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TEXAS UTILITIES GENERATING COMPANY MKYWAY TOWER
- 400 NORTH OLIVE MTHEET. L.B. #st
- DALLAM. TEXAN 75201 A
"'C" ^ ',I,";,U '" C' January 15, 1985,-
/
Mr. Darrell G. Eisenhut, Director
/
Division of Licensing, NRR Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Eisenhut:
Pursuant to our recent discussions about the NRC's inspection tour of Comanche Peak on January 10, 1905, I asked our Site Management to look into the matter further.
It appears that two craft welding supervisors lacked sufficient understanding of welding procedure requirements.
Specifically:
- The supervisors did not appear to be familiar with the requirements for controlling the time that weld rods may remain out of weld rod Cans;
- Thesg same supervisors were not immediately familiar with the weld symbols of welders under their supervision; and
- The supervisors (though possibly nervous at the time) had difficulty in locating the relevant weld procedures upon request that they do so.
I share the concerns expressed by you and your Staff and have caused the following actions to be taken immediately:
1.
All welding supervision (approximately ninety people) were retrained and given written examinations on weld procedures on Saturday, January 12, 1985; and 2.
During this week, the QA Department will conduct random surveillance of welding supervision to further test their knowledge of welding procedures.
It is my understanding that your inspection team found no hardware problems in connection with their investigation as the welder in question, Mr. Kim, accurately answered all questions about the procedures applicable to his work.
If you desire any additional information, please do not hesitate to let me know.
Very truly yours, 8607030260 860623 DE A-18 PDR aj Sp J
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cc: Service List V
A DEVENION 09' TEXAN t*TILITIES ELECTRIC COSEPANY
-p i
l C0 ;50LIDATED ISSUES LIST FOR CPSES l
CURREtiT TO: MARCH 30, 1984 l
l 1.
DESIGt ADE00ACY A!;D DESIGil CUALITY ASSURANCE A.
Design Adequacy Subject Status Reference Lead 1.
Concerns Open 12-28-83 a.
Board rejects general Open 12-28-83 industry practice on p.26, n.65 non-consideration of stability.
b.
No record documentation that Open 12-28-83 cinching of. U-bolts will resolve instability problems.
Frictional forces not quantified.
c.
Use of SA-307 steel for Open 12-28-83 U-bolts not acceptable pp.27-28 when cinching is relied upon to resolve stability p robl em.
Cites p.387 of Appendix XVII, ASME Code.
d.
No attempt to identify the Open 12-28-83 cause of 382 supports which p.29-30 did not meet ASME Code requirements for fillet welds.
Repetition of error not precluded, since changes to the support welds are being documented on CMC's, not NCRs.
U-Bolts e.
Force on U-bolts due to Open 12-28-83 torquing p.35 f.
Thermal expansion stresses Open 12-28-83 p.35 g.
Induced loads on piping Open 12-28-83 p.36
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1
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f/%D
. Subject Status Reference lead 4
h.
Analyses not introduced Open 12-28-83 X
into record by SIT on the p.36-37 above matters; rejects engineering judgment w/o
- basis, i.
overtensioning of U-bolts Open 12-28-83 will occur prior for pipe p.37-38 heatup, and w/o seismic loads, hence pre-inspection to detect overtorque of U-bolts is not valid.
j.
BN-105A - Board is concerned Open 12-28-83 about the 20 supports stiff p.39 clamps.
k.
Box frame stresses due to Open 12-28-83 thermal expansion and U-bolt p.40 stresses are in range of stiff pipe clamp stresses, hence BN-105A is relevant to soft supports.
AWS Code 1.
Applicants have not shown Open 12-28-83 that ASME Code contains p.42-50 sufficient provisions to assure that welds may be properly designed, w/o reference to AWS requirements.
m.
Unclear whether existing Open 12-28-83 weld designs comply p.43-44 w/ Applicants' beta requirement.
n.
NpSI nor brackets do not Open 12-28-83 comply w/Korol & Mirza p.44 ratio of 0.6.
o.
CASE Exhibit 763 drawings Open 12-28-83 not evaluated correctly p.44 by SIT, due to misreading of weld sizes.
-..s y
y y
-7 p
l j Subject Status Reference Lead p.
Support # exists, contrary Open 12-28-83 to SIT finding.
p.44 q.
No evidence on acceptability Open 12-28-83 of " recapping",
p.45 r.
Applicants fail to show Open 12-28-83 which AWS Code provi-p.46-47 sions have been demonstrated non-applicable because of specific qualifying tests.
s.
AWS criteria for drag angles Open 12-28-83 and work angles cannot by p.47 bypassed through qualifi-cation tests.
t.
Applicants fail to respond Open 12-28-83 that undersized weld repair p.47-48 by cap welds is unacceptable.
u.
No record evidence on Open 12-28-83 qualification program p.44-50 for welding at CPSES.
Vocer lateral Restraint v.
Board did not reference Open 12-28-83 additional reason why p'.52 error in upper lateral restraints was not significant, i.e., Dr. Chen found that error not present in other calculations using this graphical technique.
1 w.
Dr. Chen's stiffness Open 12-28-83 calculations for steam p.55-56 generator wall not submitted; nc evidence of the non-coincidence of LOCA pressure / temp. peaks.
w i
4_
Subject Status Reference Lead x.
Board finds Dr. Chen's Open 12-28-83 assumed force distribution p.64-66 is incorrect, and is of no value in determining the tension on the bolt due to torque. by the tube steel.
y.
Bolt allowable stresses will Open 12-28-83 be exceeded if magnitude of p.66 error in tension calculations
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equals 2.
z.
Board suggests that Open 12-28-83 independent design p.72-75 verification be conducted, and describes an acceptable.
IDV plan.
2.
Cygna Report Open (10-25-83) 2nd Schedu-ling Order,
- p. 3 3.
Effect of welding on A-500 steel Open 10-6-83; 3-15-84, p.19; 2nd Scheduling
- Order, pp. 6-7 y,g y w -w e-M m w =mem->m. w a _n: m y;camx_ m
--2.g i.e. < : n:c a.,- ca 5.
Reversal of safety classifica-3-15-84, p.11.
l tion of open structures.
B.
Desion Quality Assurance 1.
Concerns Open 12-28-83 a.
10 C.F.R. Part 50, Appendix B Open 12-28-83 does not apply to design.
p.2
'8
. Subject Status Reference Lead b.
10 C.F.R. Part 50, Appendix B Open 12-28-83 require prompt identification p.5-7 and correction of design errors.
c.
Applicants' iterative design Open 12-28-83 process does not satisfy p.20-25 Appendix B requirement that design deficiencies ~be promptly identified and corrected. No NCR system for design deficiencies.
d.
Board cannot determine Open 12-28-83 whether Applicants corrected p.25, and the designs " solely under note 62.
pressure from litigation."
Board also unsure if Appli.
cants would have identified these problems but for Walsh/Doyle.
e.
No attempt to identify the Open 12-28-83 cause of 382 supports which p.29-30 did not meet ASME Code requirements for fillet welds.
Repetition of error not precluded, since changes to the support welds are being documented on CMC's, not NCRs.
f.
No group at CpSES respon-Open 12-28-83 sible for calculating p.41 local pipe stresses.
Generic Stiffness Values g.
" CASE correctly identified Open 12-28-83 these problems and their p.57 subsequent resolution does not eradicate our concern that these design problems were present."
Subject Status Reference Lead Differential Seismic Displacement h.
No explanation hcw 2 pipe Open 12-28-83 supports were designed p.57-58 contrary to design guidelines.
No evidence on frequency with which such errors occur, i.
Failure by Applicants to_
Open 12-28-83 promptly revise NPSI and p.58 ITT-Grinnell guidelines to prohibit wall to wall /
floor to ceiling supports unless slip joints are employed.
CC-2-008-709-A43K j.
Initial designs required Open 12-28-83 to be "of same quality" p.59 as final designs.
k.
Board has no way of knowing Open 12-28-83 whether or not error would p.59 have been caught in design verification process.
Richmond Inserts 1.
Board has no basis for con-Open 12-28-83 cluding that safety factor p.62 problem w/ Richmond inserts would have been detected in the Applicants' normal design
- process, m.
Error in calculating bolt Open 12-28-83 tension due to axial torsion p.65 would not have been detected in the Applicants' normal design process.
n.
Board suggests that indepen-Open 12-28-83 dent design verification be p.72-75 conducted, and describes an acceptable IDV plan.
,a -
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l l l p e ect Status Reference I
tee Cygna Report Open (10-25-83) Memo-
)
i randum & Order, 2nd Scheduling Order, p. 3 l
3 Staff Walkdown Open 2nd Scheduling l
Inspections Order, p. 2 II. C0:STRUCTIOtt OUALITY ASSURA!;CE 1.
Implications of Applicants' Open 3-15-84, p.6; failure to develop QA procedures for excavation 7-29-83, p.10.
activities.
2.
Weld Rod Centrol Open 10-25-83, p. 11; 9-23-83, pp. 29-30; 7-29-83, pp. 34-35
! / 3.
plug Welds Open 10-25-83, p. 10; 9-25-83, pp. 24-25; 7-24-83, pp. 32-33 3-15-84, p.7 7 4
Harrassment of QA inspectors, Open 10-25-83, pp. 3-5; X
in protective coatings 9-23-83, pp. 13-17 Ileferred,1s t Scheduling Order,
- p. 4 5.
Changes is Applicants' QA/
Open 3-15-84, p. 19; QC program 10-25-83, pp. 4-5; 9-23-84=3, p. 15 6.
Management's cctmittment tc Open 7-29-83, pp. 21-22; effective OA/0C program 9-23-83, p. 42, n. 100 i
s 7.
l
!!o response to! M 0 pen allegation that backfit program 9-23-83,p. 32, n. 81 for CELI pipe whip restraints was not taken seriously 8.
Unstated management directive Open j
not to rep.crt problens (ccncern 13-25-83, p. 11; raised by 5-23-83, pp. 34-35; 7-24-83, p. 42 9.
pressured to Open approve Tennessee wall, Tube 9-23-83, p. 35 and Metal Audit
-N
[
, /
/ pbject Status Reference Lead
/
10.
Incorporation of CMCs into Open 7-29-83, p. 43 appropriate documents at document control center
/
- 11. CAT concern about inadequate Open 3-15-84, p. 16; number of QC inspectors 7-24-83, p. 45
- 12. Termination of,' M Open 7-29-83, p. 28
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for reporting gauge in pipe to CC inspector.Scq"C*P)
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- 13. [ 6 unqualified for Open 7-29-83, p. 41 a QA position which she held 14 Harrassnent of Open 3-15-84, p. 18; X
includinc allegaticns in 2nd Scheduling affidavii' attached to CASE's.
Order, pp. 3-4; 11-28-83 Answer to Ecard's 7-29-83 Proposed 10-25-83 f*enorandum Decision, p. 41.
CASE had four weeks y
from 3-15-84 to file y
evidence on this 41 1ssue.
N-4'p15. Termination of Open 3-15-84, p. 9
'/
- 16. Termination of Open 3-15-84, p. 8 17.
tiemurandum Open 18.
Ineffective action taken in Closed 9-23-83 pp. 31-32 response tc M identification of problems with a pipe support 19.
Traceability of materials Closed 7-29-83 p. 40
personnel 7-29-84, p. 41
- 21. CBLI Pipe b' hip & Mcment Closed 9-23-83 p. 32.
Restraints, NRC Inspection Hcwever, the Board Report 82-25/S2-13 invites ccmments and affidavits from Staff and Applicants.
nd Scheduling Order, pp. 4-5.
Board also admits this inspection report.
f
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_Subiect Status Referer.ce Lead
/
22.
NPSI Pipe Whip Restraints, Closed 9-22-E3 pp. 32-33, but and other vendor welding see note above.
Scard surveillance prograns.
NRC also admits these Inspection Reports 82-22 and inspection reports.
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82-14
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23.
Uncertified employees per-Closed 9-23-83 forming liquid peretrent pp. 33-14 testina (concern raised by 2 4'.
Inadequate number of GA Closed 3-15-20, p. 16; inspectors M 7-29-E3, p. 45 concern)
- 25. Computerizaticn of NCRs Open 3-15-80, pp. 17-1E ;
X 9-20-83
- 26. Low worker morale Closed as 7-29-83, pp. la, independent 17, 43.
Board has issue dete rmined that mora'e of QC inspectors is relevent to intimida-tion and commitment to QA. See 3-15-84,
- p. 18.
27.
Cygna Report Open (10-25-83 Memorandum X
&' Order); 2nd Scheduling Order, p. 3 25.
Intimidation of OC inspec-Deferred 3-15-8", pp. 13-14, X
tors, and OI Investigations on Intimidation 19; 1st Scheduling Order, p. 4 E9.
Site Tour Board allows 1st Scheduling CASE to tour Order, pp. 3-4.
site, for purposes of di scove ry.
- 20. Trer.ds/ Patterns of ' 1/ ~. t Open 3-15-54, p. 20.
X Deficiencies
!!I. CCNSTRUCTION ADECUACY l
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'1.
Polar Crane Reinspection Open 3-15-64, p. 6 ;
/
' 7' 9-23-83, p. 41 02 i
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. Subject Status Reference Lead 2.
Weld Rod Control Open 10-25-83, p.11; 9-23-83, pp. 29-30; 7-29-83, pp. 30-35
, / > 3.
Dcwnhill Welding Open 10-25-83, pp. 1C-11
) / 4.
Plug Welds Open 10-25-83, p. 10; 9-25-83, pp. 24-25 ;
[
7-24-83, pp. 32-33 1
5.
Westinghouse coatincs (concern Open 3-15-8*, p. 7 raised by 10-25-83, pp. 8-9-23-83, pp. 2c h;13; i
7-29-83, pp. 24-25 6.
Near White Blast, Open 3-15-84, p. 7; protective ccatings 10-25-83,.pp.
3-*, 8; 9-23-83, pp. 20-21 7.
Paximum Roughness, Open 3-15-84, p. 7; protective coatings 9-23-83, p. 21 8.
Adhesion, prctective Open 3-15-84, pp. 7-8.
Undocumented removal of Open 3-15-84, p. 9; cable trays 7-29-83, p. 25 g
i10. Polar Crane shim reinspection Open 9'-23-83, p. 42.
1.
Memorandum Open 12.
Inadequate disposition Open 7-29-83 p. 24 X
of paint defect repairs
- b. Weave beading of weids Closed 2nd Scheduling Order, X
pp. 1-2 I
14 Torcue Seal presence as Closed 3-15-84, p. 10; X
definite evidence for 9-23-83, p. 31.
inspector not to further check records on torquing 15.
Hanger SW-1-102-106-Y33r.
Closed 3-15-84, p. 10; X
9-23-83, p. 31.
16.
Liquid Penetrant Testing of Closed 3-15-84, p. 10; Fuel Fool, Liner (cencern 9-23-83, p. 31.
raised by g
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p.-
. [ sut' ject Status Reference lead 3
17.
Ineffective action taken 'n Closed 3-15-84, p. 10; X
e response to(Mrs. Stiner's 9-23-83, p. 31-32.
identification of problems with a pipe support
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- 18. r. ;- ;
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- 19. Heat input control for fiot issue in welding proceeding.
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Lecal brief
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necessary?
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- 20. CS&I Pipe Whip & Moment Open 3-15-84, p. 12; Restraints,f1RC Inspection 9-23-83 Order, p. 32.
Report 82-25/82-13 Board admits this inspection report.
21.
f! PSI Pipe Whip Restraints, Open 3-15-84, p. 13; and other vendor welding 9-22-83, pp. 32-33; surveillance prograns. fiRC Board admits these Inspection Reports 82-22 and inspection reports.
82-14
- 22. Uncertified employees Closed 3-15-84, p. 13; performing liquid penetrent 9-23-83, pp. 33-34
, testing (corcern raised by 23.
A 490 bolt torquing Closed 3-15-84, p. 16; 9-23-83, pp. 35-36 24 Weld Quenching Closed 3-15-84, p. 16; X
9-23-83, p. 36
/3' 25.
Cold Scrincinc of Reactor Closed 3-15-83. o. 16;
/_.. # "
Ccolant lines ~
6 23-83, p. W,#
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26.
Reactor Vessel Mirror Shield flot issue in 3-15-84, p. 17 touching Shield Wall during proceeding HFT. flRC Inspection Report 83-3a/S3-18 b.' Staff walkdcwn inspections Open 3-15-84, p. 19; X
2nd Schedulinc Order, pp. 2-3 28.
Cygna Report Open 10-25-83; 2nd Schedulina j
Order, p. 3
~
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.p.
. Subiect Status Reference Lead 2:. Applicants' Reinspection of Open 2nd Scheduling Protective Coatings Order, pp. 5-6.
3C.
Site Tour Closed 2-6-84 Order (Site-Visit Discovery)
- 31. i
.Mallegations, Closed 3-15-84, p. 15.
as resolved by NRC Inspection Board states that Report 83-27 g allega-tions regarding intimidation are open.
IV. l'ISCELLANEOUS 1.
Scard Question 2, regarding Closed 3-15-84, p. 16; X
Operating QA Program 7-29-83, pp. 54-55 2.
Separate Hearings for Unit 2 Not a 3-15-84, p. 17.
licensing separate issue.
3.
Credibility / Competence of Not a 3-15-8?, p. 20.
Applicants' and NRC Staff's separate Witnesses issue.
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REVISION 2 6/28/84 SSER Task: Allegation A-Reference No.:
j Characterization:
It is alleged that specific'ations and procedures used as acceptance criteria for concrete work were frequently ignored by J. A. Jones personnel.
Assessment of Allegation: The NRC staff independently reviewed 20 of 28 concrete basemat placement packag,es. The staff review of the 20 placements specifically sampled the first three blocks (blocks 1, 2, and 6) placed, since these placements preceded the Stop Work Order which was issued to achieve corrective action of improper placement, activities. The NRC staff foun~d several violations of specifications and procedures during this review, including:
o Out-of-tolerance concrete test results (air content, slump, mixing time, mixer revolutions, volume of water added),
o concrete testing frequency, o
vibrating (concrete and reinforcing steel),
o excessive movement of concrete, o
excessive lift height, and o
concrete curing documentation.
The NRC staff review of J. A. Jones records of the basemat placement packaces showed that these violations were identified by EBASCO Quality Assurance (QA) in various placement packages. When a violation was identified, 'frrmediate corrective action was taken in the field, when possible. A discrepancy notice (DN), and when necessary a nonconformance report (NCR), was written to document the violation and to establish appropriate corrective action.
If the violation involved a change in the original design specification, a field change request (FCR) or a design change notice (DCN) was written to address the violation.
For further discussion on the above violations, refer to Allegations 139/140.
Although specifications and procedures were violated during concrete placements, each violation was identified and documented by EBASCO QA, and corrective actions were taken.
Based on its review, the NRC staff has concluded that the quality control of the concrete placements was adequate in achieving construction quality. The NRC staff consultant made.an independent evaluation of the construction F0A45-59 n
,. ~
A-111 activities and reached the same basic conclusion that the construction of the basemat was adequate to ensure the safety of the structure (See Appendix L).
This allegation has neither safety significance nor generic implicaticns.
Actions Recuired: None.
References 1.
Ebasco Specification LOU-1564.472.
2.
J. A. Jones Procedures W-WP-7 and W-SITP-7.
3.
Basemat Placement cackages; 499S01-15, 499501-14A, 499501-11A, 499502-9A, 499502-78, 499502-7A, 499502-8A, 499S02-108, 599502-88,-499502-58, 499502-4, 499502-5A, 499S02-10A, 499S02-1, 499502-6, 499502-2, 499S02-98, 499503-15, 499503-17, 499503'-118.
4.
DNs, NCRs, FCRs, and DCNs addressed in the above listed placements.
Statement Prepared By:
Date Date Reviewed By:
Team Leacer dete Reviewed By:
Site Team Leacer(s)
Date Approved By:
Task Management Date l
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REVISION 2 l
06/26/84 QM[t M 1W E
'fNC SSER Task: Allegation A-
- 3..> ;
Reference Number:
Characterization: It is alleged that the employment records for quality assurance (QA) personnel of the Mercury Constructicn Company have not been verified and that the implications of this alleged practice may apply to all Mercury employees.
Assessment of Allecation:
The implied significance of this allegation is tnat unqualifiec Mercury quality control (QC) inspectors may have performed inspections on safety-related systems, making the validity of the inspections questionable and the quality of the work indeterminant.
The NRC staff reviewed Mercury's procedure for qualification of inspecticn, examination and test personnel, inspector certification records, and persennel training and resume packages against Regulatory Guide 1.58, Rev.1, as recuired by NRC Generic Letter 81-01, ANSI'N45.2.6-1978, and IE Circular 80-22.
i l
The NRC staff sam:: led 30% of the inspector certifications of QC personriei; the results revealed that no verificaticn of past employment was documented. An I
additional staff examination of inspector qualification for Allegation A-02 has indicated a generic prcblem of improperly certified inspectors.
Mercury inspectors had performed inspections on safety-related systems.
The NRC staff believes this allegation has implied safety significance.
l l
Actions Recuired: See Item No.1 in the Enclosure to the letter frcm L
D. Eisennut to J. M. Cain (LP&L), June 13, 1984
References:
.;/'
1.
IE Circular No. 80-22, Confirmation of Empicyee Qualifications 2.
LP&L letter W3P83-3704, Re: Ccnfirmation of Employee Qualificaticns 3.
See documentation of Allegation A-02 for certification packages reviewed.
4 Regulatory Guide 1.58, Revision 1.
5.
ANSI N45.2.6, 1978.
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Statement Prepared By:
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Date Reviewed By:
Team Leader Date i
l Reviewed By:
Site Team Leader (s)
Date Approved By:
Task Management Date 1
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REVISION 1 07/01/84 lhh1 psue SSER
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Task: Allegation A.
Reference No.:
Characterization:
It is alleged that EBASCO interoffice letter W3-QA-23661 (March 4,1983) was "an example of correspondence written to cover up problems discovered in the documentary review group."
Assessment of Allegation: During the spring of 1982, EBASCO established a Quality Assurance Independent Review Group (QAIRG) to review the status of the documentation furnished by project subcontractors. One group was responsible for the documentation associated with the installation of Tompkins-Beckwith (T-8)pipinghangers. During their review, QAIRG members asked questions, about the details of their document review. To provide consistent answers to these questions and to give guidance to new QAIRG members, EBASCO management issued W3-QA-23661 on March 4,1983.
To provide continuity of direction, the letter was jointly written by the EBASCO Manager of the Site, the EBASCO Manager of Information Records, the T-B Quality Assurance (QA) Site Supervisor, and the T-B Engineering Manager. The letter, prior to release, was reviewed and verbally approved by the LP&L Site QA Manager, The alleger feels that EBASCO management may have attempted to solve problems by dictating solutions rather than by using the established discrepancy reports or nonconformance reports.
The NRC staff reviewed the letter and found no instance of an attempt to provide answers or solutions outside the established QA system. Thus, there was no evidence to sup. port the alleger's claim of a coverup.
This allegation has neither safety significance nor generic implications.
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f Actions Recuired: None.
References i
Statement Prepared By:,
Date Reviewed _Sy:
Team Leader Date
__ Reviewed By:
-Site Team Leader (s)
Date Approved By:
Task Management Date
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. 5C REVISION 1 07/01/84 Tw(trgwed@f6X h SSER Task: Allegation A-Reference No.:
Characterization:
It is alleged that there was incomplete quality control (QC) field verification of corrective " action prior to closure of EBASCO Nonconformance~ Report (NCR) W3-2333, that is, not all hanger supports were reviewed for seismic qualification.
Assessment of Allecation: The alleger supplied to the NRC staff a conversation record between himself and a former Mercury employee. From this document, the staff learned that the employee had told the alleger that, as of the time he left Mercury and the Waterford 3 site, only about 95% of the required QC field verifications pertaining to NCR W3-2333 had teen accomplished.
In view of this infomation, the alleger's concern was whether the other 5% of the field verifi-
/
cations,had,been performed prior to closure of the NCR.
-_f The NRC staif contacted the former Mercury employee in order to determine which hanger supports had not been reviewed. He stated that all but eight of the supports requi' ing rework had been completed, inspected, and documented.
The NRC staff reviewed EBASCO NCR W3-2333 and found these eight supports
.. anted in the closed NCR package. The staff reviewed the documentation
' the remainder of NCR W3-2333 for adequate' closure. The staff found that the NCR adequately addressed field verification of hanger supports and had been dispositioned and closed out properly.
This allegation has neither safety significance nor generic implications.
1
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Actions Recuired: None.
Ref'erences 1.
NCR W3-2333 2.
A11eger "C" Transcript, Exhibit 44 3.
Conversation Record between W. Marini and a former Mercury employee.
Statement Prepared By:
i 1
Date Reviewed By:
Team Leader Date Reviewed By:
Site Team Leader (s)
Date Approved By:
Task Mcnagement Date i
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