DOE F 1325.8 K) memorandum A Foaaudits of their prime/integrating contractor(s) and in the audits of major contractors conducted by the prime/integrating contractors for the Project

v U-DOE F 1325.8

Un-ited States Government K)

memorandumDATE:

REPLY TO RW-24ATTN OF:

kgartment of EnergyA ,o7 Foa

- - L -P1 - (.I WM I^t _ O )J

- .- I1 I -a., O- II (2)

,%J FEB1 pp12:-21SuBJECT: FY 1987 Consolidated Audit Schedule

TO: OGR Auditors

Attached is the FY 1987 consolidated schedule for all OGR andproject audits showing proposed participation of OGR auditors.Please advise me as soon as possible of any problems in yourparticipating in the audits indicated.

I also want to remind you that you are to prepare a writtenreport of your participation within 5 days of the completionof the audit. This is required by OGR Quality ImplementingProcedure 186.1 (copy attached). We (HQ) will be audited by NRCin the near future and it will prove embarrassing if we cannotdemonstrate compliance with our QA procedures. Attached are two"sample" reports that others have prepared; I hope this will beof assistance in writing your own.

Thanks for your willing involvement in our QA audit process - Iappreciate your contributions.

6e $e47Carl Newton, Quality Assurance ManagerOffice of Geologic Repositories

Attachments:

87060301717 670217 1?PDR WAST>E PDR

4(s,,3)

s_; 05fy/ )

WM Prject LQfJo,- 6Docket No.

PORLPDR _

at aI

Distribution

OGR Auditors

0. Thompson, RW-24C. Newton, RW-24D. Brown, WestonG. Faust, WestonJ. Richardson, WestonT. Russell, RW-32N. Abraham, RW-231K. Sommer, RW-242G. Faulkner, RW-233M. Lugo, WestonH. Bermanis, WestonR. Clark, WestonS. Panno, WestonL. Ibe, WestonR. Coleman, RW-221C. Kouts, RW-32S. Gomberg, RW-241E. Regnier, RW-242T. Gutmann, RW-32E. Gilardi, Westona. Richardson, Westona. Jones, RW-241

( (

OGR Consolidated Audit Schedule1987

P'*jct January Februay March Apifg May June July Auguat Seotmber October November December

OCR

(Thoempege) (New~Okt..) (arelm") lO$ Dow.) (TOMa GA PMog (Nua-.11) (fg~ew"(Pumme 11,01011tel (Pao"" (PiON" (Jee) (Atbaob-I

(Pou~oflt(Sevenow)

oNWm Oo~d1rat OmwVa,a8 amen.4/ Pe/Posts 01110361 M.K /? IulogruIN a/4fAehueum) (Took moviow) (Wowlom) felork) (so-mmo, (Ouas II (megotor)

ILVOge gao-me,) IFIV00e1) (Thompo.") (SBttwn) 4O01m~am.(Cotose) ........ . . .......... g....cu

SAPO ......... 114 /2t rm;ZAui- cut.SLel. W/I? toon-alo) (SO..-., ail qqowlsj IS-N.)

Columbus jo~~~~~~~(b*) (Jumee) (Kel) (nIw (agleo"") (Serased)(Clerk) .......

Aft s/ti Fleets/asISOai(C420906 (lbe) (JuneM)

________________ ~~~~~~~ ~~~~~~~~~~(La"o) (Ueonnaelg) (Loge)_ _ _ _ _ _ _ _ _ _ _ _

Lee Alow... "Noi SAIC/TAM911 1111s Deneor P55ow "Wa.NEco(Sorw-) (Nlobwrdoan) (Cutw...) (Semier) (ramst) (Ibe)

(Somnie,) (O4lerd) (Thempossi) (Tko.Poolt (Coto"000 (Clorm)

WMPO .............

Nevada pr

(Wowlen) ~ ~ ~ ~ ~ ~ oo

retals

S

a

17

7

Totals 2 1

(Nome) Selects by HO-OGR lfm PatlopActual Dteo of Audtsg go be CeIdMed S3 Days In AdvanceSecond AudWo Scheduled Is an AIenato.

4 4 7 7 5 6 ,*.t

3F A IsI Sheuld

II OWN og 2010#4?

. I

SCHEDULE OF O&.ATICIPATION IN PROJECT AUDITS _

OGR ESTIMATED PROJECTREPRESENTATIVE START DATE OFFICE CONTRACTOR

Jay Jones * 4/21/87 SRPO UNC* 7/87 BWIP Boeing-BCSR8/18/87 SRPO TFSC

Lib Ibe 3/17/87 SRPO Lawrence Berkeley Lab.6/23/87 SRPO Flour8/87 WMPO REECO

Christopher Kouts * 5/12/87 9RPO PNL7/21/87 SRPO Oak Ridge Nat. Lab.

Miguel Lugo 3/3/87 SRPO ONWI (Tech. Review)* 5/19/87 SRPO Argonne Nat. Lab.* 8/18/87 SRPO TFSC

Carl Newton 3/87 BWIP Westinghouse4/7/87 SRPO Brookhaven Nat. Lab.6/87 WMPO USGS Menlo Park

Sam Panno * 3/87 BWIP Westinghouse6/87 SRPO PNL/HEDL

Ed Regnier 8/87 SRPO Integrator

John Richardson 4/87 WMPO Holmes & Narver* 6/87 BWIP Rockwell

Tom Russell * 5/5/87 SRPO Parsons Brinckerhoff/PB7/87 BWIP Boeing-BCSR

Karl Sommer * 3/87 WMPO Los Alamos Nat. Lab.* 4/7/87 SRPO Brookhaven Nat. Lab.* 5/87 BWIP DOE-RL (Non-QSD)5/12/87 SRPO PNL6/2/87 SRPO/WMPO USGS Denver7/11/87 SRPO USBM

Owen Thompson 1/87* 5/87* 6/87

BWIPWMPOSRP0/WMPO

Battelle-PNLSAIC/T&MSSUSGS Denver

SCHEDULE OF O&J TICIPATION IN PROJECT AUDITS

OGR ESTIMATED PROJECTREPRESENTATIVE START DATE OFFICE CONTRACTOR

Naomi Abraham 2/17/87 SRPO Golder* 8/87 BWIP Morrison-Knadsen

Henry Bermanis 4/21/87 SRPO UNC* 6/23/87 SRPO Flour* 8/11/87 SRPO USBM

Dave Brown 3/87 WMPO Los Alamos Nat. Lab.4/87 BWIP Kaiser Eng/PB* 5/87 BWIP DOE-RL (QSD)* 7/87 SRPO Morrison-Knudsen

Bob Clark * 3/17/87 SRPO Lawrence Berkeley Lab.5/5/87 SRPO Parsons Brinckerhoff/PB* 8/87 WMPO REECO

Renee Coleman * 3/3/87 SRPO ONWI (Tech. Review)5/19/87 SRPO Argonne Nat. Lab.* 7/87 WMPO Fennix & Scission

Glen Faulkner * 4/87 BWIP Kaiser Eng./PB5/87 BWIP DOE-RL (Non-QSD)* 6/16/87 SRPO PNL/HEDL

Gary Faust 5/87 BWIP DOE-RL (QSD)6/87 BWIP Rockwell7/87 WMPO Fennix & Scission8/87 BWIP Morrison-Knudsen

Edward Gilardi * 4/87 WMPO Holmes & Narver

Steve Gomberg * 6/877/7/87

WMPOSRPO

USGS Menlo ParkMorrison-Knudsen

Tom Gutman 5/87* 7/21/87* 8/4/87

WMPOSRPOSRPO

SAIC/T&MSSOak Ridge Nat. Lab.Integrator

* Indicates an alternate auditor.

."'ALITY IMPLEMENTING PRO' )UREHEADQUARTOFFICE OF GEOLOGIC REATORIES (HQ-OGR)

QIP No. 18.1 Pag 1 *s 3

RAeY. 1 .Issued 8/1/8 6

TflnhE Headquarters Participation in Project O2fice %REPAREOBYAudits of Their Contractors I .9O

Y.~ ~ ~ ~~~~~~~~~.REVIEWED By. AA t A | APPROVED B

OrR A UNER D4% 4/1. e DIRECTOR -SIN UCS.,N - SOCIATE

1.0 Purpose

The purpose of this procedure is to describe the system for HeadquartersOffice of Geologic Repositories (HQ-OGR) participation in Project Officeaudits.

2.0 Scope

This procedure applies to HQ-OGR participation in the Project Officeaudits of their prime/integrating contractor(s) and in the audits ofmajor contractors conducted by the prime/integrating contractors for theProject Offices.

3.0 References

3.1 HQ-OGR Quality Assurance Plan - OGR/B-3

3.2 QIP 18.3 Auditor Training, Qualification and Certification

3.3 QIP 17.0 Quality Assurance Records

4.0 General

4.1 Reference 3.1 requires HQ-OGR to participate in selected QA auditsof the contractors which are conducted by the Project Office orassigned by them to be conducted by a prime or integratingcontractor.

4.2 Reference 3.2 requires that personnel who audit activities beprovided appropriate training to assure that suitable proficiency isachieved and maintained.

5.0 Responsibilities

5.1 The OGR - Quality Assurance Manager (QAM) is responsible forreviewing project audit schedules and selecting the audits in whichHQ personnel will participate.' He will notify the Project Office inwriting of the audits selected for HQ participation.

Procedure No. 1R .1 e IRI. 1 Isued P 2 page o 3

6.0 Procedure

6.1 OCR - Quality Assurance Manager .- |

6.1.1 The QAM will review the audit schedule and audit plans fromeach project to select the audits in which HQ-OGR willparticipate. The selection is based on trends identified inprevious audits, QA program requirements, conditionsidentified by unusual occurrence reports, or other asdetermined by the QAM.

6.1.2 The Project Office is notified by written memo of theaudit(s) in which HQ-OGR will participate and will berequested to provide HQ with confirmation of the audit datesand scope sufficiently in advance of the scheduled audit inorder that travel plans may be made.

6.2 HQ-OGR Audit Team Member

6.2.1 Upon HQ-OGR notification by the Project Office of a scheduledaudit, the QAM will assign a HQ-OGR representative toparticipate in the audit as a team member. The assignedrepresentative(s) must be certified in accordance withReference 3.2.

6.2.2 The HQ representatives will thoroughly familiarize themselveswith the QA plan and procedures identified in the auditnotification and contact the project's audit team leader, ifrequired, to obtain specific details. The audit checklist isprepared by the Audit Team Leader, but specialized questionsmay be developed by the HQ representatives for use during theaudit.

6.2.3 At the completion of the audit, the HQ representative(s) willsubmit completed checklist or notes of items examined,persons contacted, and findings and observations to the AuditTeam Leader who will issue the audit report.

6.2.4 The HQ-representative, within 5 days-of return from theaudit, will submit a written summary report. The solepurpose of this report is to provide HQ with a synopsis ofaudit results in advance of the audit team leader's officialaudit report. The summary report shall as a minimum:

a) Describe the scope of the audit.b) Identify the organization audited.c) Provide a list of audit team members.d) Provide comments.on the effectiveness of the QA Plan and

procedures audited.e) Provide a summary of the findings and observations (if

any).f) Highlight significant problems which may have an impact

on program-wide activities. Problems, if any, should bediscussed with the audit team leader prior to conclusionof the audit in order that they are accurately describedin the summary report.

7-- --

Pfec.durt No. 18.1 Issuet 1 j * N PageV .....*

6.2.5 The summary report will be addressed to the QAM with copiesto the Associate Director, OGR; the Director, Siting,Licensing and QA Division and the audit team leader.

7.0 Recbrds

Audit records are nonpermanent and as such will be maintained for aminimum of 5 years in accordance with Reference 3.3. As a minimum, thefollowing records shall be maintained:

a) Audit Plansb) Audit Reportc) Audit Summary Reportsd) Other correspondence related to each audit.

[-1 8.0 Appendix

None

KU55 LVENFANT PLAZA, S.W.

8TH FLOORWASHINGTON. D.C. 20024PHONE- (202) 646-60

Mr. D. Carl NewtonQuality Assurance ManagerSiting, Licensing, and QA DivisionOffice of Geologic RepositoriesOffice of Civilian Radioactive Waste ManagementU.S. Department of EnergyRW-24 (Forrestal)Washington, D.C. 20585

JFW-QA-DEL-01729-86October 17, ,n86

Subject: Report of Weston Participation in SRPO QA Audit of Parsons-RedpathContract # DE-ACMl-83-NE44301TDD# 3002-24-24-3006

Dear Mr. Newton:

As required by OCR Quality Implementing Procedure No. 18.1, attached isa suiamry report of Weston participation in the audit of Parsons-Redpath QAProgram on September 30 through October 2, 1986, under Audit No. PR-86-13-E.The audit was performed by the DOE's Salt Repository Project Office (SRPO) andBattelle Project Management Division LIPHD).

Should you have any questions(202) 646-6661.

on the report, please contact Lib The at

Sincerely,

ROY F. W ON, INC.

Leonard T. Skoblar, ManagerRegulatory, Safety andQuality Assurance Department

WilliamM En M6Program Manags

Enclosure

cc: R.E.J.T.S.

BlaneyBrandtFioreIsaacsKale

J.M.T.R.W.D.C.

KnightLangstonJ. Reese (SRPO)SteinHewittSiefkenHawley

Office of Civilian Radioactive Waste Management (OCRWM) - Technical Support TeamWESTON In association with: Jacobs Engineering Group Inc. * ICF Incorporated * Williams Brothers Engineering C,

Rogers and Associates Engineering * United Engineers and Constructors. Inc.

KJREPORT ON WESTON PARTICIPATION IN

SEPO QA AUDIT OFPARSONS-REDPATH QA PROGRAM

AUDIT NO.: PR-86-13-E

AUDITING ORGANIZATION:

AUDITED ORGANIZATION:

DATE OF AUDIT:

AUDIT SCOPE:

DOE Salt Repository Project Office

Parsons-Redpath

September 30 - October 2, 1986

The scope of the audit was directed towardParsons-Redpath's implementation of their QA Programas described in the QA Plan and quality implementingprocedures. In addition, verification of thecorrective actions identified by Parsons-Redpath as aresult of the previous DOE audit was performed.

Specific areas addressed during the audit were; QAprogrammatic aspects including training anddocumentation, management assessment and reports tohigher management, technical review of documents andreports, instructions and procedures, documentcontrol, procurement control, nonconformance andcorrective action, records and audits.

AUDIT TEAM: T.D.L.D.M.R.D.

J. ReeseL. AndersonD. IbePatersonL. GildnerWatersHiall

DOE/SRPO, Audit Team LeaderDOEISRPO, AuditorWeston, AuditorDOE/CER, AuditorBPMD, Auditor-in-TrainingDOE/HQ, Technical ObserverBPMD/ONWI, Technical Observer

Summary of the Audit

The Audit Team was divided into two groups. The first group, whichincluded the technical observers, looked into the design reviews, documentcontrol, QA program implementation and interface control. The second groupdid the programmatic audit. I was part of the second group.

-1-

At the end of each day, the Audit Team Leader (ASK allypresented to the Parsons-R; _4h (P-R) management, the audit fft*.t'6gs andobservations on the areas audited for that day. At the conclusion of theaudit, the ATL discussed the team's overall assessment of the P-R QA Program.He presented to the P-R Project Director one (1). audit finding and two (2)observations. He informed further that additional comments will be given inthe audit report to be prepared. The audit finding and observations are asfollows:'

Finding (AAR No. PR-86-13-E-1)The Records/Document Center does not inspect the records turnedin by the department managers. Records indexing is insufficientto identify documents within a file folder. Some single copy QArecords are not protected.

Observation (AAR No. PR-86-13-E-2)There is no identification of training requirements by jobposition. Signatures on "Read and Route" forms do not indicatewhether it is for receipt of the document or if it is forcompletion of the reading. Some training records do not indicatethe revision numbers of the documents used in training. Sometraining attendance sheets are incompletely accomplished.

Observation (AAR No. PR-86-13-E-3)P-R Staff fail to follow procedures, such as in (a) completingaudit checklists and (b) completing document reviews made. Thisobservation was also detected in the internal audit of P-R.

Comments on the Audit and P-R QA Program

1. The audit was conducted in a very professional "unner. The P-Rstaff was equally professional and quite cooperative inresponding to the questions and requests of the audit team.

2. Several inadequacies of the P-R QA Plan/Procedures were noted asthe audit was performed. However, considering that SEPO has notcompleted its review/approval of these submitted documents, theauditors could not list them as findings or observations. Somemembers of the audit team, who are also reviewing the P-Rdocuments, assured that the inadequacies will be addressed whenSRPO sends its comments on the P-R QA Plan/Procedures. Note thatP-R was authorized to implement the QA plan/procedures pendingreceipt of SRPO comments/approval on the documents submitted.

3. The audit team first group had difficulty rationalizing thedesign computations being performed by the P-R staff. P-R claimsthat the design of another contractor on the exploratory shaftwas being "reviewed for constructability and inspectability".There was vagueness on the purpose of the calculations.Moreover, P-R does not claim design control responsibility andthe calculations done by the P-R staff appear not to comply withQA requirements for design review.

-2-

I iThe problem f ied seem to stem from the vagul J of thestatement of\%.w£ issued to P-R, and the lack of i!r~tificationof documentation expected from the contractor.

4. In the procedures reviewed, it was noted that there is no directindication of what records are required to be turned over by P-Rto DOE/SRPO. The procedures merely state that "when requested bythe Client, records will be turned over." The audit-jeam leaderacknowledges the weakness of the current QAspecifications/requirements issued to P-R. However, he assuredthat, with the issuance of the OGR QA Plan and QA Supplements,the QA requirements will be revised and made more definitive.With the current situation, there could later arise on the needfor validation of prior quality records or data not having beenobtained under a qualified QA program.

5. The P-R staff, particularly the QA Department, is trying to comeup with a viable QA program. The staff attitude towards QAappears to be encouraging. Although the other audit team membershave noted a marked improvement in the QA approach since the lastaudit in 1985, it is felt that considerable indoctrination andtraining efforts, and dedication to QA principles, are stillneeded to have an acceptable QA program going for P-R. Apositive commitment on the part of P-R management could make thebig difference.

Auditor

-3-

United States Government

memorandumDepartment of Energy

DATE:

REPLY TO RW-2 4ATTN OF:

OCT 0 6 1986

MfiE= Report of Participation by Karl Sommer in SRFP QA Audit of PNL-Richland, WA

TO.

Jim Knight

Discussion:

Attached as required bymy participation in theof September 21, 1986.

section 6.2.4 of OGR QIP 18.1 is a report ofQA Audit conducted by SERPO of PNL the week

S6. S R-Karl Sommer, RW-24

Attachment:

cc w/att: J. Reese, SRPO

Report of OGR Participation in SRPO QA Audit of PNLRichland, Washington

Auditing Organization: Salt Repository Project Office.

Audited Organization: Pacific Northwest Laboratories.

Dates of Audit: September 22-25, 1986.

Audit Scope: (1) Performance Assessment(2) Waste Package Studies

Audit Team Members:

T. J. Reese, SRPO, Audit Team LeaderT. F. Orlin, BPMD/ONWI, Auditor3. C. Cunnane, ONWI, Technical ObserverS. Brown, BPMD/ONWI, AuditorS. Mohan, ONWI, Technical ObserverC. Walenga, NRC/EQ ObserverT. 3. Lefman, BPHD/ONWI, AuditorK.- K. Wu, SRPO, Technical ObserverK. G. Sommer, DOE/OGR, Auditor-T. Verma, NRC/EQ ObserverJ. Perrin, ONWI, Technical ObserverV. McCauley, ONWI, Technical Observer

Summary of Audit:

The audit was divided into three (3) teams with a balance of bothauditors and technical observers. The two (2) Team Leaders assignedto waste package activities were T. Orlin and 3.-Lefman, the thirdteam leader assigned to performance assessment was S. Brown.

Team I was responsible for solubility data, gamma radiolysis, andsurveillance verification. Team 2 was responsible for corrossiondata, spent fuel, and programmatic review and audit follow-up.Team 3 was responsible for computer code development, modeling,documentation verification, valadiation, and application.

The Audit Team Leader (ATL), J. Reese (SRPO) conducted a veryprofessional audit, from the pre-audit caucus through the finalclose out meeting with PNL management.

The focus of the audit was on QA program implementation and thetype of technical product being obtained.

KUj

-2-

During the pre-audit caucus NRC (C. Walenga) briefed audit teammembers on NRC's performance oriented inspection system, i.e., indepth review and total implementation of the QA program. NRCindicated the checklist requires additional technical questions toconfirm we will obtain a high-quality technical product. While Icannot dispute this concern by NRC, checklists are a start --- thetechnical product observers during the audit cycle confirmed that agood quality product has, to date, been supplied.

The audit revealed several concerns during the four (4) day auditcycle, many of the concerns were reviewed during the daily briefingto PlL management.

The ATL reviewed the teams' joint findings (3 total) andobservations (8 total) during the final close-out meeting, detailsare as follows:

Finding I - Problems in the area of internal audit record booksand lack of detailed documentation.

Finding 2 - Problems in the area of QA audit system;checklists not completed and not specific as toscope, responses lacking, corrective actionsunresolved, and technical personnel notinvolved.

Finding 3 - Problems in the area of waste package modeling;software procedures not fully implemented and labpersonnel retraining required.

Observations - Revealed several concerns/problems in areas of;management assessments, surveillance, procedurereview, document control, computer run verifications,hand calculations, computer codes, and QA plan.

Evaluation of Conduct of Audit:

The audit was well conducted, and very professional. The QAAuditors were experience and for the most part, all five (5)technical observers were well trained, knew the check-listcontents, and were of the proper discipline.

The audit checklist was well developed and, in my opinion, basedon my experience using technical type audit checklists for Radio-isotope Thermoelectric Generators for the Galiled and UlyssesNASA) shuttle missions, covered the necessary aspects to assessthe quality of the technical product (Data Reports).

F_

-3-

I believe, based on comments from the two (2) NRC observers,NRC were, for the most part, convinced the technical productwas properly assessed, and also the QA system was properlyassessed. The NRC observers indicated the technicalobservers were a welcome addition to the audit team, and, infact, confirmed DOE/OGR have moved-up on the "LearningCurve".

The ATL is to be congratulated for the professional conduct ofthe audit and, obtaining a good balance between QA and technicalaudit personnel.

Areas that offer a potential for improvement in the future are:

1). Attempt to limit scope to reduce the number ofelements to be audited --- this was a "long-audit".

2). If scope is reduced, more frequent audits necessary tocover all elements.

3). The PNL presentation at the pre-audit conference wasbrief, not a detailed discussion on the PNL organization.In fact, during the audit cycle, I had to make a requestthree (3) times before I received a quality organizationchart.

4). If a specific organization believes checklists are lacking(either QA or technical aspects), they should offersuggestions for improvement after receiving and reviewingthe checklists --- prior to the audit.

Evaluation of Auditing- For- Effectiveness:

SEPO used the auditing - for - effectiveness method during thisaudit --- the checklist was well developed to determine programmaticproblems.

Several comments as noted below:

1) The audit did focus on the quality of the technicalactivities.

2) All audit team members were trained for the requirements ofauditing - for - effectiveness.

3) SRPO should set-up and conduct a surveillance of PNL(specific activities) as the audit follow-up to againmeasure the effectiveness.

-4

4) The PNL QA Manager (C. Hunghey) must initiate controls toincrease effectiveness of the QA systems and audits sectionsof the Quality Achievement Division.

.L t

FOR OCRWM DISTRIBUTION

SUBJECT:

ADDRESSEE:

Report of SRPO Audit of PNL

J. Knight

OCRWX Distribution: BCC:

S. Kale, RW-20T. Isaacs, RW-22H. E. Langston, RW-40E. Steinberg, RW-33J. Knight, RW-24

#.Oriaginator's Chron: K. So~merOCRWM CCRU, RW-13 (5)OGR Reading FileL&R Div. ChronL&R Div. File # 6510,903.12.9.2

D. Siefken, WestonL. Skoblar, WestonL. Ibe, WestonJ. Kennedy, NRC

RW-24:KSoimersXHA3252-1639:typed 9/30/86PC Code: KS23Mach C

CONCURRENCES:

_ _. _ So, 6, 2. omnmer W-24

K>

, I'I .

\>-

MEMO DISTRIBUTION LISTING

SUBJECT: FY 1987 Consolidated Audit Schedule

ADRESSEE: OGR Auditors

OCRWM Distribution: BCC LISTING:

J. Knight, RW-24M. E. Langston, RW-40H. Steinberg, RW-33S. Echbls, GC-lloriginator's Chron: SommerOCRWM CCRU, RW-13 (5)OGR Reading FileL&R Div. ChronL&R Div. File # 6510.903.12.9.3.1

D. Siefken, WestonL. Skoblar, WestonJ. Kennedy, NRC ,

RW-24:KSommer:MXA:252-l639:typed 2/11/87

PC Code: KS49

CONCURRENCES:

K. Sommer, RW-242112 4'F7 C 4

C. Newton, RW-24

2./ Ly,