ML17187A987
| ML17187A987 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 04/17/1997 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML17187A986 | List: |
| References | |
| NUDOCS 9705300071 | |
| Download: ML17187A987 (30) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 REVIEW OF COMMONWEAL TH EDISON COMPANY'S RESPONSE TO THE 10 CFR 50.54(f) LETTER REGARDING SUSTAINED IMPROVEMENT 9705300071 970527 PDR ADOCK 05000237 P
PDR AND PERFORMANCE CRITERIA April 17, 1997 Enclosure
-r--
TABLE OF CONTENTS
1.0 INTRODUCTION
2.0 PERFORMANCE ASSESSMENT 3.0 REVIEW CRITERIA
4.0 ASSESSMENT
OF ComEd's 50.54(f) RESPONSE TO NRC ITEM (a)
5.0 ASSESSMENT
OF ComEd's 50.54(f) RESPONSE TO NRC ITEM ( b) 6.0 STRATEGY FOR MONITORING PERFORMANCE
7.0 CONCLUSION
--i --
I
. 1. 0 INTRODUCTION The cyclical safety performance of Commonwealth Edison Company (ComEd) nuclear stations has long concerned the Commission and the staff of the U. S. Nuclear Regulatory Commission (NRC).
In the last 10 years, LaSalle was on the NRC's watch list from April to October 1986.
Dresden was on the watch list from June 1987 until December 1988, was returned to the watch list in January 1992, and remains on the watch list today.
Zion was on the watch list from January 1991 until January 1993.
Because of declining performance, trending letters were issued to LaSalle in January and June 1994, and to Quad Cities in January and June 1994, and January 1995.
In addition, as a result of performance concerns discussed at the January 1997 Senior Management Meeting (SMM},
LaSalle and Zion were again placed on the watch list. The cyclic performance history of the ComEd nuclear facilities raises questions regarding ComEd's ability to operate six nuclear stations while sustaining performance improvement at each site.
Historically, major weaknesses that led to the poor performance at ComEd's plants included (1) lack of effective management attention and application of resources, (2) weak corporate oversight of nuclear operations, (3) poor problem recognition and failure to ensure lasting corrective actions, (4) lack of adequate engineering support, and (5) an inability or reluctance to learn from experiences at ComEd and other utilities.
During the January 1997 SMM, the NRC concluded that it requires information that will allow the.NRC to determine what actions, if any, should be taken to assure ComEd can safely operate its six nuclear stations while sustaining improvement at each of the sites.
By letter dated January 27, 1997, the NRC staff issued a Request For Information to ComEd, pursuant to 10 CFR 50.54(f},
pertaining to safety performance* at ComEd's nuclear stations. The NRC requested the following information:
(a) Information explaining why NRC should have confidence in ComEd's ability to operate six nuclear stations while sustaining performance improvement at each site.
(b) Criteria that ComEd has established or plans to establish to measure performance in light of the concerns identified, and ComEd's proposed actions if those criteria are not met.
By letter dated March 28, 1997, ComEd's Chairman and Chief Executive Officer replied to the NRC's Request For Information.
Supplemental information regarding performance criteria was submitted by letter dated April 15, 1997.
A multidisciplinary team consisting of Senior Executive Service (SES) managers and staff from Region III, the Office of Nuclear Reactor Regulation (NRR}, the Office of Analysis and Evaluation of Operational Data (AEOD), the Office of the General Counsel (OGC}, and the Office* of the Executive Director for Operations (OEDO) was assembled to conduct a thorough review of ComEd's response.
The staff's assessment of ComEd'S response was presented to the Executive Director for Operations (EDO) on April 16, 1997, and will be
- presented to the Commission during a Commission meeting scheduled for April 25, 1997.
2.0 PERFORMANCE ASSESSMENT 2.1 ComEd's View of-Its Performance ComEd's response of March 28, 1997, to the NRC's 10 CFR 50.54(f) letter, provided a candid discussion of performance at the ComEd nuclear stations.
ComEd understands that performance at Zion and LaSalle has been poor, as identified by the Independent Self-Assessment Teams and by a recent significant reactivity management event at Zion.
ComEd considers performance trends at Dresden and Quad Cities to be in a positive direction and attributes progress made at those stations to*the implementation of the "Dresden Plan" and the Quad Cities "Course of Action Plan."
ComEd considers Byron's overall performance to be "excellent*~ and considers Braidwood to be a "good performer."
2.2 NRC'S View of ComEd's Performance There is a significant range in performance among the six ComEd sites. At Zion, the recent reactivity management event served to highlight the depth of the licensee's problems and indicated that substantial improvement is needed.
At LaSalle, problems continue in a number of areas, despite implementation of nearly half of its Restart Action Plan. Overall performance at Dresden has been good and continues to improve.
In the last 6 months, performance at Quad Cities has been good, with both units in dual-unit operation for more than 100 days.
Overall performance at Braidwood is considered good and has. remained generally consistent with the last Systematic Assessment of Licensee Performance (SALP) assessment (September 1995); however~ performance in the area of plant support has declined from the excellent level.
Byron's overall performance has been good to excellent.
Good performance in operations and plant support continues to be noted, but some decline in the excellent performance observed during the last SALP (August 1996) in maintenance and engineering has recently been noted.
3.0 REVIEW CRITERIA 3.1 Development Prior to receiving ComEd's response to the 50.54(f) letter, the review team developed criteria (see attached chart) for assessin~ the response.
It is important to note that because the team did not know the approach ComEd would take, the criteria were not used to make a pass/fail determination on the quality of the response.
Rather, the criteria were developed to anticipate areas that the NRC would expect ComEd to address based upon the NRC's assessment of past and current performance problems.
Criteria were developed for both Items (a) and (b) of the NRC's 50.54(f) letter.
In addition to documented problems identified in inspection reports
- and semiannual Plant Performance Reviews for the ComEd facilities, the following reference sources were considered during the development of the criteria:
Management Directive 8.13, "Ev al uat i ng the Safety Performance of Nu cl ear Power Reactor Licensees,"
Inspection Manual Chapter 0350, "Staff Guidelines for Restart Approval,"
Letters from T. Maiman (ComEd) to NRC, dated February 18, 1997, forwarding the Independent Self Assessment Team Reports commissioned by ComEd for Zion and LaSalle, and SECY-92-228, "Performance of Commonwealth Edi son Company Pl ants, 11 dated June 25, 1992.
The criteria were formally documented in a memorandum from J. Roe and J. Caldwell to S. Collins and A. Beach dated March 27, 1997.
3.2 Measuring ComEd's Response Against The Review Criteria The staff reviewed the licensee's response against the established assessment criteria to verify that each of the criterion was addressed.
If an individual criterion was addressed, the primary areas or sections of the response that address that criterion hav~ been listed in bold on the attached chart.
Secondary areas are also listed.
Overall, the majority of assessment criteria were addressed in ComEd's response.
Five assessment criteria were not addressed or not addressed in an integrated manner in the licensee's response.
The staff evalu~ted the significance of each of the assessment criteria that ComEd did not fully address.
Four of the five areas not fully addressed in the ComEd response were considered significant.
(These areas are indicated by an-"*" in the list below.)
Significant areas are those important enough to pursue further interaction with the licensee.
In addition to the areas that were not completely addressed, the staff identified other areas where further interaction with ComEd will enhance the*
.staff's understanding of ComEd's response.
An integrated list of.the areas requiring further interaction is provided below.
- NRC Criteria a.l.c & d -- ComEd Response Section 4.1. Identification and Resolution of Fundamental Causes of Cyclic Performance Four causes for cyclic performance are described in the response and include:
oversight, management attention and resources, standards, and lessons learned.
However, the response does not elaborate on what is different about these root causes for cyclic performance versus past assessments?
In addition, the basis or rationale for rejecting other potential root causes is not*provided.
.)
- NRC Criterion a.4.c -- ComEd Response Section 4.4.2, Engaging*the Work Force and Bargaining Unit Relations The response generally describes use of a strategy at the site level through a site "Lead Team."
However, it is not clear how the use of these lead teams will gain 11 buy-in" to improvement initiatives from the work force.
Of note is the decision to defer team development at both the LaSalle and Zion stations.
- NRC Criterion a.5.b -- ComEd Response Section 5.0, Procedural Adequacy and Compliance Weaknesses in procedural adequacy and compliance are not specifically addressed in the. response from a corporate perspective.
Some information is provided in Section 4.5.2, associated with the establishment of a Peer Group for Operations; Section 4.7.4, associated with the assessment of performance weakness demonstrated by the LaSalle and Zion events; and Section 5, for site~
specific corrective actions.
- However, the corrective action initiatives of
- the corporation with regard to procedural adequacy and compliance are not specifically addressed.
NRC Criteria a.7.a and a.9.b -- ComEd Response Section 4.2 and 4.4.4, Getting Work Done Initiative The response provides several discussion topics that ~ddress plans for improving work control.
However, the section titled "Getting Work Done Initiative," does not provide a clear understanding of how standardizing the site's screening process and performance measures will result in better work productivity.
NRC Criterion a.9.b (engineering) -- ComEd Response Section 4.3, Engineering Support Engineering assurance groups were implemented at all sites and at the corporate office to perform several functions, including technical oversight of important engineering products.
The exact role of these groups in strengthening the safety culture has not been well defined.
Feedback on an individual basis may be pos.itive; but how are common weaknesses in engineering products being identified and integrated with the training program?
In addition, how long will these groups provide their oversight function?
- NRC Criterion a.9.b (licensing) -- ComEd Response Section All, Licensing The response does not provide any information on imprriving the current licensing process.
Some recent license submittals have required significant*
interactions and requests for additional information from the staff to obtain all necessary information.
- 5 """'.
- NRC Criterion a.11.a -- ComEd Response Section 5.0, Communications ComEd's response discussed corporate communications and communications between sites, but did not*specifically address communications between departments (e.g., Operations and Maintenance).
This issue is addressed by some of the individual sites in Section 5.0 of the attachment to ComEd's response, but it is not addressed globally.
Interdepartmental *communication weaknesses have been observed at most ComEd sites in inspection reports and licensee event reports.
One assessment criterion that was not completely addressed in the March 28, 1997, response was determined to be not significant and therefore, not requiring further interaction with the licensee. *Discussion on this criterion
- is provided below.
NRC Criterion a.2.f. -- ComEd Response Section 1.0, Introduction The staff categorized criterion a.2.f., "Does ComEd address any potential conflicts or negative consequences with implementing the corrective action plan?, as not significant and therefore, not requiring followup with*t~e licensee, based on the statement in the March 28, 1997, response that the actions described may be modified as circumstances warrant.
This would allow the plan to be changed in the case of potential conflicts.
3.3 Conclusion Although the staff considers that ComEd's response is comprehensive and broadly based, the response was presented in a summary manner.
Although some of the staff's assessment criteria were not addressed in ComEd's report, the staff concluded that the overall response contained sufficient information for the staff to reach conclusions which are discussed in Sections 4.0 and 5.0 of this report.
As part of its ongoing regulatory oversight of ComEd activities, the staff will be interacting with ComEd to more fully understand the details of some of its programs and initiatives as well as understanding the implementation milestones outlined in ComEd's response.
4.0 ASSESSMENT
OF ComEd's 50.54(f) RESPONSE TO NRC ITEM Ca)
Item (a) of the NRC's January 27, 1997, letter required ComEd to submit:
"Information explaining why NRC should have confidence in ComEd's ability to operate six nuclear stations while sustaining performance improvement at each site."
4.1 Background In its March 28, 1997, response, ComEd provided a comprehensive and broadly based set of actions to improve performance; these have been taken or are in various stages of development and implementation.
These actions collectively were d_es i gned to demonstrate to the NRC why it should have confidence in
- ComEd's ability to operate its six nuclear plants while sustaining performance improvement at each site.
As discussed in SECY-92-228, dated June 25, 1992, ComEd has developed many improvement programs over the years that have not been totally effective.
Either the programs did not address the appropriate root causes and/or the implementation of the programs was ineffective. Historically, ComEd has had a tendency to develop new programs to deal with problems rather than focus on implementation of existing programs.
Not identifying underlying root causes resulted in narrowly focused corrective actions that addressed only symptoms.
In some instances, corrective action programs were integrated into the line functions of various departments at the sites without providing the resources necessary to complete the tasks.* As a result, some corrective actions were ineffective due to the narrow focus or were lost in the press of day-to-day business.
In its March 28, 1997, response, ComEd addressed this issue.
ComEd stated that, in the past, *it presented plans for improving performance that were keyed to people, resources, and programs; ComEd also acknowledged that its current plan also depends on people, resources, and programs.
However, ComEd explained that where people were not right, they have been replaced.
ComEd believes that today, it has assembled one of the most experienced nuclear management teams in the country.
Where additional resources are needed, ComEd indicated that they are being provided.
Where programs have not worked, ComEd stated it is changing them.
4.2 NRC Assessment The staff reviewed ComEd's response in detail to determine if the information provided is sufficient for NRC to conclude that it should have confidence in ComEd's ability to operate six nuclear stations while sustaining performance improvement at each site. Based upon the history discussed above, the staff recognizes that the key to avoiding* cyclic performance in the future is the effective implementation of sound programs designed to correct the fundamental root causes of such performance.
Iri assessing ComEd's response, the staff could not prejudge or predict the effectiveness of the proposed initiatives.
Therefore, in evaluating the response, the staff used the criteria discussed in Section 3.0 of this report to determine if ComEd (1) recognized and acknowledged its performance weaknesses, (2) evaluated the root causes of cyclic performance, (3) developed programs or initiatives designed to correct the root causes, (4) established goals and standards for performance, (5) developed the self-assessment tools necessary to measure performance, and (6) specified the actions it would take if it determined that its performance did not meet its established goals.
Based upon the staff's review, each of the six items identified above were addressed in ComEd's response.
- With respect to item (1), ComEd has acknowledged that the cyclical performance of its nuclear facilities is unacceptable and recognizes that past plans for performance improvement have not been successful.* ComEd's response indicates
- that it recognizes the scope and severity of the challenges it faces and that serious and aggressive action is needed to improve its nuclear program performance.
With respect to item (2), the response indicates that ComEd has performed an assessment of the root causes of its failure to achi_eve sustained performance improvement.
Input to ComEd's root cause evaluation included the fundamental causes identified in the Independent Self Assessment Team (ISAT) evaluations performed at LaSalle and Zion; the causes identified in the NRC's January 27, 1997, 50.54(f) letter; the Dresden Independent Safety Inspection; and other documents.
With respect to the ISAT evaluations, _due to the independent nature of these assessments, the staff considers these evaluations
- to be a significant positive initiative for ComEd.
The staff also believes that these assessments have played a large role in ComEd's recognition of the depth of the problems it is facing.
With respect to item (3), ComEd has developed a broad set of initiatives to address the identified root causes'. Appendix 1 of ComEd's response cross-references ComEd's corrective actions to the root causes.
\\
With respect to items (4), (5), and (6), ComEd's response indicates it is establishing performance goals and standards, is developing self-assessment tools to measure performance, and, has specified th~ actions it will take if it determines that its performance does not meet its established goals.
The initiatives that ComEd is undertaking to improve performance are based on ComEd's understanding of the fundamental root causes of cyclic performance.
- ComEd has concluded that its failure to achieve sustained performance improvement is due to four causes:
- . Oversight - ComEd needs to strengthen management oversight Of nuclear operations.
Management Attention and Resources - ComEd has not consistently applied necessary resources and management attention to the sites to ensure successful completion of its improvement plans.
Standards - ComEd.has not consistently enforced high standards for nuclear performance, particularly in the areas of operations, engineering and corrective action.
Lessons Learned - ComEd has not consistently communicated and internalized the experiences of its own nuclear facilities or those of others in the industry.
ComEd's response further indicates that the essence of its performance improvement program centers around six critical strategic priorities. These priorities are:
Strengthen oversight of Nuclear Operations Division (NOD) Activities.
Increase financial resources.
Expedite corporate functional support.
Support NOD management team.
Improve cross division programs and processes.
Enforce rigorous standards of performance.
A brief summary of the significant actions that ComEd is taking to improve its ability to monitor, assess, and operate its six nuclear stations is provided below.
For ease of understanding, the actions are grouped according to ComEd's six critical strategies.
A.
Strengthen Oversight of NOD Activities I..
The ComEd Board of Directors has taken a much more direct and active role in ensuring performance improvement in ComEd's nuclear program.*
The Board has significantly. strengthened the membership in and role of its Nuclear Operating Committee (NOC).
The Board has directed that the NOC report to the Board on safety, performance, and resource allocation.issues, as well as its view on whether nuclear.program management actions are appropriate and effective.
- 2.
ComEd is significantly strengthening the corporate oversight of nuclear operations to provide independent and consistent oversight of the performance of each site and the NOD as a whole.
Some of the more significant actions include:
The Nuclear Oversight Manager reports directly to the Chief Nuclear Officer (CNO) to provide the CNO with independent and direct feedback on nuclear operation performance.
The Chief Nuclear Operating Officer (CNOO) is conducting monthly management review meetings at each site. These meetings focus on safety performance and the effectiveness of improvement initiatives.
NOD Nuclear Oversight staffing levels are being increased and the assessment and audit programs are being formalized and expanded~ The NOD audit and surveillance program is being integrated with the site oversight and quality programs.
The increased staffing is designed to support data analysis, performance monitoring, management and coordination of industry (peer) assessments, and assessments of emerging issues and special evolutions.
NOD Nuclear Oversight and Site Quality Verification (SQV) are establishing an NOD-wide standard analysis and reporting process, similar to the NRC's Integrated Performance Assessment Process (IPAP).
Using selected performance indicators, a monthly report will be developed and analyzed to evaluate emergent trends or issues in safety performance, personnel performance, material condition, programs, and procedures.
Safety or Management Review Boards (SRBs) are being implemented at all sites. The SRBs, consisting of senior experienced outside experts and ComEd personnel, evaluate station safety performance, corrective actions, and improvement plans.
In addition to providing comments and recommendations to site management, the SRB Chairmen will provide direct input to the Nuclear Operations Committee of the Board of Directors.
B.
Increase Financial Resources The ComEd Board of Directors has significantly increased the financial resources for improvement initiatives. The necessary resources have been benchmarked against industry good performers and the budgets have been increased based upon the performance issues facing the plants and the needs of the sites.
C.
Expedite Corporate Functional Support ComEd is providing additional cor~orate functional support for the nuclear division in selected areas by providing additional resources to improve spare parts availability and qualification; providing additional resources to improve the Electronic Work Control System (EWCS), which is used at the sites to plan and control work; and, transferring nuclear security functions to the NOD.
The NRC staff has observed performance weaknesses in each of these areas.
D.
Support NOD Management Team
- 1.
Since*l994, ComEd has significantly strengthened the nuclear division senior management team with corporate and site managers with proven track records in turning around poorly performing utilities.
- 2.
ComEd has developed several initiatives to improve the management selection and development process, succession planning, and supervisory skills de.vel opment.
- 3.
ComEd has recognized that support from its workforce is essential to its success and is implementing actions to engage the workforce and gain workforce ownership of ComEd's performance improvement initiatives.
E.
Improve Cross Division Programs and Processes
- 1.
Beginning in*l994, ComEd recognized that a major area requ1r1ng improvement at the corporate level and the stations was engineering and technical support.
As a result, ComEd has taken several actions to improve engineering support to the nuclear stations.
Some actions have been implemented and others. are ongoing.
Ongoing actions are based on insights from recent major inspections and events including the Dresden Independent Safety Inspection, the LaSalle service water
- system event and the Zion Engineering and Technical Support Inspection.
Some of the more significant actions include:
. developing an improved inhouse engineering capability and significantly reducing its dependence on outside engineering
- support, increasing significantly the complement of engineers at the
- stations, transferring design authority and design records from contract design engineering organizations to ComEd, forming Engineering Assurance Groups at each site and in the corporate office to improve the quality of design and technical work and to maintain the design basis (These groups report to the station manager.and consist of experienced engineering personnel who provide oversight of key engineering activities.),
initiating a ~eries of reviews of safety systems to include verification of conformance with the Updated Final Safety Analysis Report (UFSAR),
initiating selected s.afety system functional inspections at each site coupled with techn~cal reviews of the top ten risk significant systems to identify issues that may impact system readiness, developing common engineering processes and procedures for the six sites, improving the accessibility and quality of design-basi~
information, developing and validating essential design-and licensing-basis information, including the reconstitution, if necessary, of essential calculations, expanding the scope and coverage of design-basis documents, and verifying and validating design-basis information contained in the UFSAR.
2~
ComEd has several actions underway to improve the overall level of training and qualifications of its workforce.
- 3.
ComEd has embarked on a corporate initiative designed to improve ComEd's ability to complete maintenance work at the sites.
- 4.
ComEd is enhancing the sharing of experience and information across the sites. Peer Groups are being used to develop common processes,
11 -
procedures, and practices at each site. Peer groups currently exist
- in the areas of operations, work control, outage management, configuration control, equipment reliability, training, and management and administration.
- 5.
ComEd has revised the corrective action program that will be implemented at each of the sites to ensure a more common approach to problem identification and resolution.
ComEd has developed performance indicators to monitor the timeliness of implementation, the quality.of corrective actions, and the number of significant events which are repeated.
In addition, ComEd has created a corrective actions group to monitor events within the industry and at other ComEd stations.
- 6.
ComEd has summarized individual sit~ actions that are being taken to achieve sustained performance improvement.
As noted by ComEd, the current levels of performance, management challenges, and.corrective actions vary among the sites.
To that extent, the scope and detail of the improvement initiatives vary significantly among the sites. A few of the significant common actions include:
Site Operational Plans are being revised to incorporate corrective actions for the causal factors identified in the Zion and LaSalle ISAT reports.
The sites have established or ar~ establishing site performance indicators and targets to measure progress.
ComEd is strengthening the site self-assessment functions at the sites by having all assessment and performance monitoring organizations report to a senior quality manager at each station.
F.
Enforce Rigorous Standards of Performance I.
ComEd has developed an integrated structure of performance measures
- and criteria to measure site performance on a monthly basis to ensure its performance criteria are satisfied.
Indicators will measure ComEd station performance against the average of industry peers and will measure each site's progress in sustaining performanc~
improvement.
(See Section 5.0 of this report.)
- 2.
ComEd has developed a specific set of progressive response actions, up to and including plant shutdown, if the performance criteria established for each site.are not achieved.
(See Section 5.0 of this report.)
- 3.
ComEd is taking specific action to measure the safety and qua 1 ity of control room performance at all of its sites in light of operational events at LaSalle and Zion.
I
- I
- 4. 3 Conclusion
- *The staff has assessed the information provided by ComEd and concludes that the response in total provides a broadly based and reasonable set of actions, which, if effectively implemented, should enhance ComEd's capability to operate, monitor, and assess its six nuclear stations while sustaining performance improvement at each site.
Based upon the information requested by the NRC, ComEd's response focused on its overall nuclear program and did not attempt to address in depth the details of all performance improvement initiatives at each site. The adequacy of ComEd's site-specific performance is being continually monitored and assessed through the NRC's inspection program and oth~r NRC programs and processes for evaluating the safety performance of nuclear power reactor licensees described in Management Directive 8.13 The staff recognizes that although many of ComEd's actions have already been implemented and have met with various degrees of success, many other programs and initiatives outlined in its response are new and in different stages of development.
As with previous ComEd plans, long-term success is highly.
dependent on (1) the effectiveness of implementation of the plan, (2) the self-assessment activities designed to measure performance, and (3) the followup actions that will be taken.based upon performance feedback.
Given the uncertainties outlined above, three aspects of this plan are considered significant improvements from plans developed in the past. These include:
Actions are being taken by the Board of Directors to increase its independent oversight of the nuclear program and ensure that the NOD and each site have the necessary financial resources needed to operate safely and sustain performance improvement.
However, it is important to note that as part of its efforts to meet the challenge of deregulation, ComEd has stated that it is examining its assets, particularly its generating assets, with a view toward evaluating its investment and operating costs against their ability to contribute to the revenues of ComEd.
This analysis could result in early retirement or closure of one or more of its nuclear plants.
Actions are being taken by ComEd to enhance its oversight of its nuclear program at all levels of the organization.
Several specific actions are being taking at the corporate level, NOD level, and at the site level.
Actions are being taken by ComEd to develop an integrated structure of performance measures, criteria, and actions that will be taken if the performance criteria are not met.
5.0 ASSESSMENT
OF ComEd's 50.54(f) RESPONSE TO NRC ITEM (b)
- Item (b) of the NRC's January 27, 1997, letter required ComEd to s.ubmit:
"Criteria that you have established or plan to establish to measure performance in. light of the concerns identified above and your proposed action if those criteria are not met."
5.1 Indicators ComEd has identified several performance indicators that it will use to assess progress in improving the performance of individual stations and the NOD as a whole.
The indicators include (1) top-level indicators used by the NRC and the World Association of Nuclear Operators (WANO) to assess progress in meeting their goal of performance equal to, or greater than, industry peer averages and (2) ComEd internal indicators that will be used at each site to assess progress in sustaining performance improvement.
ComEd has also outlined a process of escalating action if it fails to meet performance targets at individual stations.
As an additional measure, ComEd has established a set of indicators designed to monitor the safety and quality of control room performance.
This special emphasis has been established to ensure that areas of weakness indicated by the LaSalle and Zion operational events are not present or are addressed at all ComEd nuclear stations.
The staff believes that {he indicators used to assess progress sho~ld focus on numeric and qualitative measures that assess the.broad areas of performance over a sustained period of time.
In addition, to the extent possible, the indicators chosen for use in this process should be related to nuclear safety and regulatory performance, should be based on information that is readily available to the NRC, should not be subject to manipulation, should be comparable among licensees, should reflect a range of performance, should be independent of each other, and should be leading.
ComEd's proposal to use indicators based on the NRC and WANO indicators meets these criteria and will provide a common base to work from as the staff assesses its progress.
In its April 15, 1997, supplement, ComEd provided additional information which specified the detailed definitions of the NRC and WANO indicators.
The seven indicators chosen include three NRC indicators and four WANO indicators.
Taken together, they cover all the areas addressed by the seven NRC indicators, with the exception of significant events.
For significant events, it would not be practical for the licensee to attempt to duplicate NRC's determination of which events meet the criteria for this indicator.
In addition there is a WANO indicator of Industrial Safety Accident Rate.
All of the Commonwealth indicators are defined exactly as they are defined by NRC and.WANO respectively. This fact gives reasonable assurance that the calculated numbers are comparable to, but not exactly equal to, what NRC and INPO would assign.
These differences come from the fact that some judgment is necessary in the application of these definitions.
However, the staff believes any differences will be minor.
- ComEd's commitment to monitor the indicators on a monthly basis implies that it intends to gather the data and calculate the indicators on an accelerated schedule.
However, ComEd has identified the year 2000 as a realistic time frame for attaining its performance improvement goals.
ComEd's proposal to specify more detailed ComEd internal indicators of operations, maintenance, engineering, and corre~tive actions is a positive step. These indicators are defined in the ComEd's April 15, 1997, submittal.
The use of this type of tracking and feedback to monitor plant performance on a monthly or quarterly basis has been shown elsewh~re to have a positive,
impact on performance.
However, the staff will not rely on the ComEd internal indicators for performance monitoring, as it would be difficult for NRC to validate the accuracy of the data.
If these indicators are successful in feeding back information to the plant and bringing about plant performance improvement, the results should show up in the NRC and WANO indicators, as well as in the qualitative performance measures used by Region III.
5.2 Criteria and Action Levels ComEd has established a goal of operating each facility at a better-than-average level of.its peers with respect to the NRC and WANO indicators specified above.
In addition, it has specified for each indicator, numerical criteria that wi 11 trigger action on the part of ComEd management.
For example, action will be triggered if there is more than one scram per year for a unit.
Criteria for most of the ComEd.internal indicators have been finalized.
Others will be determined based on trending actual performance for six m6nths.
ComEd has specified an escalating set of actions, which would be triggered by exceedance of the criteria. These actions involve increased attention and action by corporate management, enhanced inspection, root cause analysis, and targeted corrective actions.
5.3, Conclusion ComEd has stated that monitoring of performance indicators and achievement of the specified criteria over time will indicate that sustained improvement is occurring.
The staff.finds this to be a reasonable method for ComEd to monitor progress toward addressing the root causes of cyclical safety performance.
6.0 STRATEGY FOR MONITORING PERFORMANCE The NRC's* strategy for assessing ComEd's ability to operate six nuclear stations while sustaining performance improvement at each site, is centered around the premise that the agency's inspection and assessment programs must monitor plant performance individually and collectively such that improvement initiatives at each station can be evaluated and negative performance trends can be identified as early as possible.
In implementing this strategy, the staff will assess whether ComEd's actions in response to plant events or
- issues at one facility are impacting performance at other ComEd sites. The ability of ComEd to manage improvement initiatives at one station and not reduce good performance at another station is critical to arresting the cyclic performance.
ComEd's ability to sustain performance improvement may be demonstrated only after a significant time period.
Significant ~taff and senior man~gement resources continue to be committed to support the augmented inspection and assessment programs associated with ComEd facilities. Greater collaboration and coordination between regional and headquarters' staffs and effective utilization of agency proces~es such as confirmatory*action letters, Inspection Manual Chapter 0350, and the Plant Performance Review process have and should continue to facilitate a more comprehensive assessment effort.
NRC's current strategy for monitoring ComEd performance is composed of the following actions:
- a.
Agency resources will continue to be used to augment the region-based inspection program as necessa.ry to address performance issues.
- b.
The NRC will continue to monitor performance improvement at LaSalle and Zion through use of the joint Region III/NRR Oversight Panels.
Designated SES oversight managers will continue to provide leadership and direction for these multidisciplined panels.
The panels will assess the Restart Action Pl.ans for Zion and LaSalle, and monitor ComEd's implementation of these plans.
The staff is using Inspection Manual Chapter 0350, "Staff Guidelines for Restart Approval in its assessment efforts at those plants.
The panels will monitor and assess ComEd's corrective actions associated with the Confirmatory Action Letters issued to Zion and LaSalle;
- c.
Region III and NRR will continue to monitor and assess ComEd's corrective ac~ions associated with the Confirmatory Action Letter issued to Dresden.
- d.
The staff will continue to evaluate and close out the Independent Safety Inspection findings on Dresden as appropriate.
- e.
The Pl ant Performance Review process will be utilized to integrate performance observations from each station to identify any common areas of marginal or unsatisfactory performance.
- f.
Quarterly management meetings will be conducted between NRC and ComEd senior management to discuss performance at all ComEd plants and the effectiveness of ComEd's corporate and site-specific corrective actions as described in the licensee's response to the NRC's 50.54(f) letter.
- g.
The NRC will continue to provide increased senior management presence at ComEd facilities to enhance the agency's understanding of plant performance and provi~e valuable insights regarding the staff's assessment efforts.
- h.
The staff will continue to keep the Commission informed about performance at ComEd stations and will maintain a lower threshold for Commission involvement should adverse performance trends be identified.
- 7. 0 CONCLUSION The staff has reviewed ComEd's response to the NRC's 50.54(f) letter dated January 27, 1997, including the merits of initiatives to establish performance indicators, criteria to measure effectiveness, and actions to be taken by ComEd to sustain continuous improvement.
This review was conducted against the criteria developed by the staff and discussed in Section 3.0.
ComEd's response focused on its overall nuclear program and did not attempt to address in depth the details of performance improvements at each site. The adequacy of site-specific performance is continually monitored and assessed through the NRC's inspection program and other NRC programs and processes for evaluating the safety performance of nuclear power reactor licensees described in Management Directive 8.13.
The staff recognizes that success is highly dependent on ComEd' s ability to ( 1) effective 1 y implement its programs and initiatives, (2) perform effective self-assessments designed to measure performance, and (3) implement effective followup actions to sustain improvement based upon performance feedback.
Based on its review, the staff finds that (1) ComEd has established a set of performance measures and proposed actions if applicable criteria are not. met and (2) the response in total provides a broadly based and reasonable set of actions that, if effectively implemented, should enhance ComEd's capability to operate, monitor, and assess its six nuclear stations while sustaining performance improvement at each site. This satisfies the NRC's January 27, 1997, request for information pursuant to 10 CFR 50.54(f).
COMED 50.54(f) RESPONSE ASSESSMENT CRITERIA Item a of 50.54(f) Letter:
Information explaining why NRC should have confidence in ComEd's ability to operate six nuclear stations while sustaining performance improvement at each site:
NOT ADDRESSED NOT ADDRESSED
- 1. ROOT CAUSE IDENTIFICATION ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd understand and discuss the root causes of the Sect 4.1 cyclical safety performance of its nuclear stations?
- b.
Is there a basis for ComEd's root cause assessment?
Sect 4.1
- c.
Does ComEd provide an explanation of why this root cause
}:( 1 analysis is different from past assessments? Did they factor in any lessons learned from past assessments?
- d.
Does ComEd provide a rationale for rejecting potential root
}:( 1 causes?
- e.
Are ComEd's root causes consistent with NRC's observations Sect 4.1 and assessments?
- f.
NRC's past assessments identifying major apparent weaknesses Sect 4.1, App 1 that led to poor performance included:
- 1. Lack of effective management attentiOn and application of Sect 4. l, App 1 resources;
- 2. Weak corporate oversight of nuclear operations; Sect 4.1, App 1
- 3. Poor problem recognition and failure to ensure lasting corrective Sect 4. 1, App 1 actions;
- 4. Lack of adequate engineering support; and Sect 4.1, 4.3, App 1
- 5. An inability or reluctance to learn from experiences at ComEd Sect 4. 1, App 1 and other utilities.
- g.
Are ComEd's identified root causes consistent with the Sect 4. 1, App 1 "Fundamental & Contributing Cause Assessments" determined during ComEd's recent Independent Self-Assessments (ISA) of the LaSalle and Zion Stations?
1 See section 3.0, REVIEW CRITERIA, of this report.
ATTACHMENT NOT ADDRESSED NOT ADDRESSED*
- 2. CORRECTIVE ACTION PLAN/STRATEGY ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Is there a plan and/or strategy to specifically address the root Sect 4. 1, App 1 causes, based upon ComEd's understanding of the root causes of cyclical safety performance at its sites?
- b.
Does the plan arid/or strategy define objectives or goals to be Sect 4.7 achieved from implementing specific actions with scheduled milestones?
- c.
Are the proposed corrective actions clearly cross-referenced to App 1 all the associated root causes and causal factors they are intended to correct?
- d.
Does the plan have a method for monitoring completion of goals Sect 4.6, 4. 7 and effectivene*ss of goals?
- e.
Were the six stations, as well as corporate, involved in Sect 4.5.1, 5 development of the plan and/or strategy?
- f.
Does ComEd address any potential conflicts or negative
)(2 consequences with implementing the corrective action plan?
- g.
Does the corrective action plan address the potential need to Sect 1, 4.7.3 assess changing conditions to determine whether the licensee must modify the corrective action plan?
2 ComEd's response does not specifically address this criteria, but as stated in Section 1.0 of the attachment to ComEd's response, "The actions. described in this attachment and Appendix reflect our current activities and plans and may be modified as circumstances warrant."
. J* '
NOT ADDRESSED NOT ADDRESSED
- 3. RESOURCES AND ACCOUNTABILITY ADDRESSED SIGNIFICANT NOT SIGNIFICANT*
- a.
Has ComEd determined the resources necessary to sustain long-Sect 3, 4.2 term performance improvement at each of the stations and have those resources been committed to by ComEd?
- b.
Does ComEd specify that an individual and organization will be Sect 2 designated. to lead the implementation of the corrective action plan and that they clearly understand their responsibility? Does the individual have sufficient authority and resources to ensure the action will be adequately completed?
NOT ADDRESSED NOT ADDRESSED 4: MANAGEMENT AND ORGANIZATION ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd discuss the responsibility of corporate and site Sect 2, 4.6 leadership?
- b.
Does C.omEd discuss the development of high performance Sect 4. 1, 4. 7, App 1 standards and a strong safety culture that will ensure safety and conservative decision making are placed ahead of production and cost?
- c.
Does ComEd discuss its plan for e*ngaging the work force (i.e.,
Sect 4.4.1, 4.4.2 does ComEd address its plan to gain workforce buy-in*to high performance standards)?
- d.
Does ComEd discuss how goals and expectations will be clearly Sect 4.4,
. communicated to their staff?
Letter (pg 8), App 1 NOT ADDRESSED NOT ADDRESSED
- 5. OPERATIONS ADDRESSED SIGNIFICANT NOT SIGNIFICANT-
- a.
Does ComEd address corrective actions for weaknesses
§[;lt ~U5,2, 4.7.4 observed in communications and command and control?
- b.
Does ComEd address corrective actions for weaknesses
_j::(3 observed in procedural adequacy and compliance?
NOT ADDRESSED NOT ADDRESSED
- 6. MATERIAL CONDITION ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd address actions it is taking to assure that long-Sect 4.2, 4.3 standing material condition and engineering issues are properly identified, prioritized and addressed?
- b.
Does the response address how ComEd will assure the high Sect 4.5.2, 4.7 availability and reliability of safety systems?
NOT ADDRESSED NOT ADDRESSED
- 7. WORK CONTROL ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd address corrective actions for the significant
§©[C ~,;2, ~'~'~'
weaknesses identified in the work control process?
~,l5,2 3 This criteria is addressed by some of the individual sites in Section 5.0 of the attachment to ComEd's response, but it is not addressed globally. See section 3.0, REVIEW CRITERIA, of this report.
--~-----------------~
I NOT ADDRESSED NOT ADDRESSED -
- 8. CONTROL OF DESIGN BASIS ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd address actions it is taking to assure the adequacy Sect 4.3 and availability of design basis information at its facilities?*
- b.
Does ComEd discuss how it is addre.ssing known weaknesses Sect 4.3, Letter identified in the maintenance of the design and licensing basis (pg 9) of its facilities?
- c.
Does ComEd address what actions they have taken to ensure Sect 4.3 ComEd engineers understand the design basis and are not continuing to rely on the AE?
- Note: Responses to NRC's 10/09/96 10 CFR 50.54(f) letter regarding this subject were submitted on 02/09/~7.
I
,_ I ~
NOT ADDRESSED NOT ADDRESSED
- 9. SELF-ASSESSMENT AND CORPORATE OVERSIGHT ADDRESSED SIGNIFICANT NOT SIGNIFICANT-
- a.
Does the response address how ComEd will strengthen and Sect 2, 4.1, 4.6, utilize the results of its self-assessment process.
App 1
- b.
Does the response address how ComEd will strengthen corporate oversight of:
nuclear operations, Sect 2, 4.6.2, 4. 7.4 maintenance, Sect 4.7.2 work control,
§©'U:.©~,2, ~,~,"1).
engineering, Sect 4.3, ~Jft2 licensing,
}:{4 plant support,
§©It ~,2, ~,@,2 training, and Sect 4.4.1, 4.4.3 corrective action processes?
Sect 4.5, 4.6, App 1
- c.
Does the response address improvements in the effectiveness Sect 2.2, 4.6.3, of the on-site and off-site review committees, the site quality App 1 verification (SQV) function at each site and the Nuclear Operating Committee?
- d.
Does ComEd address how it will improve communications to Sect 4.5.2, 4.7.4, assure potentially generic problems identified at one site are App 1 effectively communicated and addressed at other affected sites?
- e.
Does the response address ComEd's benchmarking of Sect 4.3, 4.5.1, performance and/or processes against good performing utilities?
4.7.1 4 See section 3.0, REVIEW CRITERIA, of this report.
~
NOT ADDRESSED NOT ADDRESSED -
- 10. TRAINING ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd address corrective actions for weaknesses Sect 4.3, 4.4.3 identified in the knowledge and skills of personnel in operations, Letter (pg 9, 10) maintenance and engineering?
NOT ADDRESSED NOT ADDRESSED
- 11. COMMUNICATIONS ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
Does ComEd address corrective actions for weaknesses x5 identified in communications (e.g. between departments)?
NOT ADDRESSED NOT ADDRESSED
- 12. EFFECTIVENESS OF INTEGRATED ACTIONS ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
In light ~f ComEd's past history of developing improvement Sect 6, Letter plans and strategies that have been ineffective and/or not fully (pg 13) implemented, does ComEd's response specifically articulate.
why the NRC should have confidence that the actions ComEd has taken and/or plans to take will be effective in ensuring safe.
operation at each of its facilities and will end the spiral qf inconsistent and marginal plant performance?
5 This criteria is addressed by some of the individual sites jn Section 5.0 of the attachment to ComEd's response, but it is not addressed globally. See section 3.0, REVIEW CRITERIA, of this report.
r COMED 50.54(f) RESPONSE ASSESSMENT CRITERIA Item b of 50.54(f) Letter:
Criteria that ComEd has established or plans to establish to measure performance in light of the concerns identified and Com Ed's proposed actions if those criteria are not inet. Has ComEd identified a systematic assessment process to identify problems, collect data, assess performance, and monitor, measure, and feedback results of corrective actions?
- 1.
CRITERIA DEVELOPED BY COMED FOR MEASURING PERFORMANCE SHOULD MEET AS MANY OF THE NOT ADDRESSED NOT ADDRESSED FOLLOWING GUIDELINES AS POSSIBLE:
ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
linked to the root causes ComEd has identified for inconsistent
. Sect 4.7 performance,
- b.
measure the effectiveness of the corrective actions that ComEd Sect 4.7 has put in place to address inconsistent performance;
- c.
are as objective as possible; Sect 4.7
- d.
are not subject to manipulation; Sect 4.7
- e.
are consistent at each station; Sect 4.7
- f.
are well defined and meaningful; Sect 4.7.1 6
- g.
should be able to be validated by independent parties; Sect 4.7
- h.
provide real time information; Sect 4.7.2
- i.
should be clearly communicated to and understood by the Sect 4. 7. 1, Letter ComEd management and staH.
(pg 8) 6 The high level indicators are discussed in Section 4. 7.1 of the attachment to Com Ed's March 28, 1997, response. The definitions of the specific performance indicators were provided in an April 15, 1997, supplement:
ri c*
,. I
I -
NOT ADDRESSED NOT ADDRESSED
- 2. COMED'S RESPONSE SHOULD ALSO IDENTIFY:
ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
how the information will be collected; Sect 4. 7.1, 4. 7.2
- b.
how the information will be assessed; Sect 4.7
- c.
the frequency of collection and assessment; and, Sect 4.7
- d.
the method of feedback to the stations and to the NRC.
Sect 4.77
- 3.
COMED'S PROPOSED ACTIONS, IF THEIR CRITERIA ARE NOT MET, SHOULD MEET AS MANY OF THE FOLLOWING NOT ADDRESSED NOT ADDRESSED GUIDELINES AS POSSIBLE:
ADDRESSED SIGNIFICANT NOT SIGNIFICANT
- a.
should be specific; Sect 4.7.3
- b.
cover the complete spectrum of possible actions; Sect 4.7.3
- c.
have clear and well defined threshold Sect 4.7.3
- d.
should be clearly communicated to and understood by ComEd Sect 4. 7. 1, Letter management and staff personnel; and, (pg 8)
- e.
should have a process to revise the corrective actions or Sect 4.7.3 propose new corrective actions.
7 Feedback to the NRC is not specifically addressed.
J. O'Connor corporate and site-specific corrective actions.
The Commission has requested a briefing by ComEd in approximately 6 months regarding implementation of your performance improvement plan. Thus. we will be in contact with you in the coming weeks to make arrangements for such a briefing.
Docket Nos. STN 50-454. STN 50-455.
STN 50-456. STN 50-457. 50-237.
50-249. 50-373. 50-374. 50-254.
50-265. 50-295. 50-304
Enclosure:
Assessment cc w/encl:
See next page Distribution:
Docket File. T5C3.
H. Thompson. 017G21 R. Zimmerman. 012G18 G. Dick R. Lanksbury, RIII B. McCabe. 017G21 J. Caldwell. RIII J. Grobe. RIII PUBLIC S. Collins. 012G18 J. Roe. JWR C. Moore W. Kropp. RI II R. Barrett. T4A43 P. Pelke. RIII R. Gardner. RIII DOCUMENT NAME:
ALPLANTS\\RESPONSE~LTR To receive a copy of this document, indicate in the box:
Sincerely,
""tJ~~naf si~ned bv
! I
- '\\i.,.,,, ~ i'r*n
!!,., " OB6!J1 I \\;i:.',1le11 L. Joseph Ca 11 a*n Executive Director for Operations POI II-2 r/f F. Miraglia. 012G18 R. Capra G. Grant. RI II OPA. 02A13 C. Goodman. 09H15 J. Gavula. RIII D. Dambly, 015B18 "C" - Copy without enclosures "E" - Copy with enclosures "N" - No copy OFFICE RIII I
NRR I
OGC I
DEDFH/"
NAME BB EACH*
SCOLLINS*
WCHANDLER*
HTH~PJ:)ON DATE 05/15/97 05/20/97 05/22/97 05//}~97 J. Callan. 017G21 B. Beach. RIII M. Gamberoni M. Dapas. RI II OGC. 015B18 P. Castleman. 012E4 P. Prescott. T4D28
.J. Hull. 015B18
- SEE PREVIOUS CONCURRENCE
/
I ED0/7 I
JCALL:.J-\\l'l ~
05/)~//97
J. O'Connor corporate and site-specific corrective actions.
The Commission has requested a briefing by ComEd in approximately 6 months regarding implementation of your performance improvement plan.
Docket Nos. STN 50-454, STN 50-455, STN 50-456, STN 50-457, 50-237, 50-249, 50-373, 50-374, 50-254, 50-265, 50-295, 50-304
Enclosure:
Assessment cc w/encl:
See next ~age Distribution:
Docket File, T5C3 H. Thompson, 017G21 R. Zimmerman, 012Gl8 G. Dick R. Lanksbury, RIII B. McCabe, 017G21 J. Caldwell, RIII J. Grobe, RIII PUBLIC S. Collins, Ol2Gl8 J. Roe, JWR C. Moore W. Kropp, RI II R. Barrett, T4A43 P. Pelke, RIII R. Gardner, RIII DOCUMENT NAME:
ALPLANTS\\RESPONSE.LTR To receive a copy of this document, indicate in the box:
Sincerely, L. Joseph Callan Executive Director for Operations PDIII-2 r/f F. Miraglia, 012Gl8 R. Capra G. Grant, RIII OPA, 02Al3 C. Goodman, 09Hi5 J. Gavula, RIII*
D. Dambly, 015Bl8 "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy OFFICE RIII I
NRR I
OGC I
DEDR NAME BB EACH*
SCOLLINS*
WCHANDLER*
HTHOMPSON DATE 05/15/97 05/20/97 05/22/97 05/ /97 OFFIC1AL RECORD COPY J. Callan, 017G21 B. Beach,.RII I M. Gamberoni M. Dapas, RIII OGC, 015Bl8 P. Castleman, 012E4 P. Prescott, T4D28 J. Hull, 015Bl8
- SEE PREVIOUS CONCURRENCE I
EDO I
JCALLAN 05/ /97
J. O'Connor
\\
- as early as possible.
The staff will also assess whether your acti ns in response to plant events or issues at one facility are impacting perfo mance at oth~r ComEd sites.
Your ability to manage improvement initia ives at one station, without negatively impacting safety performance at another station, is critical to arresting the cyclic performance.
To enhance the staff's understanding of the details of your initiatives, a meeting. has been scheduled in Region III at 1:00 p.m. on June 3, 1997, to discuss your performance indicator program and other selected topics, as outlined in S~tion 3.2 of the staff's assessment.
In addition, the staff will schedule p~r~odic management meetings between the NRC and ComEd senior management, as w~l as periodic Commission meetings, to discuss (1) safety performance at all\\ComEd plants, and (2) the effectiveness of ComEd's corporate and site~specific corrective actions.
- ~
Sincerely, Docket Nos. STN 50-454, STN 50-4 5, STN 50-456, STN 50-457, 50-237, 50-249, 50-373, 50-374, 50-254, 50-265, 50-295, 50-304
Enclosure:
Assessment cc w/encl:
See next page L. Joseph Callan Executive Director for Operations Distribution:
Docket File, T5C3 H. Thompson, 017G21 R. Zimmerman, 012Gl8 G. Dick R. Lanksbury, RIII B. McCabe, 017G21 J. Caldwell, Rill J. Grobe, RIII PUBLIC S. Collins, 012Gl8 J. Roe, JWR C. Moore W. Kropp, RII I R. Barretti T4A43 P. Pel ke, RII I R. Gardner, RIII DOCUMENT NAME:
ALPLANTS\\RESPONSE.LTR To receive a copy of this document, indicate in the box:
"C" = Copy without enclosures "E" = Copy w.*
enc sures "N" = No copy OFFICE RIII DEDR NAME BB EACH "'ee.- 8 -" ~a.:i HTHOMPSON DATE 05/ /97 OFFICIAL RECORD COPY EDO JCALLAN 05/ /97