Information Notice 2007-04, Construction Experience Related to the Assurance of Quality in the Construction of Nuclear Power Plants: Difference between revisions

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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES


NUCLEAR REGULATORY COMMISSION
===NUCLEAR REGULATORY COMMISSION===
OFFICE OF NUCLEAR REACTOR REGULATION


OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC  20555-0001


WASHINGTON, DC 20555-0001 February 5, 2007 NRC INFORMATION NOTICE 2007-04:                 CONSTRUCTION EXPERIENCE RELATED TO
===February 5, 2007===
NRC INFORMATION NOTICE 2007-04:


===CONSTRUCTION EXPERIENCE RELATED TO===
THE ASSURANCE OF QUALITY IN THE
THE ASSURANCE OF QUALITY IN THE


CONSTRUCTION OF NUCLEAR FACILITIES
===CONSTRUCTION OF NUCLEAR FACILITIES===


==ADDRESSEES==
==ADDRESSEES==
Line 42: Line 45:
addressees to the importance of considering lessons learned from construction experience
addressees to the importance of considering lessons learned from construction experience


when planning for and constructing new nuclear power plants or fuel cycle facilities. Recipients
when planning for and constructing new nuclear power plants or fuel cycle facilities. Recipients


are expected to review the information for applicability to their planned activities and to consider
are expected to review the information for applicability to their planned activities and to consider


actions, as appropriate, to avoid similar problems. However, the suggestions contained in this
actions, as appropriate, to avoid similar problems. However, the suggestions contained in this


IN are not NRC requirements; therefore, no specific action or written response is required.
IN are not NRC requirements; therefore, no specific action or written response is required.


==DESCRIPTION OF CIRCUMSTANCES==
==DESCRIPTION OF CIRCUMSTANCES==
Interest in constructing new nuclear power plants is increasing in the United States. Fifteen
Interest in constructing new nuclear power plants is increasing in the United States.   Fifteen


utilities have officially notified the NRC of their intent to submit applications to construct more
utilities have officially notified the NRC of their intent to submit applications to construct more


than 24 new nuclear power plants. One major fuel cycle facility is currently under construction
than 24 new nuclear power plants. One major fuel cycle facility is currently under construction


in the United States with more expected. These events follow a hiatus of more than 20 years in
in the United States with more expected. These events follow a hiatus of more than 20 years in


the construction of new reactors in the United States. Lessons learned during the last period of
the construction of new reactors in the United States. Lessons learned during the last period of


plant construction in the United States and during recent international construction offer the
plant construction in the United States and during recent international construction offer the
Line 67: Line 70:
Developing an appreciation for these factors will decrease the likelihood of repeating past
Developing an appreciation for these factors will decrease the likelihood of repeating past


mistakes and will promote quality in nuclear power plant design and construction. While the
mistakes and will promote quality in nuclear power plant design and construction. While the


experiences referred to in this IN come from the construction of a new nuclear power plant, the
experiences referred to in this IN come from the construction of a new nuclear power plant, the
Line 78: Line 81:
In the late 1970s and early 1980s, several nuclear power plant construction projects
In the late 1970s and early 1980s, several nuclear power plant construction projects


experienced major problems related to design and construction quality. The Congress directed
experienced major problems related to design and construction quality. The Congress directed


the NRC to conduct a study to improve quality in the construction of future nuclear power
the NRC to conduct a study to improve quality in the construction of future nuclear power


IN 2007- 04 plants. The NRC published the results of the 1984 study as NUREG-1055, Improving Quality
IN 2007- 04 plants. The NRC published the results of the 1984 study as NUREG-1055, Improving Quality


and the Assurance of Quality in the Design and Construction of Nuclear Power Plants
and the Assurance of Quality in the Design and Construction of Nuclear Power Plants
Line 90: Line 93:
NUREG-1055 focused on what had happened in the past to derive lessons to apply in the
NUREG-1055 focused on what had happened in the past to derive lessons to apply in the


future. The report stated:
future. The report stated:
        The increased industry and NRC experience and the lessons learned, if applied
The increased industry and NRC experience and the lessons learned, if applied


properly, should decrease the probability of major quality problems in future
properly, should decrease the probability of major quality problems in future


generations of nuclear plants. However, there are several conditions under
generations of nuclear plants. However, there are several conditions under


which major quality problems might recur. These include the following:
which major quality problems might recur. These include the following:
        *         A first-time utility with staffs or an architect/engineer, construction
*
A first-time utility with staffs or an architect/engineer, construction


manager, or constructors (vendors and fabricators) that have inadequate
manager, or constructors (vendors and fabricators) that have inadequate


nuclear design or construction experience;
nuclear design or construction experience;
        *         A very large growth in the number of nuclear power plants being
*
A very large growth in the number of nuclear power plants being


constructed that can overwhelm the industrys and NRCs capabilities;
constructed that can overwhelm the industrys and NRCs capabilities;  
        *         A long delay before nuclear plant construction activities start again, resulting in a dearth of experience in the industry;
*
        *         Regulatory actions at federal and state levels that undercut quality.
A long delay before nuclear plant construction activities start again, resulting in a dearth of experience in the industry;
*
Regulatory actions at federal and state levels that undercut quality.


The NRC and the nuclear industry need to be aware of the implications for
The NRC and the nuclear industry need to be aware of the implications for
Line 115: Line 122:
Several of the conditions identified in NUREG-1055 under which major quality problems might
Several of the conditions identified in NUREG-1055 under which major quality problems might


recur currently exist in the U.S. This fact emphasizes the importance of understanding the
recur currently exist in the U.S. This fact emphasizes the importance of understanding the


causal factors associated with historical construction problems in order to chart a future course
causal factors associated with historical construction problems in order to chart a future course
Line 126: Line 133:
cycle facilities in a manner consistent with NRC regulations and other applicable federal laws.
cycle facilities in a manner consistent with NRC regulations and other applicable federal laws.


Each licensee is responsible for achieving and assuring the quality of a nuclear power plant, beginning with its design and construction. NUREG-1055 identified several causes of
Each licensee is responsible for achieving and assuring the quality of a nuclear power plant, beginning with its design and construction. NUREG-1055 identified several causes of


significant quality-related problems that have occurred during the construction of nuclear power
significant quality-related problems that have occurred during the construction of nuclear power


plants:
plants:
*       An inability of utility management to adequately control all aspects of the construction
*
An inability of utility management to adequately control all aspects of the construction


project, including planning, scheduling, procurement, and oversight of contractors;
project, including planning, scheduling, procurement, and oversight of contractors;
*       Inexperience with nuclear plant construction, resulting in utilities and their contractors
*
Inexperience with nuclear plant construction, resulting in utilities and their contractors


not fully appreciating the complexity and difficulty associated with building a nuclear
not fully appreciating the complexity and difficulty associated with building a nuclear
Line 140: Line 149:
power plant and therefore the importance of nuclear-related standards;
power plant and therefore the importance of nuclear-related standards;


IN 2007- 04 *       A false sense of security growing out of prior successes;
IN 2007- 04 *
*       A failure to establish an atmosphere that encourages problem reporting and resolution
A false sense of security growing out of prior successes;
*
A failure to establish an atmosphere that encourages problem reporting and resolution


at all levels of the organization;
at all levels of the organization;
*       A failure to delegate authority commensurate with responsibility; and
*
A failure to delegate authority commensurate with responsibility; and


*       A failure to have clear communication pathways across all project interfaces.
*
A failure to have clear communication pathways across all project interfaces.


NUREG-1055 noted that quality craftsmanship is an absolute necessity for achieving quality in
NUREG-1055 noted that quality craftsmanship is an absolute necessity for achieving quality in


nuclear construction. Further, it also noted that the failure of management to control certain
nuclear construction. Further, it also noted that the failure of management to control certain


conditions, such as the amount of rework because of excessive design changes, the failure to
conditions, such as the amount of rework because of excessive design changes, the failure to
Line 162: Line 175:
Improvements in the performance of operating reactors over the last decade may suggest that
Improvements in the performance of operating reactors over the last decade may suggest that


these historical issues will no longer pose a problem. However, recent construction
these historical issues will no longer pose a problem. However, recent construction


experiences in Finland indicate that the causal factors identified in 1984 continue to exist in the
experiences in Finland indicate that the causal factors identified in 1984 continue to exist in the


current international construction arena. In Investigation Report 1/06, Management of Safety
current international construction arena. In Investigation Report 1/06, Management of Safety


Requirements in Subcontracting During the Olkiluoto 3 Nuclear Power Plant Construction
Requirements in Subcontracting During the Olkiluoto 3 Nuclear Power Plant Construction
Line 172: Line 185:
Phase, dated July 10, 2006, the Finnish Radiation and Nuclear Safety Authority (STUK)
Phase, dated July 10, 2006, the Finnish Radiation and Nuclear Safety Authority (STUK)
identified the following causal factors related to construction problems at the Olkiluoto 3 construction site:
identified the following causal factors related to construction problems at the Olkiluoto 3 construction site:
*       Poor communication between design and construction organizations and within
*
Poor communication between design and construction organizations and within


organizations participating in construction;
organizations participating in construction;
*       Overconfidence in personnel with little nuclear industry experience and inadequate
*
Overconfidence in personnel with little nuclear industry experience and inadequate


oversight and training;
oversight and training;
*       Ineffective problem identification, reporting, and inadequate corrective actions;
*
*       Unrealistic and aggressive schedules to complete designs sufficiently ahead of
Ineffective problem identification, reporting, and inadequate corrective actions;
*
Unrealistic and aggressive schedules to complete designs sufficiently ahead of


construction;
construction;
*       Inadequate assignment of responsibilities and authority to control assigned work,
*
*       Inadequate communication of nuclear power plant specific requirements on quality and
Inadequate assignment of responsibilities and authority to control assigned work,
*
Inadequate communication of nuclear power plant specific requirements on quality and


quality control from the plant vendor to subcontractors in the tendering stage and in
quality control from the plant vendor to subcontractors in the tendering stage and in


purchase agreements;
purchase agreements;
*       Inadequate understanding by vendors and contractors of the special work practices
*
Inadequate understanding by vendors and contractors of the special work practices


required for performing work in the nuclear field,
required for performing work in the nuclear field,


IN 2007- 04 *       Inadequate training of the subcontractors at the site and the staff of the manufacturers
IN 2007- 04 *
Inadequate training of the subcontractors at the site and the staff of the manufacturers


about the importance to safety of the work and about the special requirements of
about the importance to safety of the work and about the special requirements of
Line 198: Line 219:
constructing for nuclear power plants; and
constructing for nuclear power plants; and


*       Over reliance on subcontractors by the owner.
*
Over reliance on subcontractors by the owner.


STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en GB/news 419/.
STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en GB/news 419/.
Line 204: Line 226:
In both Finland and the United States, interest in new reactor and fuel cycle facility construction
In both Finland and the United States, interest in new reactor and fuel cycle facility construction


is resuming after many years. However, the problems currently being identified in Finland are
is resuming after many years. However, the problems currently being identified in Finland are


very similar to those that occurred in the United States more than 20 years ago. Regardless of
very similar to those that occurred in the United States more than 20 years ago. Regardless of


the licensing process and the type of construction, a commitment to quality, instilled early in a
the licensing process and the type of construction, a commitment to quality, instilled early in a
Line 215: Line 237:


==CONTACT==
==CONTACT==
This IN requires no specific action or written response. Please direct any questions about this
This IN requires no specific action or written response. Please direct any questions about this


matter to the Office of New Reactors contact listed below.
matter to the Office of New Reactors contact listed below.


/RA/
/RA/
                                              Glenn M. Tracy, Director


===Glenn M. Tracy, Director===
Division of Construction Inspection
Division of Construction Inspection


and Operational Programs
and Operational Programs


Office of New Reactors
===Office of New Reactors===
Contacts:


Contacts:      Mary Ann Ashley, Office of New Reactors
===Mary Ann Ashley, Office of New Reactors===


301-415-1073 email: MAB@nrc.gov
301-415-1073 email: MAB@nrc.gov


Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.


IN 2007- 04 *       Inadequate training of the subcontractors at the site and the staff of the manufacturers
IN 2007- 04 *
Inadequate training of the subcontractors at the site and the staff of the manufacturers


about the importance to safety of the work and about the special requirements of
about the importance to safety of the work and about the special requirements of
Line 240: Line 264:
constructing for nuclear power plants; and
constructing for nuclear power plants; and


*       Over reliance on subcontractors by the owner.
*
Over reliance on subcontractors by the owner.


STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en_GB/news_419/.
STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en_GB/news_419/.
Line 246: Line 271:
In both Finland and the United States, interest in new reactor and fuel cycle facility construction
In both Finland and the United States, interest in new reactor and fuel cycle facility construction


is resuming after many years. However, the problems currently being identified in Finland are
is resuming after many years. However, the problems currently being identified in Finland are


very similar to those that occurred in the United States more than 20 years ago. Regardless of
very similar to those that occurred in the United States more than 20 years ago. Regardless of


the licensing process and the type of construction, a commitment to quality, instilled early in a
the licensing process and the type of construction, a commitment to quality, instilled early in a
Line 257: Line 282:


==CONTACT==
==CONTACT==
This IN requires no specific action or written response. Please direct any questions about this
This IN requires no specific action or written response. Please direct any questions about this


matter to the Office of New Reactors contact listed below.
matter to the Office of New Reactors contact listed below.


/RA/
/RA/
                                              Glenn M. Tracy, Director


===Glenn M. Tracy, Director===
Division of Construction Inspection
Division of Construction Inspection


and Operational Programs
and Operational Programs


Office of New Reactors
===Office of New Reactors===
Contacts:


Contacts:      Mary Ann Ashley, Office of New Reactors
===Mary Ann Ashley, Office of New Reactors===


301-415-1073 email: MAB@nrc.gov
301-415-1073 email: MAB@nrc.gov


Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.


Accession Number: ML063040426
Accession Number: ML063040426
*via-email
*via-email


OFFICE
OFFICE


DCIP/NRO     Tech Editor     DPR/NRR         Reg II/DRAC       DNRL/NRO
DCIP/NRO
 
Tech Editor
 
DPR/NRR
 
Reg II/DRAC
 
DNRL/NRO
 
NAME
 
MAshley
 
* CBladey
 
CJackson
 
*LPlisco
 
DMatthews
 
DATE
 
01/09/07   
10/24/06
02/        /07
01/11/07
01/17/07 OFFICE
 
OGC
 
DCIP/NRO
 
FCSS/NMSS
 
OIP/ICA


NAME       MAshley
NAME


* CBladey      CJackson            *LPlisco      DMatthews
TCampbell


DATE        01/09/07    10/24/06        02/    /07          01/11/07      01/17/07 OFFICE
GTracy


OGC          DCIP/NRO          FCSS/NMSS                  OIP/ICA
R Pierson


NAME        TCampbell            GTracy            R Pierson          JRamsey for CAbrams
===JRamsey for CAbrams===
DATE


DATE        01/11/07             02/5/2007         02/5/2007                   02/05/07 OFFICIAL RECORD COPY}}
01/11/07
02/5/2007
02/5/2007
02/05/07 OFFICIAL RECORD COPY}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Latest revision as of 05:20, 15 January 2025

Construction Experience Related to the Assurance of Quality in the Construction of Nuclear Power Plants
ML063040426
Person / Time
Issue date: 02/05/2007
From: Tracy G
Division of Construction Inspection and Operational Programs
To:
References
IN-07-004
Download: ML063040426 (5)
v • d • e


UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001

February 5, 2007

NRC INFORMATION NOTICE 2007-04:

CONSTRUCTION EXPERIENCE RELATED TO

THE ASSURANCE OF QUALITY IN THE

CONSTRUCTION OF NUCLEAR FACILITIES

ADDRESSEES

All current and potential applicants for an early site permit (ESP), combined operating license

(COL), or standard design certification (DC) for a nuclear power plant under the provisions of

Title 10 Code of Federal Regulations (10 CFR) Part 52, all current holders of and potential

applicants for construction permits under 10 CFR Part 50, and all licensees and potential

applicants for new fuel cycle facilities under 10 CFR Part 70.

PURPOSE

The U.S. Nuclear Regulatory Commission (NRC) is issuing this Information Notice (IN) to alert

addressees to the importance of considering lessons learned from construction experience

when planning for and constructing new nuclear power plants or fuel cycle facilities. Recipients

are expected to review the information for applicability to their planned activities and to consider

actions, as appropriate, to avoid similar problems. However, the suggestions contained in this

IN are not NRC requirements; therefore, no specific action or written response is required.

DESCRIPTION OF CIRCUMSTANCES

Interest in constructing new nuclear power plants is increasing in the United States. Fifteen

utilities have officially notified the NRC of their intent to submit applications to construct more

than 24 new nuclear power plants. One major fuel cycle facility is currently under construction

in the United States with more expected. These events follow a hiatus of more than 20 years in

the construction of new reactors in the United States. Lessons learned during the last period of

plant construction in the United States and during recent international construction offer the

industry the opportunity to understand the causal factors that have led to construction problems.

Developing an appreciation for these factors will decrease the likelihood of repeating past

mistakes and will promote quality in nuclear power plant design and construction. While the

experiences referred to in this IN come from the construction of a new nuclear power plant, the

NRC believes it is also appropriate for consideration in the construction of new fuel cycle

fabrication facilities.

BACKGROUND

In the late 1970s and early 1980s, several nuclear power plant construction projects

experienced major problems related to design and construction quality. The Congress directed

the NRC to conduct a study to improve quality in the construction of future nuclear power

IN 2007- 04 plants. The NRC published the results of the 1984 study as NUREG-1055, Improving Quality

and the Assurance of Quality in the Design and Construction of Nuclear Power Plants

(ADAMS Accession No. ML063000293).

NUREG-1055 focused on what had happened in the past to derive lessons to apply in the

future. The report stated:

The increased industry and NRC experience and the lessons learned, if applied

properly, should decrease the probability of major quality problems in future

generations of nuclear plants. However, there are several conditions under

which major quality problems might recur. These include the following:

A first-time utility with staffs or an architect/engineer, construction

manager, or constructors (vendors and fabricators) that have inadequate

nuclear design or construction experience;

A very large growth in the number of nuclear power plants being

constructed that can overwhelm the industrys and NRCs capabilities;

A long delay before nuclear plant construction activities start again, resulting in a dearth of experience in the industry;

Regulatory actions at federal and state levels that undercut quality.

The NRC and the nuclear industry need to be aware of the implications for

quality that these possibilities hold.

Several of the conditions identified in NUREG-1055 under which major quality problems might

recur currently exist in the U.S. This fact emphasizes the importance of understanding the

causal factors associated with historical construction problems in order to chart a future course

for assuring quality in new nuclear power plant construction.

DISCUSSION

The nuclear industry is responsible for designing, constructing, and operating reactors and fuel

cycle facilities in a manner consistent with NRC regulations and other applicable federal laws.

Each licensee is responsible for achieving and assuring the quality of a nuclear power plant, beginning with its design and construction. NUREG-1055 identified several causes of

significant quality-related problems that have occurred during the construction of nuclear power

plants:

An inability of utility management to adequately control all aspects of the construction

project, including planning, scheduling, procurement, and oversight of contractors;

Inexperience with nuclear plant construction, resulting in utilities and their contractors

not fully appreciating the complexity and difficulty associated with building a nuclear

power plant and therefore the importance of nuclear-related standards;

IN 2007- 04 *

A false sense of security growing out of prior successes;

A failure to establish an atmosphere that encourages problem reporting and resolution

at all levels of the organization;

A failure to delegate authority commensurate with responsibility; and

A failure to have clear communication pathways across all project interfaces.

NUREG-1055 noted that quality craftsmanship is an absolute necessity for achieving quality in

nuclear construction. Further, it also noted that the failure of management to control certain

conditions, such as the amount of rework because of excessive design changes, the failure to

complete designs sufficiently ahead of construction, uninformed supervision, and a project

environment that emphasizes production to the detriment of quality, can defeat quality

craftsmanship.

Improvements in the performance of operating reactors over the last decade may suggest that

these historical issues will no longer pose a problem. However, recent construction

experiences in Finland indicate that the causal factors identified in 1984 continue to exist in the

current international construction arena. In Investigation Report 1/06, Management of Safety

Requirements in Subcontracting During the Olkiluoto 3 Nuclear Power Plant Construction

Phase, dated July 10, 2006, the Finnish Radiation and Nuclear Safety Authority (STUK)

identified the following causal factors related to construction problems at the Olkiluoto 3 construction site:

Poor communication between design and construction organizations and within

organizations participating in construction;

Overconfidence in personnel with little nuclear industry experience and inadequate

oversight and training;

Ineffective problem identification, reporting, and inadequate corrective actions;

Unrealistic and aggressive schedules to complete designs sufficiently ahead of

construction;

Inadequate assignment of responsibilities and authority to control assigned work,

Inadequate communication of nuclear power plant specific requirements on quality and

quality control from the plant vendor to subcontractors in the tendering stage and in

purchase agreements;

Inadequate understanding by vendors and contractors of the special work practices

required for performing work in the nuclear field,

IN 2007- 04 *

Inadequate training of the subcontractors at the site and the staff of the manufacturers

about the importance to safety of the work and about the special requirements of

constructing for nuclear power plants; and

Over reliance on subcontractors by the owner.

STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en GB/news 419/.

In both Finland and the United States, interest in new reactor and fuel cycle facility construction

is resuming after many years. However, the problems currently being identified in Finland are

very similar to those that occurred in the United States more than 20 years ago. Regardless of

the licensing process and the type of construction, a commitment to quality, instilled early in a

nuclear construction project, is important to ensure that the facility is constructed and will

operate in conformance with its license and the NRCs regulations.

CONTACT

This IN requires no specific action or written response. Please direct any questions about this

matter to the Office of New Reactors contact listed below.

/RA/

Glenn M. Tracy, Director

Division of Construction Inspection

and Operational Programs

Office of New Reactors

Contacts:

Mary Ann Ashley, Office of New Reactors

301-415-1073 email: MAB@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

IN 2007- 04 *

Inadequate training of the subcontractors at the site and the staff of the manufacturers

about the importance to safety of the work and about the special requirements of

constructing for nuclear power plants; and

Over reliance on subcontractors by the owner.

STUK has posted the complete report at http://www.stuk.fi/stuk/tiedotteet/en_GB/news_419/.

In both Finland and the United States, interest in new reactor and fuel cycle facility construction

is resuming after many years. However, the problems currently being identified in Finland are

very similar to those that occurred in the United States more than 20 years ago. Regardless of

the licensing process and the type of construction, a commitment to quality, instilled early in a

nuclear construction project, is important to ensure that the facility is constructed and will

operate in conformance with its license and the NRCs regulations.

CONTACT

This IN requires no specific action or written response. Please direct any questions about this

matter to the Office of New Reactors contact listed below.

/RA/

Glenn M. Tracy, Director

Division of Construction Inspection

and Operational Programs

Office of New Reactors

Contacts:

Mary Ann Ashley, Office of New Reactors

301-415-1073 email: MAB@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.

Accession Number: ML063040426

  • via-email

OFFICE

DCIP/NRO

Tech Editor

DPR/NRR

Reg II/DRAC

DNRL/NRO

NAME

MAshley

  • CBladey

CJackson

  • LPlisco

DMatthews

DATE

01/09/07

10/24/06

02/ /07

01/11/07

01/17/07 OFFICE

OGC

DCIP/NRO

FCSS/NMSS

OIP/ICA

NAME

TCampbell

GTracy

R Pierson

JRamsey for CAbrams

DATE

01/11/07

02/5/2007

02/5/2007

02/05/07 OFFICIAL RECORD COPY


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