ML20211K617
| ML20211K617 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1981 |
| From: | Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Reinmuth G NRC |
| Shared Package | |
| ML20011C460 | List:
|
| References | |
| FOIA-86-656, REF-QA-99900334 NUDOCS 8612120152 | |
| Download: ML20211K617 (4) | |
Text
. . _ . . _..-- - . - _ - - - ._- -..-._ __ --. - . ..- -. _
/
I
... ,, . SE Mg. Lgg4; ..
,p ,
- iean 4
- .% ', y:. p
. .:hy . i 2
1 -r. . ' u..; - ys4;
2 e.- . - .O k.
- . g j el j$ % -
, *'. 'QE
. & i b % :{ { .;
we
- me n w o m r e j'. vi h inmuth,7 ms'er;
. n . h u u: w -
-v > . K.
,PRM ".$1dfs Petepers. tijfef?hv.]a y .Insp M Drench. It'tW V
. ., x .
. .- y .:
l
SUBJECT:
DFRtFER WELDIE SY TRARBMERI'CA MUNE. IRCWpSATED W ASME pip!NG SUPPLIED TO Wpp55: W P-1/4 (A!15 50.' M 0)
A Site inspection was performed at Transamerica Delaval Incorporated en October 14-17,1980, which included the subject Angton V A!13 Item in the scope of the 1 inspection. The results of the inspection are discussed la the attached Inspection Report (99900334/80-01) and this item has not been closed by the Vendor Inspec-tion Branch.
It is apparent fetss' the reported findings that effective -ections have not been taken by Transamerica Delaval Inc. to correct the inspection and manufacturing process control inadequacies in their ASME fabrication area, which led to the shipment to Wpp5S of deficient piping assemblies. Accordingly, the presence of similar weld defects in diesel ponerator piping assemblies at other nuclear sites cannot be precluded. We wou ld therefore recommend that eensideration i be given to either issue of an IE Cirt:ular en the subject or initiation of Reglenal followup inspections at sites with Transamerica Ontaval diesel generators.
t pleasecontactMr.I.Barnes(334-2846) if you have any questions en this subject or need additional inforuntion.
Original Signed Ey:
, - .., s @ iLIM " !*mre - m
'UldtsPotapers'IonBranch thief '-
t -
Bander Inspect -
es: Acan Branch Chiefs 's --
RI. RII. RIII. RIV. RV y I
8612120152 861203 e PDR FOIA ~
ELLIS96-656 PDR D/M omcc) .. 81 YAP.llidm W. . . ..g.... . ............... ......... . ... .. .
som.c)..f.os.ter.I. .. ...18ar.nes.... . . .UP.o tapovs. . .. .WEV e r. . . .... . .... . . . ~ .
onc > . .1./1928.1. . . . . .11/.1/81.. . . 1/. T.81. . . . . . . . /. . . /81. . . . . . .. . . . . .... .
. i kkJL: W Docket No. 99900334/80-01 l
l Transamerica Delaval Incorporated Engine and Compressor Division Attn: Mr. D. H. Martini Vice President and General Manager 550 85th Avenue Oakland, California 94621 Gentlemen:
This refers to the reactive and QA Program inspection conducted by Mr. W. E. Foster of this office on October 14-17, 1980, of your facility at Oakland, California, associated with the manufacture of diesel generators and to the discussions of our findings with you and members of your staff at the conclusion of the inspection.
This inspection was made to confim that, in the areas inspected, your program is effective in responding to identified problems and your QA Program is effectively implemented. The inspection effort is not designed to assure that unique quality requirements imposed by a customer are being implemented; nor to assure that a specific product, component or service provided by you to your customers, is of acceptable quality. As you know, the NRC requires each of its licensees to assume full responsibility for the quality of specific products, components or services procured from others. You should therefore not conclude that the NRC's inspection exengts you from inspections by an NRC licensee or his agents nor from taking effective corrective action in response to their findings.
Areas examined and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination of procedures and representative records, interviews with personnel, and observations by the inspector.
During the inspection it was found that the effectiveness of your response to identified problems and your QA Program implementation failed to meet certain NRC requirements. The specific findings and references to the pertinent require-ments are identified in the enclosures to this letter.
l l The Notice of Violation is sent to you pursuant to the provisions of 10 CFR 2.201. You are required to submit to this office within twenty-five days of your receipt of this report, a written statement containing. (1) a description of steps that have been or will be taken to correct these items. (2) a descrip-tion of steps that have been or will be taken to prevent recurrence, and (3) the dates your corrective actions and preventive measures were or will be completed ,
O L6\* ct89 iop dVM l
,,h , [ ,, ggf), ', '
o,,,CE ). RIV/WPU/dm , , ,,
SURNAMEk. ... . /. . .. . . .. - . . . .. .
oaTc).1/1/.19/Bl... .1/N./81. . . lfl.I/.81. ..1/h/81..Q .. . .
D U.S. GOVERNMENT PRINTING OFFICE: 1979-289 369
.. _. - . NRC FORM
. ,_ ,___. 318_(9. . 7 6 ) N R CM O2 4 0_ _ . _ _ _ _ , . _ _
Transamerica Delaval Incorporated 2 You are also requested to submit a similar written statement for each iten which appears in the enclosed Notice of Deviation.
In accordance with Section 2.790 of the Comadssion's " Rules of Practice,"
Part 2 Title 10, Code of Federal Regulations, a copy of this letter with enclosure and your reply, together with the enclosed inspection report will be placed in the Commission's Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within thirty (30) days to this office to withhold such infomation from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the informa- 1 tion is proprietary, and should be prepamd so that proprietary infomation l identified in the application is contained in a separate part of the document. 1 If we do not hear from you in this mgard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, g9 3,";pse Uldis Potapovs. Chief Vendor Inspection Branch
Enclosures:
- 1. ilotice of Violation
- 2. Notice of Deviation
- 3. Inspection Report No. 99900334/80-01 bec:
AD/RCI (Reinmuth)
IE FILES NRR:DPM:QAB REG. I, II, III & V PDR HQS CENTRAL FILES WEVETTER, RIV ASME NBB&PVI
o Transamerica Delaval Incorporated Engine and Compressor Division Docket No. 99900334/80-01 NOTICE OF VIOLATION As a result of the inspection conducted on October 14-17, 1980, and in accor-dance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following violation was identified:
Paragraph 21.51 of 10 CFR 21 requires that: (1) "Each licensee of 'a facility or activity subject to the regulations in this part shall main-tain such records. . . as may be required to assure compliance with the regulations in this part;" and (2) "Each individual, corporation, partner-ship, or other entity subject to the regulations in this part shall pre-pare records in connection with the design, manufacture, fabrication. . .
inspection, or testing of any facility, basic component supplied for any licensed facility or to be used in any licensed activity sufficient to assure compliance with the regulations in this part. After delivery of the facility or component and prior to the destruction of the records relating to evaluations. . .or notifications to the Commission. . .such records shall be offered to the purchaser of the facility or component."
Bechtel Power Corporation Purchase Order No. 9645-M-018.0, Revision 13, dated January 17, 1978, invoked 10 CFR Part 21.
Contrary to the above, records had not been maintained with respect to fractured thermostatic control valves in Grand Gulf Unit 1 emergency diesel generators, to indicate that:
- 1. An evaluation had been conducted in accordance with 10 CFR Part 21 requirements.
- 2. Actions had been taken to identify whether the product deviation contributing to the valve fractures, i.e. improper use of raised face flanges in connecting piping, was present in equipment supplied to other customers. See DetailsSection I, paragraph B.4.b.
This is a Severity Level IV violation (Supplement II).
l l
l L
l D
iP -
)
- )
o Transamerica Delaval Incorporated Engine and Compressor Division Docket No. 99900334/80-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted on October 14-17, 1980, it appears that certain of your activities were not conducted in accordance with NRC requirements as indicated below:
Criterion V of Appendix B to 10 CFR 50 states: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or draw-ings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Deviations from these requirements are as follows:
A. Section 10, dated June 30, 1979, of the Quality Control Manual, contains the following requirements:
- 1. Paragraph 10.6.4 states, "New tools and gages will be identified with a tool and/or Gage Tryout Tag (Quality Control Form P-270). This is a temporary tag reflecting the fact of dimensional acceptance of the tool and/or gage. The temporary tag is removed and replaced with the calibration decal after the tool and/or gage accurately produces or accepts a first part."
- 2. Paragraph 10.6.5 states, "All gages and equipment will be identified by Company name, gage or equipment name, part and/or serial number, as applicable."
Contrary to the above, the gage used to measure, accept / reject the diameter and depth of the link rod dowel counterbore had not been identified with: (1) A tool and/or Gage Tryout Tag; (2) A calibration decal; or (3) Company name, gage or equipment name, part and/or serial number, as applicable; although the gage has been in use since February 1980.
B. Paragraph 7.1.1 in Section 7 of Quality Control Procedure I.P.-700 states in part, ". . . Quality Engineering will process Corrective Action Request Form P-260 when required by any of the following conditions: . . 7.1.1.6 Internal and external failures to meet contract requirements."
4 ee _
s
~
2 Contrary to the above, Quality Engineering did not process.a Corrective Action Request Form with respect to customer identified Transamerica Delaval (TD) failures to meet weld quality contract requirements in ASME Section III Class 3 diesel generator piping (See DetailsSection II, para-graph B.4.a.(1)).
C. Paragraph ND-5521(a)(2) in Section III of the ASME Code states, "The procedure (s) used for examination of Level I, II, and III nondestructive examination personnel shall be described in the Employer's written practice which is required by SNT-TC-1A, paragraph 5 and shall be referenced in the Employer's Quality Program." Paragraph ND-5521(a)(6) states, "For non-destructive examination methods not covered by SNT-TC-1A documents, per-sonnel shall be qualified to comparable levels of competency by subjection to comparable examinations on the particular method involved."
Contrary to the above:
- 1. The TD written practice (Section 4 of Quality Control Procedure I.P.
-600, " Qualification-Certification of NDE Personnel") did not de-scribe the procedure (s) used for examination of Level III nondestruc-tive examination personnel.
- 2. Personnel performing ASME Section III, Subsection ND and NF required visual examinations, had not been qualified by being subjected to an examination of comparable standard to methods covered by SNT-TC-1A documents.
D. Paragraph ND-4321(a) in Section III of the ASME Code states, "Each Certi-ficate Holder is responsible for the welding done by his organization and he shall establish the procedure and conduct the tests required by this Article and by Section IX in order to qualify both the welding procedures and the performance of welders and welding operators who apply these procedures." Paragraph ND-4323 states in part, ". . .Only welders and welding operators who are qualified in accordance with ND-4320 and Section IX shall be used."
Contrary to the above: -
- 1. Shielded metal arc welding of a six (6) inch Schedule 40 ASME Section III Class 3 piping assembly (Shop Engine No. 2931, Shop Order No. 94302, Part No. 02-717-02 YR, Item F to Item F) was observed being performed in the vertical up position (3G), al-though the welder had been qualified in accordance with ASME Section IX requirements for the flat position (1G) only.
3
- 2. Shielded metal arc welding was identified to have been performed on a two (2) inch ASME Section III Class 3 piping assembly (Part No.
02-717-02 YE) by a welder who had been qualified in accordance with ASME Section IX requirements only for pipe outside diameters of 2 7/8 inch (2 1/2 inch nominal pipe size) and over.
(See DetailsSection II, paragraph B.4.a.(3)).
E. Paragraph 5.5.4 in Section 5 of Quality Control Procedures I.P.-500 states in part, " Rod shall be issued from the storage area to the welder. The welder will return unused rod to the storage area within four hours of issuance. . . ."
Contrary to the above, unused rod was not being returned to the storage area within four hours of issuance, as evidenced by the following examples:
- 1. On October 11, 1980, rods were returned by three (3) welders after respective issue times of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> 55 minutes, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 20 minutes and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 30 minutes.
- 2. On October 14, 1980, rods were returned by a welder after an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> issue time.
F. Paragraph 4.2.4 in Section 4 of Quality Control Procedure I.P.-500 states,
" Verification of weld procedure and welder will be accomplished by pro-viding space on the Route Sheet for entrance of the weld procedure number and welder identification. Records of each weld including welding and weld rod, will be provided by the Weld Report."
Contrary to the above, although space was provided on the Route Sheet for welder identification, verification of the use of certain welders could not be accomplished, in that:
- 1. Welding of Item F to Item F, Shop Engine No. 2931, Shop Order No.
94302, Part No. 02-717-02YR, was observed being performed by a different welder than the individual identified on the Route Sheet.
- 2. Welding on Operation 140 of the Route Sheet for Shop Engine No.
2957, Shop Order No. 94583, was observed being performed by a different welder than the individual identified on the Route Sheet.
- 3. Welding records were not provided, in that Weld Reports had not been prepared as of the inspection for the operations observed.
(See DetailsSection II, paragraph B.4.a.(5)).
G. Paragraph 10.3.2 in Section 10 of Quality Control Procedure I.P.-500 states in part, "All in process and completed components, parts or piping
i 4
subassemblies found to be defective will be immediately rejected and documented on an Inspection Report and placed in Bond. The Material Review Board will review all defective components, parts or piping sub-assemblies . . . ."
Contrary to the above:
- 1. A defective weld (Item F to Item F, Shop Engine No. 2931, Shop Order No. 94302, Part No. 02-717-02YR) was removed and replaced without rejection and documentation on an Inspection Report.
- 2. Disposition was made by Quality Control supervision of a dimensional nonconformance in Shop Engine No. 2931, Shop Order No. 94749, Part No. 02-540-07-B7, without submission of the Inspection Report to
, the Material Review Board for review.
H. Paragraph 11.2 in CF Braun & Co. Project 4840-P Specification 164-03 states in part, ". . . Fillet welds shall be of the specified size with full throat and legs of uniform size. . . . "
Drawing 02-540-0787, Revision D requires the weld of Item A to Item B (Roof to Sidewall Joint) of the Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment to be a single full penetration weld with 1/4 inch fillet.
Contrary to the above, the identified weld was observed to contain an area with less than a 1/4 inch fillet resulting from a fitup condition where the tank roof and sidewall were almost flush.
(See DetailsSection II, Paragraph B.4.a.(7)).
i I. Paragraph 4.3.1 in Section 4 of Quality Control Procedure I.P.-500 states, "All components, parts and piping subassemblies manufactured in accordance with ASME Section III, Class 3 will be inspected during the process of fabrication after each manufacturing operation is complete. The item
, will be examined for adherence to specification for each individual characteristic affected by the operation. If the item is acceptable at the operation inspected, the inspector will enter his inspection stamp in the space provided on the Production Routing Sheet."
Contrary to the above, performance of required inspections for completed Operation Nos. 10 through 130 on the Production Route Sheet for the Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment could not be
- verified; in that neither inspection acceptance stamps had been entered for the operations on the Production Route Sheet, nor had Inspection e Reports been prepared to denote a rejected condition after inspection.
(See DetailsSection II, paragraph B.4.a.(8)).
l 4
l 4
-,,,-n en , , . , . - - - - - - - - - - - - - - - - -- - - - , - - - - - - - - - - - - - - - -- -
l l
~ l U. S. NUCLEAR REGULATORY COPMISSION l l
OFFICE OF INSPECTION AND ENFORCEMENT
. REGION IV
- Report No. 99900334/80-01 Program No. 51300 51400 Company
- Transamerica Delaval Incorporated Engine and Compressor Division 550 85th Avenue Oakland, California Inspection Conducted: . October 14-17-1980
, Inspectors: -
Nw * /e 9 h e 70 W. E. Foster, Contractor Inspector Date ComponentsSection II Vendor Inspection Branch W S ~ .a shs/es I. Barnes, Chief Date
! ComponentsSection II Vendor Inspection Branch Approved by: I 8u~., s / '7/n I. Barnes, Chief Date ComponentsSection II Vendor Inspection Branch
. Summary:
Inspection on October 14-17, 1980 (99900334/80-01) ,
l Areas Inspected: Implementation of 10 CFR 50, Appendix B criteria, and applic-able codes and standards; including follow-up on regional requests; and follow-up on a Part 21 report. The inspection involved forty-two inspector-hours on
~
site by two NRC inspectors.
. Results: In the three areas inspected, the following violation, nine deviations, and two unresolved items were identified:
3 i
k
- 81c(,ilo M 3 Mg. ,
2 Violation: Follow-up on regional requests practice was not consistent with paragraph 21.51 of 10 CFR 21 (See Notice of Violation).
Deviations: Control of Measuring and Test Equipment: Practices were not consistent with Criterion V of Appendix B to 10 CFR 50, paragraphs-10.6.4 and 10.6.5 of Section 10, dated June 30, 1979, of the Quality Control Manual I (See Notice of Deviation, Item A).
Follow-up on Identified Deficiencies in Diesel Generator Piping Welds: Prac-tices were not consistent with Criterion V of Appendix B to 10 CFR 50; paragraph 7.1.1 of Section 7 of Quality Control Procedure I.P.-700 (See Notice of Deviation, Item B); paragraph ND-5521(a), subparagraphs (2) and (6) of Section III of the ASME Code (See Notice of Deviation, Item C); paragraphs ND-4321(a) and ND-4323 of Section III of the ASME Code (See Notice of Deviation, Item D);
paragraph 5.5.4 of Section 5 of Quality Control Procedure I.P.-500 (See Notice of Deviation, Item E); paragraph 4.2.4 of Section 4 of Quality Control Pro-cedure I.P.-500 (See Notice of Deviation, Item F); paragraph 10.3.2 of Section 10 of Quality Control Procedure I.P.-500 (See Notice of Deviation, Item G);
paragraph 11.2 of C.F. Braun and Company's Specification 164-03 and drawing number 02-540-0787, Revision D (See Notice of Deviation Item H); and paragraph 4.3.1 of Section 4 of Quality Control Procedure I.P.-500 (See Notice of Deviation, Item I).
Unresolved Item: Part 21 Report Follow-up: Inspection Form and Attendant Rework Tag did not indicate inspection of rework (DetailsSection I, paragraph D. 4.c).
Follow-up on Regional Requests: Battery rack seismically tested subsequent to the dates identified in the Seismic Report (DetailsSection I, paragraph B.4.d).
l l
l l
l
)
l
i 3
DETAILS SECTION I (Prepared by W.E. Foster)
A. Persons Contacted
- R. E. Boyer, Manager, Quality Assurance
- D. R. Cady, Manager, Quality Engineering (NDE)
- B. Durie, Manager, Customer Services K. Kropf, Supervisor, Quility Control
- D. H. Martini, Vice President and General Manager A. Nance, Engineer, Quality G. Spease, Senior Engineer, Quality
- G. E. Trussell, Manager, Engineering
- E. H. Wilson, Manager, Manufacturing
- Attended Exit Interview B. Follow-up on Regional Requests
- 1. Background
- a. Mississippi Power and Light reported a diesel generator jacket water thermostatic control valve problem to the Office of Inspection and Enforcement, Region II. The problem was revealed during purge testing at Grand Gulf, Unit 1 and identified as a fracture in the valve body.
- b. Duke Power Corporation reported a diesel generator battery rack problem to the Office of Inspection and Enforcement, Region II.
The battery racks at Catawba 1 and 2 were determined to be seis-mically unqualified. The battery racks were manufactured by Nife, Incorporated, but supplied by Transamerica Delaval Incorporated -
Engine and Compressor Division.
- c. Mississippi Power and Light reported damaged generator stator coils, at Grand Gulf 1, to the Office of Inspection and Enforcement, Region II.
- 2. Objectives The objective of this area of the inspection were to verify that adequate corrective actions and preventive measures had been taken, and generic considerations had been assessed regarding the problems addressed in paragraph B.1.
l
. I 4
- 3. Methods of Accomplishment The preceding objectives were accomplished by:
- a. Reviewing the following documents to verify the objectives had been satisfied:
(1) Transamerica Delaval Incorporated - Engine and Compressor Division's Letters -
(a) Dated August 29, 1980; to Bechtel Power Corporation, Attention: Mr. A. Zaccaria;
Reference:
Bechtel Request on Corrective Action For Thermostatic Valves, (b) Dated August 8, 1980; to Bechtel Power Corporation, Attention: Mr. A. Zaccaria;
Subject:
Failure of Thermostatic Control Valve Body, (c) Dated June 30, 1980; to Duke Power Company, Attention: Mr. Tom Webb,
Subject:
Catawba Nuclear Station Units 1 and 2, (d) Dated July 11, 1980; to Bechtel Power Corporation;
Subject:
Damaged Generator Stator Coils, and (e) Dated July 10, 1980; to Bechtel Power Corporation;
Subject:
Damaged Diesel Generator Coils.
(2) Power Conversion Products, Incorporated letter, dated September 3,1980, to Transamerica Delaval, Attention:
Karen Orr,
Subject:
Duke / Catawba Battery Rack Replacement.
(3) Power Conversion Products, Incorporated TWX, dated August 25, 1980, to Transamerica Delaval, Attention:
Karen Orr,
Reference:
Battery Racks.
(4) Transamerica Delaval Incorporated-Engine and Compressor Division's TWxs-(a) Dated August 25, 1980, to Duke Power, Attention:
J. Voglewede,
Subject:
Catawba Standby Diesel Generator Battery Racks, (b) Dated August 11, 1980, to Power Conversion Products, Attentiori: Don Ogden,
Reference:
Transamerica Delaval P.O... Duke Catawba,
n 5
(c) Dated August 1980, to Power Conversion Products, Attention: Don Ogden,
Reference:
Transamerica Delaval P.O... Duke Catawba, (d) Dated July 14, 1980, to Duke Power, Attention:
Joe Voglewede, Tom Webb,
Subject:
Battery Racks, and (e) Dated July 7, 1980, to Duke Power, Attention:
. Tom Webb,
Subject:
Battery Racks-(5) Duke Power Company Memo to File: CN-1301.00,
Subject:
Battery Racks, By: J. P. Voglewede.
(6) Drawings, Nos.
(a) 101776, Revision G, dated July 1, 1980, entitled -
Jacket Water System Assembly, (b) 02-717-01-ES, Revision A, dated October 12, 1976, entitled-Pipe, Jacket Water By-Pass, Amot Valve to Cooler, (c) 02-717-01-FB, Revision B, dated May 17, 1977, entitled Pipe (Jacket Water Pump to Amot Valve),
(d) 02-717-01-EQ, Revision A, dated October 12, 1976, entitled Pipe, J. W.- Amot Valve to Cooler Inlet, (e) 64-12305, Revision 1, dated August 26, 1980, entitled, Battery Rack for PCP for 92 cells MDP24 and (f) Source Inspection Report for P.O. No. 62651. . . at Nife, Inc. for. . 4 sets Battery Racks.
- b. Reviewing Bechtel's Release Form No. G-321, dated September 15, 1977 for Jacket Water and Lube Oil Heat Exchangers and Piping to verify the equipment had been released for shipment.
- c. Reviewing Bechtel Power Corporation's Purchase Order No. 9645-M-018.0, Revision 13, dated January 17, 1978, to verify that 10 CFR 21 had been invoked regarding the thermostatic control valves.
- d. Reviewing Structu,al Dynamics Research Corporation's Seismic Qualification Report No. 1532-1, Dated January 1 to March 30, 1979 to determine the results of battery rack test.
J l
l 6
- e. Reviewing Purchase Materials Specification Revision B, dated January 25, 1977, for Part No. 75017-116, Battery Rack and Accessories from Nife, Inc. to determine the requirements for source inspection.
- f. Reviewing Purchase Material Specification, dated July 28, and
' November 5, 1975, for Part Nos. 74033-101 and -102, Generator,
' Exciter and Voltage Regulator to determine the requirements for source inspection.
- 4. Findinas
- a. Comments i
(1) The jacket water thermostatic control valves were manufactured by Amot, utilizing a cast iron valve body material. Available records indicated that: (a) incorrect flanges had been instal-led (on pipe spools), (b) the incorrect flanges had been replaced with correct flanges and (c) cause of failure had been variously ascribed in correspondence to be indeterminate, resulting from use of incorrect piping flanges, or a combina-tion of incorrect piping flanges and imposition of abnormal stresses on the valve bodies by site erection and test personnel. Discussions with the QA Manager revealed that Bechtel would purchase replacement valves.
(2) The battery rack selected for the seismic test failed during the initial excitation of the set-up. The battery l rack was successfully tested after rework. In the meantime, three battery racks had been shipped to the site. Four new battery racks were manufactured, source inspected by Transamerica Delaval and a Duke Power Company repre-sentative, and will be shipped to the site. A current order for the Cherokee Nuclear Station required supplying batteries, battery chargers, and battery racks. Work is in progress ;
to delete these items from the order.
, (3) It appears that damage to the generator stator coils occurred l at the site. The generator on which the damage was observed, j
- had been subjected to source inspection; however, available !
records were not definitive regarding visual inspection. The damaged stator is to be returned to the manufacturer (Electric
- Products) for rewind.
- b. Violation According to available records and discussions with cognizant personnel, circumferential fractures at the valve flange had been
- found in two Grand Gulf cast iron jacket water thermostatic control valves. Transamerica Delaval investigation finally ascribed the failures to be a result of combination of imposition of abnormal j
i
, . w,,.-. , , . _ . _ , , , , ,,,,,,-,_-,,__.,,.n__n - ~ . , , - . _ . . -
....,..,,,,,,-,--_--._,_.n,,.. _ -
. i 7
stresses on the valve body by site erection and test personnel and installation by Transamerica Deleval of incorrect flanges on the connecting piping spools. Raised face flanges were identified to have been installed on the spools and not the flat face flanges required by the applicable drawing. Connection of these flanges with the valve flat face flanges would result in deflection of the valve flanges and consequent fracture of the non-ductile valve material. In response to questions by the inspector, it was ascer-tained that torque instructions had not been provided to site per-sonnel.
No records were available to indicate that this deviation from drawing requirements had been evaluated under 10 CFR Part 21.
Three other users were identified during the inspection where installation of raised face flanges may possibly exist; i.e.
(1) Long Island Lighting, (2) Southern California Edison and (3)
Tennessee Valley Authority (Bellefunte). None of these customers had been notified as of the inspection with respect to verification of flange type used on piping spools.
See Notice of Violation
- c. Deviations From Commitment None
- d. Unresolved Item The Structural Dynamics Research Corporation's (SDRC) Seismic Qualification Report No. 1532-1, dated January 1 to March 30, 1979, indicates the battery rack (Section V.19) was tested June 12, 13, 1979.
Additionally, Transamerica Delaval Incorporated-Engine and Compressor Division's Seismic Certificate of Compliance for this report is dated July 19, 20, 1979.
As a result of the discrepancies in dates, the NRC inspector was unable to determine whether or not acceptance of the Seismic Report included the battery rack.
C. Control of Measuring and Test Equipment
- 1. Objectives The objectives of this area of the inspection were to verify that measures had been established to assure that tools, gages, instru-ments, and other measuring and testing devices used in activities affecting quality had been properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits.
8 .
- 2. Methods of Accomplishment The preceeding objectives were accomplished by:
- a. Reviewing the following documents to verify the objectives had been satisfied:
(1) Quality Control Inspection Procedures, No. I. P. 100, dated June 30, 1979, entitled- Calibration Manual, (2) Quality Control Manual, Section 10, dated June 30, 1979, entitled- Calibration of Measuring and Test Equipment, and (3) Quality Assurance Manual, Section 12, dated September 30, 1980, entitled- Control of Measuring and Test Equipment.
- b. Observing the link rod dowel counterbore gage and a demonstra-tion of its use.
- 3. Findings
- a. Deviation From Commitment See Notice of Deviation, Item A
- b. Unresolved Item None D. Part 21 Report Followup
- 1. Background Transamerica Delaval's Engine and Compressor Division filed a 10 CFR Part 21 report on September 19, 1980, regarding a potential problem in the link rod assembly of diesel generators manufactured by them. The potential defect is that the dowel counterbore in the link rod may be too shallow and cause link rod bolt failure and i
result in failure of the diesel generator.
- 2. Objectives The objectives of this area of the inspection were to verify that:
(1) the report accurately described the problem and satisfied the reporting requirements; (2) the problem had been evaluated as required; (3) the generic implication had been assessed; and (4) the stated corrective action is appropriate, adequate and implemented or planned.
l
. I g
- 3. ' Methods of Accomplishment The preceding objectives were accomplished by:
- a. Reviewing the following Transamerica Delaval Incorporated -
Engine and Compressor Division's letters and an attachment-Transamerica Delaval Service Information Memo No. 349-to verify that customers had been notified and had been provided instruc-tions for detecting the potential problem; all letters were dated September 22, 1980, while the Service Information Memo was dated September 18, 1980:
(1) Mill Power Supply Company, Attention: Project Manager-Catawba Nuclear Station,
Subject:
S/N 75017-20, DSRV-16, (2) Washington Public Power Supply System, Attention: Mr. J. P.
Thomas,
Subject:
Engine S/N76031/32,
- (3) Mississippi Power and Light Company, Attention
- Mr. N. L.
Stampley,
Subject:
Engine S/N 74033/36 and (4) Tennessee Valley Authority, Attention: Mr. C. A. Chandley,
Subject:
Engine S/N 77032/35.
)'
- b. Reviewing Customer Service Reports, dated September 15-21, 1980 and May 22-28, 1980 (sic), regarding inspection of Engine S/Ns 75041 and 75042 located at the San Onofre Nuclear Generating Station to verify that the stated corrective action is underway.
- c. Reviewing Inter-0ffice Correspondence, dated September 18, 1980, i To: G. E. Trussell, From: R. A. Pratt, to verify that the 4
problem had been evaluated.
- d. Reviewing the following drawings to verify that the report accurately described the problem:
(1) No. 02-340-03BD, Revision E, dated August 12, 1980, entitled-Connecting Rod Link, I
(2) No. 02-340-01-0C, Revision E, dated August 12, 1980, entitled-Link Rod Pin, and (3) No. 08-340-01-AD, Revision B, dated August 15, 1980, 4 entitled-Dowel Link Rod to Pin.
1
- e. Observing the lin% rod in the machine shop for familiarization with the hardware and a better definition of the suspected area to verify that the report accurately described the problem, i
i
- - . - - , - - - - - ,, , , _ . - , - - . - - - - . - - , - - - , . .,- ,-, -, - , - _ , - - . - - , . _ , , - _ - - - - _n - -
. t 10
- f. Reviewing the following documents in the Machine Shop, to verify that preventive measures had been implemented:
(1) Inspection Form No. P-262 for Link Rod Assembly, Part No.
1A-6283, (2) Production Routing Sheet, Revision 06, dated February 13, 1980, for Part No. 1A-6283, and (3) Rcwork Tag No. R-0959, dated June 13, 1980, on five Link Rods, Part No. 1A-6283.
- g. Observing a demonstration in the Machine Shop, of the gage which was developed to measure, accept / reject the link rod dowel counterbore.
- 4. Findings
- a. Comments Customers had been notified and had been provided with instruc-tions for determining whether or not the dowel counterbore was too shallow in the link rod. In an effort to preclude recurrence, (1) affected drawings had been revised to depict decimalized dimensions, (2) a gage had been developed to measure the dowel counterbore, and (3) one-hundred percent inspection is being conducted on the dowel counterbore during manufacture.
- b. Deviations From Commitment None
- c. Unresolved Item An Inspection Ferm, P-262, uncated, located in the Machine Shop, for Link Rod Assembly, Part No. 1A-6283, indicated that five items had failed the 1.3777/1.3772 diameter and 7/8 inch depth and required rework. The form did not indicate that rework had been accomplished. Rework Tag No. R-0959 indicated the dowel counterbore was shallow and required rework to drawing.
The tag reflected a completion date of July 25 (?), 1980, with a space for inspection acknowledgement, but no name, initials, stamp or number, had been entered.
As a result of the foregoing, the NRC inspector was unable to determine whether or not the counterbore had been satisfactorily reworked.
11 E. Exit Interview
- 1. The inspectors met with management representatives denoted in para-graph A. at the conclusion of the inspection on October 17, 1980.
- 2. The following subjects were discussed:
- a. Areas inspected,
- b. Violation identified.
- c. Deviations identified,
- d. Unresolved Items identified.
- e. Contractor response to the report.
The contractor was requested to structure his response under headings of corrective action, preventive measures, and dates for each deviation.
Additionally, management representatives were requested to notify the Commission in writing if dates require adjustment, commitments require modification, etc.
- 3. Management representatives acknowledged the comments made by the inspectors.
1
- t 12 DETAILS SECTION II (Prepared by I. Barnes)
Persons Contacted A.
R. E. Boyer, Manager, Quality Assurance D. R. Cady, Manager, Quality Engineering B. Followup on Identified Deficiencies in Diesel Generator Piping Welds
- 1. Background Improper welding by Transamerica Delaval (TD) of diesel generator ASME Section III Class 3 piping furnished to the WPPSS Units 1 and 4 facility was identified in early 1979, with subsequent transmittal of Nonconformance Reports to TD by United Engineers and Constructors (UE&C) on April 3, 1979. The reported deficiencies included:
arc strikes, excessive undercut, lack of fusion, lack of penetra-tion, excessive penetration, undersize socket welds and porosity.
The identified deficiencies were subsequently resolved by return to TD of subassemblies containing unacceptable welds for performance of required repair and rework.
- 2. Inspection Objectives The objectives of this area of the inspection were to review the nature and scope of the reported deficiencies and determine any generic implications.
- 3. Method of Accomplishment The preceding objectives were accomplished by:
- a. Review of UE&C Specification No. 9779-53, Division 17, Section 17A, " Supplementary Requirements for Welding And Nondestructive Examination of Nuclear Pressure Components and Nuclear Power Piping."
- b. Examination of UE&C Nonconformance Report Nos. 1-NCR-53-12 and 1-NCR-53-13.
- c. Review of TD Quality Control Nondestructive Examination Procedure No. 600-11, Revision 1, dated March 28, 1977,
" Visual Weld Inspection."
- d. Review of training and special process requirements in the QA Manual.
l i
)
l i
13 '
- e. Review of inspection, process control, nonconforming material ;
control, welding and nondestructive examination requirements in Quality Control Procedure I.P.-500, "ASME Nuclear,Section III Class 3."
- f. Review of Quality Control Procedure I.P.-600, " Nondestructive Examination."
- g. Examination of nondestructive examination personnel qualifications and discussion with QA management on the qualifications and train-ing of welding inspectors.
- h. Review of Quality Control Procedure I.P.-700, " Quality Engineering Manual."
- i. Discussion with QA management on the formalized actions taken to preclude recurrence of similar welding deficiencies in ASME Section III components furnished to nuclear sites.
- j. Examination of in process Tank Lube Oil Sump Inlet Components for Shop Engine Nos. 2931 and 2957 with respect to:
(1) Compliance with Production Route Sheet operational sequence and instructions.
(2) Signoff of completed operations.
(3) Identification of welding and nondestructive examination personnel performing applicable welding and examination operations.
(4) Verification of use of welding personnel qualified in accordance with Section IX of the ASME Code.
(5) Compliance of fillet welds with drawing dimensional requirements.
(6) Compliance of welds with visual inspection criteria contained in Procedure No. 600-11.
(7) Use of welding procedures specified on the appropriate drawings.
(8) Compliance with QA program nonconformance and process control requirements.
l 14 i
l (9) Use of welding materials specified in designated welding procedure specifications (WPS). '
- k. Examination of welding material storage and issue area with respect to:
(1) Control of welding material identity to the point of con-sumption.
(2) Electrode oven temperature control and segregation of materials.
(3) Compliance with QA program electrode issue time requirements.
- 1. Observation of shielded metal arc welding operations on Job No. 94302, Shop Engine No. 2931, six (6) inch Schedule 40 piping subassembly with respect to:
(1) Compliance with Production Route Sheet instructions.
(2) Documentation of welding operation and personnel.
(3) Conformance with WPS parameter and welding material requirements.
(4) Qualification of personnel for operation performed.
- m. Examination of a two (2) inch piping subassembly Part No. 02-717-02YE, with respect to performance qualification status of welder.
- 4. Findings
- a. Desiations from Commitment (1) Paragraph 4.2 (page 17A-29) of UE&C Specification No. 9779-53, Division 17, Section 17A, required visual examination to be performed to a written procedure in accordance with Article 9 of ASME Section V, with acceptance criteria as specified in ASME Section III. The applicable TD specification for visual examination, No. 600-11 Revision 1, provided, with the exception of permissible butt weld internal and external reinforcement, sufficient criteria to perform weld inspection consistent with the contract and ASME Section III Class 3 requirements. Reinforcement criteria was also provided by the applicable TD welding procedure specifications for butt welds.
~
l
, 15 ;
The identified piping weld-deficiencies at the WPPSS Unit 1/4 facility is therefore indicated, from the foregoing, to be related to a failure to implement existing inspection requirements. Discussion with QA management failed to reveal any formalized corrective actions that had been taken to preclude recurrence of similar inspection failures.
See Notice of Deviation, Item B.
(2) See Notice of Deviation, Item C.
(3) Observation of shielded metal arc welding operations on Shop Engine No. 2931, Shop Order No. 94302, Part No. 02-717-02 YR, showed the welding of the 6 inch Schedule 40 pipe being performed in quadrants using from the 3G to 1G positions. Examination of the performance qualification records for the welder indicated, however, qualification only in the IG position. Table QW-461.7 in Section IX of the ASME Code qualifies only for 1G and IF welds, when a 1G qualification test is utilized.
4 Tables QW-353 and QW-452.3 in Section IX of the ASME Code q qualify a welder for pipe outside diameters of 2 7/8 inches and over, when a performance qualification sample size of
, over 2 inches is used. Review of the performance quali-fication records for a welder, identified as being employed for a 2 inch piping assembly, failed to show actual sample size used for the qualification. The inspector was informed by QA management that all pipe performance qualifications had been made using a 6 inch diameter sample size.
(4) See Notice of Deviation, Item E.
(5) Examination of the Production Route Sheets for the two assemblies identified in Item F of the Notice of Deviation, failed to show the identity of the welders working on the assemblies. The inspector was informed that weld reports which would have provided an additional method for identifying personnel used to perform welding, are made up from the Production Route Sheets and not until after completion of assembly. See Notice of Deviation, Item F.
(6) See Notice of Deviation, Item G.
(7) The Production Route Sheets for the Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment indicated a welding date of July 29, 1980, for the weld of Item A to Item B with a magnetic particle examination acceptance on the same date. No record was made on the Production Route
I 16 4 -
Sheet to indicate a visual inspection acceptance had been made. Paragraph 5.4.4 in Section 5 of Quality Control Procedure I.P.-500 states with respect to weld inspection, however, "The welder will request the A inspector to inspect the weld upon completion of tha operation or as required. The inspector will indirace acceptance of the weld in the space provided on the Production Route Sheet." It was not ascertained during the inspection whether the magnetic particle examina-tion acceptance signified final QC acceptance of the weld. See Notice of Deviation, Item H.
(8) Review of the Production Route Sheets for the Shop Engine No. 2931 Tank Lube Oil Sump Inlet Compartment showed no inspection acceptance stamps for Operation Nos. 10, 20, 30, 40, 50, 60, 70, 80, 90, 100, 110, 120, and 130. These operations included: burning material to size and required shapes; layout of openings for burning and subsequent burning operations; layout for drilling etc. Inspection Reports denoting a rejected status were also not available for these operations to confirm an inspection had been I made. See Notice of Deviation, Item I. ,
- b. Unresolved Items None -
- c. Other Findings-Comments (1) The TD drawing practice does not provide a system for 'l unique identification of welds in assemblies, i.e, a specific number or letter symbol is not assigned to a given weld. Base materials are assigned a letter symbol for each item, but duplicate symbols are assigned for items of the same configuration and size. This practice could lead to weld repair and examination traceability and control problems, e.g. if two welds existed in an assembly with the same base material items utilized for each weld.
(2) The map used to show type and size of electrodes in the holding oven did not contain the lot identity of the electrodes. No deviation from ASME Code traceability requirements was identified during the inspection, however, in that only one lot number was in the storage area and in use for each size and type of electrode.
17 C. Followup on Reported Deficiencies in Diesel Generator Piping System Component Supports
- 1. Background Region IV of the Office of Inspection and Enforcement was notified on September 26, 1980, concerning irregularities in TD emergency diesel generator piping system component supports furnished to the Comanche Peak Units 1 and 2 facility. The reported problems included both welds not meeting visual inspection requirements and the component supports not being certified to have been manufactured in accordance with Subsection NF of the ASME Code.
- 2. Inspection Objectives The objectives of this area of the inspection were to review the nature and scope of the reported deficiencies and determine any generic implications.
- 3. Method of Accomplishment The preceding objectives were accomplished by:
- a. Review of Gibbs & Hill Specification No. 2323-MS-34, Revision 1, with respect to fabrication requirements and designated Codes and standards for the Comanche Peak diesel generator component supports.
- b. Review of TD internal correspondence on the reported problems.
- c. Discussions with QA management.
- 4. Findings
- a. Within this area of the inspection, no deviations from commitment or unresolved items were identified.
- b. Review by the inspector of the customer parchase specification failed to reveal any specific refererce o or requirement for fabrication of the diesel genera +ct :on nent supports in accordance with Subsection NF o; 4 P;,, Code.
- c. Insufficient information was available to determine the nature of the weld visual inspection problems. This subject will be further examined during a future inspection.
- r. e- ,
)
6
, b8erite 870114 NUCLEAR CaoutATORY -"
Q,",MjR,C y 7,se, INSPECTfDN & ENFORCEMENT -STATISTICAL DATA
-C O.3 1 F ACILtTY NAMEb m e m a a e i t a De la al INSPECTOR (3) U. C En f N 1 PRINCIPAL INSPECTO REa M -
LICENSEE /VENCOR EY, rb e i C.m,ft a 11 e a Div r.a4==ae TRANS. OOCKET NUMrER REVIEWER E bELn t t N LAs j REPORT NO.
ACTION DATES 6NQ/sNvEST/iNSP REGION 9 9 FROM TYPE 19 CONOUCTING 24 ACTivlTY 1
191919 lolol213141
AE ONE 15 18
<eili ) ofi 14 1 & I M M 0 0 Y Y 39 04 LICENSE NO. (BY PRODUQ C- 2 ,.
lII of Clii 2, TO 30 5~,,e i IIIIIIIl l lI l l unli lot s 171 Plol
- =CTION PE R50RMEO ev- ' M M 00 Y Y n
F 1 %EGIONAL OFFICE STAFF 2 O RESIDENTINSPECTOR 3 C PERFORMANCE APPRAISALTEAM TYPE OF ACTIvlTY CONOUCTED (CHECK ONE BOX ONL Y1 D 34 INSPECTION OTHER G
06 C MANAGEMENT AUDIT 00 C MATL ACCT. 13 C 4MPORT 02 C SAF ETY 08 C MANAGEMENT VISif 14 C IMOUIRY 03 C INCIO ENT 10 C PLANT SEC. I 15 C INVESTIGATION OF C SPECIAL 11 C INVENT. VERIF.
04 C ENFORCEMENT OEpENDOR l sie invest. ALso CMECK 12 C SHIPMENT / EXPO RT g eLoCKsi g INSPECTION OR INVESTIG ATION WA RNING-
.35 1%ANNOUNCE0 2C UNANNOUNCEO
, ClON SMC-1% DAY SHIFT 2 COFF. SHIFT 3 0 WEE KEND/HOLIC AY J INSPECTIONilNVESTIC ATION NOTI 8' CATION 'CMECK ONE 80x ONLYi 37 1 C 591 2YREGION AL OFFICE LETTER 3 C REFERRED TO MCS FOR ACTION 4 C REGtON LETTER & HQS FOR AC* TON INSPECTION /INVERTIGATiON 8tN0iNGS #CMECK ONE SOK ONLYS K 3 1CCLEAR 2 C NONCOMPLf ANCE 3 C DEVIATION ogNONCOMPLIANCE & OEVfATION L IENFORCEMENT CONFERENCE MELO I C 39 M 'O
NUMBER OF NONCOMPLIANCE ITEMS IN LETTER TQ LICENSEE:
NOTE: CMANos must es suaulTTso ON 704 WMENEVER PAfVIOusLY N CITED ITEM CP NoNCOMPUANCE NUMSER OF DEVIATION ITEMS IN LETTER TO LICENSEE: Is opticiaLLY ostsTro smou TME AEcomo.
O 44 45 NUMSER OF LICENSEE EVENTS g g g
, 48 INSPECTION FEE 1 C NON. ROUTINE / VENDOR INo Feel 2 C ROUTINE INo Feel 3 C ROUTtNE (Feel 4 C ROUTINE (Pee R+M O
47 CONTENTS 2.7900 INFORMATION O T YES R EGION AL OFFICE LETTER OR REPORT TRANSMITTAL DATE FOR INSPECTION OR INVESTIGATION g Set OR LETTER tsSUED TO LICENSEE REPORT SENT TO HCS FOR ACTION as M 54 IMME01 ATE ACTION LETTER
' M 60 OATE 65 IOl li'iDIRll l I IIIIII I II III I M M 0 0 Y Y M M 0 0 Y Y MM O O Y Y SU8vECT OF INVESTIGATION (CHECK QNE 80x ONLY) 6H7 TYPE A to CFR 20 403 TYPEB to CFR 20.405 MtSC.
01 C INTE RN AL OVER EXPOSUR E 06 C 11 C INT. OVEREXPOSURE 15 C CRITICALITY 21C EQUIP. FAILURE 02 C EXTERNAL OVEREXPOSURE 07 C 12 C EXT. OVEREXPOSURE 16 C LOSS / THEFT
$ 03 C RELEASE TO UNREST. AREA 220 ALLEGATION /
08 C 13C EXCESS AAD. LEVELS 17 C MUF COMPLAINT 04 C LOSS OF F ACILtTY 09 C 14 C EXCESS CONC. LEV ELS 18 C TR ANSPORTATION 23O PUSLIC INTEREST OS O PRCPERTY DAMAGE 10 C 19 C CONTAM/ LEAKING 24C SA80TAGE SOURCE 2SC ASNORMAL OCCUR 20 C ENVIRONMENTAL EVENT 26C OTHER ME AOQUARTE RS EN TRIES T HQS ACTION ON INSP/ INVEST REFERRED 8Y REGION:
tsee Reseeam La ee, Ceev
/
~
l l l .c 70 75 U l OATE MOS ENFORCEMENT LETTER. NOTICE. ORDER ISSUED.
- g lllllll\
M M 0 0 Y Y NOTE: 8 LOCKS K TO N MUST 96 VERIFIED 8Y IE:MCS WHENEVER ENTRIES ARE V MADE IN GLOCKS T, U CIVIL PENALTY ISSUEC: AND V 77 80 W I DATE 766 ENTERE0 INTO COMPUTER FILE (MO/YRI: u y y y TS PERE CE-
a 4 8 %
I *
-~ "d* - I !l- l _ _
-l _
l _
l l
l~ ll_ j$ h,
- I i l l l l l l l lI g i ,i i , j ; = -
! I l a
l l 1 i i a=>
is W I a j $.
l , .--
O mW h aWD l lM e .ag
$ 5E a se m >y l 5 R
< f ..is _
g g [*,gg a-> l ci .5 y
a 2 a E
< go. o y _
u I
aw> 1 J l I i 2 m U e . i H * %
Z 8 j u
y^ W l IN O
e .
- *:W I ma, i '
I i ::
C 2 8 BE a ga<p. Ig % -
w "on a
2 Nj:g.
3 s
40
" o.
5 d
l t e ,,go- j g 5-czz "-
,vnNVW:
g a gggg l
=tagst isvad i i g
m 3 aus $
E -i~ g snivist i i i i i l II II II II II II le
! C U z j l l ll l is i E E 3 .35d*
W i i i
$ o I I I i ii i : 3 E! h gIIo U< >L $ce.i Cil. I 0; i Q l i I l ll i l 10 i =
jj g 5 Ol i H - l I l 3
t j;2
=~~- 5 g8=-s
=g=g$- i of ol I o I ! t !
i: ig
!"2 5; !
5
,S:. ,3^371 col ad no l i l i I '
! !! lj ee: a . " , ,, - -. ,
i i i
- =*
l,$y j
.x, i ol i ~
~,
~
~
ii i
i I !
i ,
! I I
l ji
[ ggg y eywot of Ni d I i i t i I ! '
- g gegg g ,vn~vn, m i o-i i e- i ! I i !
- i ,
I:3 i i asvwei et i evi ! etl i! 6I i i i i - -
I l @ ,
i a! ! ii~iie i !.i i a a i i-! ; ; - i- ;
, i o
i c: o; i ai ; j i !l l I . <~
l
\ s a e, : a, 's e= ,a. a = = -
I.
e-m m r .* rer--y- --
sw -v,--e, --gy, e-w,,w. 3-----,-,,e----v, -- -,.--,w. . , - - - - - - - - - - - , , , . , - - - - - , - . = , - - , , --w. .- .-w, ,--m, - . - - - - - - - - * - - -
- ,~_ - ._. . . . . - . . . - . .- _ .-_ .. .
- - - - -L ' -- -. . . - - - - - - . _ . . . ._.
b
~
PORM NRC 7#8 i* OCTOGER 1977 GICOGN)
Wieff89 STAfg eMACLEAA REGULATORY 00ansml0N INSPECTION an ENPORCEMENT- STATISTICAL DATA SUPPLEMENT GENERAL INSTRUCTIONS: SLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM 15 TO SE COMPLETED FOR EACH.
(Al ITEM OF NONCOMPLIANCE CITED.
(3) ITEM OF NONCOMPUA8eCE NOT CITED, AND.
(C) DEVIATION CITED IN ENFORCEMENT CORRESPONOENCE DOCKET NUGASER OO3Ib OR LICENSE NuesEER REPORT NUMSER IC- 0/
A- F BMCIFic NM CODE puNCTioNAL X LY) OR DEVIATION CAueE pm0CEDung severity AREA 2 7 1 1 10 11 12
, A W iANCE IAlcj&hl I C O III 1 2 8 LICENSEE IDENTIFIED ITEMS C-4000ULE NUMBER 13 19 C DEVIATION O 9 h O l '7 b D-MOW ITEM IDENTIFIED E-0000850USNCES (CHECK ONE SOX ONLY) (CHECK OffE BOX ONLYl L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 I 18dEPECTOR 21 P HAO POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N DID NOT HAVE POTENTIAL TO RESULT IN ACTUAL l
OCCURRENCE F -EXEMPT INFORMATION G-ADDITIONAL UNITS (ENTER "M" IN FIRST 90X FOLLOWED SY OTHER 23 26 22 $ CHECK SOX IF EXEMPT INFORMATION 18 INCLUDED IN TEXT BELOW PER 10 CFR 2.790 H-.NONeoMPLIANcf REPETITIVE OCCURRENCE 7 (IF FIRST OCCURRENCE ENTER "1"i I-TEXT (ENTER UP TO 2400 0 ARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLlANCE OR DEVIATION EXCEEDS THIS NutesER. IT WILL SE NECESSARY TO PARAPHRASE) 1 50
- f. C.J,,, u je ced xn er Ao B J to crn .ro ,,Ru I O, a am) r e. s.r "'
a l' %). t o 'hol,e af Eo 'Q c kw al Ma_' N A s t a en) J. neanne. ~
let..Wer !ed $ a_ $;ameln anl dun n/' hA? hw k a.ed Luol
! e d h k ebe k A J m t f.. : J.J / ,1,# ca a Li A.J 4. Ga n
! he.J r a 10 A f A flLas Mk it.A I
- O E (C\ Ca. W AM . d4dt m R e.O In. '
m LL m a" 'and a.,1/On .ra:AI . .. ' A , a .. h . Ale ' *.IN.n a k da '*'
w .ka,G~ :,. - c-a ra,L:,;me.
6 6 (si (9)
(101 (11)
(12)
(13)
(146
( )
asi i
& f E l N } O l &l NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN TH15 INFORM ATION.
1 5 IOVER)
I .
w .
FORM NRC 706-$
OCTOSER 1977 .
n (MC 06351 useetso States muctsAn neoutATony commmessoN INSPECTION at ENFORCEMENT-8TATISTICAL DATA SUPPLEMENT GENE R AL INSTRUCTIONS: eLOCK A MuST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM 15 TO BE COMPLETED FOR EACH.
(A) ITEM OF NONCOMPLtANCE CITED.
(0) ITEM OF NONCOMPLIANCE NOT CITED, AND.
(C) DEVIATION ClTED IN ENFORCEMENT CORRESPONDENCE DOCKET NUMSER Oc 234 OR LICENSE NUMsER REPORT NuMeER f C- eI A-TYPE OF FINDINGS 5-MCIFIC N/C CODE PuNctioMAL (CHECK ONE SOX ONLY) QR DEVIATH')N cAuss PnocsDuMs $sVE RITY AREA 3 7 9 10 11 12
, A NONCOMPUANCE lIlAlCl l l [gj l l l 1 2 O LICENSEE IDENTIFIED ITEMS C-410DULE NUMBER 13 19 C O DEVIATION 12 9 2 7 / c a D-HOW ITEM IDENTIFIED E-@NSEQUENCES (CHECK ONE SOX ONLY) (CHECK ONE BOX ONLY)
L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 1 b INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N DID NOT HAVE POTENTI AL TO RESULT IN ACTUAL OCCURRENCE F -EXEMPT INFORMATION G-ADDITION AL UNITS (ENTER "M
IN FIRST 80X FOLLOWED 8Y OTHER 23 26 22 S CHECK BOX IF EXEMPTINFORMATION is INCLUDED IN TEXT 8ELOW, PER 10 CFR 2.790 H-NONCOMPLI ANCE REPETITIVE OCCURRENCE 7 (IF FIRST OCCURRENCE ENTER ~1")
I-TEXT (ENTER UP TO 2400 CH AM ACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEVIATION EXCEEDS THl3 NUM8ER, IT WILL SE NECESSARY TO PARAPHRASE) 1 50
- 1. C nl...m O J. .... s.. .L a l, rl or i o c.r n u m u..L L.) n J 1,een n.:J Ari,J I, : 14J. 4LJ NA k e L.) 1.en on,L A) em ~
4R }Rea~1/A1:a e.nl. I salac an M e.nneck,a al:.. Lal l,us I clas .) .. L L ax n a s a ,, J - . e h en suosi Lin lesal: m , L >aer er
U n n .)aka. c. n l n . I u *A k u 1 :4L ea::,J (A a , flaa u euid:'s G .. J C._ i t. # (7) 18r (9s (101 (111!
(12)
(131 (141 (hl
! 148)
- &lE lNi Dl 8 NOTE
- DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN THIS IN FORM ATION.
1 5 (OVER) l
- pOnMNaC =
s (M:TOSER 1977 SBC 085) uNetso stares muctaAa neoutAfony commsessions INSPECTKW & ENFORCEMENT-8TATISTICAL DATA SUPPLEMENT ,
I GENER AL 1NSTRUCTIONS: sLOCK A Must et CHECXED TO SHOW TYPE OF INFORMATION l
, CONTAINED ON THE FORM. ONE FORM IS TO BE COMPLETED FOR EACH. '
(Al ITEM OF NONCOMPLIANCE CITED.
(3) ITEM OF NONCOMPLIANCE NOT CITED, AND.
(C) DEVIATION CITED IN ENFOACEMENT CORRESPONDENCE DOCKET NUMSER T 9 900 ~I3'" OR LICENSE NUMeER REPORT NUMSER 80"O1 A-TYPE OF FINDINGS SMCIFIC N/C CODE punctioNAL (CHECK ONE SOX ONLY) OR DEVIATION cAust PmoctoumE sevensTV AREA J 3 7 9 10 11 12
, A NONCOMeciANCE loIcloimi I Ull l l 1 2 5 LICENSEE IDENTIFIED ITEMS C-MODULE NUMBER 13 10 C DEVIATION l2 i 2 7 0 8 8 0-MOW ITEM IDENTIFIED E-OONSEQUENCES (CHECK ONE 80X ONLY) (CHECK ONE BOX ONLY)
L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 i b INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N X DID NOT HAVE POTENTIAL TO RESULT IN ACTUAL OCCURRENCE i F -EXEMPT INFORMATION G-AODITIONAL UNITS (ENTER "M" IN FIRST SOX FOLLOWED SY OTHER 23 26 UNIT NUMSERS) l l l l l 22 S CHECK SOX IF EXEMPT INFORMATION 15 INCLUDED IN TEXT BELOW PER 10 CFR U90 H NONCOMPLtANCE REPETITIVE OCCURRENCE 7 (IF FIRST OCCURRENCE ENTER ~1")
I-TEXT (ENTER UP TO 2400 CHARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEVIATION EXCEEDS THIS NUMSER, IT WILL SE NECESSARY TO PAR APH R ASE) 1 50 2e h DW-A_ Tc/ k ' l~ A*x "A C /O C P'A SO -]
//
$=> Yw ~7
(/
/ L8" ? s X. R ~ ~70 0 O. b" (2) 2 2./ b .d -. - - __ G L+ A & %- N
f L A A /- k u L *L mad L: LL J Vm --
?__ f~T*Y $ w uY Y om eh g h i 4.s me m & 77r cL a U._f ~&- #
(7)
EL.
/ / (/ - <si (91 (101 (11) 112)
(13)
(14)
(kI (48)
& l E l N l 0 l &l NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN THIS !NFORM ATION.
) -
FORM NRC.706 5 OCTOSER 1977 (MC 0636)
Wasstas s7ATAs NUCLEAR RESULATOAV C0anNESHM INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GENE R AL INSTRUCTIONS: BLOCK A MUST SE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM 15 TO BE COMPLETED FOR EACH.
(A) ITEM OF NONCOMPLIANCE CITED.
(C) ITEM CF NONCOMPLIANCE NOT CITED. ANO.
(C) DEVIATION CITED IN ENFORCEMENT CORRESPONDENCE DOCKET NUMSER 999DMb OR LICENSE NUMSER REPORT NUMSER M~C' A-TYPE OF FINOtNGS 8-SPECIFIC N/C CODE PvNctioNAL (CHECK ONE SOX ONLY) 3R DEVIATION CAUSE PAOCEDURE SEVEmiTV AREA 3 7 1 g to 11 12
, A NONCOMPuANCE lolcloinl I O [~~l l I I 1 2 8 LICENSEE IDENTIFIED ITEMS C-MODULE NUMcF8 13 Ig C DEVIATION h i 2. l"I C C 8 D-HOW ITEM IDENTIFIED E-CONSEQUENCES (CHECK ONE 80X ONLY) (CHECK ONE BOX ONLY) i L 0 tiCENSEE A CAuSE Oa CONSTITUTED ACTUAL OCCuaaENCE 20 1 INSPECTOR 21 P HAO POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N X 010 NOT HAVE POTENTIAL TO RESULT IN ACTUAL i OCCURRENCE F -EXEMPT INFORMATION G-ADolTION AL UNITS (ENTER "M" IN FIRST SOX FOLLOWED 8Y OTHER 23 26 22 S O CHECK 80x lF ExEuPT iNFOaMATiON
""" lIII I IS INCLUDED IN TEXT 8ELOW PER 10 CFR 2.790 H-NONCOMPLIANCE REPETITIVE OCCURRENCE 7 (IF FIRST OCCURREN4E ENTER "1" 3 I-TEXT (ENTER UP TO 2400 CHAR ACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEVIATION EXCEEDS THis NUM8ER, IT WILL 8E NECESSARY TO PAR APHRASE) 1 50 "J . 80* Niw Y) k WY u ~8 N T O C.P R A"O w
/
x _ M wh - m i M [2% D wh-ss1oM M
- LL V /
(3) rs t Yu ASMW ?
(4) q_ _ y*2 e m h . Se . lJ- / M- w
' h_ d"M ,L
- r_2 - r.e_-coo) M J 1 a e ,) / 4 < en - l &-M ifI w ' -
ox \_- h_^ ^- ' ~ --m{
/ 191
,L " I
,J e l i n l& / ? ,,/ b J h.i c A f- "'1 6 / 8 (14 SN " r~ T C - 1A M-m b.
IhI (481
&lElNlDf& NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAD.
THIS INFORM ATION g
- ~ *
, ) _ .
. PORM NRC 70M e CCTOGER ten -
esc Osas) uenteo stAree mucteAn neoutAvoav--
INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GENERAL INSTRUCTIONS: SLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM IS TO BE COMPLETED FOR EACH.
(A) ITEM OF NONCOMPLIANCE CITED.
(5) ITEM OF NONCOMPLlANCE NOT CITED, ANO.
(C) DEVIATION CITED IN ENFORCEMENT CORRESPONOENCE DOCKET NUse0ER 9"O07 h OR LICENSE NUMSER REPORT NUMSER D ~O I A- i .-arECwiC =C COoE , u,,c,,,,,o X LY) OR DEVIATION cAuge PRoceoung sevenify AREA 3 7 1 g to 11 12 8
^ * '^act loIcl*lMI I O IIIl i 1 2 8 LICENSEE lOENTIFIED ITEMS C-MODULE NUMBER 13 1e i C DEVIATION 2. */ '2- 7 C 5 8
! 0-MOW ITEM IDENTIFIED E-CONSEQUENCES (CNECK ONE SOX ONLYI (CMECK ONE BOX ONLY)
L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 1 INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N DID NOT HAVE POTENTIAL TO RESULT IN ACTUAL l OCCURRENCE i F -EXEM INFORMATION G-AODITIONAL UNITS (ENTER "M" 23 20 l
IN FIRST SOX FOLLOWED SY OTHER ,
22 S CHECK 50X IF EXEMPT INFORMATION
"' "' !!!!! l' 18 INCLUDEO IN TEXT BELOW. PER N C'" H-NONCOMPLIANCE REPETITIVE OCCURRENCE (IF FIRST OCCURRENCE ENTER ~1" 3 I-TEXT (ENTER UP TO 2400 CHARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEVIATION EXCEEDS THIS NUMSER, IT WILL BE NECESEARY TO PARAPHRASE) 1 50 L4 . 6 N_____, k Ckk 7 J A un2 e & s e c. ar a s- o A Y -
d ah U 2.Y _ J N1 -t 3 23 -
- r. A M /d u-,, a : F (4)
- 4. Y * )YY ~ [ . a a N*m m k-4 bN 7
j AKL - e 4 L A L.A l A u.c/WLW , L IITF M dM<- ~ -
($1 l* .d? _-__R 0 A n*L J? S ? ! &2 2 8
- f e L u.J = - A T M c" JJ /L,- &f AL2- '*'
S .L i n ' u."
. y u -
.L - d _,
! ! 111)
$[LL)- h) m ,EL , w . l M2.Y $ $=.~.n fN "'
L.
- L J D ,, , e k
22 A s'e ,E .SL- _i6o
~
C Y 3 d A *.~-
alb,L /w/ En e _ L,1.,,) ~, . # # /
/ ,.
- . nJ<_, $ .t-114) n l Y A5M E .$L be~ _. W rs< eIn p.-py&. f 6 W % .,g 2.+ M ~ J av ). l'el
& l E l N l D l &l NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN
. THIS INFORMATION.
.. -- ..- - -. . ~-.-- .J FORM NRC 7645 OCTO.SE.R (MC D 3 ) 1977 Uanteo eTAte0 WUCLEAR AGOULATORV COesessestoss INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT G EN E R AL INSTRUCTIONS: BLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. O*fE FORM IS TO BE COMPLETED FOR EACH (A) ITEM OF NONCOMPLIANCE CITED.
(8) ITEM OF NONCOMPLIANCE NOT CITED, AND.
(C) DEVIATION CITED IN ENFORCEMENT CORRESPONDENCE DOCKET NUM8ER 99D0 3D OR LICENSE NUMSER REPORT NUMSER N *O/
A-TYPE OF F8NDINGS B-FECIFIC N/C COOE punctionn (CHECK ONE BOX ONLY) OR DEVIATION CAUSE PACCEDURE SEVE RITY AREA 3 7 1 g 10 11 12
, A NONCOMRuANCE lolc.le IH I O III 1 2 8 LICENSEE IDENTIFIED ITEMS C-MODULE NUMSER 13 tg C DEVIATION l2-1 2 "I l O T 8l 0-How ITEM IDENTIFIED E-CONSEQUENCES (CHECK ONE 80X ONLY) (CHECK ONE BOX ONLY)
L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 1 INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N X DIO NOT HAVE POTENTIAL TO RESULT IN ACTUAL OCCURRENCE F -EXEMPT INFORMATION G-ADDITION AL UNITS lENTER **M" IN FIRST SOX FOLLOWED BY OTHER 23 26 22 $ 0 CHECK sox iF EXEMPT iNFOaMATiON
""""" IIIII IS INCLUDED IN TEXT 8ELOW, PER 10 CFR 2.790 H-NONCOMPLI ANCE REPETITIVE OCCURRENCE (IF FIRST OCCURRENCE ENTER 1)
I-TEXT (ENTER UP TO 2400 CHAR ACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEVIATION EXCEEDS THIS NUMBER, IT WILL BE NECESSARY TO PARAPHRASE) 1 50
- s. (d ~ 2* C 'h.~~7~ #./U A M v b t o cen ro J L ?wf T' J L$'N. W Adn (2)
.z'. P. -Co c> w_ )
> e %h M ,,
M F ends 4 U n
(5)
(6)
(7)
(8)
(91 l
l f 101, (11 (12) 113i Ital (h)
(48)
& l E l N l D l ail NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN THl$ INFO RM ATION
_ . _ . _ . .-. . . . _ . . - . _ _ . _ ~ . . _ . ..
b'
'~ e . .
M 19RC198 S
, OCTOBER ten
. SAC 005) unutes svATes asucLsAn ResuLATony ceanneeMin INSPECTION & ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GENERAL INSTRUCTIONS: SLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM IS TO BE COMPLETED FOR EACM.
(Al ITEM OF NONCOMPLIANCE CITED.
IS) ITEM OF NONCOMPLIANCE NOT CITED. ANO, J (C) DEVIATION CITED IN ENFORCEMENT CORREMM60ENCE i 00CKEffeUMSER 9 990*M b OR LICENSE NUMSER REPORT NUMBER PO ~O 8 ;
, A- nu -
- . 9 86Pic N/C CDDE puncT m
, . -'" 4 . * *X* LYi OR DEVIATION cAuss Paccsount sevensTv AmeA
- 3 7 a 9 10 11 12
, A NONooMr0ANCE lolcloinl I C C Wl ,
4 1 2 O LICENSEE IDENTIFIED ITEMS C-es0DuLE NutEER 13 19 C DEVIATION 2. 9 2 ~7 o f 8 0-teolar ITEM IDENTIFIED E N NCES ICHECK ONE 80X ONLYi (CNECK ONE DOX ONLY)
- L O 'LiCEN EE A CAU.E Oa CONsTiTuTEo ACTUAL OCCuaaENCE 20 1 INOPECTOR 21 P HAD FOTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N h 040 NOT HAVE FOTEi4TIAL TO RESULT IN ACTUAL OCCURRENCE 4 F -EXEMPT INFORMATION G-ADDITIONAL UNITS (ENTER "M" IN FIRST SOX FOLLOWED SY OTHER 23 26 NIT NUMSERS l l l l l l i
22 $ CHECK SOX IF EXEMPT INFORMATION '
IS INCLUDED IN TEXT BELOW, PER 10 CFR 2.M H-seoNconapttANcf mEPETITivt occurrence 7 (tF FIRST OCCURRENCE ENTER "1"I i I-TEXT (ENTER UP TO 2400 CHARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEVIATION EXCEEDS THis NUMSER, IT WILL BE NECESSARY TO PARAPHRASE) 1 60
$. A N= W C' N
- Y )A'L $ ~ R 1b ~ f o c.c n r c - _ _ _I N_
L. / o . .2 1 ), F $ 4 ~:c~m Coc. A2_ 2 wt 1 -- Yw $ NY Y A- .$ - Y N&$
/ V '*'
J J J 23 - - - - A L .~ 2 } ._ ; fu & J 1 1
.m i di :
lei cr \A.fx & m1 JD.5 A> kt_ Aw ., ~ Co ha.)
i m $ik i A M J ? DD $ A- &* %.,2 % i< '*
\ 2 M: / .? WA.i FA. &
00)
- b. b$ me f Uwhel kb" \ 0 L, .-. :-
a
/
e (
D: - = . n d wb"" f.a.n-AmeA-en-,4 A. Y I aLL
/
. dad . 03' 1141 (k1
! let)
I & l E l N l D l &l NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED Mu'if CONTAIN l TMi$ INFO RM ATION.
1 5 IOVER) l l
) . .
FORM NRC 706-5 OCTOGER 1977 (MC 0636) use TeO OTATOS feUCLEAR RGOULATORY COamses#0N INSPECTION ai ENFORCEMENT-STATISTICAL DATA SUPPLEMENT GENER AL INSTRUCTIONS: SLOCK A MUST SE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM 15 TO OE COMPLETED FOR EACH (A) ITEM OF NOMCOMPLIANCE CITED.
(8) ITEM OF NONCOMPLIANCE NOT CITED, AND.
(C) DEVIATION CITED IN ENFORCEMENT CORRESPONDENCE DOCKET NUMSER YT9#OU3b OR LICENSE NUMSER REPORT NUM8ER N*W A-TYPE OF FINotNGS 5-SPECIFIC N/C CODE av eiomat (CHECK ONE BOX ONLY) OR DEVIATION cAuss pnocsouns savsnity ansa 3 7 9 10 11 12 A #
1 2 B LICENSEE IDENTIFIED ITEMS C-MODULE NUMBER 13 sg C DEVIATION l2- 9 1 7 O S~
0-HOW ITEM IDENTIFIED E-CONSEQUENCES (CHECK ONE BOX ONLY) (CHECK ONE 80X ONLY)
L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 t b INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURRENCE O OTHER N DID NOT HAVE POTENTIAL TO RESULT IN ACTUAL OCCURRENCE F -EXEMPT INFORMATION G-ADDITION AL UNITS (ENTER "M" IN FIRST BOX FOLLOWED BY OTHER 23 26 22 S CHECK 80X IF EXEMPT INFORMATION IS INCLUDED IN TEXT SELOW, PER to CFR 2.790 H-NONCOMPLIANCE mEPETITIVE OCCURRENCE D (IF FIRST OCCURRENCE ENTER ~1** I I-TEXT (ENTER UP TO 2400 CHAR ACTERS FOR E ACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR OEVIATION EXCEEDS THIS NUM8ER, IT WILL BE NECESSARY TO PARAPHR ASE) l 1 50
~7 t%b;~ Ydk ' n "R b;" / C C /~/E T O n --]-
L/d u, / em _ dA, 2-M[~Pd r_ P_ - s co * '*'
w / - a,
, _l J A~ J *
- A 1 s. E . .22 -,
l JWk LL.. - / ,2~_.kEL ~ ~ "'
-r -xL sa / /
l iti
- l
- 1. 2 /it s . h_ 1 V 7 . - -
G n n. k & A$ L _PA k - W -.h l
/L L Y d d d--n s i L A l< /- A- E m L P "*1
$ < L fO ,
- 112)
(13)l I
l114 a,
1481
& ! E lN l 0 f &l NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN THIS IN FO R M ATION 1 S 1OVE 0 ,!
l
I l .
+ .
pored NRC fee 8
- OCTOSER 1977 94C 0638) uNeTeo e7Ates NucLean RecutAtony comeNeeHHs !
INSPECTION at ENFORCEMENT-STATISTICAL DATA SUPPLEMEN T l
1 I
GENER AL INSTRUCTIONS: SLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM IS TO SE COMPLETED FOR EACH.
(A) ITEM OF NONCOMPLlANCE CITED.
(S) ITEM OF NONCOMPWANCE NOT CITED, ANO.
ICI OEVIATION CITEC IN ENFORCEMENT CORRESPONDENCE DOCKET NUMSER 9998073 4 OR LICENSE NUMBER REPORT NUMSER PO ~ Of A- F ' 5-FECIFIC N/C CODE pusectio8eAL X LYi OR DEVIATION CAust P#CCSount SEVEmiTV AREA 3 7 9 to 11 12 S
^
1 2 8 LICENSEE 10ENTIFIED ITEMS C-MODULE NUMBER 13 19 C b DEVIATION 9 2 7 o f8 E-CONSEOUENCES 0-HOW (TEM tOENTIFIED (CHECK ONE SOX ONLY) (CHECK ONE 80X ONLY)
L O 'uCENSEE A CAuSE Oa CONSTiTuTEo ACTUAL OCCuRaENCE 20 I h INSPECTOR 21 P HAD POTENTIAL TO RESULT IN ACTUAL OCCURR ENCE O O OTHER N 8 oio NOT HAvE FOTENTiAL TO RESULT iN ACTUAL OCCURRENCE F -EXEMPT INFORMATION I G-ADDtTION AL UNITS (ENTER "M" IN FIRST OOX FOLLOWED BY OTHER 23 26
" I l l l l l 22 S CHECK SOX IF EXEMPT INFORMATION iS INCLUDED IN TEXT BELOW. PER 10 CFR N H-NONCOMPLlANCE REPETITtvE OCCURRENCE 7 (lF FIRSTOCCURRENCE ENTER "1")
I-TEXT (ENTER UP TO 2400 CHARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEvlATION EXCEEDS THIS NUMSER,IT WILL SE NECESSARY TO PARAPHRASE) 1 50 8, $ f ~~~ . b [.!b Y J A-1 LJ v 8 h te e e n s"Dw
&, 67c. P' 2Tw ~ dG P A )/
O I i+-5 % c ~ P % >* J % L (2)
/ 4 Le ~ C ~T e. Y d A $ ~$ _
A - l & J :i- L- ,2 h' -
A i.d k
,.R A G & .: -
~i /
x1J W A
p' M wiL- <<
Ae *', gg A~ ~o 01 ~ .s%- e ~ o ~7 8 ~7 Mh
[# (7)
(8)
(9)
(101 (11)
(121 (13)
(141 (h) tes) l 6 l E lN l Dl &l NOTE: DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN THis INFORM ATION.
I
~
26 . ) .
a FORM NRC 700 5 OCTOGER 1977 (MC 0636) uswTse sTATea NUCLEAR RseuLATORV COMassOS40N INSPECTION & ENFORCEMENT-4TATISTICAL DATA SUPPLEMENT GENER AL INSTRUCTIONS: SLOCK A MUST BE CHECKED TO SHOW TYPE OF INFORMATION CONTAINED ON THE FORM. ONE FORM IS TO BE COMPLETED FOR EACH (A) BTEM OF NONCOMPLIANCE CITED.
(5) ITEM OF NONCOMPLIANCE NOT CITED. AND.
(C) DEVIATION CITED IN ENFORCEMENT CORRESPONDENCE DOCKET NUMSER 9%00Uh OR LICENSE NUMBER REPORT NUMSER PO ~ OI A-TYPE OF FINDINGS S-SPECIFIC N/C COOE puNcTioNAL (CHECK ONE DOX ONLY) OR DEVIATION CAuSE PROCEDURE S2 VERITY AREA 3 7 g 10 11 12 S
A UANCE lddON l l l l l l 1 2 5 LICENSEE IDENTIFIED ITEMS C-880DVLE 1 NUMSER 13 19 C DEVIATION l2- #
Tl"2- 7 C Y Ol D-HOW ITEM iOENTIFIED E-CONSEOUE NCES (CHECK ONE GOX ONLY) (CHECK ONE BOX ONLY)
L LICENSEE A CAUSE OR CONSTITUTED ACTUAL OCCURRENCE 20 1 INSPECTOR 21 P HAD POTENTIAL TO RESULT N ACTUAL OCCURRENCE O O OTHER N oiD NOT H ave ,OTENTiAL TO RESULT i~ ACTUAL OCCURRENCE F -EX EMPT INFORM ATION G-AOD TION AL UNITS (ENTER "M" IN FIRST BOX FOLLOWED 8Y OTHER 23 26 22 S CHECK 80X IF EXEMPT INFORMATION IS INCLUCEO IN TEXT SELOW. PER 10 CFR 2.790 H.goNcOMPLtANcE REPETITIVE OCCURRENCE 7 (IF FIRST OCCURRENCE ENTER "1")
I. TEXT (ENTER UP TO 2400 CHARACTERS FOR EACH ITEM. IF THE TEXT OF THE NONCOMPLIANCE OR DEvlATION EXCEEDS THIS NUMGER. IT WILL BE NECESSARY TO PARAPHRASE) 1 50
~
9 [ - ~ b~ C L - d A 11 l', -Er b soe.p n s~o <. .J LWw L-, Q t O ?l-R J r.?-sco LK-
/ A.J-_x W L - A cL W'i
/ - f a % +-es- b.. Mkb
& ne.f e = a a,T, ra u os a *'
TJh C s- r Led J &_ D J*
& 'd w& - M. xl . U !
Y_ /w n Y L.2 e+'L L1 w x a a /n /
LKa)
/
8* b W e V U w l* cLC-*
/
O Aa$n I (12) tI3N (141 Ik)
(48
& E lN l 0! & NOTE. DATA ENTRY CLERK-THE LAST LINE ENTERED MUST CONTAIN THl$ INFO RM ATION.
I
- - . - _ _ __ _ _ _ - _ _ ~ ._. -
Trarisamerict.
'. 11elaval .. .
as g DIVISION 10CFR21 POLICY GENERAL -
Manufacturers of equipment for Nuclear Power Plants are subject to Federal Law. Title 10, Code of Federal Regulations, Part 21 (10CFR21) requires that the manufacturer rewrt to the NRC Any defect in equipment supplied which could create a " substantial safety hazard". The following policy describes the method used to comply with this regulation.
1 INTERNAL NOTIFICATION Any person who becomes aware of a defect which could create a substantial safety hazard in deliverable equipment or delivered equipment for a Nuclear Power Plant shall notify the Q.A. Manager. The Initial notifica-tion may be verbal but must be confirmed in writing. Copies of the written report will be sent to the DPT group. The DPT group will be utilized for 10CFR21 evaluations. As required, the Q.A. Manager will schedule a meeting or use the next D.P.T. meeting for evaluating the problem.
ll EVALUATION A. Meeting The evaluation meeting will determine if a reportable problem exist.
The results of this meeting will be documented and filed in the master 10CFR21 file maintained in Quality Assurance Department. If decisions cannot be completed, the process of evaluation will continue at every meeting untti completion.
B. Responsibility it is the responsibility of the Q.A. Manager to insure that the evaluation is completed in a timely manner and that the Division General Manager is kept informed of the results.
111 REPORTING If the Division General Manager, after notification by the Q.A. Manager, concludes that the problem is reportable, the NRC will be notified
' within two (2) days. If the initial report is by phone, a written report must be submitted within five (5) days. It is the responsibility of the Q.A. Manager to coordinate reporting to the NRC. The phone report will be made to Region 5, Walnut Creek and the written report will be sent to the NRC, Washington, D.C. The written report will be l
In triplicate with an additional copy to Region 5.
IV COMPANY DISTRIBUTION The Q.A. Manager is responsible for distribution of the 10CFR21 report within the company. The attached distribution list will be used and maintained by the Q.A. Manager for this purpose.
gr
.; g Transamenct 7
- I6l8VS!
- PAGE 2 kT li V CUSTOMER NOTIFICATION A. Responsibility The Service Department is responsible for notifying Nuclear customers whose equipnent has the potential defect.
B. Directory The Service Department maintains a customer 10CFR21 report directory.
Coples of the directory will be kept in the Service Department and Project Administration. This directory gives the name and address of the person end office to receive the report. The Service Department coordinates the directory with Project Management and up dates the Information annually, the first of each year.
C. Initial Notification The initial report to the customer will consist of a copy of the written report to the NRC with a letter of transmittal, and comply with other contractual requirements. The initial report will be sent no later than five (5) days after the report is submitted to the WRC. This letter of transmittal will give the estimated date for sending the detailed Inspection and repair procedures.
D. Detailed Notification The Inspection procedure, repair procedure, or other information will be coordinated by Service with Project Administration, Engineer-Ing, and Sales to insure that our contractual obligations are met.
VI RECORDS Coples of all correspondence relating to 10CFR21 will be sent to the Q.A. Manager for filing in the 10CFR21 master flie. Customer actions will not be reported to the NRC by Transamerica Delaval. Retention of records shall be in accordance with the Division Q.A. Manual.
The following is a flow chart describing this procedure.
- FILE I NO SAFETYNs,YES . REPORT [
NOTIFY DEFECT /FhlLURE :- INVESTIGATE HAZARD /'
~
TO NRC CUSTOMER REPORTING a
MAYBE
Transamerict. ' '
Selaval : -
Y -
FE PAGE 3 h.
DISTRISUTION LIST FOR 10CFR21 REPORTS INTERNAL ,
General Manager General Sales Manager
- Quality Assurance Manager
- Engineering Manager Project Administration Manager Parts Sales Manager Sales Manager - Nuclear Foundry Manager Customer Service Manager Manufacturing Manager
- Copies should be forwarded to Project Manager, Project Engineer, Project Quality Engineer and Project Service Engineer, as applicable.
OUTSIDE Corp. General Counsel Corp. Asst. Counsel
- Corp. Fleid Sales Manager
- Regional Sales Manager
- District Sales Managers
- FleId Salesman
- Affected Areas Only issued by:__ b W
R.E. Boyer Manager quality Assurance 1-26-81
, Transamence l'";'"7'/C%";,;f .. ..
=5m^~
Delaval P O Box 2161 g Oakland. Cahfornia 94621 (415)577 7400 February 10, 1981 United States Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas, 76011 Attention: Uldis Pctapovs, Chief Vendor Inspection Branch Re: Docket No. 99900334/80-01
Dear Sir:
Enclosed please find Transamerica Delavals' written responses to the Commissions' Notice of Violation and Notice of Deviation which resulted from the Q.A. Program inspection conducted by Mr. W.E. Foster on October 14-17, 1980 at Transamerica Delavals' Oakland, California facility.
Sincerely,
\ ;
R.E. Boyer Quality Assurance Manager Transamerica Delaval Inc.
Engine and Compressor Division REB /dc Enc;
(
4rcrob2.o2 Tss" PP
/9
TRANSAMERICA DELAVAL STATEMENT OF ACTION T0:
NOTICE OF VIOLATION VIOLATION IDENTIFIED: Records had not been maintained with respect to fractured thermostatic valves in Grand Gulf Unit 1 emergency diesel generators to indicate that:
- 1. An evaluation had been conducted in accordance with 10CFR Part 21 requirements.
- 2. Actions had been taken to identify whether the product deviations contributing to the valve fractures, i.e.
improper use of raised face flanges in connecting piping was present in equipment supplied to other customers.
CORRECTIVE ACTION: A complete evaluation has been conducted for Grand Gulf and all identical thermostatic control valves furnished to sites by Transamerica Delaval to determine if the defined deviation was present in equipment supplied other customers. Records of the evaluation are now maintained in a 10CFR Part 21 report file maintained by the Quality Assurance Manager.
The three (3) sites which could have had the same problem as Grand Gulf were Long Island Lighting, Shoreham Station; Southern California Edison, San Onofre; and TVA, Bellefonte.
At Long Island Lighting it was determined that a different manufaturers valve was used and the potential problem did not exist. At TVA Bellefonte flat face flanges were specified and installed. At San Onofre one of the valve connecting flanges is a raised face flange. Calculations were made indicating that the stress resulting from a raised face flange mating with a flat face flange was well below acceptable allowable stress. The stress resulting from this assembly is 4015 PSI when using the torque recommended in our instruction manual. The yield stress for the thermo-static valve material is 40,000 PSI. This reinforces our contention that the original failure was not a result of the flange problem, but abnormal stresses imposed during assembly by site erection personnel.
PREVENTIVE MEASURES: Transamerica Delaval has implemented a formal 10CFR21 Division Policy for the assignment of responsibility for evaluation, documentation and notification of potential defects in equipment' subject to 10CFR Part 21.
COMPLETION DATE: February 10, 1981
= _ - - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _
, ( TRANSAMERICA DELAVAL STATEMENT OF ACTION TO:
NOTICE OF DEVIATION:
A. FINDING: Gage used to measure the diameter and depth of the link rod dowel counterbore had not been identified with:
- 1. A tool and/or Gage Tryout Tag;
- 2. A calibration decal; or
- 3. Company name, gage or equipment name, part and/or serial number as applicable; gage had been in use since February 1980.
CORRECTIVE ACTION: The link rod dowel gage has been identified and entered into Transamerica Delaval's Metrology Lab system as required by the Q.C. Manual and Quality Control Procedure IP-100, calibration.
PREVENTIVE MEASURES: Implementation of the requirements of the Quality Control Manual for new tools and gages regardless of the source of the tool or gage.
COMPLETION DATE: December 16, 1980 B. FINDING: Quality Engineering did not process a Corrective Action Request Form with respect to customer identified Transamerica Delaval failures to meet quality contract requirements in ASME Section 111, Class 3, piping.
CORRECTIVE ACTION: Quality Engineering now processes Cntrective Action Request for internal and external failures to meet contract requirements.
Specifically for the WPPSS 1/4 Welding problem, Quality Engineering conducted a meeting on April 6, 1979 for all personnel involved with the WPPSS welding. The meeting addressed the problem in terms of cause and solution and was considered to supercede the issuance of a Corrective Action Request. The memo scheduling the meeting and the agenda of the meeting were presented during the October 14-17 inspection.
PREVENTIVE MEASURES: For all internal and external failures, Corrective Action Requests are issued to the department / personnel responsible. The activity of Corrective Action Requests is repo*ted to the Division General Manager by the Quality Assurance Manager.
'*' _4
' COMPLETION DATE: November 30, 1980 C. FINDING: Transamerica Delavals' written practice IP-600 did not describe the procedure used for examination of Level III NDE personnel.
Personnel performing inspection per ASME Section III, Subsection ND and NF had not been qualified by examinations of comparable standards and methods referenced in SNT-TC-1A.
CORRECTIVE ACTION: Transamerica Delaval will revise procedure IP-600 to better define the procedure used for examination of NDE Level III personnel. Weld Inspectors performing visual examination for ASME Section III, Subsections ND and NF fabrications shall be qualified by examination comparable to those referenced in SNT-TC-1A.
PREVENTIVE MEASURES: Implementation of training in visual examination for inspectors. Verification and review of training record through the Internal Audit program.
COMPLETION DATE: April 30, 1981 D. FINDING:
- 1. SMAW welding of 6 inch pipe observed being performed in the 3G position, welder had been qualified for 1G position only.
- 2. SMAW welding was identified to have been performed on a 2 inch ASME Section III, Class 3 piping assembly by a welder who had been qualified per ASME Section IX for pipe diameters of 2-7/8 inch and over. ,
CORRECTIVE ACTION: Welders have been recertified on small diameter pipe, 2-7/8 inch and under in the 6G position. All existing welder certifications were reviewed for compliance to ASHI Section IX for correctness of essential variables.
PREVENTIVE MEASURES: A committee has been formed to review and implement the Welder Certification / qualifications in accordance with ASME Section IX, and the Quality Assurance Manual and procedures.
k- COMPLETION DATE: December 30, 1980 E .' FINDING:, Unused weld rod was not being returned to the storage area within four hours of issuance.
CORRECTIVE ACTION: A Corrective Action Request was issued to the Fabrication Shop Supervisor requiring that the veld rod. control program be implemented as stated in the Quality Assurance Manual and procedures.
The program requirements were reviewed with all welders to re-inforce their responsibility to comply with the Weld Rod Control Procedures.
PREVENTIVE MEASURES: Verification of implementation of Corrective Action through the Internal Audit Program.
COMPLETION DATE: December 1, 1980 F. FINDING: Verification of the use of certain welders could not be accomplished in that welding was observed being performed by a different welder than the individual identified on the Route Sheet. Welding records were not provided in that Weld Reports had not been prepared for the operations observed.
CORRECTIVE ACTION: A Corrective Action Request was issued to the Weld Shop Supervisor requiring that welders be instructed to sign the Route Sheet prior to welding and that all individuals performing-welding on a pipe spool must be identified on the Route Sheet. Route Sheets now identify the welder assigned, date, procedure being used and electrode heat number. Weld reports as referenced in procedures are accomplished after completion of all operations on the Route Sheet. Weld Reports are utilized to compile information from Route Sheets in a uniform manner and itemize information from Route Sheets.
PREVENTIVE MEASURES: Route Sheets will be revised to allow all welders performing welding to be identified. Verification of compliance to IP-500 and related procedures to be verified by Internal Audit and follow-up on Cor'ective Action Request.
COMPLETION DATE: November 30, 1980 All welders identified on Route Sheets. Revised Route Sheets implementation to be complete June 30, 1981.
G. FINDING: A defective weld was removed and replaced without rejection and documentation on an Inspection Report. Disposition was made by Quality Control Supervision of a dimensional nonconformance without submission of the Inspection Report to the Material Review Board for review.
CORRECTIVE ACTION: A Corrective Action Request has been issued to the Q.C. Supervisor requiring that all defective welds be put on a Inspection Report and that all Inspection Reports on ASME Fabrication be submitted to-the Material Review Board. In addition, a ASME Fabrication Recork Record has been developed and implemented to better document any recork on a ASME fabrication.
PREVENTIVE MEASURES: Complete implementation of Quality Control Procedure IP-500. Implementation of ASME Rework Record Form and verification of the program implementation through the Internal Audit program.
COMPLETION DATE: January 2, 1981 H. FINDING: Weld was observed to contain an area with less than a required 1/4 inch fillet resulting from a fit-up condition.
CORRECTIVE ACTION: The welds observed had not been final accepted by a weld Inspector although initial NDE had been accomplished. Welds in question were documented on an Inspection Report for MRB Review, desposition and rework. Final acceptance of welds must be by a Weld Inspector, not the NDE Technician assigned to perform any Magnetic Particle or Liquid Penetrant Testing. e PREVENTIVE MEASURES: A Corrective Action Request was issued to the Q.C. Supervisor requiring that Weld Inspectors be instructed in the requirements of IP-500 and that they specifically starp and date all
7_
- items accepted on Route Sheet operations. Additionally, Weld Inspectors have been scheduled for training in Weld Inspection and have been given eye examinations.
COMPLETION DATE: December 1, 1980 for correction of undersized fillet welds. April 30, 1981 for training of Weld Inspectors.
I. FINDING: Inspection acceptance stamps had not been entered for operations on the Production Route Sheet, nor had Inspection Reports been prepared to denote a rejected condition after inspection.
CORRECTIVE ACTION: By issuance of a Corrective Action Request Inspectors have been instructed to stamp and date all accepted operations on Production Routing Sheets at the time of acceptance. Items not acceptable after inspection are documented on an Inspection Report and submitted to the tbterial Review Board for disposition.
PREVENTIVE MEASURES: Implementation of Quality Control Procedure IP-500, specifically, Section 4 to be verified by follow-up of Corrective Action Request and Internal Audit.
COMPLETION DATE: December 10. 1980
Docket No.. 99900334/81-01 g r. W . M Transmeerica Delaval. Inc.
ATTN: Mr. R. E. Boyer Quality Assurance Manager
- 550 85th Avenue Oakland, CA 94621 Gentlemen:
This si to confim the telephone conversation on March 19, 1981 by Mr. V. H. Hunter of this office with you, concerning the inspection at the Oakland, CA plant on April 6, 7, and 8, 1981.
The NRC inspector will be Mr. V. H. Hunter.
The inspection will relate to implementation of your QA program.
Your cooperation concerning this matter will be appreciated.
Sincerely, cos. . > . . t r D.: stu:s;c-Uldis Potapovs. Chief Vendor Inspection Branch Jisaceao39 %
1F o,,,up gym Neag(gff .
l . ....
- DEWhitese11 - UPotapovs - -
suaNAME kVHHunte, r/rf
... . >..n
~=c.-,,,,,,~,..,. _
sw a n.
y g . m ~,. ~,,~ _
.,,,cy ,_,7,..,3.,
gg g?s O Docket No. 99900334/80-01 Transamerica Delaval. Incorporated Engine and Compressor Division ATTN: Mr. D. H. Martini Vice President and General Manager 550 85th Avenue Oakland, CA 94261 Gentlemen:
Thank you for your letter of February 10,1981, in response to our letter dated January 22, 1981. As a result of our review, we find that additional infomation is needed on the following items in the Notice of Deviation:
Item A: Please describe what documented actions have been taken to assure implementation of Quality Control Manual require-ments in regard to new tools and gages.
Item C, E, F, G I: Please describe what documented actions have been taken to assure inclusion of these items in the internal audit program.
Please provide this additional infomation within 25 days from the date of this letter in order that we may complete our review.
l Sincerely.
^
Uldis Potapovs Chief Vendor Inspection Branch
- - O 06l20 2 F D
' 6' ' 4 VIB:RIVM M, .dk. s / !
.WEVe
. .'(({[/ tollins o r ric e )I. ' IBarnes UPotipov... te/
2/&/81 2/j-/A1 t/81-5-5hWEFoster/rf 2/26/81 2/381- '
- j. -~~ ~~ '~~ -
-- - oue>!.. . . , , e. z, i m n , m. , . , , , , , , , ,m , , , < . , , , , . , , , . x ,
.