ML17309A487
| ML17309A487 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/14/1992 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9205200210 | |
| Download: ML17309A487 (62) | |
Text
LmiBP I'Ii~TdwF fl1&XiB (3 lÃjjj ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER N.Y. 14649.0001 ROBERT C MECREDY May 1992 TELEPHONE Vice P(evident AREA CODE 71B 546 2700 c'"" gp,'y~mas T Martin ~
Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
Subject:
Response to SALP Report 50-244/90-99 dated April 1, 1992 R.E. Ginna Nuclear Power Plant Docket Number 50-244
Dear Mr. Martin,
This document provides our response to the April 1, 1992 SALP Report No. 50-244/90-99, transmitting the initial results of the R.E. Ginna Nuclear Power Plant SALP Board meeting.
We appreciate that the NRC has acknowledged the significant effort RG&E has dedicated to maintaining Ginna Station as a safe, reliable, and economic source of power for our community. The SALP Board's recognition of superior performance in Maintenance/Sur-veillance, Emergency Preparedness, and. Security is gratifying. The recognition of strengths=in other categories, as well as sugges-tions for improvements, are appreciated. In general, we concur with this report.
RG&E acknowledges the constructive comments provided in the SALP Report regarding the Emergency Preparedness Program. We note that overall, NRC's assessment of our program has been very positive, and the Commission has noted our management's support and partici-pation. We believe that our performance in this category is not reflective of a "declining" trend, based on the definition "licensee performance was determined. to be declining during the assessment period and the licensee had not taken meaningful steps to address this pattern." As stated. in the SALP report, and as discussed in greater detail in the attachment,. improvements were noted throughout the assessment period regarding exercise scenarios and timeliness of Protective Action Recommendations. Also, regarding our capability to perform dose assessments promptly by on-shift personnel, the SALP report noted that "the licensee took timely action to implement an appropriate interim procedure and additional training." We will continue to devote management attention and resources to achieve superior performance Emergency Preparedness as well as the other evaluated, areas.
i~
/
Very truly yours, C. Me c'obert redy Q GJW/229
Attachment - RG&E comments relative individual 4/1/92 SALP Categories A. PLANT OPERATIONS We acknowledge your assessment of our 'performance in plant operations, including the demonstration of our strong commitment to safety and high quality operations. This will continue, fostered by active management involvement in plant activities and response to operational events.
Our strengthened focus on procedural adherence and independent verification of system alignments continues to be a top priority, as does our vigorous maintenance of excellent plant housekeeping.
Our fostered team approach and cooperation between all Nuclear Production departments will result in a synergy where "Together Everyone Achieves More."
We recognize your assessment of our operator response to off normal conditions which demonstrates their knowledge of integrated plant operations in fulfillingour. responsibility
-to protect the health and -safety of the public. You have recognized our operators'nowledge, competence, and professionalism in the operation of our facility. We will continue to pursue excellence in these stated strengths.
Your insight is valuable in our assessment and oversight for continuous improvement. Comprehensive actions are being planned or have already been implemented to address weaknesses included in this SALP Report. Our actions to resolve procedure inadequacies and deficiencies in assessing the impact of maintenance tasks on plant operations are focusing on increased formality and attention to detail in the control of plant activities. Examples of initiatives contained within each focus category are as follows:
In the area of formality, we recently instituted a new procedure providing instructions for screening infrequent or complex events to ensure that these events are controlled and properly planned. Also, we have recently instituted a, revised daily morning priority action meeting agenda to be directed by a'hift Supervisor to ensure appropriate attention is focused on priorities sensitive to our operational excellence.
In the area of attention to detail, all operating shifts have recently completed Control Room Teamwork Development Training aimed at improving crew performance. Also, the position of a dedicated Shirt Supervisor, whose responsibilities are to provide day to day pre-planning, prioritization and review of maintenance work packages,'as been established.
Management attention and involvement will continue to be readily evident. We will continue to place our emphasis on increased formality and attention to detail which will result in a p'ride in ownership and superior performance of operational activities.
In the next period, we will maintain our aggressive posture and commitment to maintain the highest standards and achieve the highest category rating.
RADIOLOGICAL 'CONTROLS RG&E has focused considerable attention toward improving the organization and performance of our Radiological Controls program. As noted in the SALP Report, several measures were taken to address previously identified areas for improvement.
These include: a well-defined Radiological Protection (RP) organization and an augmented technician and professional RP staff. We have designated Lead Technicians and a Quality Improvement Specialist. We have made significant improvement in the Radiological Environmental Monitoring Program area by appointing a degreed and experienced environmental technician to the laboratory. During the recent SALP period, a professional Health Physicist with extensive RP and plant systems experience also joined our staff.
Considerable emphasis has been placed upon supervisory oversight, with an overall objective to improve procedure compliance, the quality of radiological surveillances, communications, and improved radiological work practices in the plant.
We are also pursuing issues where opportunities for improvement exist:
Review of Procedure Chan es We are continuing to direct careful attention to proper, detailed review of all procedure revisions to assure proper technical content.
- 2. Resolution of Technical Issues RG&E will assure that timely attention continues to be given to the resolution of technical issues in the RP area. We believe we have made significant progress in self-identifying and resolving technical issues, and attribute much of our progress to the improved RP staff organization and staffing depth.
- 3. ualit Assurance Technical Reviews We have recognized the need for more in-depth reviews of RP program areas. For this reason, in 1991 we engaged a highly qualified consulting firm to assist our Quality .
Assurance audit'team in performing a detailed review of our Radiological Environmental Monitoring Program. The review did include an in-depth technical audit of laboratory procedures, practices and Quality Control. We will continue to monitor this program area to assure continued improvement.
We are nearing completion of an extensive appendix to our Ginna Quality Assurance Manual which more clearly delineates requirements for RP and chemistry program controls, in a manner that is consistent with the overall Station QA Program.
4, REMP Trainin Significant improvements were made in the Radiological Environmental Monitoring Program. To correct a previous weakness, we appointed an experienced laboratory technician who holds a Bachelor of Science degree and was trained in the Nuclear Navy's Engineering Laboratory Technician Program. The technician has had extensive onsite qualification instruction and attended. an intensive industry course on Effluent and Environmental monitoring in 1991. This has resulted in several technical, Quality Control and housekeeping improvements in the environmental laboratory. The laboratory program has also been strengthened through equipment upgrades and additional technical controls. Our laboratory personnel have sought out improved, state-of-the-art laboratory practices through site visits to other laboratories.
'tility We will closely monitor our efforts in Radiological Controls to assure that the improvements initiated are effective in providing the high quality performance we desire.
C .. MAINTENANCE/SURVEILLANCE Rochester Gas and Electric concurs with the NRC assessment of the Maintenance/Surveillance functional area. We appreciate the NRC recognition of our strengths and achievements in this area.
Our current, level of performance in the Maintenance/
Surveillance area has been achieved through our proactive efforts in performing self-assessments which have resulted in an effective work control system utilizing engineered maintenance procedures to implement a Preventive and Predictive Maintenance Program via the Reliability Centered Maintenance (RCM) Project.
Corporate and. Site-Management attention and involvement will,"
continue to be readily evident while we continue an aggressive posture toward maintaining the high standards that result in continued superior performance in the Maintenance/Surveillance activities. t.
D. EMERGENCY PREPAREDNESS RG&E appreciates the constructive comments provided in the SALP Report regarding the Emergency Preparedness Program.
that overall, NRC's assessment of our program has been We'ote very positive, and the Commission has "pointed to our management's support and participation. We believe this support has resulted in a very strong and effective emergency organization. We have a philosophy to continue building upon our strengths, and to pursue opportunities for program improvements whenever possible.
We appreciate the fact that the NRC has recognized strengths, such as; the proficient performance we have maintained consistently during annual,'ederally-evaluated emergency exercises; and our development of varied, and challenging drill scenarios, and use of the Ginna Training Simulator drills and exercises. NRC has also noted, in particular,during the excellent working relationship we have with Wayne County, Monroe County and New York State. All parties have worked diligently in highly-valued, close cooperation to assure emergency readiness at all times. This cooperation has extended to other community support organizations through training we have provided to local ambulance and fire companies-, hospitals, and other agency personnel.
To assure that our Emergency Preparedness Program maintains its superior performance, we have taken great care to assure improvement in certain areas.
On-Shift Dose Assessment We concur with the need. for proper and timely dose assessment during potential fast-breaking events. RGGE has .previously demonstrated that appropriate dose, assessment capability and expertise exists within our emergency response organization, RG&E understands the increased emphasis on improved on-shift accident assessment capability for fast-breaking event's',
particularly for. purposes of proper emergency classification. When this issue was first raised during this past December, several corrective measures included:
were immediately taken by RGEE. Those actions Revised Control Room Dose Assessment procedures which allow improved, rapid calculation of offsite dose rates under emergency release conditions.
Prompt retraining of all on-shift Radiation Protection technicians on the revised assessment procedures.
Other procedure and training improvements, including for example, a pilot program to allow radiation protection technicians to practice dose assessment skills 'uring simulator training sessions with other Control Room teams.
Nuclear Emer enc Res onse Plan (NERP)
RGGE took steps to incorporate several of NRC's suggested clarifications to the Plan, as soon as those suggestions were raised. All remaining suggested Plan improvements will be addressed during our 1992 annual plan review and revisions.
Im roved Documentation and Administrative Su ort We have concentrated our efforts to assure consistency and formality of program documentation for all drills, exercises, scenario development, facility and equipment testing, and commitment tracking. Several orprocedure ar'e and nearing program improvements have been completed full implementation. We have also taken steps to transfer several administrative tasks from the EP staff to a supervised clerical staff member.'
t Emer enc Res onse Or anization Staffin and Trainin We believe that sufficient personnel are qualified to support protracted operations during emergencies.
However, steps are underway to recruit additional
Emergency Response personnel for certain critical positions. In addition, our staffing objective continues to be a minimum of 3 persons qualified for each position in our Emergency Response Organization.
We have also simplified the administration of our annual requalification program. In addition to formal classroom training, we believe it necessary to conduct periodic "hands-on" training as well. Our practice has been to provide emergency response training in a variety of ways such as facility walk-throughs, tabletops, drills and other practice sessions.. We have also conducted these activities at various times throughout the calendar year and will continue that practice.
In conclusion, we believe that we have a superior Emergency Preparedness Program, and that we have qui."ckly and'effectively taken meaningful steps to address any noted weaknesses.
SECURITY We appreciate the NRC's acknowledgement of the significant improvements made to our Security System, particularly the ongoing upgrades and enhancements to our physical security hardware. We intend to continue our commitments to the installation of the balance of our security upgrades.
We agree that our training and qualification program was well-developed, and that our experience with use of the program is effectively used to make enhanced changes to the lesson plans.
Management attention will continue to be devoted to the ongoing improvement and maintenance of all aspects of the Security System, to ensure continued superior performance.
ENGINEERING/TECHNICAL SUPPORT We appreciate the comments provided. in the SALP report which recognizes the accomplishments of our people and the strengths of our organizational processes to provide sound, technical support for Ginna. We continue to seek improvement in our processes to strengthen safety and efficiency of the station.
We continue to have pride in our capability to plan and implement modifications. This performance results from a root cause approach to solving problems and from frequent and close interaction with the station. Our Ginna Outage Planning Committee meets year round to prepare for outages and to plan activities. Each modification has a Modification Follow Group which consists of people from all affected areas including HP, QC, Training, Operations, Maintenance, Results and Tests and other appropriate groups assigned to provide input and review functions for each change to the station.
Our support of daily activities has continued to improve throughout this evaluation period as demonstrated. by responses
-to undervoltage system problems, a secondary side pipe hanger issue, and signal interferences on the .digital feedwater control system. Communication of potential safety issues has been improved and formalized. with the Potential Condition Adverse to Quality (PCAQ) procedure. Nuclear Engineering Services presence on site has be'en encouraged. with rotating assignments for attendance at the morning meeting, the use of duty engineers for periods of peak activity and by locating personnel on site full-time for specific activities. 'e track the number of engineering days on site each month as a also mechanism to remind people that site contact is important.
Support for licensing activities remains strong. We try to be responsive:and"to provide open communication of our issues and.
activities. We strive to "provide strong technical
-justification for our positions, but also to remain flexible in our response. Contact with the NRR project manager is frequent.
We are very pleased that your assessment noted that "technical competence of engineering personnel....continues to be a strength". Technical skills and analytical capabilities remain the backbone of any technical organization. We are doing less work through outside organizations and more work internally with direct control. We are moving ahead, with design standards and with standard designs as evidenced by standard designs for tube supports.
We also recognize that there are areas for improvement, such as support for the Service Water System, which will receive additional attention. Resources have been applied over the years to assure operability of the system, including recently completing a rewind and refurbishment of all four pump motors.
We have also been planning for a major inspection and overhaul of the system in 1993 to assure long term operability into the next decade.
We will provide the same strong support for Service Water concerns that was demonstrated in work provided for electrical distribution systems and motor operated valves.
We believe good communication exists between the engineering staff and stationpersonnel with an understanding and respect for the roles each play. Good planning and execution has existed. for modifications and programs while still maintaining strong support for daily activities and emerging issues,
G. SAFETY ASSESSMENT/ UALITY VERIFICATION We appreciate the recognition of the SALP Board regarding our strengths in licensing matters, resolution of generic issues, preparation of safety evaluations, use of NSARB, and particularly, our ability to be constructively self-critical.
Only by being able to self-identify areas that 'can be improved, and then taking the necessary actions, can we achieve superior performance.
We agree that our corrective action mechanisms have been improved, including significant changes to our procedure review process. The designation of an additional shift supervisor using his training, experience, and leadership
,qualities to be responsible for operational safety reviews of maintenance work packages, is expected to be-a major benefit.
We are also looking at other utilities'ractices to determine ways of improving our process of safety reviews even further.
As noted in Section B, Radiological Controls, improvements in the REMP QA/QC program were self-initiated following a June 1991 audit. We will continue to re-examine our 'performance in these areas to determine ways we can improve.
Finally, we are pleased to have been recognized as having made operational decisions on the basis of safety implications. We have stressed to our personnel that placing our- emphasis on safety in the short term serves us well in the long term, 'by ensuring safe, continued performance.
ENCLOSURE 5 SALP PRESENTATION SLIDES
4 4N'X,,
~ ". >>'.:.:: >>:
irma s...,,!',,< 5 - ...,,<...,;-.<;',.i ,-,, 5>f>..., ... Ii< 4?is>'<..,.,ply><.
-'3~ .'3: -: ":"",> > ->-;;> >qp>gNmssp;-.6 ~<"; .3 g~ g ~
"..': 5> +el'$>3>" >ss:"'S'p'5'~s~;"> '~>>~ 3 P'p<'5
,>>.....:.5?5>,~ .I...?3.;..>,4s,,<s<<s, sk >..,j.(~jj<<SS N>~$4>N Sss ">3~3>>$
?55'~a>v. &q
!I,'4>>yI'>>>r>>k~i~!!!!~
~
+ +
- 5%:::?>? >."
~ l& "l??'3'~"
'm~, ,,(AI?53?N>s), 8 (@ +P33<<~
3'"'"
< q<335 P ygA+>'<QgXg>g Ir, 3:. (3355?a>M~
Ihr 5<35
+~ "" -"~33'."'5 "" ..i,r?3 >is i,i',I
,$P+g, ~ >>>>. P+SN
' ..., >3?? 5?. < . I33N>~k>>SS.SA.S
>35>>g>Is,
?)> :? 8$
> "'53'~"">>5>"i?" m 5341 s@: ..
>>>g>'~>s3 s3'333',?
3 5313< I?
@i.d~d>>e.>ps ;,
- -'3>>!I>>>?'i?3'551>)
? .<<:,::..:I::;::I-?:5:
s 5 3
,.n.al.. Area D Iscussien 53,.>s
- >",'('->>5 33m 53 3 33PN
- .::!?((I 33?p,>I/I $ 3 5<I<N>s><>.~s
>XKPggmg
~.:).,'a4434 3)F,.':;..~
."4'M'Fg ";.>. a!:rsiIII, r ?3 'I>>>c>355>?r??.3i 5>
- 4!~.
5 5
!>rr>s!i> <<<>:.
3 rS?r
~!
3
""" (33,.<g,.s, 3>>>'i:?>>j:;::35 5
7 333/?I)'
%...,%,,,3!!C!'>s>hhw~>x~~i 5~%PW~m3"'3 3 . e C>ss r<3 g < Ss~<<(9 .~r... r..> r 5 :..'i'.?35~33.',P>
>>:::><<::>?5
'g < Pg'<~'qg.;,I',,'.; @,',',>~I......',,>,~j;:s. '; 5>::::;:, .x
+pe! XQ+xNxy<'?3!i>)<, "'>>:.
, $X~>
+$+I<:;jR '3jjk~ '45'~'<3'jN>3? &3~53>'I-: >A>S"
""'+~i~'w'" ~~~i,,?,,h
)P:3: '.553'F'>a'v!!pi )'~>?<','~:,>jii'.>33?;33:,i'~'l?>??iii!?:":i iiiiii?
ih!3>,;i!':"!3:
'v RIPE
>>:.a):5>4:.'.">ha>>5 '>>>:.5>>+l~'WN>CM;55555;.'55>>',. >, 4r'5>5','< Ia @~)>d< ( n,.,n:N>>
~V('>'5>>>;.k>>..',;'?9>>>>5
.<<>>-<5>>a >>5'~A I ,g$ >gQ P (@(p>N<>5)I'><+ 5I,L555$ $ >
'~na",pe>;,h gI>>,">>A>>j .'ll;>>>.:'..:.:'>i ,'.':. ':"55!;>j!K>h>M>N5;-';"%5>>; 5 5'5,:<5 ~a 5>)><5> >'<5>' >5
)
- ,, S><>.3<. Ia>..I<>>(~5 )I 55>i ', 5>>.5>I>55 5 5L5 5'5
.A>I(3 I55p Y>.....
N:.">>'a',i
>>>)~,44)h> g .5>>>>>> >n >5,>5+55 5555.55>>a, a'>>>>>>>x...,>aa,.g,> .(>>
I>5." >";i>j.:.:a ',:,'>...':('III;:,'5I(
1;gXggm> g < n .p<>55j< p@Q 8>>)>> 6<(NP/ ++5<>> A>. 5<< "'>-> .<>>5 5>Y'>>n >)F~ i:5!N>>.'p>I',!
P'>
5 Nh" g>
5 > >5 S3$ >>":
>>>>) p5:',';+I
>?g
r RLP
'.-:A whack St
,'.;,:',:,:::,::,:,:',-:;...,,Sero,ng, op erator iresponse:;:,to;,::;:,
pg<> g>g ), $ ~&<k
'i:::::::;:='-:::::-:,-:::-::.'-;:::':!::':I!A"i~i essiv'e, ma
>>" >>E proc>edures ali"""""'""""""""-"""""
tio f system
>,,,Gopd(~housekeepjng
4
~ - " ~
i.. sys, 'hs)h>>~ pip,N'><y<~ss s+c4g~smQ>> ~':ih>>:Q%khh" ~443) gX;+
Areas for- Ci atte>>nfl,.o.n-.,".; ;,~~~ hh,
- ,,:;,:.,',:;-';::::::,'::y; Atteintion o detail in revising::;.proce'dores~'"":l';-""....~
"%~i:ih,'"i op e rational impact'::;of,::,","alii'i4<j';I,',,;;~
t activitie >>i>>i?s.,>> )>)>:,.)?<.s..;?s>)s)) )<gs)y'ys:s&s y>>i<A>(IS <y'g:.~~'?sss.s 8's ysi~<N?;
- -- -i--<>;,>> )>hs?'. >i is 8>>s>>>!ss:!:?> s>>si'sk4> sbs<ssss;..se i4<S'" s
.>'s.'(>>."i)>>"..><<.<>>>><>><: i":"sl<sg~&i"()'spj' sag(c '?
y, s...,'s. 3...(
3)..
?;:;d?). sNis;,:i>sip
':: " 3
>?i>>s
- AI i')::wji':M~Ywgx,!"
SK8'ihX<%R4 i?s)>) iI>>-,?)
)i, < ) sl: 4IiImN)?,")?)i?
Q~,g<,.)y,, ?3krs>>(wii(( (<sk<m? .>sf(c~.A, ).;,? s hy) < ) ~,),y,)? y>>
)huh'<+4A~",shh:)hh.
'%s Lh..@X gYx@;.
4'
f '
'W
'hg',gN(4;;g qiiii'."ii>
~'~AjXixi~i'@xkM a ~
X~y588
- (g
@,:84pi
,!..., .....,~ .~,ji(ma~c,...,,N,,g,.)p):,
',,:-'l',)3."',."."p~j?:;::.".'sk>"~R$';4+"'""), '
~ i)+ )(
ss(~
(. 5::.'~~kx~Q>qXhp~!~g4N.
%~ >~ ~'Xh',hXQp'gx+i (S. Qd4(r'~~$pg q c~
t pi!55NVA@4gkg A
."S.;,,j:,"", 3,;:.: ., .",.'?.".,"'; ',:;:;jA.';3" .;,","-':i:i.":. "$
N) i!i:-.Q>i@(;(p~'jji"'.g; 3 Fp(
I (Njg
~M ::Sg~
<" ~i'XM""
~!9' ib
.R xx . X....m>> >5..,F.x.A>x>> x.<>x .. x .,>>xpgY~).
q,..tip xQN>,'4; xL Stre x x x
x X
W Xxg>+i",
"4Q>
':::::::,";::::;:.'.;:;::,".-I,.ALARA ;Progra m.:-was'v.ei. y...,effective...,.ig...gyp<,<@,,,,...,.
~
. ";; > > 3) %x<>) i z <>>"
',:!:;,:::;-:::::,:::.',""'"::.",;:,:-:',.'.::,:'",,con'ti oiling
.....i,...,...,,, contamination ~s R+
~<
-.lent&.:=";..-:!::=-:"i~":8:
'!(;:,:!~-;.::~~:,~;,:,:;.>-"Strong:,fYlax na :xg:em ent support ,:.0'..:::,-.:::,::
llil
'x:."."::P>,.'. -'! xI>'::-". ii'l":!:"x!s-'4P>II"-";"<
>x
'y>3)'::Co g'5")I>'4.'ss'W well ti ai'r'ie"8""""- >q 2>>>
I '>)'NN'(g
..>)3I;.>P>,x>>x.i>.->,'x x>$ x, I>x'.III(3
- C':
d
ain
4 h,(>333 g
,A>>h, jxili,>
x,<,b,g?hkh , (
INN!'3 AAb%<<iI ~ )ms 5< g:4N3"-'->>
Detail o as-found and as-.l eft;,,do,cumen4taeiop,,...,., A':':""'':',:-::.::"':::::.II':,
~y>44~+8'<':
strengthened- w~i<X
~ ~
>> >>. ),35g,sS3 5>r.... 5 > .5>>...3,,y, >>,.),,>5, .
jI "k'"":"Ij](i"f $3'Ais?'jfj"'>
'$)53Y<4@"M'Icy'< '">j;(y(i'":ll3i'3m>33>>i'?;"."-':5>r>i."i '.i:ii
>.:.I>rkk. >)Y,,!if,!
- .:.:,:!:.,'>:;(A53:',.Pu!,'j3 53!N 3:;.i':ah(wi;"gj::...:Sysr~s~;.-,::P+skh(3 N,5$ >..>. A>>>>>>IS.,>(3>>
rr k8 Sm><F<<3
~@55 sg(g is.:h" : >>>.".SN 5>5':;
.,~wI>>,,)km
- .'5 '; 5<~:,I;5@<3 <333>3> 3$
>33: ".'SSP(3$ (
'yyy533g 53><553><yy>3>53!sk>>>N>3
>$ <,.>3>>ss>3
'3 >3>>>>>>3<y>5
)
- ?5 R>>h<'@~~(m'(4@31(3 5>35 r'y>'r >: Sg,59"j@<ps",Ipy.'>y'j..., . 53. I,,..... ().,>>> ....., ...,,,,.....
M + @<~<553>@<< 5<3II353I<>~,,<;>5 >jap...sg .,13>>>;,, 5 yy>>,a>>...,. >,:3<>> (>>>>?3>>>>,3,3>>>>z .. >ps?ss?>y'j3!Ig>y;3
>>>>>> <>>:::::: >>:?:? >:?? 5555
>>SK .'$
>,,SNIP'3>."5>>.';$ 3>5 HEIDI;; NI'>
m?mm;:NI;; :::.rs ~l?p
('ys'5'(':
L '3 px;>; %
- .:.??:Hsi::,;
P4~ ~>>
<<>>3<
53y>
~g >g h@c';i"3<>>% HiP x,>:::,>3~
- h,,~5<!>hj
- ,3!(jw< "'g Sjy3)p5>3<>3 4.;:.>5 'wg,"3355~y.'>;5:N..rpr 3-:Py....>>....,.;.,...<r..3>, .I >'.::"::.:.?:;?;;.;.:::"::::::>>
X44WgX'k X+ Ng<. ~+ > 5 hA
ii4Y 'hx 'i 1)hg)NB g4g !l~>xK
Nag hi<>N
- 5;::IPr>:::::::::;::::::::.,;,:";,::..'.::-'::.: ':??-'." >>:,'5?>>,'.".';:,>'?
y>>
'5."..'>'.P:5'?'"'Q>'
>>> ~'.55 >>
~ r>>N'"@~A,~~,'>4'5,.j
- .::>>5>>>><>>>>>>>>>>>>:::::>>>>>>5::::>>>>>>:::!:::,.:,>>:::><i::? .;.,-,:;,5:,,::,-,,5 >:,-,::: ",,:;,,45)~~;,,>,,A A
?>>>>
4 "5'>>.;.>?'y~~ ~p;.;4p;~ r5? ~>N<4(<P( ,r.
<5
>' < N>5?<>'~~j;,qjLQX >,,
<",<:f<)K,,<pg<,:, 4 ~.
'.",'k~.:;:,<'l.",!>y.:>9-"'iy;;F55:,yi55%5X5" NN!>>555,,".'>',m 155((' >5('5
<>~>$ N I5$
'4~5plg'I
)I
>h
~>~~<>>QX~:Q;~
'pqiigiP>>>::
>~ah,,
QKAAi4%
g g"'M'8j
.5 ............. ~ . . . >> .. y ........................ ...................... ..................................,............... .>>> .. >...5.>.<.
)>>l>- >>>>y>5)555hly>N>>>) >>5>)55iN5 554) lj)(4?,,I<bjjjq<<j>!)II',".
~>>)~m,(s5
'5iPg',Sp,'" 5
.,>>h?y<).(.,),,>I,
>>>>>>> 5>>>>>
N;g'%,
~
I'::;>,% '" q%;,r,~.'>'
- y>i
~N:,:?< >l>A>
- ,';.>g;< .,:;, 5, "5..>>.,5),p>>...,>>. <
.'5>'>5."'; .'>)S? >: (>
< 5.. >l @g>>c>I'-
.5P+$ (hi~'<',IPq >'5';<gcgy5)?>,,~p:;)g;;.,3Nk5'5gy,,::?.'5>:J>>:> r?r..pi'>?I5 m."y.
- .:..::.5>>>I:
>>>>i>><>>>>>>>>
>55/>g<>>.>>5> > . (, 5> y ~ ry... '>>>>>>: >:>>>>>" >>>>>.5'>>'5>>>5)5>>y>>> <>?>><> r.
>>>>>.?3?:I>>>>>?> 'r)kP y?~IN>v';.PP(>5551 Mph' j "'%Vygj)3(ijNr?'P)kp:;-'5!i;"5'ji::r'-"i5>>? '.~ '? ">> l'>ll'i>>>y? '.?">;>>>>>>>>>>>>>>>>>>>:?
.:i'.i::-,",:iii:.'.i:>S>Ii)ag:,'>
II)~?II)gjk?:I!>55?>I; y, >>>>;5I: >>'>?
?a>?2i."?('.:>?g<<<>)
4k;.. -. '><~~a. >;<; N-A>~>? ..55..-">>>,:, >55>>>>>,>i, ....>>>>.;:?y?<':..'.".':?.>>:.::-::.:.::..::.:i.-".::..:.::.?:
C Are
- ,,:;:;:::.:::;:,'a:;:::::.:;:,::::,:-::,::,:-:,b::::::,::::::.4:::::::::::::,.b,::::::::::.,:-::4 %<4
- ,"
- :.,":,':::!;:::':"::',:,,',':I':,",::',,,;:,;::::,Pro-c'e'd>> ure/t raining,,l imitatiops,for,,,dos,. e@q,y,l,g pPp
<i<t(~'alu
~c8,@gal gS X<ogg+
>~~( >gg+
$ N~<<(pS;
) "i<(+)>> ($
'<0
) >
)s g&)
34)
':;,:;.-.-:;:,:.:;:;!l,:';;==,---',::::::;:;;:::;:::administrat(ve workloacl jpi":":NN f<~.'<))<<>.g:,>>. Q<,
>V/ "gg3 j6C)8d~~>
M $ (5N wk;,(N
'$'Sg
>,)
,,f,, !iii),g
,<<,;,.,,.>,,~.,;:,,;I,,;,,:¹mbers,,of in Isq ualified! foi r.i,S@
, F)...,)s .,
S'>>
<C"::::::;::
>&4.'<:i
<px44"Q<xxP.'...,()gk :::i<,<":ti<<!:[!</I<
- k;;,h a
- ,!%X<<!~k!:;
>>>><< '<<>>>>:i<>> '.
0<4+%%
I
)hag>h'>>.xx (
ngirie eringlTechnIcaI.,Sup;,p...
Stre "mls Xh x(ih jR:>h'
%~>>+A, f,)I,.);., I>?
++,
m;i.>>,.>>>> i inte rated su .. PP...,,...,,P...-
ort'to',:'"""':Ia'n't'"::.'.:":,'o'=",'.'.e'rations',I, jh
- 'k::::::::-'::::.::.':,':::::::::,.a~Na mafnt>e nance
('j .
'I I'I'%',,",Mpdifica!tjon>s,: 'DFCS , zebra, m,uss,el! :,,O'QQgroe fs"vq(;,
......................................>..?,?,I > <,i>?
,'i'>!?Il!'!"!!,4~?Ip~k>>>'. >j!II>I'i!>1>f?,>jt
'Y????&NFN!;-,!N g!N>)
Ipm>maim>>>m N
insulati on re
'?
lac'emen"""""'"""""'""-""""""'i
.??->?.'?????. .:? . ',:?'.?,':?,:.'.: '.?:??:???::.
'>""""""""""""" "i" """""">>'n corrosIon,prog!ram!,,:;.~
gm:. q~
I?5NI
<>>m~h~
c
'Xx ~
...yK>~~4:):,;@5>
E ngin'eer>>jng /Tech,nl,cal(,.Suy,. ) (>> )(g?>> ) Lj $ $8 > >
3~ >>@g(p >)
ypqP O
'.p.
>>))>>>>>>>>>>>>>
)>>>P>>'? )".;::;;; Are as for attentjon,,>,,,,,,,,,,...,, X ..~xPh
+%%'M+XX?
'"-'":;:-"':::,":::"::.'::I...
Weik e n ) (@Web,...
-.---- --------- >)'>?-)?">'>>>> )?;? <)>;?I)>< ><'I 4..gg ~?
I sap@> , <+>pa%
, 4?,<IP,,
ystem defic Q n ) C>>)
i QS ,,; .,
< '? >P ?>j>>>'pY(N@ws
<.:(.>I?<?> I ...r+..<A
~y:.~Mph)g'?>"'
5<?>5>
AI'Q ~
I, ?',> IN, ,,, 34h",
> 'mgips<
?F>
- ..:::-.::8g:,!?: >...) <?>?....;?>."??>>pg)<PI~....'<?h<.k;;:
?>>)gk:~(I, gp)3</?g
>>)>>>>>>>>>'I>>."? I>?>i':i!:>>i:< 'I?>?i>'pHN(r(p>>>: P P>i@6 ii?:'>>:i!>)I:>.'>g<??:?aN:g> )?>.;::,~,':;..'?>N I;SNS>>F>'N>>:
,,??Ki.,H>m>>><>h(, ?<>?P>>?<>(&m,,wg,~s.;b...,,:>Kr~,?,,!,>>>>>>)...<..?)!;?.):>>?).y~>>..?'
- .:.i:.'33ji!>>)>I
- -::.i
)II!I(?
, ,>>>,,),4 RiYAFK)
- <<>><<gX 0@< NgX
))~~+~>g)gg(>>$ gp(< >@(> PgF>... I. > <<.> .$ >>>...... ) >
)>.. ). >. ?>>>?> > .,3.
>>) >))>>>>>>>>>>>>))>>33$ '?;-
~g~~e><:>>4!4m ;:::;:;;';:;;;;:"";3>>>.
?: I?:.?:.?:-::)? ?:.:.:..::-. i:?3>>
>>')))")>)>>>:))>>")>>"?")">)>"? '-
w,,?,, >:>>>>)>>))>>)" >>>>><<))">>":"">>>> ':":" ~
,:i)j~hg~~~i
- ghik kx>FS
<,.?
ae g'gggNR3)N~'.yx g
- ~S>> 5'"
.... -.5....5, ..55 .....,) .) . <<),,
eI r ica:I -:
~
. )) 5.>>..'...'..,'.........>>.....................,................ i+~
,+hh,h,, g4Xg3 ua l d.
);;;;)'55>)53555:,5 5;, SN35:5,">"...i 3: 55 << > ", 5'5",3 <
@:,;,.:).'.@>5,;,~N:;,3,;@YPg<:@ g!yI,II(y5 i'r,';:."';".;iI!L)!f;P~)"!3<<53k)3<<')'j tN)lj)N$
gp)(M 3 <<
5>>5)I%s)":<< 55 85 q'(j
>53355 3.',:.'v",
'3<<-3I'3m.""- )5> (
353>5I I5..3 '%'>.33:))))." ><<> ?'.33 "3.;55 ::R)s!
...., ,. .),3.3)> . 3> 3'.'.) 5 3,....) >, 3P,53 5>>,,5..
>3>..>>)<<) .
3.) 335
,. >33,,533 3>5>33).. ><<.'.3))533
":),'AD>3!))ii'.
55N 3,,355NMc, kP<<Y~ ~4 <<, .
) <<><<3,54()b(3).)a <<5~, 3;g~I3 g>55;
.3)>55.",,;.:
,,.,,,,p~I~Np,., ... 5,,~. :HP)3 ,')5)3,
- PM;~, XXX~'+4'"~
g,g,xj;h','3Pwxghxg'<< "g'e 35+ 55 ~ 55)5 x..
R%
+~3(
3,k hh>h,:
.AJgp,@if, >f, >i(, 3!~N~p,4!;! h
,"."": '.::-';i:;:,:;::,I.,..;Strong<<> m ana gement piarticipa>ii.o>n,,in
'"t"""n""'o""" 3, ( 0 "~ ~A>,;
fo o
>3
,,, progra>ms,t c u s rga ni i)~i p>>>> )l, st a>ffhe<<>.CI., We
,. t>ailed audit~"",-;:::::"
!<$g(,:)'!~Safety.-'goalsIIc :.OAl'01 l '-p I 8 Alu'lgat8dIl>'='-'~ y;-'i!,-.=.:3~
Li?$'WP~N 3,jhow'gP,)<j~;3'>> 'gN,"N<<(:3g <<?>gj37~'S; F$ ,$ .,>"g+:",::?>,)>53 3.':,:,3,;>:,'g(>3>-,">:::,
7
- ,:::::.?.>>,,:..,,:...,...,..>>,..,.?>?> ..,.?.,7.I;>? a...,,
chnicall Y.sound,,
N biil~ii'h
't>e ':I!
>,I;3 3
>31333!3
>..(gj,?3(7,
'":I"hi 33<<>>>3?
),
d(33
>:: >335>>'5 >5,",>
4;t4'orou,h::::,and,::,well- >: j: >>433 (g;3>3?c >33>)>::,
rovided
- 33533(3>373:(ii?
".::.>33.>>:3:>>::
- .i?.'3(I'3-'-;
Cy
4
~r