ML20204B756

Forwards Potential 10CFR50.55(e) Items Re Significant Deficiency Analysis Repts to Assist Board in Desire to Be Kept up-to-date on Matters of Potential Significance. Related Correspondence

ML20204B756
Person / Time
Site:	Comanche Peak
Issue date:	03/20/1987
From:	Ellis J Citizens Association for Sound Energy
To:	Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel
References
CON-#187-2885 OL, NUDOCS 8703250143
Download: ML20204B756 (37)

Text

1 8

t1%MTED CURRESPOMDLnyt i sC A S E = =.

DOCKETED a4/gu 9u6 JSNRC (CITIZENS ASSN. FOR SOUND ENERGY)

March 20, 1987 87 11AR 23 Pl2:05 0FFICE 05 iEL Wi? Y 00CMETING & 5f.RVICf.

Administrative Judge Peter B. Bloch Dr. Kenneth A. Mc N b"m U. S. Nuclear Regulatory Commission 1107 West Knapp Street Atomic Safety & Licensing Board Stillwater, Oklahoma 74075 Washington, D.C.

20555 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridge, Tennessee 37830

Subject:

In the Matter of Texas Utilities Electric Company, et al.

Application for an Operating License i

Comanche Peak Steam Electric Station Units 1 and 2 Docket Nos. 50-445 and 50-446 d Potential 10 CFR 50.55(e) Items To assist the Board in its desire to be kept up-to-date on matters of potential significance, CASE is attaching copies of the potential 50.55(e) items (SDAR's, or Significant Deficiency Analysis Reports) which we have received since we provided the Board with such items on 2/20/87.

It is our intention to periodically continue to provide these SDAR's unless the Board indicates otherwise.

Respectfully submitted, CASE (Citizens Association for Sound Energy) l rs.) Juanita Ellis President cc:

Service List Attachments 8703250143 870320

{DR ADOCK 05000443 PDR

}6

3 b.

Log # TXX-6317 File # 10110 903.11 2:

Ref. # 10CFR50.55(e) nlELECTRIC March 6, 1987

% c, %

Lmurow 5 nr />rsukm U. S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 CONDUIT SUPPORT SPANS SDAR: CP-85-19 (INTERIM REPORT)

Gentlemen:

On October 21, 1986, we notified you by our letter logged TXX-6017 of a deficiency regarding.the use of a nonrepresentative sample in determining generic values'for typical conduit span calculations which we deemed reportable under the provisions of 10CFR50.55(e). This is an interim report to status corrective action implemented to date.

The engineering evaluations and subsequent formulatiens of corrective actions are continuing.

These activities are scheduled for completion by March 30, 1987, for Units 1 and 2.

We anticipate submitting our next report on this issue no later than April 30, 1987.

Very truly yours, W. G. Counsil I

DAR:1w c - Mr. E. H. Johnson, Region IV l

Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV l

i 4to North Olne $treet I_H M1 Dallas. leus 75201

a~

w.'

's Log # TXX-6319 P.

File # 10110 903.9 Ref. # 10CFR50.55(e) 1UELECTRIC wwam c.co a March 6, 1987 E.wwnw 6kr heudent U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

-COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 ELECTRICAL RACEWAY-SUPPORT SYSTEM SDAR: CP-85-31 (INTERIM REPORT)

Gentlemen:

On December 5,1986 we notified you by our letter logged TXX-6138 of a deficiency involving the Unit 1 Class 1E Electrical Raceway Support System which we deemed reportable under the provisions of 10CFR50.55(e). This is an interim report submitted to status corrective actions implemented to date.

This deficiency involves the installation of Separation Barrier Material (SBM) and Radiant Energy Shield (RES) material on Unit 1 Class IE Electrical Conduit Raceways without engineering interdisciplinary design review of the proposed change.

As a result of installations without interdisciplinary design reviews and other design concerns identified through the CPRT Design Adequacy Program, we have reviewed and revised the CPSES Design Control Program to provide positive interdiscipline interface controls. This program establishes procedural requirements for interdiscipline engineering reviews and analysis of all proposed design changes, tests or experiments. This revised procedural j

program is adequate to prevent recurrence of similar causative deficiencies.

1 We have also completed the evaluation of conduit installations affected by the RES. As a result of the evaluation, thirty five (35) supports will be i

modified and eleven (11) new supports added where none have existed previously.

Design change authorizations and travelers have been approved and issued.

Physical work started in January 1987.

New and/or additional conduit installations requiring RES have been identified and will be evaluated in accordance with the revised interdiscipline procedural program.

This evaluation is scheduled to begin in April 1987.

I f

400 North Olne Street L H. Mi Dall4% Tesas 75201 I

TXX-6319 March 6, 1987 Page 2 Class IE raceways affected by SBN are currently undergoing population identification evaluation review as described in our response to SDAR CP-86-83 (Separation Barrier Material on Power Cables and Power Raceways) logged TXX-6195. This evaluation is scheduled for completion by March 31, 1987.

We anticipate submitting our next report on or before ~ June 26, 1987.

Very truly yours, W. G. Counsil DAR:ef-9

~s c - Mr. I. H. Johnson, Region IV-Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV

(

L 0

Log # TXX-6318 E

File # 10110 P """"

903.9 1

C C

Ref # 10CFR50.55(e)

TUELECTRIC w n.. c. cw March 12, 1987 E.sra ume b ut Presulent U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 INSTALLATION OF SUPER HILTI KWIK BOLTS SDAR: CP-86-08 (INTERIM REPORT)

Gentlemen:

On February 6,1987, we verbally notified your Mr. T. F. Westerman of a deficiency involving the control of stamps used to identify Super Hilti Kwik Bolts (HKB). This is an interim report of a potentially reportable item under the provisions of 10CFR50.55(e). Our previous report was logged TXX-6122 dated December 1, 1986.

Ultrasonic testing has been completeo on a random sample of supports in each of the cable tray, conduit and HVAC systems in Units I and II. A total of 360 supports were involved in the analysis. Quality engineering has completed examination of the results and has determined that three (3) cable tray supports had standard HKBs installed where the design drawings specified Super 163s.

The standard HKBs were found to be stamped for identification indicating " Super" HKB. Non-conformance reports have been issued for these supports documenting the installations concurrent with the evaluation for possible adverse effects on plant safety.

A similar program of sampling, testing and evaluation is underway for electrical equipment and structural steel supports which were installed using HKBs.

These actions and our evaluations are scheduled for completion on June 30, 1987.

400 North Olne Street i.H si Dalle. Tese 75201

.. > s..

TXX-6318 March 12, 1987 Page 2 of 2 Corrective Action: Reports (CAR) were initiated for ASME installations ' CAR-058), which documents the programs outlined above, and for Non-ASME installations.(CAR-074). CAR-058 has been completed and indicates that 'is issue is not reportable. CAR-074 has not been completed.

We will submit our next report no later than July 22, 1987.

Very truly yours, 2

[M j

GLB/dl c - Mr. E. H. Johnso, - Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV

l

~; y a

Log # TXX-6341 P-File #10110' 4

908.3 C

Ref #10CFR50.55(e)

NELECTRIC March 16, 1987 Emume ikr besurnt U.S. Nuclear Regulatory Commission ATTN:. Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 6.9KV SWITCHGEAR BREAKER JACK SHAFT WELD FAILURE SDAR:

CP-86-14 (FINAL REPORT)

Gentlemen:

On March 11, 1986, we verbally notified your Mr. T. F. Westerman of a deficiency involving a weld failure in a component of a Class IE 6.9KV switchgear breaker. This is a final report of a potentially reportable item under the provisions of 10CFR50.55(e). Our last report, logged TXX-6172, was submitted on December 18, 1986. We have concluded that this deficiency is reportable under the provisions of 10CFR50.55(e) and the required information follows:

DESCRIPTION OF PROBLEM

!i During normal maintenance, a 6.9KV switchgear breaker (IA3 cubicle 7: service air compressor) was closed and reopened automatically due to a phase imbalance. Our subsequent investigation revealed that a weld connecting the right hand jack shaft and the lever arm had failed due to inadequate weld fussion. 'The defective breaker was replaced with a spare.

During a subsequent, common mode failure analysis, a visual inspection program of all critical breakers and a statistical random sample check on the non-critical breakers was completed using acceptance criteria provided by the breaker manufacturer (Brown Boveri). The initial results of this inspection concluded that the jack shaft welds.did not meet the vendor's acceptance criteria in all cases.

As a result of these findings, the manufacturer initiated an evaluation of the established design criteria, including design testing to verify breaker operability.

Adequate inspection criteria could not be developed for installed jackshafts.

The models developed for the test program ~were not adequate to assure operability of the breakers; therefore the jackshafts will be replaced.

400 North Olise 5treet I.11 Ml Dallas. Tesas 75201 L,..,,......._...._.

.J

.i

.TXX-6341

~'

March 16, 1987

.f Page 2-SAFETY IMPLICATION The lack of-adequat'e welding between the jack shaft and the lever arm could result. in failure of the breaker. The safety of plant operations could have been adversely affected had this condition remained uncorrected.

CORRECTIVE ACTION All jack shafts in the 6.9KV switchgear at CPSES are scheduled to be replaced by November 21, 1987.

'If any subsequent reports of this issue (SDAR CP-86-14)' are required concerning the status of implementation of corrective actions under the provision of 10CFR50.55(e), they will be reported via SDAR: CP-87-03, "6.9KV Switchgear Installation".

Very truly yours, M4&

W. G. Counsil JCH/ef c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley - RI, Region IV Mr. H. S. Phillips - RI, Region IV

File No. 10002 COMMITMENT TRACKING OUTGOING CORRESPONDENCE EVALUATION SHEET DOCUMENT IDENTIFICATION Title /

Subject:

6.9KV Switchgear. Breaker Jack Shaft Weld Log No. TXX-6341 Failure SDAR CP-86-14, (Final Report)

File 10110 908.3 Date 03/16/87 ITEM TRACKING Item Tracking Item No.

Description Types

• Document /No.

001 All Jack shafts in the 6.9KV switchgear at CPSES are g

LCR-87-140 scheduled to be replaced by November 21, 1987.

Note: Any gg subsequent reports of this issue will be reported via SDAR, CP-87-03, "6.9KV Switchgear Installation." See LCR-87-139.

• Item Types: EA - External Action OB - Operational Basis DB - Design Basis IA - Internal Action DO - Description Only AS - (See LCR form)

COMPLETED BY REVIEWED BY

)

/

Date3k97 Initials A A M Date I/6d7 Initials m

i FIGURE 7.2 fiEPORTABILITY EVALUATION FORM DATE IDENTIFIED:

February 7, 1986 SERIAL NO:

0140 SOURCE OF INFORMATION:

Ter-86144 (Tuzco Miantenance Eng.. Prublem STAlEMENT OF PROBLEH:

Report 86-045) - A t t a c h e'il A compuneut weld failurc,0f,a singl U. E switchgcar breaker.

The breakers were procured per PO cP-0423 and are class 121ed as LE components.

Additional inspections will be rii6' ired using t

vendor provided criteria.

~

EVALUATION A55}GNED T0:

Roc /rss PAGATION DUE DATE: February 28,198 EVALUATION:

The iack shafts _ installed in the 6.9kv switchgcar at EES contain weldments which exhibit both lack of fusion and croper fillet wcld air.c y npecified by the man uliTe u r c r of

,,subicce.i t e m 'i.

The lack of adequate welding b e t; w s w i Lhe einhL band J a n. k shart a:U

___the lever arm could result in failure of tilie breaker.

The safety of plant operations could have'~been adverscAy effected had this condition remained un(orrected.

RECOMMENDATION:~

PORTABLE 4 YES NO / APPLICABLE TO: _

50.55(e7 3, /d,h7 EVALUATOR:

DATE:

- y y

REVIEW OF REPORTA81LITY RECOMMJDATION E

CONCLUSION:

REPORTABLE

_A YES COMMENTS:

__ NO / APPLICABLE T0:

50.55(e)

PART 21

~~

1 BOTH

^

- ~,

M YIEWER.( & &f7 W DAlt: J//6 //~J i;

Q L.0 Nke CONCLUSION:

REPORTABLE YES NO / APPLICABLE TO:

50.5S(e)

COMMENTS:

,PART 21 ei BOTH

^

s

//n n

RVIEWER:

/o'ADM11mf DATE: T//h /f1

's i

)

/

i NEO CS-1

5

,.3 LICENSING COMMITMENT RESOLUTION (LCR) FORM LCR No.

LCR-87-140 Rev. No. 0 Date:

03/16/87 T0:

J. L. Barker Comitment

Description:

All jack shafts in the 6.9KV switchgear at CPSES are scheduled to be replaced by November 21, 1987. Note: Any subsequent reports of this issue will be reported via SDAR, CP-87-03, "6.9KV Switchgear Installation." See LCR-87-139.

Comitment Source: TXX-6341 Date: 03/16/87 File:

10110 Due Date: 11/21/87 This is a committed date.

Licensing Lead:

D. A. Ringle 979-8879 Above is a description of formal commitment made by Texas Utilities to a regulatory agency. This commitment requires action by your organization by the date shown.

Please complete the reverse side and return this form to document the resolution of this commitment.

If resolution cannot be achieved by the commitment due date, provide a new resolution date at least seven (7) calender days prior to the date specified.

Irteml This commitment requires 4*ternal-Action and resolution should be accomplished by completion of the committed action.

i sA &

Signature, Supervisor Docket Licensing Date Copy to:

LCR log, T. A. Hope, D. A. Ringle L. D. Nace, J. E. Krechting, R. E. Camp, D. M. Reynerson i

i

p

. i9 : $

Log # TXX-6323 P """

File # 10110 1

C 909.4 C

C

' Ref # 10CFR50.55(e) 1UELECTRIC

\\

u MiMiam G. Coumil tm,n, u, r,,,am March 9, 1987 7

i U. S. Nuclear Regulatory Commission Attn: Document Control Desk-3 Washington, D.C.

P.9555 i,

N s \\

SUBJECT:

COMA.NCHE PEAK STEAM ELECTRIC STATION (.CPSES)

(,'

DOCKET NOS. 50-445 SAFETY CHILLED WATER CHILLER UNITS' g(.

, SDAR: CP-86-18 (INTERIM REPORT) 3*

(

Gentlemen:h; 05 May 21, 1986, our letter logged TXX-4820 provided notification that the issue involv.ing difficulties -in starting and operating the safety chilled water chiller units was reportable under the provisions of 10CFR50.55(e). The issue identifies the. failure of the Component Cooling Water (CCW) supply to maintain temperatures at or above the chilled water return temperature for both the operating and standby chillers. Our last interim report logged was s

TXX-6175 dated December 18, 1986.

t s

We have complete"d a Motalled review of vendor specifications and Ma identified twenty-seven"ccmponents served by the component cooling water system that' are affected.' The components will either be qualified by analysis to accept tfie revised"CCW inlet temperature (40 degree F)'cr have individual

.s component or system modifications implemented.

3

.(

Presently, all vendors hhve been contacted to ascertain the acceptability of the revised CCW inlet 4ncoture. --she status of evaluation by the vendors is l

as follows:

'N A)

Component / System' Modification Required 110102 Comoonent

• York i Safety Chillers - Condensers

+

(Trane

, Vent. Chillers - Condensers Inger:oll-Rand (Instr. Air Compr. - Jacket /

(N' Aftgeboder

,p s

l r

l

~

400 North Oine Street t li 81 Delas. Jesas ?$201

r r

s, er)?!

f TXX-6323

. March 9,.1987 Page 2 of 2 B)

Equipment Acceptable Without Modification.

Westinghouse Pos. Disp. Chg. Pump

-Hydraulic Coupling 011 Cir.

Sentry Equipment Process Sample Coolers Pass Sample Coolers Bingham Willmet.

Contet. Spray Pmps. - Seal Clrs.

CVI Control Rm. Air Conditioners -

Condensers UPS Air Conditioners-Condensers C)

. Completion of Evaluation Pending.

J. Oat Contmt. Spray Heat Exchangers Spent Fuel Pool Ht. Exchangers Westinghouse Miscellaneous Equip.

All an dyses and modifications for Units 1'and 2 are scheduled for completion

{

by. the en6 of November 1987.

We will submit our next report no later than December 18, 1987.

Very truly yours,

&J c. M W. G. Counsil By:

)

4 John /I. Beck Viceresident Nuclear Engineering GLB/gj c

Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI -' Region IV

.+.

c

!!!E!!!!

Log # TXX-6305

.9 File # 10110 903.9 2:

Ref. # 10CFR50.55(e) 1UELECTRIC w

c.c.,,

February 27, 1987 Emwrw 5 nr Prendent U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 CONDUIT SUPPORT DESIGN SDAR: CP-85-34 (INTERIM REPORT)

Gentlemen:

On October 21, 1986, we notified you by our letter logged TXX-6047 of a deficiency involving the adequacy of conduit supports to perform their intended design functions which we deemed reportable under the provisions of 10CFR50.55(e). This is an interim report submitted to status corrective actions implemented to date.

Based upon our evaluation completed to date, additional fP :

verifications of Unit I and common area conduit support systems is required to assure the conduit installations conform to the revised criteria of the S-0910. The S-0910 package governs seismic conduit and support design for Unit I and common areas. As-built data will be obtained in accordance with Procedure FVM-CS-033, " Design Control of Electrical Conduit Raceways for Unit 1 Installations in Unit 1 and Common Areas", for Unit 1 lighting, power and control conduits and FVM-CS-014, " Design Installations in Unit I and Common Areas", for Unit 2 conduits in the Unit 1 and common areas.

As previously reported, Unistrut and transverse supports have been examined differently than in the above mentioned verification activity.

For Unistrut supports, a Unistrut Test Program has been implemented to determine the adequacy of Unistrut supports with regard to torsional loading. Any Unistrut support, as determined from testing, having capacities below those given in the original S-0910 package, or not tested, will be replaced or demonstrated to be not needed. Additionally, all transverse supports will either be converted to multidirectional supports or demonstrated to be not needed.

400 North Olne Street I..B. 81 Dallas, Tesas 75201

~ TXX-6305 February 27, 1987 Pag 2 2 y

The field walkdown activities now underway are scheduled for completion by.

December 31, 1987.

We anticipate submitting our next report no later than February 1, 1988.

Very truly yours, UN W. G. Counsil DAR:lw c - hv. E. H. Johnson, Region IV he. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV t

i r

1----

• +4 3.-

Log # TXX-6296 File # 10110 2""

903.9 "E-f2[

Ref. # 10CFR50.55(e) 1UELECTRIC w mm. c. c--a February 20, 1987 Emunw 6 he hrsk/rrer U. S. Nuclear-Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 I

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKETS NOS. 50-445 AND 50-446 LARGE BORE PIPING AND SUPPORTS SDAR:

CP-86-36 (INTERIM REPORT)

Gentlemen:

On June 9,1986, we verbally notified you of a reportable item involving the scope of plant modifications resulting from the project's pipe support reverification

' program (see TXX-4844). This is a follow-up interim report on a reportable item under provisions of 10CFR50.55(e). Our latest interim report logged TXX-6206 was submitted on January 8, 1987.

.The continuing engineering evaluation has not identified any additional instances-which are considered reportable pursuant to 10CFR50.55(e). The attached list shows the support modifications issued to date. The evaluation is continuing and we anticipate submitting our next report by April 10, 1987.

Very truly yours, N

W. G. Counsil BSD/amb Attachment c - Mr. E. H. Johnson', Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV 400 North Othe Street L B. 81 Dallas. Texas 75201

TXX-6296-4, 9 February 20, 1987

, Attachment Page 1 o'-1 ATTACHMENT LARGE BORE PIPE SUPPORT MODIFICATIONS Number of Unit Cateaory Modifications

• 1 Prudent 870 Recent Industry Practice 1354 Adjustment 870 Cumulative Effects 1202 2

Prudent 1014 Recent~ Industry Practice 356 Adjustment 283 Cumulat'/e Effects 546 Changes in these figures from the last report represent not only identification of further modifications but a. reclassification and/or recategorization of certain supports. Reductions in these figures from the previous report are due in part to tracking changes in the program.

i I

I

y Log # TXX-6313 File # 10110 C

903.11 C

C Ref # 10CFR50.55(e) 1IIELECTRIC

%illione G. Counsil cmmm, er,,s,,,,

March 2, 1987

~

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 APPLICATION OF NON-QUALIFIED AGASTAT RELAYS

'SDAR:

CP-86-40 (INTERIM REPORT)

Gentlemen:

On October 10,'1986, we notified you by our letter logged TXX-6017 of a deficiency infolving the procurement and use of non-qualified Agastat relays in~several Class 1E applications which we deemed reportable under the provisions of 10CFR50.55(e). This is an interim report submitted to status corrective action implemented to date. Our most recent interim report was logged TXX-6227, dated January 26, 1987.

The-identification of non-qualified relays by document review ard inspection is continuing.

Additional corrective action steps (e.g., replacement) will be establishiiid upon completion of these reviews and inspections. These activities are scheduled for completion by April 25, 1987.

We expect to submit our next report on this issue by May 29, 1987.

Very truly yours, uWaX W. G. Counsil WJH/dl c - Mr. Eric H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV 4

Mr. H. S. Phillips, RI - Region IV 400 North Olne Street I B. BI Dalle. Tenas 75201

.i

's Log # TXX-6292

-==

File # 10110 9

903.10 1

r 2:

Ref # 10CFR50.55(e) 1UELECTRIC w am. c. c w February 23, 1987 Eenurne s ur Presutent U. S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 UNISTRUT SPRING NUTS ON INSTRUMENT SUPPORTS SDAR:

CP-86-50 (FINAL REPORT)

Gentlemen:

On October 10, 1986, we notified your Mr. E. H. Johnson of a reportable deficiency involving nut alignment and torque requirements for Unistrut spring nuts on instrument mounts via our letter logged TXX-6019.

Plans requiring rework of affected installations are being integrated with other instrumentation issues and the status of modifications will be reported via SDAR CP-86-19, " Instrumentation Installations."

Very truly yours,

$b. /

hum W. G. Counsil By:

< E, G. S. Keeley Manager, NucleTF s{ m/

sing JDS/dl c - Mr. E. H. Johnson, Region IV Mr. D. L. Ke1 ley, RI - Region IV Mr. H. S. Phillips, RI - Region IV l

l l

i 300 North Olne Street I..B si Dallas. Texas 75201 l

- ;7_ y.

o

h e.

J 2-Log -# TXX-6286 File # 10110 903.10 C

C Ref # 10CFR50.55(e) 1UELECTRIC wm c.cm.m February 20, 1987 rm.= u, a,,u,,,,

i U. S. Nuclear Regulatory Commission ATTN: - Document Control Desk

- Washington, DC 20555-

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SEISMIC DESIGN OF CONDUIT SDAR: CP-86-53 (INTERIM REPORT)

Gentlemen:

On October 21, 1986, we notified you by our letter logged TXX-6054 of a deficiency involving the seismic design of conduit, which we deemed reportable under the provisions of 10CFR50.55(e). This is an interim report submitted to status corrective action implemented to date.

The testing program to evaluate the ability of adhesives or clamps applied to conduit couplings after installation to resist torsional moments is currently underway.

Preliminary results indicate that previously used adhesives or

- clamps will not adequately resist torsional moments. However, these results have also shown that a heretofore unused combination of fiberglass cloth and resin may be suitable for the loading conditions identified. The identification of further corrective actions is dependent upon the results of the testing of this materia 1' program. The testing program is currently scheduled for completion by March 31, 1987.

Our next report on this issue will be submitted no later than May 1,1987.

Very truly yours, W. G. Counsil RSB:lw c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV i

i 400 North Ohve Street L B. 81 Dallas Texas 75201 a

av.,,%-,

w--

.c, ym,---.-.,--.,-..,---r,-

-..-.4-.

._.,..m.

"6:

g Log # TXX-6291 File # 10110 llllllllr =

903.7 Ref # IDCFR50.55(e) lilELECTRIC w mw. c. c February 20, 1987 Emwsw the Pressdent U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555

SUBJECT:

CDMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 ORIGINAL DESIGN OF CONTROL ROOM CEILING SUAR: CP-86-54 (INTERIM REPORT)

Gentlemen:

On October 3,1986, we notified you by our letter logged TXX-6007 of a deficiency involving the design and installation of the control room ceiling which we deemed reportable under the provisions of 10CFR50.55(e). Tlis is an interim report submitted to status corrective action implemented to date. Our most recent interim report was logged TXX-6168, dated December 18, 1986.

Resolution of Open Quality Control inspection items is continuing and is scheduled for completion by June 30, 1987.

We will submit our next report on this issue no later than July 21, 1987.

Very truly yours, MW W. G. Counsil i

JCH/dl c - Mr. E. H. Johnson, Region IV Mr. D: L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV l

i 400 North Othe Street ! B.8' Dallas, Texas 75201

4

..c Log # TXX-6321'

"""" 9 File #10110.

C 903.7 C

C Ref#10CFR50.55(e)

TilELECTRIC wim c.co a

~ March 13, 1987 Emmern he Presideru -

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 SEISMIC AIR GAP DESIGN ADEQUACY SDAR: CP-86-55 Gentlemen:

On August 14, 1986, we verbally notified your Mr. I. Barnes of a deficiency involving the seismic air gap design adequacy between the Auxiliary Building and Units 1 and 2 Containment Buildings. This is an interim report of a potentially reportable item under~the provisions of 10CFR50.55(e). Our last interim report was, logged TXX-6107, dated November 21, 1986.

The evaluation of the refined calculations indicating acceptability of the s

i,, 3 existing gap (as noted in cur previous reports) is continuing in conjunction with the validation of the Seismic Category I Building analysis.- The results-h of this composite evaluation are needed to complete our assessment of the

' impact of this issue upon the safety of plant operations. The validation program is currently scheduled for completion by June 1,1987.

..a :

~-

Our next report en this issue will be submitted no later than July 8,1987.

Very truly yours,

?

W. G. Counsil,

t By: /b l/

~

/'

G. S. Keeley Manager,NuclearLiceping JCH/ef c - Mr. E. H. Johnson, Region IV i

Mr. D. L. Kelley - RI, Region IV Mr. H. S. Phillips - RI, Region IV 400 North Olne Street L H. 81 D.alla. lese M201

, ~,.... _ _.

___,_m..,_..._..

I

= ':=ll Log # TXX-6330 r

""" 9 File #10110

~

903.8 h

C C

Ref#10CFR50.55(e)

TUELECTRIC was.. c. cw March 13, 1987 Luersarve ne l>rssJent E g U.S. Nuclear Regulatory Commission P

ATTN: Document Control Desk Washington, D.C.

20555 m

@~~

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES) i b ice wuruer w.

DOCKET NO. 50-446..

.~

m -

- - Aw

+4 UNCONSOLIDATED CONCRETE-UNIT 2 RCB EXTERIOR WALL SDAR: CP-86-65 (FINAL REPORT) a a.

_ p.

Gentlemen:

e On October 15, 1986, we verbally notified your Mr. I Barnes of a deficiency

.G. 9 -

,," '~ involving unconsolidated concrete in the exterior wall of CPSES unit 2 Reactor Containment Building. Our last interim report was logged TXX-6208, dated J

January 21, 1987.

s - g( 0 W '_' Specifically, the issue involves unconsolidated concrete identified on the'

.A ty. {g 4 CS A feetWMiiWexterior wall of Unit 2 Reactor Containment Building (CU) at elevation 921

!.ID azimuth 326 degrees. The deficiency was documented by Nonconformance-

4. h W ;0 O Q Report Number NCR,C-86-201273..

-. a,y s.

~

w y ey,

~

l During our evaluation, a review of the QA documentation related to the specified area was conducted. There was no evidence of a significant

. x - x. breakdown in the QA program.~ Additionally, an engineering analysis has concluded no condition adverse to the safety of plant operations or the 3

structural integrity of the exterior wall would exist in the event the i

deficiency had remained uncorrected.

The unconsolidated concrete has been repaired in accordance with established site procedures. The issue is not reportable under the provisions of 10CFR50.55(e).--Records supporting this determination are available for your inspectors to review at the CPSES sita.

Very truly yours, h(f htnhb F

W. G. Counsil By:

G. S. Keeley v

Manager,NuclearL/ censing JCH/ef MO North Olne Street

1. H. Ml Dallas. icm 75201

o.

i p."

.,.,f' i

Log # TXX-6282 E

File # 10110 903.8 3_2p - f2i Ref. : 10CFR50.55(e)

RIELECTRIC w nm. c. c--m-February 18, 1987 cm.m. ru rma,.

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk

-Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)-

DOCKET NOS. 50-445 AND 50-446 NON-CONTACT LAP SPLICES IN THE AUXILIARY BUILDING SDAR: CP-86-66 (FINAL REPORT)-

4 Gentlemen:

4 P

On September 26, 1986, we verbally notified your Mr. I. Barnes of a potential 1

deficiency regarding vertical rebar in the Auxiliary Building that apparently

.does not satisfy the criteria of an ACI code defined lap splice.

Specifically, the issue involves rebar identified during an investigation conducted in accordance with the Comanche Peak Response Team (CPRT) Issue

~

Specific Action Plan (ISAP) II.a for missing reinforcing steel. Our last-interim report ' sogged was TXX-6136 dated December 5, 1986.

Previous reports indicated the issue involved two vertical dowels and two lap splice bars which had not been installed within prescribed design locations.

One of the lap splices did not conform to ACI Code requirements for non-i contact lap splices. Consistent with our plan of evaluation, engineering calculations and the review of applicable _ quality documents have been i

completed.

In our analysis, the inactive reinforcing bars were discounted from the strength calculation. The remaining area of reinforcement bars-available was found to be greater than the area required in the original design. The design l

input'obtained from the original design is subject to confirmation in

_accordance wi.th our ongoing Corrective Action Program. This analysis, documented per calculation number 16345/6-CS(S)-076, Rev. O, has established the acceptability of the original deviation. The deviation has no adverse affects on the safety of plant operations or structural integrity of the Auxiliary Building. Therefore in the event this issue had remained undetected, no condition adverse to safety would exist.

L i

400 North Olive Street L B. 81 Dallas, Texas 75201

t TXX-6282.

February 18, 1987 q

Page 2

.o Based upon these results, we have concluded this issue is not reportable under the provisions of 10CFR50.55(e).

Records supporting this documentation are available for your inspectors review at the CPSES site.

Very truly yours, W. G. Counsil By:

G. S. Keeley

/

Manager, Nuclear L%nsing JCH/mlh c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI Region IV Mr. H. S. Phillips, RI - Region IV t

6 4

e n-.

--n

,,,,,,,,_7,.

,a

Log # TXX-6290 g2e File # 10110 P9 903.9 3

g_

Ref. # 10CFR50.55(e)

- 1UELECTRIC wai

c. cw February 19, 1987 Execunw Vite l'rrsidens U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKETS NOS. 50-445 AND 50-446 PRE-OPERATIONAL VIBRATIONAL TEST CRITERIA SDAR: CP-86-67 (INTERIM REPORT)

Gentlemen:

On September 26, 1986, we verbally notified your Mr. Ian Barnes of a potential deficiency regarding the design calculations and tests used to qualify the Pre-operational Piping Vibration Program. This is a~n interim report of a potentially reportable item under the provisions of 10CFR50.55(e). We have submitted interim reports logged TXX-6072 and'TXX-6187, dated October 27, 1986, and December 19, 1986, respectively.

The evaluation of this issue is continuing. We will provide our next report no later thar. March 19, 1987.

Very truly yours, N. $o Cl W. G. Counsil By-0

. S. Marshall Supervisor, Generic Licensing f

BSD/amb

[

c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV l

400 North Olive Street ! B. 81 Dallas. Texas 75201

f e

Log # TXX-6288 E

File # 10110 7

908.3

.=

Ref # 10CFR50.55(e) lilELECTRIC wn c.w February 25, 1987

~

Ewwns he Premlem U. S. Nuclear Regulatory Commission Attn: Document Control Desk.

Washington, D. C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 CABLE PULLING TENSION SDAR:

CP-86-71 (INTERIM REPORT)

Gentlemen:

-On October 2,1986, we verbally notified your Mr. Ian Barnes of a deficiency regarding electrical cable pulling. This is an interim report of a potentially reportable item under the provisions of 10CFR50.55(e). Our most recent interim report was logged TXX-6125, dated November 26, 1986.

Engineering has completed the preliminary report on the methodology for evaluation of the issue. Revision 1 of STIR-NRC-E-002, " Specific Technical Issue Report - Cable Tension Evaluation," incorporating third party review comments, is scheduled for issuance by February 28, 1987.

For vertical cable pulls and subsequent pulls into conduits with previously pulled cables, a comprehensive review will be performed on installed class IE cables for technical adequacy based on conduit configuration, maximum allowable cable tension and maximum sidewall pressure.

The following is a summary of our plan:

1.

Formal calculations for allowable cable tension have been completed and are currently being reviewed. After approval of the calculations, revised cable pulling charts will be issued and incorporated into the Electrical Specification (2323-ES-100).

2.

A Field Verification Methbd (FVM) will be developed to obtain conduit configuration for cables requiring engineering review.

The FVM procedure is scheduled for issuance by March 27, 1987.

3.

Cable data obtained from the walkdowns will be compared to the revised cable pulling charts for acceptability.

4.

The majority of cable tension concerns will be eliminated by the above activities. Any remaining cables will be evaluated by specific calculations or testing.

400 North Olne Street t B. 81 Dallas. Texas 75201 i

_.rm--

_.,,_,__,m_..__,..__,_x.,.._-

og' TXX-6288 y

February 25, 1987 Page 2 of 2 Scheduled completion dates for these activities and the associated evaluation for Units 1 and 2 are April 30, 1987, and August 31, 1987, respectively.

The effects of the reported deviation on the safety of plant operations will be evaluated upon completion.

We expect to submit our next report on this issue by June 19, 1987.

Very truly yours, b'h,'

W. G.

ounsil 8y:

G. S. Keeley W

Manager,NuclearLifensing WJH/dl c - Mr. Eric H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV h

si

9

" %:O

• ~

Log # TXX-6297-E File # 10110

"". "5 903.9 Ref. # 10CFR50.55(e) 1EIELECTRIC wn c.cw February 20, 1987 Emurow he hrsutron U. S. Nuclear Regulatory-Commission ATTN: Document Control Desk Washington, DC 20555

~

SUBJECT:

. COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKETS NOS. 50-445 AND 50-446 SMALL BORE PIPING AND SUPPORTS-SDAR:

CP-86-72 (INTERIM REPORT)

Gentlemen:

On June 9,1986, we verbally notified you of a reportable item involving the scope of plant modifications resulting from the project's pipe support reverification

. program (see TXX-4844).- This is a follow-up interim report on a reportable item under provisions of 10CFR50.55(e). Our latest interim report logged TXX-6207 was submitted on January 9, 1987.

The continuing engineering evaluation has not identified any additional instances which are. considered reportable pursuant _to 10CFR50.55(e). The attached list shows the support modifications issued to date. The evaluation is continuing and we anticipate submitting our next report by April 10, 1987.

Very truly yours, l

blM W. G. Counsil BSD/amb Attachment c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV 400 North Olive Street L B. 81 Dallas, Texas 75201

...TXX-6297

• =

• • - February 20, 1987 j

. Attachment Page.I'of I ATTACHMENT.

SMALL BORE PIPE SUPPORT MODIFICATIONS Number of US11

.CA1Ett1 Modifications

• 1 Prudent.

20 Recent Industry Practice 85

' Adjustment

' '174 Cumulative Effects 124 2

Prudent 3

Recent Industry Practice 17 Adjustment 48 Cumulative ~ Effects 18

• Changes in these figures from the last report represent not only identification of further modifications but a reclassification and/or recategorization of t

certain supports. Reductions in these figures from the previous report are due in part to tracking changes in the program.

4 m

]

e Log # TXX-6287 E

File # 10110 1"" 9 909.4 C.

Ref:

10CFR50.55(e)_

~

1HELECTRIC

- wa-c. c.

February 19, 1987 tm-- s.,, mim -

U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 ASCO SOLEN 0ID VALVES IN PISTON AIR ACTUATORS OF PAPC0 DAMPERS SDAR: CP-86-75 (FINAL REPORT)

Gentlemen:

On September 4,1986, we verbally notified your Mr. I. Barnes of a deficiency involving ASCO solenoid valves in piston air actuators of PAPC0 dampers.

Specifically, grease and oils used to reduce friction in the piston air actuators of PAPC0 dampers could degrade ethylene propylene diaphrams, seals and 0-rings of ASCO solenoid' valves. Our last interim report was logged TXX-6097 dated November 20, 1986.

The ethylene propylene diaphrams, seals, and 0-rings in these valves were replaced with units of Viton material per design changes issued in 1983 (DCA' 13243).

In addition, an evaluation demonstrated that failure of these seals would not adversely affect the safety of plant operations.

In the event this deficiency had remained undetected, no condition adverse to the safety of plant operations would exist. Therefore, this deficiency is not reportable under the provisions of 10CFR50.55(e). Records supporting this conclusion are available for your inspectors to review at the CPSES project site.

Very truly yours, Mc W. G. Counsil By:

G. S. Keeley

/

Manager,NuclearLiegng JDS/ef We North Olne Street I..B. El Dallas. Texas 75201

7 e

y?

y E

Log # TXX-6326 r===:

File # 10110 c

903.9

=

=

Ref. # 10CFR50.55(e) nlELECTRIC wn c.c a March 9, 1987 Emunn $kr Prendent U. S. Nuclear Regulatory Cownission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 STRUCTURAL STEEL BOLTING CONNECTIONS WITH THREADS IN THE SHEAR PLANE JN THE UNIT 1 CABLE SPREADING ROOM SDAR: CP-86-78 (INTERIM REPORT)

Gentlemen:

On November 7,1986, we verbally notified your Mr. Tom Westerman of deviations in the structural steel bolting in the cable spreading room. This is an interim report of a potentially reportable item under the provisions of 10CFR50.55(e). Our latest interim report, logged TXX-6139, was submitted on December 5, 1986.

Specifically, specification 2323-5S-168, Section 9.5, states that all field connections shall be made with high strength steel bolts in bearing type connections with threads excluded from the shear planes except where otherwise stated or shown on engineering drawings.

Instancu of bolted connections with threads in the shear plane which were not stated or shown on engineering drawings have been discovered in the Unit 1 Cable Spreading Room.

Calculations have been completed which verify the design adequacy of the Cable Spreading Room as-bitilt framing. These calculations were prepared to document the structural adequacy of connections with bolts having threads included in the shear plane. Currently, these calculations are pending final review by Stone & Webster Engineering Corporation (SWEC) and are scheduled for issue by the end of March,1987.

A Design Change Authorization (DCA) has been issued allowing threads in the shear plane of bolts for Unit 2 cable spreading room. Also, DCAs have been issued to approve the use of bolt threads in the shear plane for cable tray clamps and cable tray and conduit supports which are under the jurisdiction of this specification.

400 North Olne Mreet LH 81 Dallas, Texas 7520f

L TXX-6326 March 9, 1987 e,

Page 2 We are continuing our evaluation of bolted seismic structural and miscellaneous steel installations. Also, we are continuing our evaluation and assessment of the impact of this condition on plant safety during accidents.

We anticipate submitting our next report no later than June 4,1987.

Very truly yours, W. G. Counsil DAR:1w c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV O

9 9

)

. -o

\\

• o,,

E Log # TXX-6316 P9 File # 10110 1

2 903.9 r

Ref. # 10CFR50.55(e) illELECTRIC March 9, 1987 Lwunvr s ur Preu.kort Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D, 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 FISHER CONTROL VALVES SDAR: CP-87-02(FINALREPORT)

Gentlemen:

On February 6,1987 we verbally notified your Mr. I. Barnes that an evaluation of equipment supplied by Fisher Controls would be performed to assure that two anomalies identified by the vendor do not create conditions adverse to the safety of' plant operations.

Fisher Anomaly Notice (FAN 86-1) was issued December 17, 1986 involving sliding stem globe valves with Limitorque motor actuators. The problem as described by Fisher is that under highly unusual circumstances, it may be possible for the actuator power stem to disconnect itself from the valve stem.

Our evaluation of this anomaly has resulted in the identification of ten (10) valves which are installed at CPSES which meet the above criteria. Six (6) of these valves are installed in the ventilation chilled water system, are non-safety related, and have been excluded from the evaluation.

Four (4) valves (two each in Units 1 and 2) are installed in the containment spray system. As a result of the design installation configuration and the ongoing motor-operated valve program established in accordance with IE Bulletin 85-03, no additional corrective action is necessary. Our Engineering evaluation has concluded that had this item remained uncorrected, it would not have affected the safety of plant operations and is not reportable per 10CFR50.55(e).

The engineering review of Fisher Anomaly Notice (FAN 86-2) which affected Fisher valves type 1073 through 1076 manual actuators has been completed. Our evaluation concluded that CPSES does not have any of these valves installed in safety related systems. Therefore, this notice is not applicable to CPSES and not reportable per 10CFR50.55(e).

400 North Olne Street t.H Ml Dall.a. Tem 75201

TXX-6316 i

o March 9,~1987 i$.= Pag] 2' Records supporting these evaluations are available for your inspectors review at the'CPSES site.

Very truly yours, 7,M W. G. Counsil DAR:1w c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV

\\

b

.4 e

an B

i mi ni iimii

1&

go Log # TXX-6334 l"" ".

File # 10110

..=

908.3 l

C C

'Ref f 10CFR50.55(e)

RIELECTRIC

$UjdY,am, March 16, 1987 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 6.9 KV SWITCHGEAR INSTALLATION SDAR: CP-87-03 (FINAL REPORT)

Gentlemen:

On February 13, 1987, we verbally notified your Mr. I. Barnes of a deficiency involving the installation of the safety-related 6.9kV Switchgear on structural embedmonts which were not level. We are reporting this issue under the provisions of 10CFR50.55(e) and the required information follows.

DESCRIPTION Pre-Operational testing.for the Unit Two safety-related 6.9kV Switchgear revealed construction deficiencies involving the structural embedments and concrete floor supporting the switchgear. The equipment manufacturer (Brown Boveri) expanded on the scope of the deficient installation by letter on September 5, 1986. Due to the structural embedmonts and concrete floor not being level, the switchgear was not installed on a level surface.

Resulting gaps between the switchgear and the floor could cause the metal floors to distort because of breaker weight, which could cause a change in the dimensional relationship between the 6.9kV breaker tulip:. and the 6.9kV cabinet stabs and, therefore, inadequate contact.

The switchgear, as initially installed, failed to conform to the manufacturer's installation specifications and therefore would not meet the criteria used for the equipment's seismic qualification. However, further equipment qualification will not be required since the reworked instaliation will meet the original manufacturer's installation specifications.

The scope of this issue includes both Unit One and Unit Two 6.9kV Switchgear.

SAFETY IMPLICATIONS In the event these construction deficiencies had remained uncorrected, the performance of the safety-related 6.9kV Switchgear could not be assured under normal operating and accident conditions.

400 North Olne Street I..it 81 Dallas. Texas 75201

i

[kw go TXX-6334 March 16, 1987 Page 2 of 2 CORRECTIVE ACTION The corrective action for this issue will include disconnecting and removing all cables from the safety-related 6.9kV Switchgear, followed by the' removal of the switchgear from the structural embedmonts. After the switchgear is removed, the concrete floor and structural embedmonts will be reworked in accordance with site issued Design Change Authorizations. After verification of floor levelness is complete, the switchgear will be reinstalled and attached in accordance with the vendor's (Brown Boveri) requirements. After cables have been terminated, the switchgear will undergo Pre-Operational y

testing. The reinstallation and testing of the safety-related 6.9kV

?.

Switchgear is scheduled for completion by November 21, 1987.

The scope of this issue has been expanded to include corrective actions associated with SDAR CP-86-14, "6.9 kV Switchgear Breaker Jack Shaft Wald Failure" (See TXX-6341 of March 16,1987).

Very truly yours, W. G. Counsil WJH/dl f

c - Mr. E. H. Johnson - Region IV Mr. D. L. Kelley, RI - Region IV Mr. H. S. Phillips, RI - Region IV i

i e8 0

4

/