection
of Pipe-Whip Restraints"
PPP-X-18, dated 2/2/84
" Field Welding Inspection"
PPP-XV-2, dated 7/11/84
" Procedure for Handling Noncon-
formances (Field)"
PPP-XV-4, dated 4/26/84
" Hold Tag Usage"
.PPP-SI-47, Rev. 5
" Site Instructions-for Marking
Material, Parts, and Small
Items"
PPP-SI-70, Rev. O
" Instruction for Rework of
Accepted Supports"
During the above review, the inspector noted that paragraph 10.21
and attachments 25 and 26 of PPP-IX-50 allowed field changes of
weld types (fillet to partial penetration groove) from those
specified on design drawings when angular deviations of as-built
structural bracing members are within
4* of the angle specified.
When this modification is done, no changes of' weld symbols on
design drawings nor annotation of quality records are completed
since the weld is considered acceptable provided minimum effective
throat requirements are met;
i.e.,
the required effective throat
'of the specified fillet weld.
QC acceptance of the final
partial penetration groove weld is predicated on meeting this
requirement by attachment-26.
However,
cognizant. licensee
personnel informed the inspector that past practice has been to
accept this type of weld without any fit-up inspection (since this
hold point is not specified) to ensure meeting required effective
throat. The inspector informed the licensee that the requirement
that QC inspection verify effective throat without being able to
inspect fit-up is a lack of capability of procedure IX-50 to
adequately control the welding involved. This matter is consid-
ered a lack of conformance with 10 CFR 50, Appendix B, Crite-
rion IX, and will be identified as Violation 424, 425/85-08-03,
" Failure of Pipe Support Field Installation and Fabrication
Procedure to Provide for Control of Welding Quality."
b.
Visual Inspection of Welds (551558)
The inspector visually examined completed welds on Unit 1 containment
pipe racks, pipe supports, pipe whip restraints, and instrumentation
supports as described below to determine whether applicable code and
procedure requirements are being met. Applicable design drawings are
as follows:
Pipe Racks - MOIG-594-R5 and M0IG-595-R6
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Pipe Supports - VI-1202-196-H602, Rev. O
Pipe Whip Restraints - IX2D69F031, Rev. 0
Instrumentation' Supports - IX5D400159A, Rev. I and sketch
CX5DPM030, Rev. 0
ISK5402009-A, Rev. O and sketches
CX5DP8203, Rev. 5
and CX5DPM070, Rev. 1
(1) The below listed welds were examined relative to the following:
location, length, size and shape; weld surface finish and
appearance; transitions between different wall thicknesses; weld
-reinforcement--height and appearance; joint configurations on
permanent attachments and- structural
supports;
removal
of
temporary attachments, arc strikes and weld spatter;. finish-
grinding and machining of weld surface, surface finish and absence
of wall. thinning; surface defects, cracks, laps, lack of penetra-
tion, lack of fusion, porosity, slag, oxide film and undercut
exceeding prescribed limits.
Rack R0006
Weld Joint
P201 to C4
P201 to 81
B5 to P201 Top
B5 to P201 Bottom
Pipe Support VI-1202-196-H602
Weld Joint
40.5* Cross Brace to Vertical Support member *
40.5' Cross Brace to Cable Tray Support Steel *
Pipe Whip Restraint PBR-031
Weld Joint
FW-1
FW-3
Instrumentation Supports
Sketch CX5DPM030 Weld Joints
Weld No. A
Weld No. B
Weld No. E
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Weld No. F
Sketch CX5DP8203 Weld Joints
-Weld No. A
-Weld No. B
Sketch CX5DPM070 Weld Joints
Weld No. A
Weld No. B
- Final QC inspection not complete.
During the above inspection, the inspector noted the following:
(a) Weld joint B5 to P201 bottom on pipe rack R0006 had been QC
final accepted with unacceptable porosity.
QC inspectinn
personnel informed the inspector that they were unable to .
reject the weld due to lack of requirements for rejection of
porosity in PPP procedure X-18.
Independent verification by
the inspec' tor and two contractor QC inspectors established
that the weld contained clustered porosity sufficient for
rejection under present requirements for Category A welds.
Additional discussion is reported in paragraph 3.b.
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(b) The connections for the 40.5* cross brace on pipe . support
VI-1202-196-H602 had been completed as partial penetration
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groove welds.
Design drawing VI-1202-196-H602, Rev. O,
initially specified a 45* cross brace. The angle was field
corrected to 40.5* by the Vogtle-Structural Analysis Mobile
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Unit (V-SAMU) on February 28, 1985.
This deviation is
outside the 14* allowance specified in procedure IX-50 as
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reported in paragraph 6.a.(2).
In this case,, Proce-
dure IX-50 mandates a partial penetration groove weld and
fillet welds are not an option. However, the drawing was not
corrected from the original fillet welds specified.
The
inspector requested information as to design calculations
substantiating _ the 40.5* angle and was informed by cognizant
licensee personnel that the proper corrections were.not made
due to an oversight.
The inspector noted that failures to
properly correct design drawings had been the root causes of
previous violations 424, 425/84-30-01 and 424, 425/85-03-01.
The inspector informed the licensee that this matter was
considered to be another example of Violation 424,
425/84-30-01 and noted that the response to be developed for
violation- 424, 425/85-03-01 should be expanded as necessary
to consider this example.
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(2) Quality Records . for. the welds listed in paragraph 6.b(1) were :
examined relative to the following: . records covering visual and
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dimensional inspections indicate _ that the specified inspections
were completed; the records reflect adequate weld quality; history
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records are adequate.
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Welder. Qualification (551578)'
- The inspector reviewed. the licensee's . program for qualification- of
welders and welding operators ' for compliance-with - QA procedures and
ASME Code requirements. The applicable code for welding qualification
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is ASME Boiler and Pressure vessel (B&PV) Code,Section IX,_as invoked
-by Georgia Power Company _ (GPC) Specification X2AG06, Rev. 4, - and
X4AZ01, Section P.1, Revision 8.
The following welder ~ qualification status . records .and " Records of
' Performance Qualification. Test" were reviewed relative to the weld
joints listed in paragraph 6.b(1).
Weld Symbol
HT-2 PPP.
ZB-3 PPP
YC-3 PPP
EZ-4 PPP
WA-3 PPP
d.
_ elding Ft11er Material Control (551528)~'
W
The inspector reviewed the licensee's program for control of welding.
materials to odetermine whether . materials were being purchased,:
accepted,estored, and handled in1accordance with QA procedures and
applicable' code requirements.
The _ following specific ' areas were-
examined:
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Purchasing,
receiving,
storing,
distribution,
and- handling-
procedures, material identification.
-The following welding materials from those currently being used in
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completion _- of production welding were selected for review of
purchasing and receiving records for conformance with applicable
procedures and code requirements:
Type-
Size
Heat / Control No.
E7018
3/32"
KK037
E7018
1/8"
LLO15
-E7018
3/32"
090BBB
E7018
1/8"
KK087
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e.
Observation of Work : QC-Inspector Qual'ification -(55154B)
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.The inspector reviewed the' licensee's program qualifications of welding
Code requirements.
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-The~1following inspector. qualification: . status < records and "QA/QC
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. Inspector Qualification / Certification" . records were reviewed relative
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to -inspection: of the weld joints ~ listed in paragraph 6.b.(1).
Inspector.
Type of Certification
JEYJ
VT-II
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-PMH
VT-II
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VT-II
HGS
VT-II
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, ithin .the ' areas examined, no_ violations or deviations were identified
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.except as reported in paragraphs 6.a.(2) and 6.b.(1)(a).
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17.
' Safety-Related Piping (Unit 1)-
1The ' inspector observed' welding work activities for safety-related piping as
described below to determine whether applicable code and procedure require-
ments were being met.- The applicable code for safety-related piping is .the
ASME Boiler and Pressure Vessel Code,Section III, Subsections NC and ND,
1977Jedition.with' addenda through winter 1977.
a '.
Observation of Work (55183B):
The below listed welds were examined in process to determine. work
conducted Lin 'accordance with traveler; welder. identification and
location; welding procedure' assignment; welding technique and sequence;
materials identity; weld geometry; fit-up; temporary attachments; gas
. purging; preheat; electrical characteristics; shielding Lgas; welding
equipment condition; interpass temperature; interpass cleaning; process
control systems; ~1dentity ~ of welders; qualification of inspection
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personnel;'and weld history records.
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Weld No.
-ISO No.
Unit
System
- W-15
1X5DY00956-B-R1
1
Instrumentation-
W-16
1X50Y00956-B-R1
1
Instrumentation-
W-21
1X5DY00956-B-R1
1
. Instrumentation
W-22
IX50Y00956-B-R1
1
Instrumentation
The following inspector qualification status records and "QA/QC
Inspector Qualification / Certification" records were reviewed relative
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to inspection of the weld joints listed above.
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Type of Certification
VT-II
WDR
VT-II
b.
' Welding Procedure Specifications _(551818)
Welding Procedure Specifications (WPS) applicable to the weld joints
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listed in paragraph 7.a., were selected for review and comparison with-
the ASME Code as follows:
WPS
Process
38-III/I-8-K1-1
GTAW*
120, 121
- GTAW - Gas Tungsten Arc Welding
The above WPSs and their supporting PQRs were reviewed to ascertain
whether essential,
supplementary and/or nonessential
variables,
including thermal treatment, were consistent with Code requirements;
whether the WPSs were properly-qualified and their supporting PQRs were
accurate and retrievable; whether all mechanical tests had been
performed and the results met the minimum requirements; whether the
PQRs had been reviewed and certified by appropriate personnel; and
whether.any revisions and/or changes to nonessential variables were
noted.
WPSs are qualified in accordance with ASME Section IX, the
latest edition and addenda at the time of qualification.
c.
Welding Filler Material Control (551828)
The inspector reviewed -the PPP programs for control of welding
materials to determine whether materials are being purchased, accepted,
stored, and handled in accordance with QA procedures and applicable
code requirements. The following specific areas were examined:
Purchasing,
receiving,
storing,
distributing, and handling
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procedures, material identification
Welding material purchasing and receiving records for the
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following materials were reviewed for conformance with applicable
procedures and code requirements:
Type
Size
. Heat / Control No.
Application
3/32"
05394
Safety-Related Piping
1/8"
05394
Safety-Related Piping
E308-16
1/8"
54180
Safety-Related Piping
E309L-16 3/32"
GG093
Safety-Related Piping
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d.
WelderQualification.(551878)
The-inspector reviewed the PPP, program for qualification of welders and,
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welding . operators Lfor compliance . with QA procedures and ASME Code
- requirements. : The applicable code for welding qualification is ASME
B&PV Code Section. IX .as --invoked by GPC Specifications X2AG06, Rev. 4,
and X4AZ01, Section P.1, Revision 8.
'The following welder qualification ' status records and " Records of
Performance . Qualification. Test" were reviewed relative to' the weld
' joints listed in paragraph 7.a.
Weld Symbol
Application
a
TF-3
Safety-Related Piping
'Within the areas examined, no violations or deviations:were identified.
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. Licensee Identified Items (92700)
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Prior to the inspection, the licensee identified the following items under
a.
.(Open) Item 424/CDR 84-66, Containment Pipe-Rack Welds
On July 20,1984,- the licensee notified Region II of a 50.55(e) item
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. involving cracks in Unit I containment ' pipe-rack welds.
The final
report was submitted on October 17, 1984.
The ' proposed corrective action plan (DER-061) was reviewed during
previous inspections and concerns documented within inspection reports
424/84-30, 424/84-36, and 424/85-03.
The~ inspector conducted additional discussions with cognizant licensee
personnel ;on the previously listed concerns.
Cognizant licensee
' personnel were informed that necessary repair for welds C10 to B18 on
Rack R0003-and P40 to C10 on Rack R0002 should have been listed in PPP ~
Deviation _ Report (DR), PP-07213 -(issued 11/8/84) as they'were identi-
fled.
Further, that all. suspect welds identified by the' DER-061
analysis of highly restrained -joints had been reinspected and repair
scheduled under DR PP-07934 issued 12/14/84. Further that hold tags
-had been issued on 2/27/85 for C10 to B18 on Rack R0003, P40 to C10 on
Rack R0002 and several additional welds not identified on DR PP-07934.
The inspector concluded. that these actions satisfy previous concerns
that all known deficient welds be -incorporated in the DER-061 correc-
tive action plan. The inspector informed the licensee that this item
remains open pending completion of corrective action.
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b.
(Closed) Item 424, 425/COR 80-07, Embed Plate Assembly
'On December 20, 1978, the -licensee notified Region II .of a 50.55(e)
item involving tn'e' improper installation and inspection of embedded
plate assemblies. The final report was submitted on November 21, 1979,
and~ amended on April 10,.1980, and June 20, 1980.
The report has been reviewed and determined to be acceptable by
Region II. The inspector held discussions with responsible licensee
representatives,
reviewed supporting documentation,
and. observed
representative samples of work to veri fy that corrective actions
identified in the report have been completed.
c.
(Closed) Item 424, 425/CDR 82-21, Use of Derated/ Abandoned Embed Plates
On . February 22,-1982, the licensee notified Region II of a potential
50.55(e) item involving use of 44 of the abandoned or derated embeds as
discussed above. On April 22, 1982, the licensee informed Region II ~
that this item was not reportable due to completion of pertinent
engineering evaluation. The inspector reviewed pertinent engineering
evaluation and concurred with the conclusion that all derated embeds
used were structurally adequate.
(_ Closed) Item 424, 425/CCisB2-25, Embed Plates - 1982
d.
On April 26,1982, .the licensee notified Region II of a 50.55(e) item
concerning a lack of anchor-bolt thread engagement for 222 embed
plates. The final report was submitted on July 1,1983. The report
has been reviewed and determined to be acceptable by Region II. - The
inspector held discussions with responsible licensee representatives,
reviewed supporting documentation, and observed representative samples
of work to verify that corrective actions identified in the report have
been completed.
9.
.Previously. Identified Inspector Followup Items
a.
(0 pen) Inspector Followup Item 424, 425/85-03-02, " Adequacy of
Temperature Marking Crayons"
This item concerns adequacy of temperature marking crayons. Welding
material issue stations are provided with both markal thermomelt and
tempilstick temperature indicating crayons.
The crayons are issued
indiscriminate 1y for use on stainless steel as well as carbon steel
Further, in conformance to GPC procedure GDT-14, Rev. 6,
the crayons are used as the reference standard to ensure adequate oven
temperature before issuing electrodes requiring moisture control. The
inspector reviewed certification information from Tempilstick which
verified control of inorganic halogen content and low melting point
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metals Jas well as assurance that specified melt _ temperature was
accurately indicated on several lots of marking crayons currently being
. issued for production work. Cognizant licensee personnel informed the
licensee that similar information was. not yet received from Marka1.
- This item remains open.
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