ML20203L167

Informs That Applicant Delivered Encl Rev 0 to Results Rept,Isap III.a.4, 'Traceability of Test Equipment,' to V Noonan on 860819.Rept Provided to ASLB for Info Only. Related Correspondence

ML20203L167
Person / Time
Site:	Comanche Peak
Issue date:	08/19/1986
From:	Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
To:	Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel
References
CON-#386-430 OL, NUDOCS 8608250136
Download: ML20203L167 (19)

Text

.

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" ^ " , ," * " , m, " ' , , , August 19, 1986 CECELrA J. emunge JOC 4. DAvst cm c .metemSoN Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp

• U. S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter H. Jordan Elizabeth B. Johnsor.

Administrative Judge Oak Ridge National Laboratory 881 West Outer Drive P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 & 2); Docket Nos. 50-445 and 50-446 O/

Dear Administrative Judges:

Applicants have this date delivered to Mr. Vincent S. Noonan the SRT approved Results Report III.a.4 Traceability of Test Equipment, Revision 0.

As a part of our continuing effort to keep the Board apprised of matters which relate to the licensing of Comanche Peak, we are enclosing four copies of this Results Report. This material is not being offered into evidence at this time, and is provided for information only.

Respect ly,

/

/

Robert A. Wooldridge RAW /tj Enclosures cc Service List 060925013e> 860319 PDR ADOCK 0S000445 0 PM -

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e CPRT-611 .

Log # TXX-4973 File # 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER . 400 NORT98 O1JVE STREET. L.B. 8I e DALLAS, TEXA5 75301 August 19, 1986 ant 272 3?.7.*h Director of Nuclear Reactor Regulation Attn: Vince S. Noonan, Director Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 CPRT RESULTS REPORT

Dear Mr. Noonan:

We transmit herewith the SRT approved Result Report listed below. The files which contain supporting documentation for the Result Report have been reproduced in their entirety and are available for public inspection in our Dallas office. Anyone wishing to inspect these files should contact Ms. Susan Palmer (214/979-8242).

III.a.4 Traceability of Test Equipment We shall issue future Result Reports on a periodic basis as they are approved by the CPRT Senior Review Team.

Very truly yours,

. . A W. G. Counsil WGC/grr Enclosure A DIVISION UV TEXAd UTILITTES ELECTRIC COMPANY e

CPRT-610 Log # TUS-4904 File # 10068 TEXAS UTILITIES GENERATING COMPANY NKYWAY TOWER

• 400 NORTH OLIVE MTREET. L.B. M1

• DALLAM. TEXAM 73208 August 19, 1986

'L".",.T.US*

MEMORANDUM T0: Mr. W. G. Counsil

SUBJECT:

CPRT RESULTS REPORT We transmit herewith the SRT approved Results Report listed below. The files which contain supporting documentation for this Results Report have been reproduced and are available in the Dallas file room for public inspe: tion.

III.a.4 Traceability of Test Equipment 4). /k John W. Beck Chairman, CPRT Senior Review Team JWB:grr Enclosure cc: CPRT File A DIVintON OF TEXAN ETILITIEN ELECTRIC COMPANY

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i COMANCHE PEAK RESPONSE TEAM RESULTS REPORT ISAP: III.a.4

Title:

Traceability of Test Equipment REVISION 0 O ' .

N- 9 M (to Issue Coordinator Date /

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aw Team Leader Date O r a. L John p Beck, Chairman CPRT-SRT sh/u Date O

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• Revision: O Page 1 of 14 m

\'- RESULTS REPORT ISAP III.a.4 Traceability of Test Equipment

1.0 DESCRIPTION

OF ISSUE The NRC-TRT described the issue in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-72 and 73, Item 4. " Assessment of Safety Significance," as follows:

...although temperatures were taken and logged during the test

[1CP-PT-55-11. " Thermal Expansion,"}, the specific (temperature] asasuring device used at each monitored location was not logged. As a result the calibration of the measuring device could not be traced to the monitored location with the information contained in the test data packages. The TRT found that the completed test data packages did contain the calibration data for the measuring devices used, but as alleged, the devices could not be traced directly to specific monitored locations. While pursuing this matter, the TRT interviewed TUEC personnel who participated in the testing and found that a test coordinator maintained a log which tied the O devices to the specific monitored locations; however, the log was not made a part of the test data package. The TRT pointed out to TUEC that while the direct connection was not required by the test procedure as written, the data must be included as part of the test data package.

2.0 ACTION IDENTIFIED BY NRC The actions identified by the NRC-TRT in the CPSES Safety Evaluation Report, Supplement No. 7 at Page J-17 Item 4.2.1, " Hot

! Functional Testing," as being necessary to resolve this issue are as follows:

Incorporate the information necessary to provide traceability between thermal expansion test monitoring locations and measuring instruments. Also establish administrative controls to assure appropriate test and measuring equipment traceability during future testing and plant operations.

I

3.0 BACKGROUND

The preoperational test program is conducted according to written procedures approved by a Joint Test Group (JTG), whose seabership reflects the major CPSES design, testing, and operating O organizations. The preoperational tests are conducted by the L - - - - _ _

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• Page 2 of L4 RESULTS REPORT ISAP III.a.4 (Cont'd)

3.0 BACKGROUND

(Cont'd)

Startup organization according to the JTG approved procedures. The System Test Engineer (STE) responsible for performing a particular test also prepares the final test data package for subsequent review and approval by the JTC. The test package for LCP-PT-55-L1,

" Thermal Expansion " had been prepared and was in the process of being reviewed by Startup prior to JTG review when the NRC-TRT 2 reviewed the package. When the concern described in Section 1.0 was expressed by the NRC-TRT, the Startup organization revised the test package to include the requested information. l As referred to in various standards, the word " traceability" i

defines a requirement that measuring and test equipment (M&TE) l shall be calibrated utilizing reference standards whose calibration has a known valid relationship to nationally recognized standards such as those maintained by the National Bureau of Standards. The traceability requirement referred to by the NRC-TRT is established l

- when M&TE exhibits a nonconformance, that is, when a calibration i

check indicates the equipment was out-of-calibration. This latter requirement is discussed fully in Section 5.1,

" Standards / Commitments Review."

l i

i CP-SAP-12. " Deviations to Test Instructions / Procedures," allows deviations from approved test procedures when certain approval and documentation requirements are met. The fore used to document such deviations is known as a Test Procedure Deviation (TPD).

CP-SAP-16. " Test Deficiency and Nonconformance Reporting,"

establishes requirements for the use of Test Deficiency Reports

] (TDRs). TDRs are issued when unacceptable or indeterminate i

conditions asist in system or equipment operating characteristics, l test documentation, or for any testing procedure noncompliance.

j TDRs contain a description of the specific problem, the corrective action required, and/or the ratesting necessary to resolve the probise. Both TDRs and TFDs become part of the completed test ,

record reviewed by the JTG prior to acceptance of the test results.

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4.0 CPRT ACTION FLAN i

4.1 Scope and Methodoloaf The objective of this action plan was to ensure that 1CP-FT-55-11. " thermal Espansion," had traceability of M&TE to i

the degree requested by the NRC-TRT, and that administrative

' controls are in place to ensure required traceability during future testing and plant operation.

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ISAP III.a.4 (Cont'd) 1 E

4.0 CPRT ACTION PLAN (Cont'd)  !

The following tasks were implemented to achieve the above )

1 objective:

4.1.1 Industry standards and TUGC0 commitments were reviewed to ascertain the degree of traceability documentation for M&TE which should be included in applicable '

i procedures.

4.1.2 Test Procedure Deviation (TPD) No. 36 was issued to include information requested by the TRT in the test data package that related specific test instrument identification numbers to the locations where the test j instruments were used. Test Deficiency Report (TDR) i No. 3418 and TPD No. 37 were then issued to include traceability (required by TUGCO) to calibration of the instruments and the required calibration data relating i to the instrument identification numbers in the thermal expansion test data package for ICP-PT-55-11.

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4.1.3 All Startup personnel responsible for conduct of testing were reinstructed on the Startup administrative j requirements applicable to the traceability of M&TE.

i

) 4.1.4 Startup personnel responsible for conduct of testing were reinstructed on the Startup administrative requirements applicable to the use of Test Procedure Deviations.

4.1.5 Administrative controls applicable to documentation requirements for M&TE which have been established for i the Initial Startup Test program were reviewed for adequacy.

4.1.6 Administrative controls applicable to documentation requirements for M&TE which have been established for station operation and maintenance activities were i reviewed for adequacy.

4.1.7 Startup Administrative Procedure requirements for

! indoctrination and training of Startup personnel were

! reviewed to ensure that lessons learned from this activity had been incorporated.

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RESULTS REPORT ISAP III.a.4 (Cont'd) 4.0 CPRT ACTION PLAN (Cont'd) 4.2 Participants' Roles and Rasponsibilities 4.2.1 The Startup Special Projects Group Supervisor, Mr.

S. M. Franks, was responsible for ensuring that traceability information on M&TE used for thermal expansion testing as requested by the TRT had been included in the completed test data package for ICP-PT-55-11.

4.2.2 The Startup Manager, Mr. R. E. Camp, was responsible for ensuring that all Startup personnel had been adequately reinstructed on the administrative requirements for M&TE traceability and proper utilization of test procedure deviations.

4.2.3 The CPRT Testing Programs Review Tean Leader, Mr. J. E.

Rushwick, and the Issue Coordinator, Mr. T. M. Broad,

> were responsible for reviewing existing administrative controls for docusenting the traceability of M&TE including training requirements used for Preoperational Testing, Initial Startup Testing, Operation and Maintenance activities, and assuring necessary corrective actions were taken.

4.3 Qualifications of Personnel 1

4.3.1 The CPSES Startup Manager and Startup Special Projects

! Group Supervisor are qualified to the highest level i provided in CP-SAP-19. " Training / Qualification l

Requirements for Startup Personnel."

l l

4.3.2 The CPRT Testing Programs Review Team Leader meets the qualifications as described by the CFRT Program Plan.

f 4.3.3 The Review Team Leader was responsible for ensuring i that other personnel previding assistance .a the conduct of the Action Plan were appropriately qualified.

4.4 Acceptance Criteria i

Administrative controls for M&TE traceability are acceptable if applicable administrative procedures are used. These procedures are acceptable if they require that identification O and calibration information for H&TE used to obtain acceptance data be entered on the permanent test results record.

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Revision: 0 Page 5 of 14 O RESUI.TS REPORT ISAP III.a.4 (Cont'd) l 4.0 CPRT ACTION PLAN (Cont'd) 4.5 Decision Criteria The action plan will be considered complete when the CPRT has determined that applicable administrative procedures are consistent with the commitments to be identified during the conduct of this ISAP with regard to control of M&TE traceability documentation, and there is reasonable assurance that M&TE information is being handled in accordance with these procedures.

5.0 IMPI,EMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS The CPRT reviewed this issue by examining the specific test data package in question, and performing the reviews requested by the NRC-TRT and described in Section 4.1 above. The following presents the results of the review.

5.1 Standards / Commitments Review TUCCO's commitseat relative to M&Td traceability is presented in Section 17.2.12 of the CPSES FSAR When test and measuring devices utilized in activities affecting quality are found to be out of calibration, an evaluation is made and documented concerning the validity of previous tests and the acceptability of items previously tested since the last valid calibration.

The above couaiteent is consistent with the requirements of industry standards and guidelines which address M&TE use, control, and calibration. In particular, IEEE Standard 494-1980, " Standard Requirements for the Calibration and Control of Measuring and Test Equipment Used in the Construction and Maintenance of Nuclear Power Generating Stations," and ANSI N45.2.8-1975, " Supplementary Quality Assurance Requirements for Installation. Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," discuss this subject.

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• Rovision: O Page 6 of 14 RESUI.TS REPORT l

ISAP III.a.4 l (Cont'd) i s

5.0 IMPLEMENTATION OF ACTION Pt.AN AND DISCUSSION OF RESUI.TS (Cont'd) f Specifically, ANSI N45.2.8-1975 states:

I When measuring and test equipment is found to be out of calibration, an evaluation shall be made of the validity of previous inspection or test results and the acceptability of mechanical items inspected or tested since the last calibration check. i and IEEE 498-1980 contains the following:

M&TE and reference standards found to be out of calibration or which have not been properly maintained, or calibrated, or which have been subjected to possible damage, shall be identified as nonconforming and removed from service until such time as corrective measures have been taken. All equipment tested or calibrated by the ites since the last calibration shall be identified and sufficient investigations performed O to either reestablish the acceptability of the equipment or to confirm a nonconformance.

TUGCO's specific testing-related commitment concerning M&TE is established in Regulatory Guide 1.68, " Initial Test Programs for Water-Cooled Nuclear Power Plants," paragraph 1

" Documentation of Test Results," of Appendix C, "Freparation of Procedures," which states the following:

Records should identify each observer and/or data recorder participating in the test, the type of observation, the identifying numbers of test or measuring equipment, the results, the acceptability, and the action taken to correct any deficiencies.

The recording of calibration data for M&TE for preoperational testing is addressed in two Startup Administrative Procedures.

CF-gAF-7, " Format and Content of Test Instruction / Procedures,"

establishes the following requirement for NATE used in preoperational tests:

Aspacewillbegrovidedinthissection(section4.0,

" Test Equipment, ) or on the appropriate data sheet to record the test equipment identification number, calibration due date. . .

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• Revision: O Page 7 of 14 2

RESULTS REPORT l

ISAP III.a.4 (Cont'd) 5.0 IMPt.EMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

CP-SAP-21. " Conduct of Testing," establishes the following requirement: l The STE shall ensure that the test equipment identification number and calibration due date for test equipment used to measure and record acceptance data is recorded on the test data sheet or provided in the body of test procedures.

Based on the above, it was concluded that compliance with the traceability requirements for a nonconforming situation may be achieved by various methods as long as sufficient information is available to perform the required evaluation. For example, compliance may be achieved by requiring traceability of M&TE use to a building, a room within a building, or an elevation within a building. Recognizing that various options are available, TUGCO's Startup organisation established two O alternatives for M&TE traceability compliance. The M&TE used any be traced to the specific test procedure by recording the calibration and identification information in Section 4.0,

" Test Equipasnt," of a test procedure. The M&TE used may also be traced to specific locations when the calibration and identification information is recorded on the data sheets used to record test data. Both enthods are acceptable and achieve coupliance with industry codes and standards.

With traceability only to a tent procedure, an entire test may have to be repeated if M&TE usted is subsequently found to be out-of-calibration. For that reason, providing traceability for M&TE to each monitoring location can prove to be useful when performing the required evaluation after identifying a nonconformance. However, this Jegree of traceability, as requested by the NRC-TRT for 1CP-PT-55-11, is not a requireasses it is a matter of convenience and economics in order to sintaise the amount of ratesting which may be required to be performed.

. 5.2 Test Data Psekane. 1CP-PT-55-11. "Therest Exoansion" ___

This test data package had been amended by the Startup organisation to include the inforestion requested by the NRC-TRT and was subsequently reviewed and approved by the JTG.

The C?tT Third-Party reviewed the JTG approved test data package for M&TE traceability conformance with TUGC0 O coesiements.

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( ) RESULTS REPORT ISAP III a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) 5.2.1 Observations During this review, the following were observed:

a) Two pages of Table II, " Digital Thermometer Calibration Record," which were designated to contain the information required to meet TUGCO's M&TE traceability commitment, were blank at the time of the NRC-TRT review.

b) The specific instrument calibration data sheets which contained the information necessary to complete Table II were in the j

data package in Section 5.0 Miscellaneous i

Information."

The STE had failed to fill out Table II when 4

c) the test equipment was checked out from the TUGC0 I&C group although the information was included in Section 5.0.

d) All that was required at the time of the TRT review to be in complete compliance with Startup administrative procedures and TUGC0 commitments was to transfer the unique test -

equipment identifier and calibration due date from the calibration data sheets which were in the test data package to Table II.

l

e) Temperature and thermal movement data were recorded and analysed at specific steady-etate temperature plateaus during the rise to normal operating temperature and l

1 pressure. At each plateau and at normal i

operating conditions, the actual recorded temperature and thermal movement data were

! correlated with those movements predicted by l

' the stress analyses. It should be noted that previous ISAFs for III.a.4 mentioned in the background information section that the temperature data obtained from this test was used for information only and was not used to judge acceptability of the test or to substantiate any engineering calculations.

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Page 9 of 14 RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

{ f) Subsequent to its use in ICP-PT-55-11,

' calibration checks were performed on all M&TE utilised, and no items of nonconformance were identifi6d.

! g) The los that is referred to in Section 1.0 was, in essence, a test planning document developed by the STE to coordinate the efforts of more than 120 data collectors for this preoperational test. The additional information which it contained was utilised, by the Startup group in responding to the NRC-TRT's request.

l h) During the conduct of ICP-PT-55-11 and subsequent consolidation of data and results, thirty-eight TFDs and 636 TDRs were properly generated. The TPDs were generated to add 4

O new design information to data sheets, and most of the TDRs were generated due to supports not being installed, support modifications required during conduct of '

I test, or failure of supports to meet acceptance criteria. The TDRs identified the specific discrepancy and established ratest i requirements.

1) All itses which failed to meet the test acceptance criteria were either resolved by i

engineering action or lef t as open items which were transferred to Plant Operations for ratesting and scheduled as part of the l Initial Startup Program.

i 5.2.2 Conclusions Based on the above observations it was concluded that

! the appropriate information required by CP-SAP-7 and CP-SAP-21 was included in the test data package for i

1CP-PT-55-11, and only an oversight on the part of the STE resulted in his-failure to completely fill out Table II.

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e Revision: 0 Page 10 of L4 RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd)

To provide an added measure of assurance that the applicable requirements concerning M&TE were being properly implemented, a review of other test data packages was undertaken. In conjunction with the implementation of Action Plan III.a.1, " Hot Functional Test Data Packages," twenty-seven preoperational test data packages were reviewed for proper M&TE documentation. In all of the tests, provisions for M&TE were found to have been made in accordance with requirements of CP-SAP-7 and data were entered in accordance with the requirements of CP-SAP-21.

. 5.3 M&TE Reindoctrination Startup personnel were reindoctrinated in the M&TE requirements established in CP-SAP-7 and CP-SAP-21.

5.4 Test Procedure Reindoctrination Startup personnel were reindoctrinated in the requirements of CP-SAP-21, " Conduct of Testing," which establishes l

requirements applicable to the use of Test Procedure Deviations.

l 5.5 Initial Startup Procedures A review was conducted of the Initial Startup procedures listed in Attachment I to this Results Report, and it was '.

determined that M&TE traceability requirements were seequately addressed in accordance with the criterion in Section 4.4.

5.6 Station Procedures A review was conducted of the Station administrative procedures listed in Attachment.2 to this Results Report, and it was determined that M&TE traceability requirements were adequately addressed in accordance with the criterion in Section 4.4.

As an additional indication of the adequacy of the M&TE program at CPSES, it should be noted that an evaluation was conducted by the Institute of Nuclear Power Operations (INPO) of the entire CPSES Instrument and Control Program in April and May, 1985, and no discrepancies were identified. The 6

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Revision: O Page 11 of 14 O RESULTS REPORT ISAP III.a.4 (Cont'd) 5.0 IMPLEMENTATION OF ACTION PLAN AND DISCUSSION OF RESULTS (Cont'd) evaluation stated that strict, detailed adherence to the program as detailed in CPSES Procedure STA-608, " Control of Measuring and Test Equipment," was noted as well as comprehensive incorporation o' the reconstendations of INPO Good Practice MA-303, " Control and Calibration of Measuring and Test Equipment (M&TE)."

5.7 Training Requirements The administrative procedure which addresses personnel training, CP-SAP-19. " Indoctrination / Training /Qu11fication Requirements for Startup Personnel." defines the indoctrination and minimum qualifications that are required for Startup personnel assigned to perform testing and related activities and provides a method of documenting personnel indoctrination and qualification. The review of this procedure and the personnel training files indicated that indoctrination in the requirements of CP-SAP-7 and CP-SAP-21

' O. was required, conducted, and documented.

5.8 Root Cause and Generic Implications No testing deviation or deficiency was identified and no generic condition exists which indicates that there are inadequate controls on M&TE traceability in preoperational testing, initial startup testing, or station procedures at l

CPSES. Accordingly, no root cause determination is required.

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6.0 CONCLUSION

S Based on the discussion presented in Section 5.0 above, it was concluded that; j 1. The M&TE traceability information requested by the NRC-TRT is l

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included in the ICP-PT-55-11 " Thermal Expansion," test data package.

2. Requirements exist in Startup and Station implementing procedures to ensure compliance with TUGCO's M&TE traceability commitments.

7.0 ONGOING ACTIVITIES There are no ongoing activities.

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. Page 12 of 14 RESULTS REPORT ISAP III a.4 i (Cont'd) 1 8.0 ACTION TO PRECLUDE OCCURRENCE IN THE FUTtTE 1

)

No action was required as a result of this issue, but it should be noted that subsequent to the identification of this issue by the NRC-TRT, CP-SAP-19 was revised to provide more specific requirements for training of personnel involved in various levels of testing activities, and reindoctrination of personnel was conducted as described in Sections 5.3 and 5.4.

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Revision: 0 Page 13 of 14

( RESULTS REPORT ISAP III.a.4 (Cont'd)

Attachment i Initial Startup Procedures Reviewed STA-801 Initial Startup Program ISA-001 Initial Startup Test Procedures ISA-004 Conduct of Initial Startup Testing ISA-005 Initial Startup Test Package Preparation, Review, and Approval O

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O RESULTS REPORT l ISAP III.a.4 (Cont'd)

Attachment 2 CPSES Station Procedures Reviewed STA-202 Preparation, Review, Approval, and Revision of Station Procedures STA-209 Preparation Review, Approval, and Revision of Station Instructions STA-608 Control of Measuring and Test Equipment STA-702 Surveillanca Test Prograa EDA-105 Engineering Department Survaillance Test Procedures EDA-112 Results Engineering Testing Guidelines EDA-113 Conduct of Results Engineering Test Procedures ODA-206 Preparation of Operations Test Procedures and Equipment Test Procedures ODA-207 Caidelines for the Preparation and Review of Operations Pricedures MDA-201 Electrical and Mechanical Maintenance Procedures and Instructions MDA-204 Maintenance Engineering Instructions INC-107 IEC Scheduled Calibration Maintenance Prograa O.

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TO: CPRT SENIOR REVIEW TEAM FROM: Chairman, Results Report and Working File Review Committee DATE: July 24, 1986

SUBJECT:

Working File Verification Report for ISAP No.III.a.4, Rev. O The Working File review and verification team has completed its review of the Working File for ISAP No. III.a.4, Rev. O. Our conclusions and (if applicable) any remaining unresolved comments are presented below.

NO YES X The ISAP was implemented as defined and approved by the SRT.

X The content of the Working File is complate and organized in a sanner consistent with the requirements ,

of the CPRT Program.

X The work reported in and conclusions reached in the Results Report for the ISAP are substantiated by the inforestion contained in the Working File.

Review Comittee Comments:

l l

Coment Continutation Sheets Attached: Yes No X No. of Sheets mf -_ _-

g & h k. So m Chairman, Results RepqFt and Eaview Team Leader, Working File Review Cosmittee O- ISAP No. III.a.4 . . - ..

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