ML20213A423
| ML20213A423 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/22/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20213A334 | List: |
| References | |
| 231.1(B), 231.1(B)-R02, 231.1(B)-R2, NUDOCS 8702030270 | |
| Download: ML20213A423 (14) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 231.1 (B)
SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 2 TITLE: FIRE PROTECTION DESIGN Undersized Distribution Headers PAGE 1 0F 13 REASON FOR REVISION:
- 1. Revised to incorporate additional TVA connents and corrections per H. Mahlman/L Damon phone conference of 11/05/86.
- 2. Revised to incorporate TVA SRP and TAS comments; and to add Chronology; Section 10, Corrective Action; and CATD List.
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ECSP MANAGER i-m7 DATE Ri-MANAGER OF NUCLEAR POWER DATE S@a CONCURRENCE (FINAL REPORT ONLY)
, *SRP Secretary's signature denotes SRP concurrences are in files.
e 1 TVA EMPLOYEE CONCERNS REPORT NUMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 13
- 1. CHARACTERIZATION OF ISSUE (S):
Concerns: Issues:
BNP-QCP-10.35-8-16 a. Change in pipe size could result "CI concerned that welding small- in flow restriction.
ler diameter pipes to larger di-ameter pipes in FPS could restrict b. Fire insurance company review and the flow of water. He would documentation needed to confinn feel much better if he could compliance with specifications, see a docuent from an insurance company or sme reliable author- c. The HPFPS piping is undersized for ity stating that the system the amount of sprinklers, cmplied with specifications."
- d. HPFPS pipe sizing is not in IN-85-010-004 accordance with NFPA requirements.
" Problem with fire protection piping design in Unit #1.
CI gave this example: Unit 1, Aux. Bldg, Elev. 692', under-sized fire protection piping for the amount of sprinklers being fed by line. EG: 5 sprinkler heads on a 1" line being fed by a 1-l /4" lines.
CI feels that this design does note meet fire protection codes."
IN-85-534-002
" Fire protection lines do not meet NFPA code, both units.
See supply lines are 1/2", which is too small. Example: Located in fresh air handling rom aux.
bldg Unit 1. 30' fra air lock to reactor Bldg, on left, 713' Elevation."
1101d (01/07/87) l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 13 IN-85-534-001
" Fire protection system not installed per NFPA code require-ments. Many lines have too many sprinkler heads for the pipe size (e.g. more than 10 heads on 2" pipe, or more than 5 heads on 1-1/2" pipe); Eg wrong pipe size in unit 2 Aux., 713 ele.
'gowesttowardreactor,runof 1 pipe at corner before wall with mezzanine over it.'"
- 2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by Sequoyah Special Report 84-08 Date 12/19/84 Documentation Identifiers:
TVA letter (P. R. Wallace) to USNRC, "TVA SQN #1 & 2 Docket Nos.
50-327 & 50-328 - Facility Operating License DPR-77 & DPR-79, Special Report 84-08, Appendix R" (12/19/84)
- 3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.
Fire Protection Suppression System (FPSS)
- 4. INTERVIEW FILES REVIEWED:
BN P-QCP-10. 35-8-16 IN-85-101 -004 IN-85-534-002 IN-85-534-001
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
1101d (01/07/87)
TVA EMPLOYEE CONCERNS REPORT NtMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 13
- 6. WHAT REGULATIONS, LICENSING C0f94ITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
- 8. EVALUATION PROCESS:
- a. Addressed concern BNP-QCP-10.35-8-16 as related to SQN by establishing line sizing requirement for branch connections and the existence
- of fire protection insurance inspection and coverage.
- b. Verified the existence of a program to bring SQN into compliance.
- c. Established that any deficiencies noted as a result of Step b above are being addressed and that corrective action is being taken,
- e. Confirmed that any generic WBN concerns will be included in the SQN effort to comply with 10CFR50 Appendix R and NFPA 13.
- f. Assessed the validity of the concern and addressed any outstanding issues.
- 9. DISCUSSION, FINDINGS AND CONCLUSIONS Chronology:
12/19/84: TVA issues Special Report 84-08 identifying modifications necessary to bring portions of FPSS into compliance with NFPA 13 01/05/85: TVA issues SCN L6319 to correct deficiencies in fire protection systems 03/28/85: TVA issues memo recognizing need to perfonn hydraulic calculations for fire protection systems 1101d (01/07/87)
i TVA EMPLOYEE CONCERNS REPORT NtMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NIMBER: 2 PAGE 5 0F 13 05/17/85: TVA issues Revision 1 to Special Report 84-08 advising of deficiencies revealed by calculations and committing to an interim fire watch 06/14/85: TVA receives first WBN employee concern relating to fire protection systm 06/23/86: TVA receives BLN employee concern relating to fire protection system which was subsequently detemined to Le generic to SQN 08/12/86: NRC issues letter reporting cmpletion of Phase 1 of program to bring FPSS into compliance with NFPA 13 and NRC guidelines Discussion:
Concern BNP-QCP-10.35-8-16 was raised on BLN but also relates to the SQN Fire Protection Suppression System (FPSS) flow capacity in small diameter piping take-offs from larger diameter headers.
Assming the header (i.e., the " larger diameter pipes" referred to in the concern) is adequately sized, it presents essentially an infinite capacity to the branch (i.e., the " smaller diameter pipes") lines. Whether or not the branch lines have adequate
( capacity depends upon the neber and size of sprinklers each branch line must serve. The National Fire Protection Association (NFPA)
Code establishes pipe size / service design parameters to ensure that these conditions are met. This concern, therefore, becmes one of cmpliance with NFPA code pipe sizing requirements.
The sizing of sprinkler system distribution headers in accordance with NFPA code requirements may be accomplished by one of two methods: " Pipe Schedules Method" (NFPA 13. Section 3-4) or the
" Hydraulic Calculation Method" (NFPA, Chapter 7). The Pipe Schedule Method allows for conservative sizing on the basis of i restrictive tables, limitations on orifice size (1/2-inch only),
and sprinkler quantity to pipe size ratios. The inherent conservatism of the Pipe Schedule Method allows for acceptable sizing in the absence of docuented calculations.
The SQN Fire Protection System was initially designed in accordance with NRC Branch Technical Position (BTP) APCSB 9.5-1 and sized i using the NFPA-13 Pipe Schedule Method based on ordinary hazard occupancies. The NRC evaluated the SQN FPSS against NFPA-13 and NFPA-15, as well as BTP APSCB 9.5-1, and in their SER found that:
1101d (01/07/87) i _ _ _ _ _
TVA EMPLOYEE CONCERNS REPORT NtMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 13
" Fixed water spray systems and sprinkler systems are designed according to the requirements of NFPA Standard No.13, ' Standard for Installation of Sprinkler Systems,' and NFPA Standard No.15,
' Standard for Water Spray Fixed System. '"
The NRC further concluded that; "Our conclusion, given in Section VII, is that the Fire Protection Program at the Sequoyah plant was adequate and met General Design Criterion 3.
However, to further ensure the ability of the plant to withstand the damaging effects of fires that could occur, we required and the applicant has committed to provide additional fire protection system improvements. These additional fire protection features have been completed for Unit 1 and will be completed for Unit 2 prior to Unit 2 fuel load."
Aside from the NRC, SQN has also been inspected by specially trained personnel working for the insurance underwriters, American Nuclear Insurance of Fannington, Connecticut. This independent review, called a " Candidate Inspection," includes a physical walkdown of the unit. A finding of general compliance with NFPA requirements is a prerequisite to obtcining property insurance.
SQN was issued Policy Nisnber 5001 based on such an inspection confinning compliance with NFPA. Part of the requirements for retaining such coverage is a re-inspection every 6 months with a finding of general compliance and TVA's making adjustments /
improvements in any areas suggested. In a 10/08/86 telephone conference with Ms. Vicki Dudley, TVA Nuclear Insurance Program Manager, the evaluator established that the insurance has never been cancelled and is in effect at this time.
i With the advent of 10CFR50.48 and Appendix R, TVA found it i necessary to retrofit certain portions of the SQN FPSS protecting i
safety-related equipment to meet the new requirements. This effort, initiated by SQN-DCR-D-2133, necessitated a series of walkdowns on a phased basis as described in H. L. Abercrombie's 12/07/84 memo. The first phase included compliance with NFPA-13 criteria where fire suppression capability was required to meet Appendix R separations requirements while the second phase continued the effort to the remaining plant areas containing safety-related equipment. These remaining areas either do not contain Appendix R required equipment or Appendix R requirements were met by fire barriers without dependence upon suppression systems.
1101d (01/07/87)
TVA EMPLOYEE CONCERNS REPORT NtMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 13 On 12/19/84, TVA issued Special Report 84-08 to the NRC advising that portions of the FPSS ". . . do not comply with the literal requirements of NFPA Standard 13, as committed to in the Fire Protection Program submitted and the SER Supplement I." Following this report, ECN L6319 was issued in January 1985 to continue the compliance efforts. In his memo of February 14,1985, J. P.
Vineyard expanded and clarified these efforts to include the following activities:
"(1) The 'As Constructed' location of the modified or added heads will be located on drawings which currently show the 'As Designed' location of sprinkler heads.
(2) 'As Constructed' locations of sprinkler piping which is added or relocated will be included in calculation packages as sketches.
(3) Calculations will be perfonned to provide a design basis for the sprinkler heads being moved significantly, or added.
(4) Modifications to sprinkler piping 2 inches and larger will be shown on design drawings."
This memo was explicit in that only the " modified /added heads" would have their adequacy confimed by hydraulic calculations and recommended that the scope of DCR 2133 be expanded to:
- 1) Perform hydraulic calculations to confim the HPFPS adequacy using "as constructed" drawings and to
, 2) Provide Quality Assurance level documentation of such
! adequacy.
J. P. Vineyard followed this up with an 03/28/85 memo to H. B.
Rankin in which he advised that, as a result of additional walkdowns and calculation work, ". . . the present piping cannot provide the required flow / pressure demands." This 03/28/85 memo confinned the need to perform the hydraulic calculations. ,
Revision 1 of SQN Special Report 84-08 to the NRC was filed shortly thereafter (May 17, 1985). This revised Special Report also ". . .
detennined that there were potential hydraulic deficiencies associated with the sprinkler system" and concluded with the l
l 1101d (01/07/87)
. l TVA EMPLOYEE CONCERNS REPORT NUMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 l
PAGE 8 0F 13 comitment that ". . . roving fire watches will continue until the sprinkler systems are modified to correct hydraulic deficiencies or until TVA can justify that deficiencies do not exist under current system configuration and level of corrosion build up."
Phase 1 of the SQN separations / fire protection compliance program is complete. In the attachment to their 08/12/86 letter on this subject the NRC concluded:
"(Closed) Special Report 327 and 328/84-08, Sprinkler System Modifications. TVA's special reports, dated December 19, 1984 and May 17, 1985, identified a neber of modifications required to bring the auxiliary building automatic sprinkler systems into compliance with the requirements of NFPA-13, Automatic Sprinkler Systems. These modifications required relocating approximately 418 sprinkler heads, removal of approximately 400 sprinkler heads and the installation of approximately 226 additional sprinkler heads.
Also, the sprinkler systems for Units 1 and 2 elevations 734', 749' and 759' have been provided with additional flow paths to assure adequate pressure and flow are available to these areas.
The system for each unit area, i.e., a system for each unit, is now supplied from the original four-inch feed main and a new six-inch feed main.
The two feed mains to each system are provided with preaction valves. The two valves to each system are activated simultaneously by the smoke detector system within each area. All sprinkler system l piping has been installed to meet TVA Class G piping support requirements for pressure retention following a seismic event. The inspector conducted a plant tour to review the new system installation and modifications. These modifications appear to bring the systems into compliance with NFPA-13 and l the NRC guidelines. Therefore, this item is closed."
Phase 2 continues the NFPA-13 compliance activity into the remaining plant areas containing safety-related and other equipment is in progress. The Plant Restart effort has priority over the continuation of the program into remaining fire protection system areas. Internal TVA docuentation indicates a concerted effort to close this issue out entirely. The NRC is also monitoring progress in the Phase 2 program.
l
! 1101d (01/07/87)
TVA EMPLOYEE CONCERNS REPORT NIMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 13 The Watts Bar concerns, IN-85-010-004, IN-85-534-001, and IN-85-534-002, cite specific cases of sprinkler system sizing unique to WBN as well as the more generic issues of the NFPA code compliance. Two investigative reports ( App. A, 5.a and 5.b) relating to the WBN concerns found that the issues were not valid for several reasons specifically relating to WBN. These reasons were based on the " Hydraulic Method" pipe sizing used on WBN and therefore do not apply to the generic NFPA sizing concern for SQN since SQN used the " Pipe Schedule" methods. As explained above, however, these WBN generic pipe sizing concerns are being addressed as they apply to SQN.
Findings :
The conservative NFPA-13 " Pipe Schedule Method" was used to size the FPSS piping. This method ensures that main headers have sufficient capacity to support branch lines and that branch lines are large enough to meet their service requi rements. The NRC's SER found this design adequate and licensable.
- b. Independent inspections by fire protection specialists were performed to obtain insurance. The insurance is in effect at this time. Independent reviews of SQN for NFPA compliance are conducted on a semi-annual bases by specially trained and certified personnel on contract to the fire insurance underwri ter.
- c. The initial SQN FPSS must be upgraded to meet newer (10CFR50.48 and Appendix R) regulatory requirements. TVA has l a two-phased program in place at Sequoyah to accomplish this. As part of this program, TVA is perfonning system walkdowns and identifying areas requiring modifications.
As-built drawings reflecting the present system and any necessary modification are being generated. Hydraulic calculations based on these as-built drawings are being performed to confina compliance with NFPA 13 header sizing and sprinkler density requirements.
- d. Phase 1 of this program, which addresses portions of the FPSS necessary to meet Appendix R criteria is completed and has been accepted by the NRC. Additional piping has been installed to bring the pipe sizing into compliance with NFPA-13. Phase 2 will continue this effort to additional l plant areas. Phase 2 is in progress.
1101d (01/07/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 13
Conclusions:
The concerns raise legitimate issues regarding the SQN FPS capability to protect safety-related equipment in compliance with current regulatory and NFPA requirements. These issues are well known within TVA and have been reported to the NRC. An extensive program of corrective action was initiated to bring the SQN FPS into compliance. This program is being audited closely by the NRC and is presently nearing completion.
In addition to NRC review to ensure regulatory compliance, the SQN FPSS adequacy is independently inspected for compliance with specifications by the fire insurance underwriter on a semiannual basis. No unresolved safety issues were discovered during the evaluation of these concerns.
- 10. CORRECTIVE ACTION TVA has subnitted a corrective action plan (App. A, 5.p) which includes commitments to (a) revise drawings to reflect Phase I modifications already made to FPSS and (b) to complete program to upgrade FPSS to conform to NFPA 13 and NRC guidelines. The corrective action is satisfactory to the evaluation team.
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1 110ld (01/07/87)
TVA EMPLOYEE CONCERNS REPORT NIMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 11 0F 13 APPENDIX A
- 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
- a. NSRS Investigation Report No. I-85-396-WBN, Employee Concern IN-85-534-001, (Report approved by N. A. Harrison 10/09/85)
- b. NSRS Investigation Report No. I-85-454-WBN, Employee Concern IN-85-534-002 (Report approved by M. A. Harrison 10/22/85)
- c. Letter from NRC, O'Reilly, to TVA (A02 840817 001), SQN Docket Nos. 50-327 and 50-328 "Confinnation of Action,"
(08/10/84)
- d. TVA memo from Campbell to Vineyard, (SQP 840914 014),
SQN - SQ-DCR D2133, (09/12/84)
- e. Letter from TVA, Domer, to NRC, (L44 841109 806), (11/09/84) 1
- f. TVA memo from Abercrombie to Those Listed, (S01841203 910),
SQN - Appendix R " Fire Protection Suppression System Walkdown," (12/07/84) 9 Letter from TVA, Damer, to NRC, (L44 841218 800), "SQN Docket No.s 50-327 and 50-328," (12/18/84)
- h. Letter from TVA, Damer, to NRC, (L44 841221 804), (12/24/84)
- 1. ECN L6319 (B25 851101 507)
- j. TVA memo from Vineyard to Rankin, (SQP 850214 012), SQN - DCR 2133 - ECN 6319 " Additions and Modifications to Sprinkler Systems," (02/14/85)
Appendix R "High Pressure Fire Protection (HPFP) Design and Modification Work Under ECN-L-6319," (03/28/85)
Docket Nos. 50-327 and 50-328 " Facility Operating License DPR-77 and Special Report 84-08 Revision 1, Appendix R," (05/17/85)
- m. SQN Safety Evaluation Report, Section 9.5, " Fire Protection Systems"
- n. American Huclear Insurers, Insurance Inspection Report, TVA SQN 1 & 2, Property File No. NS-23, (02/17/82) l 1101d (01/07/87) l
~ TVA EMPLOYEE CONCERNS REPORT NUMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 12 0F 13 APPENDIX A (Cont'd)
- o. American Nuclear Insurers, Insurance Inspection Report, TVA SQN 1 & 2, Property File No. N-229, (03/25-27/86)
- p. TCAB-016, Corrective Action Plan for Element Report 231.01, (11/26/86)
- 6. WHAT REGULATIONS, LICENSING COMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
- a. 10CFR50.48, " Fire Protection"
- b. 10CFR50 Appendix A, " General Design Criteria"
- c. 10CFR50 Appendix R, " Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979"
- d. NRC Branch Technical Position - Auxiliary Power Conversion System Branch BTP APCSB 9.5-1, " Guidelines for Fire Protection for Nuclear Power Plants," (05/76)
- e. Appendix A to BTP APSCB 9.5-1, " Guidelines for Fire Protection of Nuclear Power Plants Docketed Prior to July 1, 1976," (08/76)
- f. NFPA 13, Standard for the Installation of Sprinkler Systems
- 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
- a. Telecon from S. Presser, Bechtel, to H. Mahlman, TVA, IOM l #512, (09/08/86)
- b. Telecon from D. Drouhard, TVA, to S. Presser, Bechtel, IOM
! #513, (09/09/86)
- c. RFI #SQN 541
- d. Telecon from L. Damon, Bechtel, to V. Dudley, TVA, IOM #514 (10/06/86)
I 110ld (01/07/87) l l
TVA EMPLOYEE CONCERNS REPORT NLMBER: 231.1 (B)
SPECIAL PROGRAM REVISION NLMBER: 2 PAGE 13 0F 13 CATD LIST The following CATD identifies and provides corrective actions for the findings included in this report:
231.1 SQN 01 (11/18/86) 1101d (01/07/87)
ill .
0,
-) .
REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE -
123 g FREQUENCY - REQUEST OFFICE OF NUCLEAR PONER RUN TIME - 12:57:19
.I ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 23101 UNDERSIZED DISTRIBUTION HEADERS 1 S GENERIC KEYNORD A H APPL QTC/ NSRS P KEYHORD B .
CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C CAT D LOC FLQB REPORT DESCRIPTION KEYHORD D
) NUMBER CAT R SR PROBLEM HITH FIRE PROTECTION PIPING DESIGN PROCESS IN 010-004 EN 23101 N HBN NNYY IN-85-010-004 T50029 REPORT DESIGN IN UNIT 81. CI GAVE THIS EXA SPECIFICATIONS MPLE: UNIT 1, AUX BLDG, ELEV. 692', U ENGINEERING 3 NDERSIZED FIRE PROTECTION PIPING FOR FIRE PROTECTION THE AMOUNT OF SPRINKLERS BEING FED BY LINE. EG 5 SPRINKLER HEADS ON A 1" LINE BEING FED BY A 1 1/4" LINE.
C) CI FEELS THAT THIS DESIGN DOES NOT MEET FIRE PROTECTION CODES IN 534-001 EN 23101 N HBN NNYY I-85-396-H5N SR FIRE PROTECTION SYSTEM NOT INSTALLED STANDARDS
) T50115 REPORT PER NFPA CODE REQUIREMENTS. MANY L NONCONFORMANCE SYSTEMS INES HAVE TOO MANY SPRINKLER HEADS F OR THE PIPE SIZE (E.G. MORE THAN 10 FIRE PROTECTION HEADS ON 2" PIPE, OR MORE THAN 5 HEA
) DS OH 1 1/2" PIPE); EG HRONG PIPE SI ZE IN UNIT 2 AUX., 713' ELE. "GO HES T T0HARD REACTOR, RUN OF 1" PIPE AT CORNER BEFORE HALL HITH MESSANINE OV
) ER IT" CI HAS NO FURTHER INFORMATION
. CONSTRUCTION DEPARTMENT CONCERN.
APPLICABLE TO BOTH UNITS. NO FOLLO H UP REQUIRED.
) IN 534-002 EN 23101 N HBN NNYY I-85-454-HBN SR FIRE PROTECTION LINES DO NOT MEET NF STANDARDS T50135 REPORT PA CODE, BOTH UNITS. SOME SUPPLY LI NONCONFORMANCE NES ARE 1/2", HHICH IS TOO SMALL. E SYSTEMS
) XAMPLE: LOCATED IN FRESH AIR HANDLIN FIRE PROTECTION G ROOM AUX BLDG UNIT 1. 30' FROM AIR LOCK TO REACTOR BLDG, ON LEFT, 713' EtEVATION. CONSTRUCTION DEPT CONCE
> RN. CI HAS NO FURTHER INFORMATION.
QCP10.35-8-16 EN 23101 N BLN YYYY SR CI CONCER!IED THAT HELDING SMALLER DI REPORT AMETER PIPES TO LARGER DIAMETER PIPE J S IN FPS COULD RESTRICT THE FLON OF HATER. HE HOULD FEEL MUCH BETTER IF
"" HE COULD SEE A DOCUMENT FROM AN INS URANCE COMPANY OR SOME RELIABLE AUTH ORITY STATING THAT THE SYSTEM COMPLI ED HITH SPECIFICATIONS.
4 CONCERNS FOR CATEGORY EN SUBCATEGORY 23101 o
e