ML20003C759
| ML20003C759 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/28/1981 |
| From: | Fiorelli G, Gallagher E, Knop R, Landsman R, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20003C751 | List: |
| References | |
| 50-329-81-01, 50-329-81-1, 50-330-81-01, 50-330-81-1, NUDOCS 8103180215 | |
| Download: ML20003C759 (13) | |
See also: IR 05000329/1981001
Text
r
'
.
.
O
(./
.
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND EhTORCEMENT
REGION III
Report No. 50-329/81-01; 50-330/81-01
Docket No. 50-329; 50-330
License No. CPPR-81; CPPR-82
Licensee:
Consumers Power Company
1945 Parnall Road
Jackson, MI 49201
Facility Name: Midland Nuclear Power Plant, Units 1 and 2
Inspection At: Midland Site
Inspection Conducted: January 7-9, 1981
O
b/d-O/
Inspectors:
E. J. Gallagher
I
/-2.f - I'/
R. B. Landsman
M
.
R. N. Sutphin, Jr.
M,
/ - 2 6 - f/
scKW
I -2 7- E/
Reviewed By:
R. C. Knop, Chief,
Projection Section
elli,k
/
'
Approved By:
. F'
Reactor Construction and
I
/
Engineering Support Branch
Inspection Summary
Inspection on January 7-9, 1981 (Report No. 50-329/81-01; 50-330/81-01)
Areas Inspected: Consumers Power Company response and implementation of
corrective actions regarding the 10 CFR 50.54(f) request of question 1 of NRC
letter dated March 21, 1979 and question 23, request for e;dditional information
dated September 11, 1979; procedures, quality records and observation of work
related soils work activity; quality assurance organization status, construction
schedule; and status of personnel air locks. The inspection involved a total of
60 inspector-hours on site by three NRC inspectors.
810818o [
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ . _
_
.
Results: Three items of noncompliance and one devistion were identified in the
above inspected areas - Severity Level IV, Inadequate Procedures; Severity Level
IV - Inadequate document control; Severity VI - Inadeqt. ate Quality Assurance
Records; Deviation from commitment to provide Geotechnical Engineer.
.
-2-
I
'
.
.
.
DETAILS
Persons Contacted
Consumers Power Company
D. Miller, Site Manager.
- W. Bird, Quality Assurance Manager
- T. Cooke, Project Superintendent
- R. Davis, Quality Engineer
- R. Wheeler, Staff Engineer
- D. Horn, Civil Group Supervisor
- H. Leonard, Section Head, Quality Engineering
- D.'Turnbull, Site Quality Assurance Superintendent
D. Keating, Section Head IE and TV
Bechtel Power Company
- J. Russel, Assistant Project Field Quality Control Engineer
- E. Smith, Project Field Quality Cor. trol Engineer
- P. Corcoran, Resident Assistant Project Engineer
- P. Goguen, Lead Civil Field Engineer
- J. Betts, Assistant Field Project Engineer
- H. Deitrich, Project Quality Assurance Engineer
- L. Snyder, Resident Quality Engineer
U. S. Testing Company
J. Speltz, Lab. Manager
The inspectors also contacted other licensee and contractor personnel during the
course of the inspection.
- Denotes those in attendance at the exit meeting on January 9, 1981.
Licensee Action on Previously Identified Items
(Closed) CPCo Action Item: S100D, NRC Inspector E. W. K. Lee's concern regarding
" unreadable documents" in one of the document packages for a shop weld, as ex-
pressed.by the inspector during his October 9-10,.1979 inspection, and item "D"
l
of J. L. Corley October 12,~1979, Midland Memo No. 344FQA79. CPCo determined that
'
documents of concern applied to spos t piece 2CCA-61-S611-2-6 wherein parts of two
radiograph reports were not legible due to copy machine problems. Legible copies
were secured for this file.
In addition Bechtel QC reviewed 20 other M-104-A data
. packages and found 9 out of 298 pages in similar condition. Legible copies were
,
made of all' discrepant pages and filed, as recorded'in L. A. Dreisbach Memo
l
LAD 168S of August 8,1980, ,to J. L. Corley. This item of NRC concern is closed.
.
-3-
_
___
_
_ _ _ _ _
__ _ . _ _ _ _ . _ _ _ _ _ . . _ _ _
_ _ _ _ .
.
.
-
.
.
(Closed) 329/79-12-01; 330/79-12-01 " Work Prints in use were not current :evision",
CPCo Action Item S500. CPCo advised inspector that incorrect issue (Rev. 11) of
print was removed and correct issue (Rev. 12) provided to the work area at the
time of the original inspection.
Current issue of the drawing is Revision 14,
issued September 14, 1979, title of the drawing in Question is " Decay Heat Removal,
Core Flooding System Unit 2 Hangers, Location and Identification". Three audits
have been performed since the original inspection. One was reported in May 1979,
one reported September 9, 1980, and another reported on Tovember 24, 1980, the
results of which indicate a significant improvement in the revision control of
work prints.
Based on this corrective action and commitments by CPCo to maintain
a continuing program of audits in this area of activity, the referenced item of
noncompliance is closed.
(Closed) Unresolved Item 329/80-11-03; 330/80-12-03, " Snubber Missing Required
Spacer". Two snubbers were found to have one missing spacer washer each, however,
they had not gone through the regular inspection and acceptance by Quality Control
at the time 24 pipe supports in various stages of inspection and installation were
observed by the NRC inspector. As a result of the express concern of the NRC
inspector training was planned and conducted on June 10, 1980, construction corrected
the condition of the two snubbers, and documented the inspection on a QC-G1-1 form,
and activity 3.1.c in the P-2.10 PQCI has been added to verify future configurations
and orientations are correct, per M. A. Dietrich Memo No. LAD 1754 of November 12,
1980. Based on this documented corrective action, this unresolved item is con-
sidered closed.
(Closed) CPCo Action Item: S479, NRC inspector R. N. Sutphins concern regarding
lack of update of EDPIS per comments in NRC reports No. 50-329/80-30; 50-330/80-31,
Page 11. The inspector checked the two items in the Bechtel Power Corporation
Engineering Department procedures manual and found them to be in proper order.
This concern is closed. However, additional technical review of the Engineering
Department procedures manual will be conducted at subsequent inspections.
,
-4-
.
-
r,
--
.
.
.
Section I
Prepared by
R. N. Sutphin
Reviewed by
R. C. Knop, Chief
Projects Section 1
1.
Functional or Program Areas Inspected
a.
CPCo Quality Assurance Organization
The inspector reviewed the organization chart of the combined CPCo -
Bechtel Quality Assurance Organization, issue date January 1, 1981.
Mr. M. A. Dietrich is (Acting) PQAE replacing Mr. L. A. Dreisbach who
has been reassigned.
Mr. D. M. Turnbull had reported to the site in
the position of Site Project QA Superintendent. The combined Midland
project Quality Assurance organization now has 40 persons assigned
compared to 36 as of mid October 1980. The supervisor of the adminis-
tration Group reporting to the site project Quality Assurance Superin-
tendent will be announced in January 1981. Additional information was
requested on the person who has been selected to fill an open position
as Civil Quality Control Engineer in the Bechtel Quality Control Organi-
zation.
b.
Construction Schedule
The inspector checked the status of construction and construction
schedules for the overall project, and received a copy of the January 8,
1981 CPCo report memo to NRC on the current yellow book schedule.
c.
Onsite Design Activity
The inspector checked the status of the ongoing onsite design activity
and continued his review of the engineering department procedures manual.
The inspector toured the site to observe the status of the work.
No items of noncompliance or deviations were identified.
2.
Other Inspection Areas
a.
50.55(e) Personnel Air Locks
The inspector checked on the status of the activity to resolve the
remaining open questions on the personnel air locks. The manufacturer
is working on the completion of the as-built record, revised drawings,
and updated stress report. Bechtel will review these item when they
are completed. The manufacturer will advise if any further repair or
rework is recommend. This item will remain open and additional review
will be conducted at subsequent inspections.
-5-
c:
.
.
Section 11
Prepared by
E. J. Gallagher
R. B. Landsman
Reviewed by
R. C. Knop, Chief
P: 9jects Section 1
1.
Review of Onsite Soils Works Activities
As a followup to NRC Inspection Report No. 50-329/80-32; No. 50-330/80-33
the region III inspectors performed an inspection of the current onsite
soils work activities to verify whether adequate corrective actions have
been implemented as described in Consumers Power Company response to
questions 1 and 23 of 10 CFR 50.54(f) submittals. The following are the
specific findings.
'a.
Procedural Controls for Soils Work
It was determined that U. S. Testing Company (UST) have not established
written procedures for implementing the requirements of Testing
Specification C-208.
This specification references numerous ASTM
standards for performing specific tests but does not include procedural
control or instructions for the implementation of such tests.
(1) While observing a laboratory relative density test (ASTM 2049)
it was observed that the variable rheostat on the testing
apparatus was set at maximum setting. The lab te:chnician stated
that ASTM D2049 requires the setting of the machine at maximum
amplitude.
It was determined that UST did not previously determine
the rheostat setting that produced the maximum density for the
material being used onsite.
It was assumed by UST that maximum
setting produced maximum density. Relative density tests are used
to assure that the inplace field density meets the specification
requirements.
-Corpc~of Engineers Manual EM 1110-2-1906 dated November 30, 1970,
Appendix XII,_Page XII-8 states the following:
"It has'been determined that for a particular vibrating table,
mold,.and surcharge assembly, the maximum dry density of a speci-
men may be obtained at a displacement amplitude (rheostat setting)
less than the maximum amplitude of which the apparatus is capable;
i.e. dry density may' increase with increase in rheostat setting to
a setting, beyond which the dry density decreases, therefore each
laboratory-should determine for it's apparatus the rheostat setting
at which maximum density is produced and use this setting for sub-
sequent maximum density testing."
Footnote on Page XII-8 states:
6-
.
-
-
o
.
.
.
.
,
"It may be desirable to redetermine the optimum rheostat setting
at the inception of testing for each major project."
U. S. Testing had not determined this setting nor did a procedural
control exist for the determination of the rheostat setting.
(2) While observing limited field soils work being performed at the
metering pits south of the essential service water intake structure
at elevation 630' it was determined that samples used to perform
relative density tests have been taken af te r the material has been
compacted. These samples should be taken prior to compaction since
grain size and gradations can be altered during compaction. The
relative density test should be performed on as received material
used prior to cotpaction. Grain size is one of the important char-
acteristics of how soil behaves. The inspector determined from a
review of the available grain size analysis that there appears to
be a gradation change of the material comparing before and after
compaction.
A procedural control specifying where and when to taken soil samples
should have been established. UST does not have procedural instruc-
tions specifying the field technique where and when to take samples for
density tests.
(3)
It was determined from discussions with the cognizant UST personnel
that they have been performing in place density tests "at the direction
of the onsite geotechnical engineer." However, there are no pro-
cedural instructions as to what depth below the lift being compacted
the test should be performed. A review of the density test reports
indicate.that they are not correlating the density test depth to the
lift being compacted.
Based on the above, it has been determined that CPCo is in noncompliance
with 10 CFR 50, Criterion V (Procedures) in that adequate laboratory and
field test procedures have not been established for the control of soil
testing activities.
(50-325/81-01-01; 50-330/81-01-01).
CPCo response to 50.54(f) question 23, subsection 3.11, page 23-31
states that "U. S. Testing was required to demonstrate to cognizant
engineering representatives that testing procedures, equipment, and
personnel used for quality verification testing were capable of pro-
'viding accurate test results.
.This commitment has not been
"
..
satisfied based on the above findings.
Subsequent to the inspection CPCo informed the RIII offices on
January 16, 1981, by telephone that U. S. Testing Corporation would
develop and issue implementing procedures for soil work activities.
These procedures will be reviewed during subsequent inspections.
7-
-
- -----
r ..
'
.
.
b.
Document Control For Soils Work
It war determined that U. S. Testing was using uncontrolled forms to
record quality control test results. A binder was observed in the U.S.
Testing lab which contained QC forms used to record test results. On
the inside cover it stated that the index does not reflect the latest
revision of each form. The cognizant lab personnel were not able to
demonstrate that the latest revision of QC test forms were being used
since there were no document control provisions established to control
these forms. An undated U.S. Testing inter-office memo was presented
to the NRC inspector as the procedure to follow when receiving revised
forms.
It states in part, " log into controlled forms index".
The
inspector requested such a form index but did not receive it.
There
was no documentation onsite as to what forms are to be used for what
test as well as what are the latest revisions of the forms.
Based on the above, it was determined that CPCo is in noncompliance
with 10 CFR 50, Appendix B, Criterion VI, (Document Control) in that
measures have not been established to control the issuance of documents
which affect quality activities. (50-329/81-01-02; 50-330/81-01-02)
Subsequent to the inspection CPCo informed the RIII office that quality
control verification forms would be. controlled by the implementing pro-
cedures. This will be verified during subsequent NRC inspections.
c.
Soils Test Records
(1) Quality assurance records for backfill work activities were reviewed
for completeness and compliance with licensee specifications, pro-
cedures, and commitments.
'
~ Bechtel field instruction FIC 1.100, Appendix A, duties and respons-
ibilities of the onsite geotechnical engineer, Paragraph 18, requires
that the onsite geotechnical engineer review and initial all accept-
able UST test report forms.
ANSI N45.2.9 (Quality Assurance Records), Section 3.2.1, requires
that " quality assurance records shall be considered valid only if
stamped, initialed, signed, or otherwise authenticated and dated
by authorized personnel".
Numerous UST density test reports were rubber stamped by the
geotechnical engineer, however, none were dated.
In addition
no procedural controls were established for the use or control
of the rubber signature stamp of the geotechnical engineer.
Based on the above it was determined that CPCo is in noncompliance
with 10 CFR 50, Appendix B, Criterion XVII (Quality Assurance Records)
in that the soil test reports are not initialed or dated and there
were no established controls on the use of a rubber signature stamp.
(50-329/81-01-03; 50-330/81-01-03)
.
-8-
-
-
.,
-
.
.
.
Subsequent to the inspection CPCo informed the RIII office that
soil test reports would be initialed and dated as required. This
will be verified during subsequent inspections.
(2) Specification C-208, Section 9.1.3(d) requires the geotechnical
engineer to review and evaluate test results when densities exceed
certain values. From discussions with the previous geotechnical
engineer, it was (ftermined that the evaluation consisted only of
a check of the numerical calculations for numerical errors.
If the
calculations were correct the disposition was "use as is", this
review does not meet the requirement to evaluate test results.
Subsequent to the inspection CPCo informed the RIII office the'.
documented evaluations of the above would be performed. This
is an unresolved item pending review of the evaluation (50-329/
81-01-04; 50-330/81-01-04).
d.
Review of Nonconformance Reports
The NRC inspector requested all nonconformance reports regarding soil
work activities since March of 1979.
The following reports were made
available.
Bechtel NRC No.
Date
Description of NRC
Status
2294
6/23/79
Failing density tests
Closed
2307
6/25/79
Failing density tests
Closed
2350
7/16/79
Failing gradation test
Closed
2492
8/30/79
Qual. of compaction equip.
Closed
3041
6/25/80
Failing density tests
re-Opened
3159
10/07/80
Failing gradation test
Closed
3165
10/09/80
Lift thickness exceeded
Closed
CPCo NRC No.
Date
Description of NRC
Status
M-01-4-0-005
1/18/80
No spec. requirement for
backfil around piping
Open
M-01-2-9-060
7/19/80
Spec & purchase ~ der for
sand gradation not the
same.
Closed
M-01-9-0-038
5/15/80
Final report on qualifica-
tion of compaction equip-
ment.
Open
The above closed NCR's were determined to be adequately resolved,
those open or reopened will be reviewed during subsequent inspections.
.
-9-
L
[F
'*
. .
.
e.
Qualifications of Onsite Geotechnical Engineer
CPCo response to 50.54(f) question 23, subsection 3.7, page 23-20, states
. that, "one full time and one part time onsite geotechnical soils engineer
have been assigned." The inspector requested the qualifications of the
onsite geotechnical engineer. A resume was presented to the inspector
as representing the assigned individual to implement the commitment in
order to preclude-future soils problems. This engineer is to provide
-the technical direction and monitoring of the entire earthwork process.
The resume that was presented was of an " Engineering Technician" with
no previous formal education in engineering or geotechnical engineering.
-The engineering technician had nominally 15 years of field and laboratory
testing of soils.
r
This information was discussed with representatives of the NRC geotech-
nical branch.
It was determined that CPCo committed to provide techn-
ical direction from a geotechnical engineer capable of being recognized
and licensed by a. state board of registration of professional engineering
or equivalent.
In view of- the fact that adequate' technical direction had not been pro-
- vided per the commitment by CPCo ir. the 50.54(f) response it has been
determined that CPCO is in deviation from a NRC commitment as described
in Appendix B of the transmittal letter of this report.
(50-329/81-01-05;
. 50-330/81-01-05).
- Subsequent,to the inspection, CPCo informed the RIII office that a
- geotechnical engineer would be'onsite beginning January:19,.1981 and
that job descriptions and qualifications for the geotechnical engineer
-for the speciality remedial: work to follow would be developed. This
. action willibe verified during subsequent inspection.
,
~ 2.
Borated Water Storage Tank Reanalysis
During the inspection, the. licensee informed the inspector that the prelimin-
_
ary structural reanalysis of the-borated water storage tank ring foundation
~ yielded results that indicated-the foundation to be overstressed. The in--
~
spector inquired to .the. quality assurance group if this. condition had been-
considered for reportability. After this inquiry, the Manager of Quality
- Assurance produced the CPCo form entitled, " Safety' concern and reportability
3 evaluation" for.the BWST. ring foundation.
,
This ' document indicates that a finitefelement analysis results in forces
~
and moments in excess ~of FSAR'allowables. .The reportability evaluation-
' indicated the event was "not reportable" with further evaluation necessary.
l
'
The planned ~ actions included retaining a consultant to_ review the results
- obtained'by the analysis and/or perform'an independent check and excavate
'
.and Linspect: the foundation for' aigns of overstressing1(i.e. , cracking).
l
-
_
,
,
.10 -
<
<
r-+'
.- i-
ti -
v's
y
y
y
i - e4 c'
w.
gip'w,-e
g-
, , -4
-.4i
, , ,,
ggw.--
+,yg
y
,,-vi.t+
,
qu.
gy,,-
a-
3-,,.s.y
,
s.,,,
3==s-r-7-
--y-mr*"vy-g-
$3-
's.+-
--
p-
m
.
-
4
i
9
On January 23, 1981, CEPo informed the RIII office the excavation around the
Unit 1 tank was complete and that cracks were observed in the areas of over-
stress. CPCo identified this item as a 50.55(e), significant construction
,
deficiency. This item is under review by the NRC staff.
The inspector informed the Region III office and NRR project manager on
January 9, 1981. The licensee's evaluations of the matter are included as
Attachment No. 1 of this report.
Unresolved Items
Unresolved items are matters about which more information is required in order to
ascertain whether they are acceptable items or items of noncompliance or deviations.
Unresolved items disclosed during this inspection are discussed in Section II,
Paragraph 1.c.(2).
Exit Meeting
The inspectors met with licensee and contractor representatives at the conclusion
of the inspection on January 9,1981 and summarized the inspection scope and
findings. The licensee acknowledged the inspection findings. Subsequent to the
exit meeting the inspectors and RIII management. telephoned on January 14, 1981
the Quality Assurance Manager in order to verify what corrective action would
be taken based on the inspection findings. On January 16, 1981, CPCo informed
the RIII office of the actions to be taken which are contained in the report
Section II, Paragraph la, Ib, Ic, and le.
Attachment:
Attachment No. 1
.
-
.
6
- 11 -
.
Attachment No 1
-
.
.
A} m:=m
~
SAFETY CONCERN AND
""!$'cS#McT
Q M l2f
,
OUAtlTY ASSURANCE CtPARTMEN
.
W,M.%
REPORTABILITY EVALUATION
Pm 1
h.
HOW WAS CONCERI; IDEiiTIFIED WHEN, WERE?
TO ~ MANAG ER-MPQ A
Asaresultofthe50.54(f3commitmentstodoa
1. FROM:
R L Rixford
structural reanalysis of Category I Structures (See Items
14-7 and 48-2), the BWST ring foundation was reanalyzed
, OEMNIQ WD - 30{
and values were obtained which were inconsistent with
lSCRE NO:
5
previous values, and inconsistent with FSAR requirements.
! FILE NO: 15.1
The results of the analysis were obtained 1-4-81 and dis- !DATERECEIVED:
cussed la a 1-5-81 CPCo/Bechtel meeting. The Project
g f
~.,,.y
g,
Manager attended this meeting and subsequently briefed
D YES @fic
the Manager of Quality Assurance.
WHENT
N/A
BY WHOM?
N/A
3. IS NRC AWARE CF THIS?
YES M UO
WHENT
N/A
(CONTINUE ON NEXT PAGE)
-
BY WHOM?
N/A
5
BRIEF DESCRIPTION OF C0"CERN - SYSTEM, CCMPONENT, ACTIVITY, POSSIBLE SAFETY IMPACT -
(ATTACH SUPPCRTING DOCUMENTS).
The BWST ring foundation was analyzed for several loading combinations including the. dead
load plus live load which was determined to be the most severe. The analysis was first
performed using the methods of BC-TOP-4A, Rev. 3 (this method uses springs for soil /
,
structure interaction during a seismic event), but gave displacement values inconsistent
with anticipated and measured values. The analysis was then done using a finite element
technique which gave consistent displacement values but forces and moments in excess of
FSAR allowables. The values obtained fron the reanalyses which have been done indicate
an overstressing and, hence, a potential for failure of the foundation of the Category 1
BWST.
~
-
(CONTI!IUE CU NEXT FAGE)
6.
IWEDIATE REPORTABILITY EVAIDATION:
7
ORGANIZATION REFONSIBI.E FOP FURTHER
a. O REPCRTABLE
- GO TO 13
EVALUATION:
b.
POTENTIE LY REPORIABLE - GO TO 13
Bechtel Engineering - Civil
e.O NOT REPOICABLE, FURTHER EVALUATION
8.
FINAL REPORTABILITY EVALUATION
d. O nor REF0FTABLE
(IP 6 e. CHECK 3D):
.
R3POPTABLE
b, U NCT REFORTABLE
a.
'
~
9
QA APPRO'lAL OF EVALUATION
'
OF BLOCVS 1 TO 7:
A/M
YU
.
W / '--
MANACER - MPQA
DATE
_
10.
JUSTIFICATION OF EVALUATION - ( ATTACH SUPPORTING DOCUMENTS)
The first reanalysis gave displacement values which vere inconsistent with measured
settlement and anticipated values. This cast doubt upon the spring values used in the
analysis. The subsequint finite element analysis gase displacement values which were con =
sistent with the.other values available for comparison, but gave forces.and moments which
exceeded the FSAR allo tables by an amount suf ficient to warrant an additional check on
these values also.
Two acticas planned to check these values are:
,
'
l.
Retain a consuleant to review the results obtained by analyses donc, and/or
do an independent check.
2
Excavate and inspect the founda*. ion for signs of overstressing (i.e., cracking).
It was considered prenature to judge this a reportabic condition prior to confirmation of
.
the values obtained'by the finite element analysis.
(CONTINUE 0:: NEXT PAGE)
11.
EVALUATO E
NATUhE/DAT":
12. FINAL QA AlPROVAL - I'AI!AGER MFQA/DisTE:
l
.
Jr-p
/-S~ rP/
,
13. EC Nor'?ICA110N: 110'!?
DATE:
TIME:
INDIVICUAL NJTIFIFD:
ar rnrncF:
.FEB 0 6 1M
L cggym
'
dAFETY CONCERN AND
"i?# TS #lt fs ?
.
.
'gll'J
REPORTABILITY. EVALUATION """"[j'joi"f""
'
'
i
o
'
h.
CohTTNtTED
'
.
-
.
.
-
.-
.
-
~
.
.
5.
CONTINUED
.
.
-
-
i
10.
CONTINUED
!
.
.
'
.
l
.
.
-
i
.
.
!
lb. MINIMUM DISTRIBUTION:
15
ADDITIONAL DISTRIBUTION:
VICE PRESIDENT - PELC
11PQAD - DQAE Supervisor
l
VICE PRESIDENT - MIDLAND PROJECT
'
DIRECTOR - E:iVIRONMEllTAL SERVICES & QA
MIDLMIP SITE IWIAGER
SITE QA SUPERINTENDE!!T
l
MANAGER - SAFETY & LICENSING
'MIDLA'.ID FILE NO 15.1
'
.
n