IR 05000245/1998210

Evaluation Repts 50-245/98-210,50-336/98-210 & 50-423/98-210 on 971208-12 & 980105-09.No Violations Noted.Major Areas Inspected:Status & Effectivness of Independent third-party, Oversight Program,Established to Oversee ECP Implementation

ML20247J725
Person / Time
Site:	Millstone
Issue date:	04/21/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20247J712	List: IR 05000245/1998210 ML20247J708
References
50-245-98-210, 50-336-98-210, 50-423-98-210, NUDOCS 9805210396
Download: ML20247J725 (12)

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U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation I

Docket Nos: 50-245,50-336, and 50-423 Report No: 98-210 l l

License Nos. DPR-21, DPR-65, and NPF-49 Licensee: Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385  ;

Facilit Millstone Nuclear Power Station, Units 1,2, and 3 i i

Dates: December 8-12,1997, and January 5-9,1998 Team Leader: Helen N. Pastis, Senior Project Manager  ;

Evaluators: Robert DeFayette, NRC Consultant ,

Steve Dembek, Millstone Unit 1 Project Manager Carl Mohrwinkel, Assistant Agency Allegation Advisor i Roy Mullikin, Region IV Allegations Coordinator I

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Richard Pelton, Training and Assessment Specialist l Richard Urbar., Region i Millstone Project Engineer

Approved by: William D. Travers, Director, Special Projects Office Phillip F. McKee, Deputy Director for Licensing, Special Projects Office :

Helen N. Pastis, ECP and ITPOP Oversight Senior Project Manager

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9905210396 990421 PDR ADOCK 05000245 G PDR

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TABLE OF CONTENTS 1.0 Purpose of the Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 Review Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 3.0 Ba ckg rou nd . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 4.0 Evalu ation Sco pe . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 5.0 Observation and Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 6.0 C on clu sions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i

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Evaluation Report Puroose of the Evaluation Assess the status and the effectiveness of the independent, third-party, oversight program (ITPOP), which was established by the U.S. Nuclear Regulatory Commission (NRC) Order, to oversee the implementation of the Employee Concems Program (ECP) and the safety-conscious work environment (SCWE) at Millstone Nuclear Power Statio .0 Review Methodoloav

An NRC team was formed to evaluate the effectiveness of Millstone's ECP and elements of the SCWE. During its evaluation, the team additionally assessed the ITPOP organization, Little Harbor Consultants, Inc. (LHC), which oversees Northeast Nuclear Energy Company (NNECO's) implementation of the ECP and the SCWE at Millston LHC's evaluation conducted, in conjunction with the NRC's evaluation of NNECO's ECP and l programs addressing an SCWE at Millstone. As part of the staff's evaluations, findings related to NNECO's programs were compared to findings made by LHC. The team also assessed input from NRC's ongoing onsite monitoring of licensee and LHC activitie The team conducted its evaluation in two parts. During the week of December 8-12,1997, the evaluators met with LHC team members and requested information. At the end of that week, the team retumed to NRC Headquarters to evaluate the information gathered at the sit During the week of January 5-9,1998, the team retumed to the site to follow up on certain issues and questions that arose during the evaluatio .0 Backaround On October 24,1996, the Director of the Office of Nuclear Reactor Regulation sent an Order to

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NNECO, requiring establishment of (1) a comprehensive plan for handling the Millstone employees' safety concems, (2) an independent third-party oversight organization, and (3) a '

plan by the independent, third-party, organization for overseeing NNECO's implementation of the comprehensive pla The NRC staff has performed the following activities to ensure that NNECO's programs for handling safety concems and independent, third-party oversight will be effectively implemented:

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Reviewed the Millstone employee safety concems comprehensive plan for reviewing

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and dispositioning safety issues raised by employees of NNEC *

Approved the selection of the ITPOP organization to ensure that the organization has qualified individuals who will conduct the review adequately and independently of l NNECO. The ITPOP organization will oversee the implementation of the NNECO employee's program for handling safety concem .

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Anproved the iTPOP plan, which audits the implementation of the Millstone programs for handling employee safety concerns. The ITPOP review must be comprehensive, incorporating appropriate audit and technical disciplines so that the NRC can be confident that NNECO has been thorough in identifying and resolving employee safety concems at Millston in response to the NRC order of October 24,1996, NNECO established LHC as the ITPOP organization to monitor and evaluate NNECO's efforts to improve the safety culture at Millstone.

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l LHC's plan for oversight specifies that the ITPOP will monitor and oversee NNECO's efforts to l correct, and prevent repetition of, its past failures in its treatment of employee concems and of l those employees who raised such concems. LHC will observe and monitor NNECO's activities, perform technical and audit reviews, investigate concems, and assess changes in NNECO's treatment of employee concems as compared with past practices. LHC oversight will continue until the NRC determines that NNECO has demonstrated by its performance that the conditions that led to the requirement for the oversight have been corrected and that safety issues raised by employees are being evaluated and resolved in a timely manne .0 Evaluation Scone l Section IV.2 of the NRC order of October 24,1996, to Millstone stated that the licensee was to submit for NRC's approval the name of an independent, tnird-party organization to oversee implementation of the licensee's programs for handling employee safety concems. The order further stated that the activities of the third-party were to be subject to continuing NRC oversight, and that the third-party was to oversee licensee implementation of the third-party's comprehensive plan by, among other things -

(1) observing and monitoring the licensee's activities, (2) performing technical reviews, (3) auditing and investigating, when necessary, cases of alleged harassment, intimidation, and discrimination, (4) auditing and reviewing the licensee's handling of employee safety concems, (5) assessing and monitoring the licensee's performance This task was to be accomplished by submitting, for NRC's approval, an Oversight Plan, and by submitting reports on oversight activities, findings, and recommendations to both the licensee

and the NRC at least quarterly following NRC's approvsl of the Oversight Pla On April 7,1997, the NRC approved LHC as the third-party, and on July 14,1997, approved the Oversight Plan. The NRC's review of the plan noted that the evaluations would focus on 1 NNECO's efforts to -

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(1) correct and prevent repetition of past failures in its treatment af employee safety concems, (2) create an environment in which employees and contractors are encouraged and feel free to raise concems, (3) review and resolve safety concems in a timely manner, (4) conduct self-assessments and changes to the ECP to maintain the effectiveness of the program, (5) maintain a SCWE in the future To oversee LHC, the team reviewed LHC documents and files, and discussed issues with LHC personnel to determine whether the specific elements discussed in those documents had been accomplished. In addition to the oversight activities carried out as part of this current team evaluation, the team has monitored LHC activities periodically over a period of a few month Some of the documents that were reviewed are -

(1) NRC October 24,1996, Order, (2) approved LHC July 14,1997, Oversight Plan, j (3) LHC files, (4) NNECO's responses to LHC's recommendations; LHC's tracking of those -

l responses, including their timeliness and quality; and any commitments made by l NNECO to the recommendations l

l The team also observed LHC's interactions with NNECO during routine meetings and at some l special meetings.

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! The NRC assessed LHC's implementation of the elements of the Oversight Plan. In October 1997, the staff who monitored LHC's activities assessed LHC's implementation of its plan. At

that time, a number of the elements had not yet been accomplished. Since October 1997, most I

of the elements of the Oversight Plan have been accomplished or are ongoing. LHC identified l some elements of the Oversight Plan as not required, and as allowed by Section 8.0 of the plan, steps have been initiated to update the plan. Revision 2 of the Oversight Plan was <

submitted to the NRC on March 20,199 ;

initial staff review of changes to LHC's plan indicate they represent appropriate adjustments based on experience gained in plan implementatio Selected elements of the Oversight Plan and the status and staff findings with respect to that element follo !

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Assessment of the Millstone Safety Culture 1 l Plan Element (Sections 3M and 3.30 Perform an assessment to determine the prevailing i attitudes of the site population regarding all aspects of the handling of employee safety l concems. When conducting structured interviews, determine if cultural factors are directly I

affecting willingness to express concems, and whether more general cultural factors, including perceptions of management and Millstone's future, might have an indirect effect on l an individual's willingness to report a conce Status LHC conducted structured interviews as a principalinstrument for establishing a baseline and to measure subsequent changes in the safety culture. LHC performed its first set of structured interviews in June and July 1997. The second set of interviews was-conducted in February 1998. A large population of the workforce was interviewed (239 in the first set and 298 in the second); the selection process was designed to ensure a cross section of workers from every work group and department. The interview questions involved a broad spectrum of environmental issues, including the willingness of the workforce to raise concems, the confidence of the work force that safety concems will be handled properly, the existence of a questioning attitude at the site, and the general work environment at the sit These interviews were determined to be thorough, well structured, and carefully l administered, and to provide sound bases for measuring the attitudes of the workforc Plan Element (Section 3.2): Compare attributes of Millstone Station's safety culture environment against ideal attribute Status The Oversight Plan, Section 3.2, identifies a set of 12 characteristics that, when

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present in an organization, generally indicate the existence of a strong safety culture. At a meeting on November 13,1997, between NRC, LHC, and NNECO representatives, LHC presented a windows methodology it had developed for evaluating the Millstone Station's SCWE. This methodology rated each of the 12 characteristics with respect to their being l acceptable to support restart of a unit. The methodology also compared the 12 LHC l measures with the 4 SCWE success criteria developed by NNECO. Since November 1997, LHC has periodically rated the licensee with respect to the 12 characteristics and NNECO's

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4 success criteria. In conjunction with the review and approval of the Oversight Plan, the l NRC staff reviewed and found acceptable LHC's presentation of characteristics that were indicative of a strong safety culture. LHC stated that information from the structured interviews, assessment and investigation of site events, and findings from the programmatic evaluations all factored into the periodic ratings. On the basis of (1) Information presented by LHC in its assessments of Millstone's 12 safety-culture characteristics, and NNECO's 4 success criteria and (2) review of LHC files, NRC staff considers that LHC's approach is sound and assessment findings are well supporte i l

Plan Element (Section 3.5L Observe and monitor daily activities at Millstone Station. Some j of the activities are (1) daily planning meetings at which problems are pointed out to management; (2) meetings at which problems are categorized and prioritized; (3) meetings

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at which corrective actions to identified problems are discussed; (4) maintenance activities; (5) safety meetings; (6) shift tumover meetings; (7) contiol room observations; (8) ECP

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activities; (9) training classes for supervisors on handling employee concems; (10) meetings at whicil the root causes of identified problems are discussed; and (11) inspections and audit Status The reviewer determined that LHC routinely observed and monitored activities for items 1,2, 3, 8, 9,10, and 11. The reviewer determined that LHC had not routinely conducted the monitoring activities for items 4, 5, 6, and Programmatic Evaluations Plan Element (Section 4.1.11: Conduct a thorough programmatic evaluation of NNECO's Comprehensive Plan (CP) and subsequent revisions to the plan.

I Status The team verified, through discussions with LHC personnel and by attending meetings with LHC and NNECO personnel, that LHC conducted a thorough review of the CP. LHC presented its initial findings in a meeting with NNECO on May 13,1997, in which it concluded the following: (1) the CP is an adequate approach for upgrading the Millstone ECP; (2) creation of an independent concems oversight panel has the potential to accelerate progress toward achieving the CP goal; (3) the CP did not address the full scope of the NRC Order of October 24,1996, (4) the CP did not sufficiently address the established programs for problem identification and resolution; and (5) the CP did not clearly identify enteria for success or measurement techniques. NNECO subsequently proposed changes to the CP to

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Plan Element (Section 4.1.2. first phase): Perform a programmatic evaluation of NNECO's

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Employee Concems Program to ensure that it has been designed with the appropriate

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attributes to achieve effective performance.

Status' LHC completed this programmatic review and presented its findings at a meeting with NNECO on Ju:ee 3,1997. LHC concluded that (1) the documented program contained the basics for an improved ECP; (2) the ECP Manual did not address the full breadth of processing employee concems; (3) the program did not provide for expected maqagement overview; and (4) the ECP Manual lacked the following elements: (a)it did not contain a requirement for conducting an annual extemal assessment as committed to in the plan; (b) it requirci all NNECO employees to participate in an exit interview but the site exit process did

, not ensure that these employees would be directed to the ECP; (c) the manual did not l address coverage for contractors at offsite locations; (d) handling of NRC-referred l allegations was not covered; and (e) it did not address personnel qualifications and training.

l NNECO subsequently revised its program to address LHC findings and recommendations.

l l Plan Element (Section 4.1.2. second phase): Evaluate the full range of implementa3on of l

ECP activities. Some of the activities to be evaluated are: (1) auditing and reviewing the handling of specific concems, (2) evaluating the timeliness and thoroughness of investigations, (3) determining how employees were kept informed of the results of reviews, (4) reviewing qualifications and training of investigators, and (5) measuring the effectiveness of the overallimplementation of the EC .. \

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Status: The team verified, by direct observation, reviewing files, and discussion with LHC personnel, that these activities have been and are being accomplished. LHC reported the results of its initial review of implementation of the NNECO ECP in a presentation on July 22, 1997, to the NRC and NNECO. This evaluation identified a number of implementation 4 l deficiencies, including a lack of discipline, non-compliance with the ECP and the ECP l l Manual, loss of confidence by some employees in the ECP, and concems not being consistently and properly resolved or closed. On November 13,1997, LHC presented to NRC and NNECO the findings of its continuing review of ECP activities. Among the LHC activities reported were reviews of ECP case files, interviews with ECP staff and employees who raised concems, and observations of ECP activities, such as case intakes, staff meetings, ECP closure panels, and focus group meetings. Although LhC noted J improvements in the organization and leadership of the ECP, the training of the ECP staff, and program definition, the review raised some remaining issues and made additional

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recommendations. At a public meeting on January 27,1998, of NRC, NNECO, an LHC representatives, LHC reported on its completion of (1) reviews of ECP harassment, intimidation, retaliation, and discrimination (HIRD) case files and (2) observations of ECP

activities. At this meeting, LHC reported that the ECP has responded and corrected

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deficiencies and demonstrated an ability to effectively resolve employee fears about retaliation. As a result ofits activities, LHC reported, at a Commission briefing on December 12,1997, that the ECP was being implemented effectively. The NRC staff finds that the LHC approach and its conduct of the review of NNECO's implementation of the ECP has been thorough and complete. Findings during the NRC evaluation of ECP

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implementation, including review of case files, were consistent with those of LHC and confirm the ECP improvements made by NNECO in responding to LHC recommendation Plan Element (Section 4.1.3): Conduct a programmatic evaluation of the Corrective Action Program (CAP) and its implementation. Also evaluate the licensee's root cause evaluation progra Status The team verified, by reviewing files, by discussing the issues with an LHC reviewer, and by attending L.C1NRC/NNECO meetings, that this plan element has been completed. L.C. represented its findings on the CAP at a public meeting with NNECO and

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the NRC on September 24,1997. L.C. conducted the evaluation in three phases. The first l phase was a review of condition report (CR) classifications. L.C. reviewed 100 CARS and

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found only 3 that were questionable- and 2 of those 3 were essentially treated as Level 1 reports. L.C. found this result acceptable. In phase ll, L.C. evaluated the implementation of l the CAP from initiation of a CR to the approval of the corrective actions. The results were (1) site personnel were aware of the CAP and are generally initiating CARS when l appropriate; (2) investigations to determine the nature of the condition and the surrounding l facts were adequate; (3) most root cause evaluations were adequate; (4) the waiver of root l cause evaluations for Level 1 CARS was not always justified; and (5) root cause evaluations varied in quality, level of detail, and report format. Observed weaknesses were (1) cause evaluations were stopped at too high a level of cause; (2) root causes were too generally worded to lead to focused corrective actions; (3) licensees were reluctant to address )

individual performance issues; (4) the requirement to address each cause code for Level 2 !

CARS could lead to too many actions; (5) the tendency to address all contributory causes for ;

Level 1 CARS sometimes weakened the focusing on the root cause; and (6) the requirement !

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to complete the corrective action in 30 days could be too restrictive for broad programmatic problems. The NRC reviewer found that this evaluation was thorough and complete and the recommendations well supported.

l Plan Element (Section 4M.2k Perform some independent investigations of concems and cases of alleged harassment, intimidation, retaliation, and discriminatio Status The reviewer found that L.C. had satisfied this element of the plan. L.C. conducted several comprehensive, independent investigations and evaluations of alleged HARD. One independent investigation involved allegations of retaliation and chilling effect associated with disciplinary action taken by NNECO in July 1997 against personnel who had worked in I

the Training Department. Another independent investigation performed by L.C. involved

potential harassment and intimidation associated with disciplinary actions taken by NNECO

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against contract employees in the motor operator valve (MOV) Department. L.C. issued l formal reports for both of these investigations. L.C. findings associated with these events

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were also discussed at open meetings attended by NRC, L.C., and NNECO. On the basis

of a review of the reports, monitoring of L.C.'s conduct of the investigation, and L.C.'s l presentation of its findings, the NRC staff considers that the investigations were well !

conducted and documented. L.C. also monitored and conducted independent assessments of other lower profile events at the site, including a deteriorating situation in the Oversight j Quality Control Group. The findings from L.C.'s investigations of the cases helped NNECO understand weaknesses in its processes associated with the events and contributed to the

, licensee's development or confirmation of corrective actions. L.C. monitored the licensee's l actions to address the events and verified the licensee's final resolutions of actions where j appropriat Plan Element (Section 4.1.3): Observe and monitor other programs and processes

, associated with SIWE, including the licensee's self-assessment programs and performance

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effectiveness capability.

l Status As previously discussed, L.C. has reviewed in detail and rr.onitored, for example, the E.C.; the CAP; and CP. When the evaluation team reviewed L.C.'s activities in December 1997, and January 1998, it found that L.C. had not yet evaluated the Employee Concems Oversight Program or a number of the activities of the SIWE program.

i Subsequent to the team evaluation, L.C. scheduled oversight activities for those elements not previously covere Communications, Reporting, and Administration Plan Element (Section 5.5): Develop methods to monitor NNECO's progress in responding l to L.C.'s recommendations.

l Status The Oversight Plan provides guidance for L.C.'s presentation of observations, conclusions, and recommendations to NNECO on its efforts to improve the site's SIW !

Although recommendations were routinely and formally given to NNECO by L.C. in periodic I meetings and reports, NNECO's responses to the recommendations had not, until after the beginning of the year, been formally tracked by L.C.. The team considered tracking and i

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assessment of licensee responses to L.C. findings a very important activity in ascertaining the status and effectiveness of licensee programs and in providing feedback to NNEC For example, NNECO responded to the recommendations of May 21,1997, on July 6 and July 22,1997, but L.C. did not evaluate the responses until mid-December 199 Subsequent to the team's evaluation (at a public meeting on January 27,1998, with the NRC, L.C., and the licensee), L.C. provided documentation that presented the status of l NNECO's responses to L.C.'s recommendations. The team verified that L.C. had acted to correct this weaknes )

Plan Element (Section 5.4): Send a quarterly report to the licensee and NRC that contains I detailed descriptions of both routine activities and specialinvestigations undertaken by L. In addition to the quarterly report, hold pre-announced meetings with the licensee on a frequency determined by the availability and significance of the results of L.C. activitie Status The team reviewed L.C.'s first omrterly report submitted on November 25,199 The report referred only to slides and e entation presented by L.C. consultants at the periodic meetings between L.C., NNE~ . d the NRC. Although this information had been docketed and contained some detailed inivrmation, the NRC staff did not consider that the first report met the intent of Oversight Plan commitment for a detailed report. For example, I documents presented at the periodic meetings did not describe routine activities conducted by L.C., the status of ongoing major activities, details on bases for findings, and the status of l the licensee's responses to L.C.'s recommendations. Subsequent to the team's evaluation, L.C. submitted a report for the last quarter of 1997. This report contained a description of L.C. activities for the period October 1 - December 31,1997, a summary of the results of presentations to the NRC and NNECO, a description of public interactions by L.C. other than formal presentations, the status of L.C. recommendations to NNECO, and activities anticipated for the next quarter. The staff considers this report much more comprehensive, and satisfies the intent of the Oversight Plan regarding appropriate report detail.

l Plan Element (Section 5.4): Materials presented at meetings with the licensee and NRC will be dockete Status The team found that this element had been satisfied. Following meetings, routinely submits documentation by letter to the NRC and NNECO to be used at the meeting (for example, L.C.'s letters to the NRC dated May 25,1997; June 5,1997; and September 25,1997).

Plan Element (Section 7.01: Maintain security of documents, and protect the identity of sources of information by (1) keeping documents containing confidential information in a secure locked cabinet and not leaving documents unattended; (2) discussing confidential

, information only with people having a need to know; (3) protecting confidential information when using electronic media; (4) marking all pages of documents containing confidential information " CONFIDENTIAL."

Shtus: The team found that L.C. satisfied this plan element. For example, before a team member was able to review the files, the team member had to ask L.C. to open the locked cabinet _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ .

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Plan Element (Section 8.01: Conduct self-assessments of the Oversight Plan about once each quarte {

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. l Status: Revision 1 of the Oversight Plan specifies a rigorous and systematic self-assessment. L.C. had not performed this assessment but had presented the NRC team with l a more simplified assessment of its completion of elements of the Oversight Plan. l l stated that after experience in operation, it now felt that the extensive self-assessment l process described in Revision 1 of its plan was not necessary and that it planned to revise the Oversight Plan to present a more appropriate process. Revision 2 to the Oversight Plan was given to the NRC on March 20,1998, and the revised plan contained an amended process for se"-assessment. The staff reviewed and agreed with L.C.'s proposal for changes to their approach to self-assessments.

j 6. O Conclusions Overall, the team found L.C. effective in implementing its Oversight Plan for monitoring and overseeing NNECO's efforts to prevent the repetition of past failures in management processes

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and procedures for handling safety issues raised by employees, and in enst, ring that employees who raise safety concems face no discriminatory action. The team found L.C.

l particularly effective in its efforts in overseeing the licensee's activities to improve its EC.. identified weaknesses in the Millstone EC., brought those weaknesses to the attention of Millstone management, and was effective in ensuring that the weaknesses were being corrected. On the basis of comparison with NRC's evaluation of NNECO's EC., L.C.'s l

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observations and findings conceming the EC. and implementation of the EC. appears accurate and thorough in the identification of deficiencies and weaknesses. L.C.'s review of HARD l

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cases and processes was thorough and effective in its assessment and in identifying case-specific and program weaknesses. Further, L.C.'s recommendations in this area appear to have had a very constructive impact on the licensee's program improvement During the evaluation team's review of L.C.'s activities in December 1997 and January 1998, some weaknesses were found with respect to the extent and timeliness of documentation of

L.C.'s activities and tracking of NNECO's responses to L.C.'s recommendations. Also, the team found that some topics in the Oversight Plan had not been covered or were only minimally

! covered. Since January 1998, L.C. has addressed these concem L.C.'s structured interviews of the licensee's employees which were performed in the summer of 1997, and again in February 1998, were well planned and well documented. The survey findings contained detailed and relevant findings and recommendations. The structured interviews, along with input from site events and program reviews, have provided well-founded framework and basis for L.C.'s assessment of the Millstone safety culture.

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-2-If you have any questions concerning the enclosed evaluation report, please contact Helen N. Pastis at 301415-1261.

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Sincerely,

[priginal Signed by:

Phillip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation Docket Nos. 50-245, 50-336, and 50-423 Enclosure: Evaluation Report 98-?10 DISTRIBUTION:

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Docket File SPO-L Reading SPO Reading PMcKee HPastis DOCUMENT NAME: G:\PASTIS\LHCEVAL.RP2 *See previous concurrence To esceive e copy of this document, indicate in the box: 'C" = Copy without attachment /enclovere 'E' = Copy with attachme. lencloure *N' = No copy OFF!CE SPO-L:PM l SP,0-L: )D SPO-L:D l TECH ED* l NAME HPastis PP/@v WTravers RSanders hDATE 04/ /98 04M98 04/ /98 04/16/98 04/ /98 OFFICIAL RECORD COPY