ML20136E837

Forwards SALP Input for Facility Covering Feb 1983 - Jan 1984.Category 1 Assigned in Area of Mgt Involvement in Assuring Quality

ML20136E837
Person / Time
Site:	Susquehanna, 05000000
Issue date:	03/13/1984
From:	Perch R Office of Nuclear Reactor Regulation
To:	Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20136E841	List: IR 05000117/2004015 ML20136E837 ML20136E964 ML20136F664 ML20136F774 ML20136F970 ML20136F977 ML20136G052 ML20137A749 ML20137A929 ML20137A955 ML20137B013 ML20137B042 ML20137B092 ML20137B105 ML20137B123
References
FOIA-85-668 50-387-CAT1, NUDOCS 8403300260
Download: ML20136E837 (29)

Text

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i ' I' UNITED STATES 8 k NUCLEAR REGULATORY COMMISSION 74 E WASHINGTON, D. C. 20555

%,*****/ MAR 13 1984 MEMORANDUM FOR: RI- Starostecki, Director * ~

Division of Project & Resident Programs Regi.on I THRU: T. M. Novak, Assistant Director for Licensing , - -

Division of Licensing A. Schwencer, Chief 4-) 3,L p*i Licensing Branch No. 2 '

Division of Licensing FROM: R. L. Perch, Project Manager Licensing Branch No. 2, DL

SUBJECT:

SALP INPUT FOR SUSQUEHANNA 1 AND 2 Attached is the NRR SALP input for Susquehanna Steam Electric Station, Units 1 and 2 covering the period from February 1983 to January 1984. A draft of this SALP input was pr,eviously provided to Ebe McCabe on 2/29/84.

bLh d R. L. Perch, Project Manager Licensing Branch No. 2 Division of Licensing

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Attachment:

NRR SALP Input me 2

' mb Plant: Susquehanna, Unit 1 ,

(OperatingPhaseReactor)

Introduction ,

During this assessment period from February 1983 to January'1984, the -

licensee was involved in completion of power range test and commencement of 4

commercial operation of Unit 1.. During this period, the staff issued 14

. amendments to the Unit 1 license. These changes included administrative changes, updating of license conditions, and changes to technical

~

, specifications to reflect equipment modifications and new'information based

on operating experience. One amendment was processed under emergency circumstances and.one amendment was processed under exigent conditions. In each case, the staff concluded the circumstances leading to the emergency and exigent conditions could not be avoided. Supplement 5 to the Susquehanna Safety Evaluation Report was also issued during this period in support of completing several Unit 1 license conditions as well as addressing remaining open items related to issuance of an operating license for operation of Susquehanna Unit 2.

Functional Areas: -

1. ualit Management Involvement Pennsylvania Power in Assuring Q(PP&L)y

& Light Company continues to demonstrate a high

. degree of management control and involvement in achieving resolution of issues involved in license amendment requests. Corporate management has made themselves readily available to discuss and resolve the issues under review. This positive attitude facilitated the timely and thorough reviews required and completed within a expedited schedule review on the emergency service water pump sequence timer settings and the primary containment valve isolation signal changes. - - -

Rating: Category 1

, 2. Approach to Resolution of Technical Issues from a Safety Standpoint s The approaches of the licensee to resolution of technical issues from a -

safety standpoint are. technically sound. Thorough approaches were evident

• in almost all cases. After an initial learning period, the licensee has ,

provided adequate discussion of "no significant hazards considerations"

. ' with nearly all proposed amendments to the Unit 1 operating license. The licensee has also demonstrated a clear understanding of most issues

involved in technical specifications where changes were sought. In. sone cases, the initial submittals by the licensee eventually were found acceptable, but some information (e.g., system / test analysis) was lacking for the staff to draw the same conclusion initially.

Rating: Category 1 I

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3. Responsiveness to NRC Initiatives

• In response to NRC initiatives, the licensee provided timely responses, with acceptable resol,utions generally proposed. This was demonstrated in responses to several generic letters. Some license amendments proposed by the licensee that either require additional information from the i licensee or hav6 been held in abeyance by request of the licensee, need to be resolved. Final disposition of these issues should be pursued by the -

licensee.

, Rating: Category 2

4. Staffing (includingManagement)

. Personnel involved in the licensing activities are knowledgeable and professional. Appropriate personnel are in attendance at meetings with the NRC staff to make the meetings productive.

Rating: Category 1

5. Reporting and Analysis of Reportable Events Overall, corporate and plant management *is aware of and sensitive to i

deficiencies and events that are reportable to the NRC. The licensee in general reported events in a timely manner and provided effective .

corrective action with repetition indicated in only a small number of .

cases. -

Rating: Category 2

6. Training and Qualification Effectiveness An adequate number of licensed personnel has been maintained to operate Susquehanna, Unit I with most of these individuals also qualified to operate Susquehanna, Unit 2.

Rating: Category 1

7. Overall Rating for Licensing Activity Functional Area: 1 e

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Plant: Susquehanna, Unit 2 (Preoperational Phase Reactors)

Introduction I-During this assessment period from February 1983 to January 1984, the staff was involved, along with the applicant, in resolving the open items related -

to the issuance of an operating license for Susquehanna, Unit 2. During this period, Supplement 5 to the Safety Evaluation Report was issued and addresses the remaining open items on Susquehanna, Unit 2.

Functional Areas:

1. Management Involvement in Assuring Quality .

Pennsylvania Power & Light Company has demonstrated a high degree of management control and involvement in achieving resolution of licensing activity issues. Management within PP&L was readily accessible which facilitated timely and thorough reviews. Management involvement was particularly evident in the areas of independent design review, emergency service water system modifications, emergency core cooling system activation instrumentation, the initial test program, and " station blackout" testing.

Rating: Category 1

, 2. Approach to Resolution of Tech ~nical Issues from a Safety Standpoint The approaches of the applicant to. resolution of technical issues from a safety standpoint are technically sound and thorough in almost all cases. This was particularly evident with the installation of two additional engineered safety features transformers to the on-site power ~

system to evidence o,f thorough support two unit operations.

planning Changesinofminimizing and coordination this naturethe show impact on Unit 1 operations while preparing Unit 2 for licensing. PP&L also demonstrated an exceptionally clear understanding and sound technical  ;

approach towards resolution of the " station blackout" test requirements.

Rating: Category 1 ,

3. Responsiveness to NRC Initiatives In response to NRC initiatives, the applicant has generally provided '

timely responses with acceptable resolutions as initially proposed. PP&L l has generally been aware of and sensitive to the needs of the staff to perform its review function with adequate lead time; however, some delays '

were experienced in receiving submittals to resolve Susquehanna Unit 2 licensing issues. The applicant has been very responsive to meet with the staff on short notice to resolve critical path issues.

Rating: Category 2 b

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4. Staffing (includingManagement)

Personnel involved in the licensing activities of Unit 2 are essentially the same personnel involved with Unit 1. These personnel are knowledgeable and professional. Appropriate personnel are made available in meetings with the NRC staff to make the meeting productive.

Rating: Category 1 * -

5. Reporting and Analysis of Reportable Events Corporate and plant management has maintained an adequate level of control over the construction activities of Unit 2. Events are properly reported and analyzed. Corrective action is effective.

Rating: Category 1

6. Training and Qualification Effectiveness -

Training and qualification for Unit 2 has been effectively implemented to provide sufficient numbers of licensed personnel for the operation of Unit 2. Use of the Unit 2 technical specifications under development has

! been incorporated into Unit 2 plant procedures providing feedback for proposed changes to improve and enhance the technical. specifications.

Rating: Category 1

7. Overall Rating for Licensing Activity Functional Area: 1 99 e

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ENCLOSURE 2 SALP INPUT FOR SUSQUEHANNA UNIT 1 & 2 TECHNICAL SPECIFICATION CHANGES FOR THE STANDBY GAS TREATMENT SYSTEM Plant: Susquehanna Unit 1 & 2 A. Functional Areas: Licensing Activities

1. Management Involvement in Assuring Quality.

No licensee management involvement occurred during our discussions with the licensee. Therefore, no conclusion can be made.

2. Approach to Resolution of Technical Issues from a Safety Standpoint.

In general, the licensee's representative had a good understanding of the issues presented during our discussions.

Rating: Category 2.

3. Responsive to NRC Iriitiatives.

The licensee's representatives were generally responsive to NRC requests.

Rating: Category 2.

4. Staffing (includingManagement)

~~

This section is not applicable for this staff effort. No staff conclusion can be made in this area.

5. Reporting and Analysis of Reportable Events.

Fai. lure to meet required secondary containment drawdown comitments were reported in a LER within two weeks of -

event date.

Rating: Category 1

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6. Training and Qualifi. cation Effectiveness.

This section is not applicable for this effort. No staff conclusion can be made in this area. .

7. Overall Rating for Licensing Activity Functional Area: -

Category 2 9

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EllCLOSURE 2

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. SALP prepared by the Containment Systems Branch SUSQUEHANNA, UNIT 1 i Evalua tion f Criteria Ca tegory , Harrative Description

'lManagmentinvolvement N/A

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_ Approach to I(esolution 1 Approach to Resolution of issue was very reasonable, consistent with safety, and of Technical , Issues allowed additional flexibility in plant operation.

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Responsiveness .N/A s

Enforcement llistory N/A Reportable Events N/A .

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-Sta f fing '

N/A . i

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A/U/i1 c3g SALP INPUT FROM THE METE 8 lLOGY AND EFFLUENT TREATMENT BRANCH

. FOR SUSOUEHANNA, UNIT N0.1, TECHNICAL SPECIFICATION CHANGES REGARDING THE STANDBY GAS TREATMENT SYSTEM A. Licensing Activities

1. Managenent Involvement in Assuring Ouality ,

Rating: N/A - No licensee management involvement occurred during our discussions with the licensee. Therefore, no conclusion can be made.

2. Approach to Resolution of Technical Issues from a Safety Stand-

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point.

Rating: Category 2. In general, the licensee's representative had a good understanding of the issues presented during our discussions.

3. Responsive to NRC Initiatives Rating: Category 2. The licensee's representatives were generally responsive to NRC requests. .

4 Staffing (including Management)

Rating: N/A - This section is not applicable for this staff effort. No staff conclusion can be made in this area.

5. Reporting and Analysis of Reportable Events Rating: Category 1. Failure to meet required secondary contain-ment drawdown commitments were reported in a LER within two weeks of event date.

6. Training and Oualification Ef fectiveness Rating: N/A - This section is not applicable for this effort. No ,

staff conclusion can he made in this area.

7. Overall Rating for Licensing Activity Functional Area Category 2.

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4 &~/ ENCLOSURE 2 ggn m SALP CSB - Input prepared by the Containment Systems Branch i

Evaluation Cri teria Category Bases .

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1. Management Involvement N/A i

z. Approach to Resolution .

3 of Technical Issues I Good understanding of technical issue during the discussion.

3. Responsiveness I ' Representative of the licensee met,with the staff on short notice to discuss the issue.

l4. Enforcement History N/A .

! 5. Reportable Events I LER was issued within 2 weeks from date plant's failure to. meet

, secondary containment drawdown requirement. , 1 i \

6. Staf fing N/A i

q 7. Trainin9 N/A -

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7/27/T4 ENCLOSURE 2 i ,

1 SALP pFepared by the Containment Systems Branch Evaluation SUSQUEHANNA Criteria Category , Narrative Description Managtment Involvement N/A Approach to lhsolution 3 The Proposed Technical Specification change was prepared in response to a CDR prepared of Technical issues )y Region I. However, the resolution is different from what the staff found acceptable I the SER. It should have been discussed with the staff prior to its submittal and should I have been highlighted as being different from what was received at the SER staae.

Responsiveness .

Enforcement llistory '

N/A Rcportable Events N/A -

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! Staffing D N/A i ,

Training .

. N/A O

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• ENCLOSURE 2 -

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i .. SALP s ,.

- prepared by the Containment Systems Branch

' Evalua tion .

Criteria Ca tegory Narrative Description

Hanagement Involvement .

I. N/A a _

Apprsach to Hesolution - - - - .

.l of Technical Issues I

Understanding of the Technical Issue was demonstrated II

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!,R:sponsiveness ,

l} N/A .

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.; Enfcrceaant History ..

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.RepbrtableEvents

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l ~L' SALP INPUT Susquehanna Unit 2 - Systematic Assessment of Licensee Performance Functional Areas:

1. Management involvement in assuring quality Technical review of the submittal indicates that the management '

reviews are timely and technically appropriate.

Rating: Category 2*

s 2. Approach to resolution of technical issues from a safety standpoint The licens'ee showed a general understanding of the technical issue and used acceptable approaches. -.

Rating: Category 2*

3. Responsiveness to NRC Initiatives It is a viable and timely response.

Rating: Category 2

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4. Staff (includingManagement)

N/A

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5. Reporting and analysis of reportable events N/A

6. Training effectiveness and qualification i

N/A

7. Overall Rating for Functional Area: 2

Reference:

NRC Appendix 0516 - Systematic Assessment of Licensee -

Performance.

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\u R Enclosure 2 Information for a SAL.P Evaluation - Susquehanna, Unit 1

1. Management Involvement , _

The submittal was sufficient to permit evaluation without further information. This implies adequate management involvement.

Rating: Category 2

2. Resolution of Technical Issues The submittal contained adequate but not outstanding technical bases for the proposed changes. -

Rating: Category 2

3. Responsiveness to NRC Initiatives There was no inter ~ action with the licensee, therefore no'b~ asis for rating.

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ENCLOSURE 2 Susquehanna Steam Electric Station -- Systematic Assessment of Licensee Performance Functional Areas:

1. Management involvement in assuring quality.

Technical review of the submittal indicates that the management reviews are timely and technically appropriate.

Rating: Category 2*

2. Approach to resolution of technical issues from a safety standpoint.

The licensee showed a general understanding of the technical issue and used acceptable approaches.

Rating: Category 2

3. Responsiveness to NRC Initiatives. I It is a viable and timely response.

Rating:' Category 2

4. Staffing (including management). -

N/A -

- 5. Reporting and analyses of reportable events. .

N/A

6. Training and effectiveness and qualification.

N/A '

7. Overall rating for functional area: 2

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Reference:

NRC Appendix 0516 - Systematic Assessment of Licensee Performance.

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i ENCLOSURE 2 Susquehanna Unit 1 - Systematic Assessment of Licensee Performance

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Functional Areas: .

1. Management involvement in assuring quality.

Technical review of the submittal indicates that the management reviews '

are timely and technical appropriate.

Rating: Category 2*

2. Approach to resolution of technical issues for a safety standpoint.

The licensee showed a general understanding of the technical issues and used acceptable approaches.

Rating: Category 2

3. Responsiveness to NRC Initiatives It is a viable and timely response.

! Rating: Category 2

. 4. Staffing (including management)

N/A

5. Reporting and analyses of reportable events N/A

6. Training and effectiveness and qualification ,'

N/A .'

7. Overall rating for functional area: Category 2

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Reference:

NRC Appendix 0516 - Systematic Assessment of Licensee Performance.

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_ . . _ , _ _ . ~ . , _ , _ . . _ . _ . _ , _ _ _ _ _ . _ . . . . _ _ _ _ . _ _ . _ _

hbh Enclosure 3

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Information for SALP Evaluation - Susquehanna Unit 1 and 2

1. Management Involvement * -

The submittal was sufficiently complete to permit an evaluation of the proposed Technical Specification changes without requiring additional information. This implies adequate management involvement.

Rating: Category 2

2. Resolution of Technical Issues The submittal showed adequate understanding of the technical issues.

No further interaction with the licensee was necessary.

Rating: Category 2

3. Response to NRC Initiatives No basis for rating.

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s tuutvaunc ICSB SALP INPUT PLANT: Susquehanna Steam Electric Station, Unit I -

SUBJECT:

Proposed Changes to the Technical Specifications (TAC No. 56362)

EVALUATION PERFORf4ANCE BASIS CRITERIA CATEGORY L

N/A No basis for assessment.

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!. Involvement

2. Approach to 2 A clear technical understanding of the issues was demonstrated. However, Resolution of a technically sound approach was not used to justify the proposed surveil.lanc-Technical Issues frequency change for the float switches. '

3. Responsiveness N/A No basis for assessment.

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4. Enforcement N/A No basis for assessment.

Histo'ry

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! 5. Reportable Events N/A No basis for assessment.

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6. Staffing N/A No basis for assessment.

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7. Training N/A' No basis for assessment.

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ICSB SALP INPUT , ,

PLANT: Susquehanna, Units 1 & 2 - -

SUBJECT:

High Energy Line Breaks .

) EVALUATION PERFORt1ANCE BASIS CRITERIA CATEGORY The licensee appeared to adequately understand staff policies and to

,- make decisions based on adequate management review. An appropriate level *

1. Management 1 of management was present and involved in discussions held with the licensee.

Involvement i

The modifications proposed by the licensee were consistent with staff guidelines f and a clear understanding of the issues was demonstrated. In general, viabit.

2. Approach to and sound approaches were taken to resolve safety issues. However, the resolu-2 Rssolution of tion of these issues would have been expedited if the original submittal had' con-Technical Issues tained additional desion infonnation.

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The licensee's responses were generally provided in a timely manner.

3. Responsiveness ,

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4. M orcement No basis for assessment.

N/A N/A No basis for assessment.

5. Peportable Events .

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6. StaffinD N/A No basis for assessment.

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7. Training s N/A No basis for assessment.

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~. ICSB SALP INPUT .-

PLANT: SUSQUEHANNA UNITS 1 & 2 '

SUBJECT:

MULTIPLE CONTROL SYSTEM FAILURES EVALUATION PERFORMANCE BASIS CRITERIA CATEGORY The licensee appeared to adequately understand staff policies and to make decisions based on adequate management review. An appropriate level -

1. ana me 1 of management was present and involved in discussions held with the licensee.

The modifications proposed by the licensee were consistent with staff guidelines

2. Approach to 2 and a clear understanding of the issues was demonstrated. In general, viable R: solution of and sound approaches were taken to resolve safety issues. However, the resolu-Technical Issues tion of these issues would have been expedited if the original submittal had con tained additional design infonnation.

, 3. Responsiveness 1 The licensee's responses were generally provided in a timely manner.

4. Enforcement History N/A No basis for assessment. -

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5. Reportable Events N/A No basis for assessment.

6. Staffing N/A No basis for assessment.

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' 7. Training ,

N/A No' basis for assessment.

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1 i ENCLOSURE l

, ICSB SALP INPUT PLANT: lSusquehannaSteamElectricStation, Unit'l - -

SUBJECT:

Proposed Changes to the Technical Specifications (TAC Nos. 55127 and 55129)

EVALUATION PERFORttANCE BASIS CRITERIA CATEGORY ._

N/A No basis for assessment.

1. Management Involvement j i

2. Approach to 1 A sound technical understanding of the issues was demonstrated.

7 Technical Issues

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3. Responsiveness N/A No basis for assessment.

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j 4. Enforcement N/A No basis for assessment.

History

5. Reportable Events N/A No basis for assessment.

6. Staffin9 N/A No basis for assessment.

N/A  : No basis for assessment.

7. Training - s

D& 23 SALP REPORT FOR SUSQUEHANNA UNITS 1 & 2 In accordance with Office L,etter No. 44, the following HFEB SALP evaluation input is provided:

s

1. Management Involvement and Control in Assuring Quality - the licensee's

,-submittal showed evidence of prior planning and was generally responsive to the technical issues.

" Rating: Category 2

2. Approach to Resolution of Technical Issues from a Safety Standpoint -

the licensee shows a general understanding of the issues and has implemented a generally sound and thorough approach to most of the Connission requirements for an SPDS.

Rating: Category 2

3. ~ Responsiveness to NRC Initiatives - the licensee provided responses to staff concerns in a timely manner and those responses were generally

- - -acceptable.

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Rating: Category ? -

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D d F S (n kl 6. Y?Y4 SALP REPORT FOR SUSQUEHANNA 1 & 2

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SAFETY PARAMETER DISPLAY SYSTEM SER in accordance with Office Letter No. 44, the following HFEB,SALP evaluation -

input is provided:

Evaluation Criteria / Category

1. Management Inycivement and Control in Assuring Quality 2

2. Approach to Resolution of Technical Issue from Safety Standpoint ,

2

3. Responsiveness to NRC Initiatives 2 Attached are the applicable parts of NRC Manual Chapter 0516 Appendix, Part II appropriately annotated to provide specific details related to the evaluation criteria.

Attachments:

As Stated

Contact:

G. W. Lapinsky x29694 i ,,

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. . '/ "/ S1 c9s SALP EVALUATION FOR CORE PERFORMANCE BRANCH Plant: Susquehanna Units 1 and 2 A. Functional Areas: Licensing Activities 1 Management Involvement in Assuring Quality. - -

The PP&L management team has shown evidence of prior planning and proper assignment of priorities. The procedures for control of activities in our area of review are adequately defined and followed.

1 Rating: Category 2

2. Approach to Resolution of Technical Issues from a Safety Standpoint.

The licensee has shown a clear understanding of the safety issues in our area of review. Conservatism is routinely exhibited in areas of safety significance. The licensee has proposed technically sound and thorough approaches in all cases.

Rating: Category 1

3. Responsiveness to NRC Initiatives.

-The licensee has met all deadlines for submittals and has been very responsive towards timely resolution of issues. ~

Rating: Category 1

4. Staffing. ~

Positions of contact personnel in our area of review are well defined. '

Their authorities and responsibilities are well defined.

Ra ting: Category 1 I

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. SALP EVALUATION FOR CORE PERFORMANCE BRANCH Plant: Susquehanna Unit 1 A. Functional Areas: Licensing Activities

1. Management Involvement in Assuring Quality.

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Rating: Not Applicable

2. ApproichtoResolutionofTechnicalIssuesfromaSafetyStandpoint.

The licensee has shown a clear understanding of the safety issues in -

our area of review. Conservatism is routinely exhibited in areas of safety significance. The licensee has proposed technically sound and thorough approaches in all cases.

Rating: Category 1

. 3. Responsiveness to NRC Initiatives.

Rating: Not Applicable

4. Staffing. '

Rating: Not Applicable O

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'.- ENCLOSURE 2

,_ PS8/DSI SALP INPUT .

PLANT: Sus.quehanna SES, Unit 1 and Unit 2 .'

LICENSEE: Pennsylvania Power and Light Company DOCKET NO: 50-387 and 50-388 LICENSE STATUS: Operating SER

SUBJECT:

Technicab Specification Changes to DC Sources ,

PERFORMANCE PARAMETERS: (1) Management Involvement In Assuring Quality (2) Appoach To Resolution of Technical Issues From a Safety Standpoint ,

(3) Response To NRC Initiatives (4) Staffing (Including Management) .

(5) Reporting And Analysis Of Reportable Events (6) Training And Qualification Effectiveness (7) Any other SALP Functional Area

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CATEGORY / RATING PERFORMANCE NARRATIVE DESCRIPTION ..

PARAMETER . APPLICANT / LICENSEE'S PERFORMANCE 1 N/A

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2 The licensee has demonstrated clear under- 1 standing of the system design problem and technical ' specification implication. They initiate to modify the system and the associated technical specification.

3 N/A 4 N/A

• 5 N/A .

6 N/A 7 N/A i

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SALP INPUT Plant: Susquehanna, Unit 1

-1. Management Involvement and Control in Assuring Quality: Not Applicable

2. Approach to Resolution of Technical Issues from a Safety Standpoint:

Category 1

3. Responsiveness to NRC Initiatives: Category 1

4. Enforcement History: Not Applicable

5. Reporting and Analysis of Reportable Events: Not Applicable

6. Staff (Including Management): Not Applicable

7. Training and Qual'ification Effectiveness: Not Applicable The following is the narrative to inputs for Items 2 and 3 given above.

By letter dated October 17, 1984 to the licensee, the staff indicated that SDV piping system failure and the resulting consequences as identified in NUREG-0803 need not be assumed provided that certain indicated guidelines could be satisfied. In response to the above letter, the licensee provided a sub-mittal dated February 1, 1985. The licensee's submittal demonstrated a thorough knowledge of the safety issues involved and satisfied the guidelines identified. The licensee has, therefore, resolved the staff's concerns in this regard.

T", Chcedf 068NO ,

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SUSQUEHANNA UNITS 1 AND 2 BRANCH /DIV MANAGEMENT TECHNICAL RESPONSIVENESS ENFORCEMENT REPORTABLE STAFFING TRAINING INVOLVEMENT RESOLUTIONS HISTORY EVENTS CSB/DSI N/A ,

2 N/A N/A 1 N/A N/A RSB/DSI 2 2 2 N/A N/A N/A N/A ICSB/DSI 1 2 1 N/A N/A N/A N/A HFEB/DHFS 2 2 2 N/A N/A N/A

. N/A RAB/DSI 2 2 3 N/A N/A N/A N/A CPB/DSI 1 1 . 1 N/A N/A 1 N/A PSB/DSI N/A 1 N/A N/A N/A N/A N/A ASB/DSI N/A 1 1 N/A N/A- N/A N/A OVERALL 2 _2 2 N/A 1 - 1 N/A f

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