IR 05000298/1993099
| ML20056G745 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/27/1993 |
| From: | Milhoan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9309070112 | |
| Download: ML20056G745 (4) | |
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50-298 License: DPR-46 Nebraska Public Power District
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ATTN: Guy R. Horn, Vice President, Nuclear P.O. Box 98 Brownville, Nebraska 68321 SUBJECT:
FINAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT This forwards the final SALP report (50-298/93-99) for the Cooper Nuclear Station for the period of January 19, 1992, through April 24, 1993. This final SALP Report includes:
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The cover letter for the initial SALP report (no revisions to the initial SALP report were made).
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A summary of our July 12, 1993, meeting at the Cooper Nuclear Station security building auditorium in Brownville, Nebraska.
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Your August 11, i W3, response to the initial SALP report.
We have reviewed your letter dated August 11, 1993, in response to the NRC recommendations in each of the SALP functional areas.
It was noted that your response has identified specific actions to improve performance in each of the SALP functional areas. We will review your progress to achieve these improvements in inspection efforts during this SALP period.
The next SALP period for Cooper Nuclear Station is scheduled to last approximately 18 months, from April 25, 1993, to October 22, 1994. As identified in our letter dated August 11, 1993, from Mr. A. B. Beach, Director, Division of Reactor Projects, to Mr. G. R. Horn, Vice President, Nuclear, the revised SALP program will be utilized.
Sincerely, N M ih Regional Administrator Enclosures:
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Cover letter for the initial SALP report 2.
NRC Meeting Summary 3.
Nebraska Public Power District response to the initial SALP report
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(see next page)
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Nebraska Public Power District l
ATTN:
G. D. Watson, General Counsel P.O. Box 499 Columbus, Nebraska 68602-0499 Cooper Nuclear Station
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ATTN: John M. Meacham, Site Manager P.O. Box 98
.Brownville, Nebraska 68321
i Nebraska Department of Environmental Control l
ATTN: Randolph Wood, Director P.O. Box 98922 Lincoln, Nebraska 68509-8922
Nemaha County Board of Commissioners ATIN: Richard Moody, Chairman
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Nemaha County Courthouse j
1824 N Street
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Auburn, Nebraska 68305 Nebraska Department of Health ATIN: Harold Borchert, Director Division of Radiological Health 301 Centennial Mall, South P.O. Box 95007 Lincoln, Nebraska 68509-5007 Kansas Radiation Control Program Director
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AUG 27 2993 ilebraska Public Power District-3-bcc to DMB (IE40)
bcc distrib. by RIV.
J. L. Milhoan Resident Inspector DRP Section Chief (DRP/C)
Lisa Shea, RM/ALF, MS: MNBB 4503 MIS System
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DRSS-FIPS Section Chief (DRP/TSS)
Project Engineer (DRP/C)
RIV File Senior Resident Inspector - River Bend C. A. Hackney, RSLO Senior Resident Inspector - Fort Calhoun J. T. Gilliland, PA0 The Chairman (MS:
16-G-15)
Records Center, INPO
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Commissioner Rogers (MS:
16-G-15)
G. F. Sanborn, E0 C. J. Gordon
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Commissioner Remick (MS:
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RRIs at all sites Commissioner de Planque (MS:
16-G-15)
L. J. Callan, D:DRSS L
J. M. Taylor, EDO (MS:
17-G-21)
D. D. Chamberlain, DRSS J. M. Montgomery B. Murray, DRSS
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Project Engineer (DRP/C)
RIV File Senior Resident Inspector - River Bend C. A. Hackney, RSLO Senior Resident Inspector - Fort Calhoun J. T. Gilliland, PA0 The Chairuan (MS:
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Records Center, INP0 Commissioner Rogers (MS:
16-G-15)
G. F. Sanborn, E0 C. J. Gordon D:DRP Commissioner Remick (MS:
16-G-15)
RRIs at all sites Commissioner de Planque (MS:
16-G-15)
L. J. Callan, D:DRSS J. M. Taylor, EDO (MS:
17-G-21)
D. D. Chamberlain, DRSS J. M. Montgomery B. Murray, DRSS J. Roe, NRR (MS:
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ENCLOSURE 1-vNarnstarts
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Docket:
50-298
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License: DPR-46
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Nebraska Public Power District
ATTN:
Guy R. Horn, Nuclear Power Group Manager
P.O. Box 499 Columbus, Nebraska 68602-0499 SUBJECT:
INITIAL SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) REPORT This forwards the initial SALP report (50-298/93-99) for the Cooper Nuclear Station.
The SALP Board met on May 20 and June 15, 1993, to evaluate the licensee's performance for the period January 19, 1992, through April 24,
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1993.
The performance analyses and resulting evaluations are documented in the enclosed initial SALP report.
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In accordance with NRC policy, I have reviewed the SALP Board's assessment and
concur with their ratings, as discussed below:
Overall, licensee performance declined in several functional areas from the previous SALP evaluation.
A large number of equipment problems occurred during the latter part of this appraisal period that were caused, in part, by
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the failure of licensee employees to aggressively pursue the root cause of i
potentially significant equipment problems and to assume effective ownership
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of systems and components.
The problems were also caused by the willingness l
of licensee personnel to live with problems rather than thoroughly evaluate degraded or potentially degraded equipment issues. The Cooper Nuclear Station staff appears to be satisfied with working around these problems and, as a result, the licensee's problem resolution process and corrective action
systems have been weak. Many of these equipment problems were long-standing,
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and the failure to self-identify and correct the problems are viewed as
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demonstrated fundamental weaknesses in the oversight and self-assessment-l functions.
These concerns were most evident in the areas of i
Maintenance / Surveillance and Safety Assessment / Quality Verification and, as a result, these areas were assigned a rating of Category 3.
In Engineering / Technical Support, significant weaknesses were observed in problem resolution by the site engineering group.
The board was concerned j
with the examples of insufficient rigor applied to the evaluation and j
resolution of identified problems.
The evaluations relied heavily on verbal information and there was lack of formality in the approach to the resolution
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of these problems which contributed to escalated enforcement actions.
The board assigned a rating of Category 2 because of the performance of the corporate engineering group and the improvements in operations training,
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I Performance in the functional area of Operations was mixed and assigned a rating of Category 2.
Routine operations remained strong, but there was a lack of a questioning attitude on the part of the operating staff for some engineering operability determinations.
This lack of a questioning attitude
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may have contributed to some of the plant problems identified during this period.
The relationship between the operations and training staffs has
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improved but requires some additional attention.
In Radiological Controls, performance has improved. The radiological controls j
staff has made major strides in improving the overall program.
The board was concerned, however, with the apparent lack of aggressiveness in identifying radiological performance weaknesses.
Nevertheless, overall performarce was assigned a rating of Category 2 and was assigned an improving trend.
Recurring problems in the areas of offsite notification, emergency assessment, l
and decisionmaking tended to offset the improvements noted in the area of l
The failures to follow up on previously identified i
findings and the additional violations indicated a need for increased management attention.
This area was assigned a rating of Category 2 with a declining trend.
The area of Security continues to be a strength and was assigned a rating of
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Category 1.
On the basis of the SALP Board's assessment, the length of the SALP period will be approximately 15 months. Accordingly, the next SALP period will be from April 25, 1993, to July 30, 1994 A management meeting has been scheduled with you and your staff to review the
results of the initial SALP report.
The meeting will be open to the public and held at the Cooper Nuclear Station security building auditorium on July 9, 1993, at 10 a.m.
Within 20 days of this management meeting, you may provide
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comments on and amplification of, as appropriate, other aspects of the initial SALP report.
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Your written comments, a summary of our meeting, and the results of my consideration of your comments will be issued as an appendix to the enclosed
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initial SALP report and will constitute the final SALP report.
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Sincerely,
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\\w b..k kkso~O fQames L. Milhoan
(fegionalAdministrator
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Enclosure 2 I
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\\ JC _ EA R R EG
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SYS-~ E!V A~~ C ASS ESS V EN
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i NEBRASKA PUBLIC POWER DISTRICT
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COOPER NUCLEAR STATION
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JANUARY 19,1992 THROUGH
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APRIL 24,1993 l
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BROWNVILLE, NEBRASKA
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JULY 12,1993
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AGENDA t
INTRODUCTIONS NRC
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i OPENING REMARKS /
JAMES L. MILHOAN PERFORMANCE OVERVIEW
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FUNCTIONAL AREA DISCUSSION A. BILL BEACH
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COMMENTS AND/OR QUESTIONS NPPD CONCLUDE MEETING l
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i COMMENTS AND/OR QUESTIONS PUBLIC/ MEDIA
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OVERVIEW OF PERFORMANCE I
i DECLINING PERFORMANCE l
l FAILURE TO SELF-IDENTIFY PROBLEMS
WEAK PROBLEM RESOLUTION
A LACK OF A QUESTIONING ATTITUDE o
WORK AROUND PROBLEMS o
WEAK ROOT CAUSE ANALYSIS o
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PLANT OPERATIONS CATEGORY 2 PERFORMANCE MIXED e
WEAKNESSES DESCRIBED IN PREVIOUS SALP RECEIVED MANAGEMENT ATTENTION
MANAGEMENT ATTENTION EVIDENT IN ROLITINE OPERATIONS
HOUSEKEEPING GOOD e
LACK OF QUESTIONING ATTITUDE - OPERABILITY DETERMINATIONS
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RADIOLOGICAL CONTROLS CATEGORY 2 IMPROVING PERFORMANCE STRONG MANAGEMENT SUPPORT FOR ALARA
PROGRAM EFFECTIVE EXTERNAL AND INTERNAL EXPOSURE
CONTROLS NOT AGGRESSIVE IN IDENTIFYING PERFORMANCE
WEAKNESSES
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MAINTENANCE / SURVEILLANCE r
CATEGORY 3 c
SIGNIFICANT DECLINE IN PERFORMANCE
i e-WEAKNESSES IN TESTING AND MAINTENANCE OF EQUIPMENT
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REACTOR BUILDING o
SERVICE WATER SYSTEM o
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REACTOR COOLANT PRESSURE ISOLATION o
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CONTAINMENT ISOLATION. VALVES e
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EMERGENCY PREPAREDNESS CATEGORY 2 DECLINING PERFORMANCE e
IMPROVEMENTS IN AREAS NOTED IN PREVIOUS SALP e
RECURRING PROBLEMS NOTED IN OFF SITE NOTIFICATIONS, EMERGENCY ASSESSMENTS, AND DECISION MAKING e
INCREASED MANAGEMENT ATTENTION NEEDED
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SECURITY CATEGORY 1 STRONG PERFORMANCE
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PERFORMANCE EXCELLENT
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PROGRAMS EFFECTIVELY MANAGED
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i ENGINEERING / TECHNICAL SUPPORT CATEGORY 2 ENGINEERING PERFORMANCE MIXED
MODIFICATION PROCESS EFFECTIVE
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QUALITY VERIFICATION
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FUNDAMENTAL WEAKNESSES-IN CORRECTIVE ACTION PROCESSES AND SELF-ASSESSMENT e
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e OVERSIGHT AND SELF-ASSESSMENTS DID NOT
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IDENTIFY WEAK CORRECTIVE ACTION PROCESSES
INITIATIVES TO IMPROVE CORRECTIVE ACTIONS
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w COOPER NUCLEAR STATION OV E 9ALL P ERFOR VIAL \\ C E SU VIM A lY RATING LAST RATING THIS FUNCTIONAL AREA PERIOD PERIOD 7/16/90-1/18/92 1/19/92-4/24/93 PLANT OPERATIONS
2 RADIOLOGICAL CONTROLS
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MAINTENANCE / SURVEILLANCE
2" SECURITY
1 ENGINEERING / TECHNICAL SUPPORT
2 SAFETY ASSESSMENT / QUALITY VERIFICATION
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- IMPROVING TREND
- * DECLINING TREND p
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I ENCLOSURE 3
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GENERAL OF FtCE i
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P O BOX 899 COLUMBUS NEBRASKA 606024499
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~ELENONE (402) 564-4561 Nebraska Publ.ic Power D str*ct i
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i NSD930977 August 11, 1993
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U.S.
Nuclear Regulatory Commission r
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Document Control Desk Washington, DC 20555 Gentlemen:
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i Subject:
Sv e ramar_i.c A m ee-nr of Licensee Performance (SALP)
Report u nspection Report 50-928/93-99)
i On July 12, 1993 Nebraska Public Power District (NPPD) management personnel met
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with NRC management to review the results of the SALP report for Cooper Nuclear Station (CNS) for the period January 19. 1992 through April 24 1993.
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purpose of this letter is to provide co=ments on the SALP report in addition to those made at the public SALP meeting.
NPPD wishes in emphasize its commitment to the continued safe operation of CNS.
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As indicated by NPPD management at the public SALP meeting, the District will be focusing intensely on the issues contained in the SALP report to improve the
overall performance of Cooper Nuclear Station.
The District vill commit the resources and management attention necessary to effect the necessary improvements
in the District's nuclear program.
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NPPD has analyzed the licensee recommendations identified in the SALP report and
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the attachment addresses the recommendations made by the NRC in each appropriate
functional area.
As stated during the SALP meeting, many corrective measures have been taken or are in progress to address the concerns expressed in the SALP report.
The District appreciates the feedback provided by the SALP process and is i
committed to significant improvement in the perfornance of CNS.
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/e G.
Horn
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N r Power Group Manager
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NSD930977
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August 11, 1993 Page 2
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_Regicnal Administrator
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USNRC Region IV
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NRC Resident Inspector
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Cooper Nuclear Station t
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t NSD930977 Attachment Page 1 of 8
SALP RECOMMENDATIONS AND RESPONSES July 1993 A.
Plant Operations NRC Recommendation
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Licensee management needs to take appropriate measures to assure that the long term issue of operator communications during nonroutine operating
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activities has been included in the training process for all operators.
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The licenseo should implament an effective process for the evaluation of deficient conditions that impact the safe operation of the facility.
NPPD Response Operations management has exerted considerable effort towards improvament of operator communications as described in the quarterly status reports of the 1992 SALP Action Plan.
The most recent SALP report appropriately described this issue as an " ongoing challenge".
In an effort to enlist the support of those affected, Operations management will meet with the supervision from each operating crew to discuss communication inadequacies
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and to solicit their input for implementing further improvements. Topics currently under consideration are objective grading of comarunications
during training, incentives for high performance, methods for utilization
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of video taping to improve communications, the retention of training principles such that lessons learned are taken back into the plant Control Room and increased overview by management.
l The Operability Deterinination process will be reviewed and revised, as necessary, to enhance Shift Supervisor review of Operability Determinations and Evaluations. This enhancement will further the review
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process to promote technical adequacy and effectiveness.
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NSD930977
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Page 2 of 8
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B.
Radiolocical Controls NRC Recommendation The licensee needs to implement measures to assure that the facility staff is more eggressive in the pursuit of issues which are to be documented in
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the radiological safety incident report process by site procedures.
NPPD Reseense To upgrade the radiological problem resolution process, the Corrective Action Program will be revised to clearly describe occurrences which meet the established initiation criteria for a Radiological Safety Incident Report (RSIR). These criteria will be established such that radiological
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incidents which demonstrate a weakness in the CNS Radiation Protection Program will receive the necessary station management attention and involvement to ensure timely, results-oriented corrective action.
To address less significant radiological problems, new thre shol ds,
comparable to the those currently established in the lower threshold Corrective Action Program, will be developed.
'Ihese thresholds will address occurrences indicative of undesirable performance, with the degree
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of radiological safety significance lower _ than that established by the I
RSIR.
Trending of radiological problems will be developed to provide a mechanism by which Station Management is kept informed of the Radiation Protection
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I Program performance.
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The procedure changes necessary to upgrade the Corrective Action Program relative to radiological problem resolution will be developed and implemented by January 1994
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NSD930977 Attachment Page 3 of 8 i
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Maintenance / Surveillance NRC Reconusendat-f on The licensee should review the scope and depth of maintenance / surveillance activities to make sure that the mainteunce and surveillance programs for safety-related equipment are adequate to assure that the equipment con and will continue to perform its safety functions.
The licensee should also increase the emphasis on oversight by plant management and systems engineering to provide an increased level of technical support to the
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maintenance and surveillance activities at the plant.
Management should provide additional emphasis on generation of thorough and detailed maintenance and surveillance procedures, and on the need for maintenance / surveillance personnel to carefully follow the procedures.
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NPPD Resoonse Maintenance activities and programs for all safety-related systems, structures, or components will be reviewed in conjunction with Maintenance Rule implementation.
Preventive Maintenance activities and maintenance
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procedures will be thoroughly reviewed as a part of this process and will be revised as necessary to ensure accuracy.
Maintenance craft training l
will continue to stress the necessary requirements for procedural conspliance and attention-to detail.
Maintenance Managsment and
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Supervisors will monitor performance in this area through field observation in accordance with Maintenance Procedure 7.0.4, Conduct of
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Maintenance.
l The SALP analysis for the Maintenance / Surveillance areia noted that corrective actions had been initiated for several issues identified at the end of the SALP period which will be continued during the next period.
Some of the specific programs which will receive additional evaluation
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includa pressure isolation valve and check valve testing, local leak rate testing, and inservice inspection and testing.
In addition, the.
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verification of the adequacy of surveillance procedures has been included in the Design Basis Reconstitution Program. More emphasis is being placed on system engineer involvement in overall plant problems from initial identification through the timely, complete achievement of results.
It will be stressed with Maintenance and Operations personnel to utilize the
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Engineering staff when problems first arise to enhance their resolution.
As noted in the Engineering / Technical Support response, system engineer involvement led to the resolution of a number of Icngstanding and emergent problema during the refueling outage. Engineering is also reviewing their current pro 5 rams to ensure there is better utilization of their resources.
These actiona vill ensure better responsiveness and overview of plant activities.
In addition, attention to the above activities and to compliance with all maintenance and surveillance procedures will be amphasized by Manageran.
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NSD930977
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Attachment Page 4 of 8 D.
fM rrency Preo4 redness NRC Recommendation Licensee needs to take actions to assure that the recurring issues in offsite notification, amer 6ency assesaments, and decision making have been corrected.
NPPD Response The District has installed a new " hotline" telephone system to rasedy the recurring problems with late offsite notification.
The new system _is independant of the local telephone switching channels and will therefore be available even if local telephone usage is heavy.
The system was successfully demonstrated during the initial notification of the recent July 24, 1993 Notification of Unusual Event brou5 t about by local area h
flooding around the plant.
The new system completed notification to all applicable agencies within eight minutes of its initiation, well within the 15 minuto criteria. Additionally, revisions have been made to plant l
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procedures to ensure adequate consuunication takas place between the Station Operations Review Committee and the Shif t Supervisor on matters which may involve an event with an amargency classification.
This coordination has been damonstrated to be effective on three upgradad separate occasions in ensuring the timely declaration and notification of an event at Cooper Nuclear Station.
A change to the Emergency Response Organization (ERO) has been implemented This to address the weakness noted in the area of emergency assessment.
change now has the Plant Manager remaining in the Technical Support Center (TSC) in the role as the Energency Operations Director, rather than physically moving out to the Emergency Operating Facility. By remaining in the TSC, the Plant Manager will enhance the plant technical support and
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emergency assessment activities so that the facility can maintain a continuity of planning and implementation of the necessary support activities. In addition, ERO position specific training covering Accident Management Techniques was conducted in March, 1993 to enhance personnel knowledge and consideration of emergency assessment.
Aspects of this training will be incorporated into the ongoing EP training and assessment process.
The skills acquired from this training were effectively demonstrated during a June 15, 1993 drill.
In the area of decision
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making, training has been conducted for " low threshold" core damage events where the indicated plant parameter are close to the threshold levels for Particular emphasis has been placed on declaring a General Emergency.
degraded core symptoms and indicators for the potential loss of fission product barriers. These " low threshold" core damage scenarios have been included into the training program for future training and drills.
In addition, practices at other nuclear facilities in these areas are
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observed on a periodic bases by District personnel and evaluated for incorporation into the District's program as appropriate.
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e NSD930977 Attachment Page 5 of 8 E.
Security NRC Recommendation None.
NPPD Resronna Security will continue to receive strong management support with emphasis on pro 5 ram improvements.
To enhance personnel readiness, response contingency training and force-on-force exercises vill be a priority.
Additionally, training aids will continue to be assessed and upgraded, acec,rdingly.
To enhance security system readiness and response, a video capture system will be installed.
Once implemented, these enhancements l
will be assessed to assure the ongoing effectiveness of the Security program.
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o NSD930977 Attachment Page 6 of 8
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Enrineerinr/ Technical Surrort
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NRC Reconstendation The licensee needs to resolve plant problems by correcting the root cause, with the objective of closing the issue with finality, rather than by quick-fix approach to mitigate the immediate symptoms.
The using a
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licensee should put more thoroughness, formality, and attention to careful documentation into the process. The licensee should also give management oversight and/or system engineering function more emphasis, with more responsibility and authority for reviewing all aspects of a problem.
i NPPD Resoonse Actions have been initiated to strengthen the Engineering / Technical
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support staff in order to provide more effective support of plant operation.
Increased emphasis is being placed on system engineer involvament in plant problems from the initial identification through the timely, conclusive achievement of results.
Multi-disciplinary or multi-system tasks assigned to the engineering staff are now being evaluated and
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resolved through the use of an engineering department instruction to ensure comprehensive reviews and corrective actions are performed.
Job performance guidelines for system engineers will also be reviewed and
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clarified as appropriate to ensure management expectations are clearly
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defined.
To promote the identification and correction of problems which may constitute a nuclear safety concern, Management expectations stressing the
need for a questioning attitude have been effectively cosusunicated to Engineering personnel.
This has resulted in the resolution of several longstanding problems and numerous emergent problems during the recently i
completed refueling outage.
This same attitude is being stressed to eliminate repeat equipment failures by ensuring engineering evaluations
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are performed in a rigorous formal manner relying on confirmation of results.
In addition, management is emphasizing the identification and resolution of plant problems as a psitive aspect of their jobs.
These changes will continue to be reinforced and supported to ensure that the practices become deeply ingrained in the engineering culture.
Various policies and procedures are being evaluatsd. to increase the efficienc*/ and timeliness in which problems are resolved, in addition, a review has identified the need for streamlining some progra=== tic processes, and the redistribution of others, in order to better utilize the 25 engineering resources.
Finally, managerial oversight of system engineer activities is being increased to ensure that appropriate levels of responsibility and authority are assigned for resolving all aspects of plant problems.
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NSD930977 Attachment Page 7 of 8
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Sefety Assessment /Ous11tv Verification
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L NRC Recommendation
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i 1.icensee management needs to perform a critical assessment of their corrective action processes in light of the problems identified by the NRC
and correct the process to assure that the process is meeting licensee and NRC expectations.
NPPD Resoonse The District has performed a critical assessment of the Corrective Action j
Program through multiple approaches and means.
These elements of our assessment are as follows i
1)
A Corrective Action Progran Overview Group (CAPOG) was found in
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April,1993 to ensure that problems related to nuclear safety were:
l a)
Promptly identified I
b)
Properly evaluated regarding their significance i
c)
Effectively com:runicated to appropriate personnel i
d)
Aggressively resolved with rigor commensurate with their
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safety significance.
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The CAPOC is composed of three senior personnel dedicated full time to
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this effort and reports to the site manager.
Assessment of CAPOG's activities by Quality Assurance and an outside expert have concluded that
CAPOG was effective and was helping communicate managements' expectations
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to plant personnel of a safety first and fix it right the first time culture.
2)
The existing Corrective Action Program as a whole was recently evaluated by a Corrective Action Program Self Assessment Group (CAPSAG). The scope of its review was to evaluate:
a)
Managements'
effectiveness in directing, supporting and monitoring the Corrective Action Program b)
Corrective Action Program content, method and implementation
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c)
Corrective Action Program overall effectiveness
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Page 8 of 8
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3)
An investigativa team was formed in ' July. 199 3 to perform an independent assessment of enforcement issues identified in NRC Inspection Report 93-17.
One of the sbj ectives of this six member team was to determine the adequacy of the proposed corrective.
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actions to the identified issues and to recommend additienal actions.
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to prevent recurrence.
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4)
A performance assessment project was performed in late 1992 by an f
outside agency at the request of senior NPC management to:
i a)
identify root causes of the lack of uniform performance
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b)
identify changes needed to raise levels of performance up to managements * expectations
i c)
provide recommendations to effect these changes
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Information and conclusions of the above group's assessments of the
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Corrective Action Program have been taken and evaluated by NPC senior j
management. It has been determined that the program must be improved by:
1)
Improving the process by making it more stream lined
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Clarification and enforcement of ownership and accountability 3)
Improve communications at all levels to ensure all personnel
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get the same message
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4)
Establish program performance monitoring including indicators.
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5)
Increased management oversight of the corrective action process.
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The District believes the above efforts and. the future ~ program
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improvements will address the District's concerns with the. Corrective -
l Action Program.
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