ML20235G575
| ML20235G575 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/06/1987 |
| From: | Levin H, Sanan R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| References | |
| CON-#387-3985 OL, NUDOCS 8707140301 | |
| Download: ML20235G575 (25) | |
Text
l SW Filed:
July 6, 1987
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'87 JUL -9 P 1 :49
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i UNITED STATES OF AMERICA l
NUCLEAR REGULATORY COMMISSION before the i
l ATOMIC SAFETY AND LICENSING BOARD l
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In the Matter of
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Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
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50-446-OL COMPANY et al.
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(Application for an (Comanche Peak Steam Electric
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Operating License) i Station, Units 1 and 2)
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l ANSWERS TO BOARD'S 14 QUESTIONS l
(Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report V.d 1
In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan V.d, Plug Welds.
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8707140301 G70706 l
PDR ADOCK 05000445 (LEE $?>
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Opening Request:
i Produce copies of any CPRT-generated checklists that were used during the conduct of the action j
plan.
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Response
The attached ERC procedure QI-007 was developed
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for detecting the plug welds.
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Question:
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Describe the problem areas addressed in the report.
Prior to undertaking to address those areas through sampling,.what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it discover j
about the QA/QC documentation for those areas?
How extensive did it believe the. problems were?
Response
This action plan was prepared to respond to NRC/TRT's expressed concern about alleged generic problems regarding uncontrolled repairs to holes existing in pipe supports, cable tray supports and base plates in Units 1 and 2.
The TRT felt that since these supports are Seismic Category I supports and the effects of the welds had not been evaluated, this constituted a violation of Criteria IX and XVI of Appendix B to 10 CFR 50.
The TRT stated that although the effects of unauthorized, undocumented and uninspected plug welds in some locations will be 1
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inconsequential, their effects in critical locations in critically loaded supports or base plates could affect j
l their structural integrity and intended function, and therefore, requested that TU Electric perform sample inspections of cable tray supports, pipe supports and 1
base plates for plug welds quality, or perform bounding analyses of the generic effects of uncontrolled plug
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1 welds on the structural integrity vf these components.
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1 Prior to undertaking the sampling program, TU l
Electric performed tests and presented to the ASLB test I
data that was consistent with NRC staff testimony that if the plug weld was made well enough not to be readily discernible after surface grinding, the weld and the surrounding base metal are at least as strong as'the original base metal.
In addition, TU Electric
<j determined from a review of practices and procedures that the repair of mislocated holes in cable tray supports was generically authorized by Engineering in i
Design Change Authorization DCA-5347.
The problem addressed in this ISAP arose because of the apparent lack of adequate documentation of the repair of mislocated holes; the failure to report and j
investigate an instance of unauthorized repair of a l
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I mislocated hole in pipe supports, and the ASLB's consideration that this issue was a violation of certain criteria of 10 CFR 50 Appendix B.
A review of QA/QC documentation determined that:
a.
The current procedural requirement for the inspection and documentation for plug weld repairs of the mislocated holes in cable tray supports is in compliance with the QA program and licensing commitments.
b.
Previous procedures which inspected and documented the plug weld repairs in cable tray supports in Construction Operating Travelers or in inspection reports were in compliance with QA/QC procedures then in effect.
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The only practice which was s
i considered a violation of 10 CFR 50 Appendix B requirements was the use of temporary acceptance stickers prior to December 1979.
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The cable tray support inspections indicated that less than 7% of the cable tray supports have'one or more plug welds for which weld inspection records are no longer available,_that no undocumented plug welds were found on supports initially accepted by QC after l
December 1979, and that all plug welds found, both documented and undocumented, meet AWS D1.1 visual inspection criteria.
Thus, the problem is not considered to be extensive because the lack of permanent plug weld inspection records appears to be l
limited to a small portion of the population, and the presence of plug welds does not adversely affect the j
structural integrity of support members.
Question:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.
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Response
l ERC procedure QI-007 delineates the technique and methods used in the reinspection of supports to detect plug welds. j
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3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
Response
ERC procedure QI-OO7 differs from the original inspections in the following ways:
a.
Detection of the plug weld in this inspection was made chrough the paint using oblique light.
However, since the paint was then removed from the weld area, t
the inspection of the weld was made in the j
I same manner as the original inspection.
b.
Supports were considered accessible for reinspection when they had a minimum of 75% of their surfaces clear for inspection.
c.
Supports that are encased or concealed due to uncontrollable circumstances were considered inaccessible for reinspection.
d.
A team of two inspectors was used to reinspect each selected support, rather than a single inspector, in order to - _________ - -_-- _
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accomplish a' higher detection rate.
j Question:
4.
Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.
Response
Procedure QI-007 contained all the code requirements for visual' inspection of the welds.
Question:
5.
(Answer question 5 only if the answer to question 4 is that the checklists do contain fewer attributes.)
Explain the engineering basis, if j
any, for believing that the safety margin for components (and the plant) has not'been degraded by using checklists that contain fewer attributes than are required for conformance to codes.
Response
This question is not applicable by reason of the answer to above question.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Response
No changes were made to the inspection process; although, a second reinspection was performed in order to improve the rate of detection of plug welds.
Each support selected for reinspection as part of this action was reinspected in June / July of 1986 by a team _ - - - _ - _.
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l of two inspectors, whereas the first reinspection were performed by individual inspectors.
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Question:
1 7.
Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other
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practical-training.
If the training has changed or retraining occurred, explain the reason.for the changes or retraining and set forth changes j
in duration or content.
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Response
In addition to procedural training, Third Party (ERC) level II inspectors were also trained in detecting the plug welds on simulated supports erected in the welding shop.
After training, the inspectors were tested and the inspectors / inspector teams with the best scores were selected for inspecting / detecting the plug welds.
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Provide any information in Applicants' possession concerning the accuracy of use of the checklists (or the inter-observer reliability in using the checklists).
Were there any time periods in which checklists were used with questionable training or QA/QC supervision?
If applicable, are problems of inter-observer reliability addressed statistically?._
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Response
A comparison between plug weld documentation and I
the final' detection rate of the trained inspectors determined that an accuracy of approximately 84% was accomplished.
(See also response to Question 11.)
There were no time periods in which the procedure was
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It was also not considered necessary to further establish the reliability of the third-party inspectors who performed the inspection beyond that i
established by the certifications and qualifications j
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identified in the CPRT files and by the training provided by the simulated support training test.
Question:
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) j of training or of use of the checklists.
Provide the factual basis for believing that the audit 1
and review activity was adequate and that each 1
concern of the audit and review teams has been resolved in a way that is consistent with the validity of conclusions.
Response
An audit was performed in the overall implementation-of ISAP V.d.
There were no non-conformances or observations issued concerning training or the use of checklists.
The i
inspectors who performed the inspections to detect the plug welds were trained and qualified in accordance with Qoc Review Team requirements.
The training records were audited by the QOC QA function and found to be satisfactory.
The. audits were performed'in accordance with established procedures.
Audit guidance is provided by the SRT in the Program Plan.
Question:
10.
Report any instances in which draft reports were modified in an important substantive way as the result of management action.
Be sure to explain any change that was objected to (including by an employee, supervisor or consultant)-in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.
Explain what the-earlier drafts said and why they were modified.
Explain how dissenting views were' resolved.
Response
No substantive modifications were made as a result of management action.
Question.
11.
Set forth-any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached.
How were each of these unexpected difficulties resolved?,
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Response
An unexpected difficulty was encountered when~after.
training on mockup supports (where the average detection i
rate for the mockups was 82%) the four-(4) inspectors.
i selected for the in-plant inspections detected only about 1
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42%'of the plug welds documented in the original inspection records for the sample of 120 cable tray supports.
This condition was resolved by repeating the reinspection using two (2) refresher-trained inspection teams, each consisting of two (2) inspectors.
only the lead inspector had participated in the-first reinspection and he did not reinspect any of the supports with'which'he had previously been involved.
This action resulted in a detection rate of about 84% of the documented welds'in the cable tray supports sample, as mentioned in response to 1
Question 7.
A second problem was encountered when an error was detected during a third-party audit of the random sample selection.
The impact of this-error was' evaluated by the third-party and the CPRT statistical consultant and was judged to have no effect on the final inspection results.
This was documented in the Results Report. L___-_-_---_-_______-___________
Question:
12.
Explain any ambiguities'or open items left in the Results Report.
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Response
As far as the issue.of plug welds is concerned, there are no open items.
However, three discrepancies. relating to leaving unused holes unplugged were transferred to the j
-Design Adequacy Program.
As'a result of directions provided by the SRT in letter CPRT-876, follow up and closure of these items will be the responsibility of an-SRT-directed l
activity.
Question:
13.
Explain the extent to which there are actual ~or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his-own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.
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Response
All the reviews, reinspection and analysis pertaining to this action plan were performed by the third-party personnel.
The work so performed by the third-party personnel was checked and approved by other third-party personnel.
There were no conflicts of interest.
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Question:
14.
Examine the report to see that it adequately discloses the thinking and analysis uced.
If the language is ambiguous or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.
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Response
-l The Issue Coordinator, and others who aided in the preparation and approval of the Results Report, have reviewed and checked the report for clarity and believe that there are no ambiguities.
Respectfully submitted, aus r
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R.
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Sanan Act, ion' Plan V.d IssupCoordinator
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bI remu r MdWafd A.
Levi'n ' '"
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Review Team Leader
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i The foregoing responses have been reviewed and are l
concurred in by the CPRT Senior Review-Team.
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Pege 1 of 5 "
1 EVALUATION RESEARCH CORPORATION i
FORliiFORMATl0NSEY l
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COMANCHE PEAK RESPONSE TEAM QUALITY INSPECTION FOR ISSUE-SPECIFIC ACTION PLAN V.d
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i INSTRUCTION NO.:
QI-007 REVISION:
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l EFFECTIVE DATE: 04/24/86 l
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REINSPECTION OF PLUG k'E1.DS 1
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l f,/r2,/f6 Prepared By:
Date:
Ub Date: !-/.88MIP Approved By:
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-s ction Plan Issue Coordinator
+@k Approved By:
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S/S edd Date:
J-80 On-Site QA Represent ive 3hb WM/S C
Date:
Approved By:
QA/QQ' Review Team Leader
QI-007 l
Rev. 4 1.0 PURPOSE l
The purpose of this procedure is to provide detailed instructions for the location and inspection of weld repaired misdrilled holes (Plug Welds) in cable tray supports, pipe supports, and base plates.
2.0 APPLICABILITY This procedure shall apply only to those supports or base plates which are' I
selected for reinspection in accordance with the random sampling plan as l
outlined in the Issue Specific Action Plan V.d for the Flug Welding Issue.
j This procedure is not applicable to vendor supplied components which have predrilled hole l
3.0 kEFERENCES j
2 3.1 TRT Action Plan Number V.d Rev. 2.
I 4.0 GENERAL 1
I 4.1 Responsibility 4.1.1 Responsibility for the implementation of this procedure is as follows:
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Reinspection - ERC Paint Removal / Acid Etch - Brown & Root Construction i
l Engineering Evaluation & Analysis - TUGC0 Engineering l
Randon Sample Selection - TUGC0 Issus Coordinator l
Overview - TERA (third party) l 4.1.2 Evaluation Research Corporation (ERC) is responsible for the implementation of this instruction.
ERC personnel shall perform the reinspection in accordance with this Quality Instruction and shall be trained and shall satisfactorily demonstrate their proficiency in accordance with Attachment 6.2 of this Q.I.
l All training shall be documented per ERC procedure CPP-003 (Indoctrination Training,* and Certification of Personnel).
I Inspectors shall receive training in the requirements and shall satisfactorily demonstrate their proficiency in accordance with Attachment 6.2 of this procedure.
Personnel performing inspections to this procedure shall be certified Level II Inspectors and meet the education and experience requirements in accordance with ANSI N45.2.6, 1978 and Reg. Guide 1.58.
The lead inspector shall be a certified Level II Welding Inspector.
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Q1-007 R:v. 4 4.1.3 A list of the random samples and drawings for supports and base plates to be inspecte.d in accordance with this instruction shall be provided to ERC by the TUCCO Issus Coordinator. ERC will notify TUGC0 of any support or base plate that is determined to be not accessible and request an alternate support be selected.
4.1.4 The criteria for evaluation of accessibility of supports within the sample shall be as follows:
accessible supports shall here a minimum of 75% of their surfaces clear for examination. Insulation,
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except bonded insulation, shall be removed to provide access for examit.ation.
supports that are covered by bonded insulation shall be considered inaccessible.
l supports emersed in fluida or otherwise concealed due to uncontrollable circu, stances shall be considered a
inaccessible.
Supports that are evaluated to be inaccessible shall be deleted from the Sample and repisced by an aly",Re support.
Records shall be maintained to document the accessibility evaluation.
5.0 PROCEDURE l
5.1 Utilizing a calibrated Dry Film Ihickness Gage, a measurement of paint thickness shall be performed on each hanger and/or base plate selected for inspection. The technique and acceptance criteria for paint thickness measurement shall be in accordance with Attachment 6.3 of this procedure.
5.2 Those supports which have unacceptable paint thickness per attachment 6.3 shall have the paint stripped prior to inspecting for repaired holes, except in the case of tube steel where the inside surface is not painted and is actessible for visual examination.
5.3 It shall only be necessary to remove paint from those areas of the support identified as unacceptable per attachment 6.3.
5.4 Where the paine thickness exceeds tha maximum as described in 5.2 above the inspector shall Unsat the paint thickness attribute on the i
Inspection Report for that support and indicate the high spot (s) on the support drawing attached to the report and forward the report to the designated TUGC0 Issue Coordinator for paint removal in accordance with construction procedures. Additionally, the inspector shall circle the high spot (s) on the support and mark it with a "P".
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QI-007 Rev. 4 5.5 If paint thickness is within acceptable limits or has been removed, inspection of the support and/or base plate shall be accomplished by examining all accessible surfaces by holding a light at an oblique angle to the surface in order to locate any repaired misdrilled holes.
5.6 The inspector shall circle the suspected repaired hole on the support and mark it with a "W", record each suspected repaired hole only on the drawing then forward the copy of the. drawing to the TUGC0 Issue Coordinator.
5.6.1 Upon receipt of the drawing from the inspector for' a support, the TUGC0 Issue Coordinator. shall have the paint removed from the suspected repaired holes recorded on the drawing. An seid etch shall then be perforand to conclusively determine
'T the existence of repaired misdrilled holes. Acid etch shall be performed in accordance with B&R WEI-9.
5.6.2 Upon completion of the acid etch the TUGC0 issue Coordinator shall direct the lead inspector to examine tha suspected areas and record the number and location of the-
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weld repaired holes on the Inspection Report.
5.7 Weld Inspection Once existence of a weld repaired misdrilled hole is confirmed, a visual inspection of the weld shall be performed in accordance with the final visual inspection criteria listed 1
in 5.8 for cable tray and Non-ASME pipe supports.
Inspection J
of repaired misdrilled holes in ASME supports shall be in accordance with the criteria listed in 5.9.
5.8 Weld Surf ace Cable Tray And Non-ASME Pipe Supports 5.8.1 The inspection criteria for cable tray and non-ASME pipe supports is in accordance with the requirements of AWS D1.1-75.
5.8.2 All welds shall be free from cracks.
5.8.3 Thorough fus, ion shall exist between weld metal and base metal.'
5.8.4 Undercut shall not exceed 1/32".
5.8.5 The sum of. diameters of porosity shall not exceed 3/8" in any linear inch of weld.
5.9 Weld Surface ASME Fipe Supports.
5.9.1 The inspection criteria for ASME pipe supports is in accordance with ASME III, Subsection NT-1974 Edition, Winter 1974 Addenda.
5.9.2 Welds shall be free of cracks.
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QI-007 Rev. 4 5.9.3 Thorough fusion. shall exist between weld metal and base retal.
5.9.4 Undercut shall not exceed 1/32".
5.9.5 Indications with major dimensions 1/16" or less shall be con-sidered non relevant.
5.10 Inspection results shall be recorded on the Inspection Report (Attachment 6.1) which was previously used to document the location of the plug welds.
5.11 Completed Inspection Reports shall be forward to the TUGC0 Issue 4
' 'F Coordinator who shall obtain a copy of the documentation package for I
those supports containing repaireo holes and forward the package and inspection reports to Third Party Issue Coordinator for review.
Inspection Reports for supports which did not contain plug velds will also be forwarded to the Third Party Issue Coordinator.
Copies of the documentation package for these supports need not be forwarded.
6.0 ATTACHMENTS 6.1 Inspection Report, QI-007.1 6.2 Inspector Training 6.3 Paint Measurement 1
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INSPECTIONREP5RT 2nd INSPECTION
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SUPPORT NUMBER CABLE TRAT PIPE [
LOCATION INSPECTOR ELCOMETER SERIAL NUMBER CALIBRATION DUE DATE PAINT THICKNESS ACCEPTABLE [ U CCEPTABLE _
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PAINT REMOVAL NA _
ACCEPTABLE _ UNACCEPTABLE _
PERCENT SUPPORT INSPECTED
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SUSPECTED REPAIRED HOLES YES NO l
INSPECTOR'S SIGNATURE /DATE
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ACID ETCH ACCEPTABLE ~ 'ITNACCEPTABLE l
l REPAIRED HOLES IDENTIFIED TES NO NUMBER REPAIRED ROLES IDENTIFIED LOCATIONS * (INCLUDE ITEM f) l
- NOTE: If no item number is on drawing the inspector shall assign a number and initial and date.
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WELD INSPECTION ACCEPTABLE _ UNACCEPTABLE DESCRIBE INDICATIONS LEAD INSPECTOR'S SIGNAItTRE/DATE _
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Attache:nt 6.1 QI-007 Rev. 4 Psge 1 of 1
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Q1-007 Rev 4 i
Page 1 of 2 INSPECTOR TRAINING 1.0 PURPOSE The purpose of this Attachment is to provide an outline of the orientation to be given inspectors that will perform the exami-nations and inspections as described it Action Plan TRT V.d.
2.0 BACKGROUND
INSPECTION Potential inspectors shall be provided the background of the welding repair issue and the purpose and methodology of locating
~f misdrilled hole repairs. Action Plan TRT Y.d will be reviewed at j
this time.
3.0 PAINTED SAMPLES / DRY FILM CAGE l
Inspectors will be given the opportunity to observe samples of structural members which have welded. holes and have received several coats of paint. A demonstration as to the correct use of a Dry Film Thickness Cage for paint thickness measurement will be given.
i 4.0 FIELD TOUR
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Fotential Inspectors shall be given a tour of the plant area where i
they may observe cable tray supports with known misdrilled hole repairs, some of which are in a painted condition and some which have had the paint removed from the repair area and an acid etch performed.
5.0 DEMONSIMATION OF ABILITY Prior to being accepted to perform examinations and inspections in accordance with T5T Y.d. potential inspectors must demonstrate their ability to locate welded holes under shoulated field con-ditions. This will be accomplished by providing mock-ups of cable tray and pipe supports in fixed positions which have re-
' paired holes and have been painted. To successfully demonstrate ability the inspector must identify at least 75%
of the repaired holes in the mock-up supports and record the location on the drawing for the support.
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..2 QI-007 Rev 4 6.0 RECORDS OF TRAINING 6.1 The ERC Training and Certification Administrator shall prepare and maintain records.
l 6.2 Training records applying to QI-007 shall be included in the final documentation package for the inspection program.
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...3 QI-007 Rev 4 Page 1 of 1 1.0 PURPO$t The purpose of this Attachment is to outline the methods to be utilised by inspection personnel to measure paint thickness on f
supports and base plates selected for inspection in accordance with this procedure.
2.0 GENERAL 2.1 The inspector shall perform a Dry Film thickness measurement
,-W (DFT) of the coating utilising a calibrated 0-25 E1cometer Inspector DFT Gage Model 11~./15. or equivalent. Since the magnetic gage is sensitive to geometric discontionities in the steel, measurements less than 1 inch from an edge or a hole should be avoided where possible.
2.2 A spot measurement shall consist of a series of three messerements in the same genera (area. The probe shon14 be soved a short distance for each gage reading. Discard any unuseally high or low gage reading that cannot be repeated i
consistently. Take an average of the three sage readings as ojne, spot osasurement.
2.3 A spot measurement shall be taken on each accessible surf ace of structural members, to be inspected for plus welds.
3.0 ACCEPTANCE CRITERIA 3.1 Any paint thickness in excess of 15 mits shall be identified as unacceptable on the It and drawing.
3.2 If the average DFT sessurement on a single support is in excess of 13 mila, those high spots above 13 mils shall be identified as unacceptable on the IR and drawing.
i 3.3 In the event that any spot is found to be unacceptable per 3.1 and er 3.2 three additional spots shall be taken at appresimately 6" and radtally spaced 120' from the fsiled spot, to determine the extent of the unacceptable area.
Dimensions and locations of unacceptable areas shall be documented on the drawing. -
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CERTIFICATE OF SERVICE K.GadIII,herebycertifythatonJu$[6fl1907flZkade I
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service of "Anse.rs to Board's 14 Questions (Memo;gProposed Memo of 00 C r.:
,J April 14, 1986) Regarding Action Plan Results Report'fV'.d" by mailing copies thereof, postage prepaid, to:
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Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission l
U.S. Nuclear Regulatory P.O. Box 38 I
Commission Glen Rose, Texas 76043 Washington, D.C.
20555 Dr. Walter H. Jordan Ms. Billie Pirnet Garde Administrative Judge GAP-Midwest Office 881 W. Outer Drive 104 E. Wisconsin Ave. - B-Oak Ridge, Tennessee 37830 Appleton, WI 54911-4897 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing i
Appeal Panel Board Panel l
U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis l
Office of the Executive President, CASE I
Legal Director 1426 S. Polk Street l
U.S. Nuclear Regulatory Dallas, Texas 75224 Commission j
Washington, D.C.
20555 I
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d Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division
' Board Panel
'P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Mr. Lanny A.
Sinkin Suite 600 Christic Institute l
1401 New York Avenue, N.W.
1324 North Capitol Street Washington, D.C.
20005 Washington, D.C.
20002 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.
Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commission l
Oak Ridge, Tennessee 37830 Washington, D.C.
20555 Nancy H. Williams 2121 N. California Blvd.
Suite 390 Walnut Creek, CA 94596 a - +)
R.
K. Gad KI
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