ML20033E285

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Responds to Generic Ltr 90-01 Re Request for Voluntary Participation in NRC Regulatory Impact Survey.Completed Questionnaire Includes Info on NRC Insps,Required QA Audits, Nelia & Maelu Insps,State of Mi Insps & FEMA Insps
ML20033E285
Person / Time
Site: Palisades, Big Rock Point, 05000000
Issue date: 03/01/1990
From: Berry K
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-90-01, GL-90-1, NUDOCS 9003120123
Download: ML20033E285 (28)


Text

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Consumers l

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in w s.,,y Director M ERSH Nuclear Ucensing n1ENNiAN'S PROGRESS General Offices: 1946 West Pernell Road, Jackson. MI 49201 e (517) 788-1636 i

March 1, 1990 Nuclear Regulatory Commission Document Control Desk

- l Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

RESPONSE TO GENERIC LETTER 90 REQUEST FOR VOLUNTARY PARTICIPATION IN NRC REGULATORY IMPACT StlRVEY Nuclear Regulatory Commission Generic Letter 90-01, Request For Voluntary Participation in NRC Regulatory Impact Survey, requested Consumers Power Company, to complete questionnaires which would provide the NRC with insight on the time key managers spend in responding to the various inspections and-audits that are imposed upon them.

The surveys were performed using the Generic Letter guidance as well as the guidance provided in a NUMARC letter dated February 16, 1990.

The Generic Letter requested we indicate plant managers and their direct reports. We limited our responses to those individuals, however, for you to understand the total impact you should be aware that the next lower level of management spends a greater amount of their time dealing with auditors and inspectors, explaining procedures, collecting data, etc.

Attached are the completed questionnaires for our Big Rock Point and Palisades Plants.

f Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspectors - Big Rock Point & Palisades Attachments 9003120123 900301 9

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P ATTACHMENT Consumers Power Company

. Palisades Plant' Docket 50-255 i

i RESPONSE TO GENERIC LETTER 90-01 March 1, 1990 i

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13 Pages OC0290-0266-NLO4 l

NRC Regular,ory Imoar.t Survey PALISADES Quest'onnaire Sheet 4

1.

Type of inspection, audit or evaluation:

Routine nac Inspections (Perien III L Resident) - not SALP or Special Team Inspections.

2.

Based on actual experience over the past several years, about how often is this activity conducted?

32 insrection renorts ver year.

3.

Operations / Construction areas covered: training, operations, e,ecurity radiolorienl/HP. chemistry. ndmin. etc.

4 Extent of the activity (how many people, for how long) various i

5.

Approximatepercentageoftotaltime(onanannualbasis)whichthe following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads ot nvg, (numberinvolv'ed) 6

- b.

Plant Manager 25 c.

Corporate Department Heads 2%

(numberinvolved) h d.

Corporate Vice Presidents 2%

(numberinvolved) 1 e.

Chief Nuclear Officer b%

i

NRC Regulatory Imoact Survey PALISADES Questionnaire Sheet i

1.

Type of inspection, audit or evaluation:

Non-Routine NRC Inspections (SALP & Special Team) 2.

Based on actual experience over the past several years, about how often is this activity conducted?

1-h times per year (SALP + 3 Special Team) 3.

Operations / Construction areas covered:

training, security. EP. ALARA.

other, j

4.

Extent of the activity (how many people, for how long) 23 8 for Team Inspection.

1-2 people for 1 weeks on EP/ALARA SALP 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads A' h%

(numberinvolved) 6 b.

Plant Manager

% not including Enforce. conf /2 % Lvith Enforce. Conf c.

Corporate Department Heads 4%

(numberinvolved) h d.

Corp ~ orate Vice Presidents b%

(numberinvolved) 1 e.

Chief Nuclear Officer 20h%

i

NRC Reeulatory Impact Survey PEISES Questionnaire sheet 1.

Type of inspection, audit or evaluation:

NRC Recuired QA Audits 2.

Based on actual experience over the past several years, about how often is this activity conducted?

po por vosr. m st denartment heads are involved in 1 or p 4

3.

Operations / Construction areas covered:

Procurement, HP nrocram, i

t-rdnine maintenance, EP, T&C, other 4

4.

Extent of the activity (how many people, for how long) 2 h auditors 1 9 weeks 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 63% avs.

(numberinvolved) 6 b.

Plant Manager 2%

c.

Corporate Department Heads M

(numberinvolved) h d.

Corp ~ orate Vice Presidents 4 4%

(numberinvolved) 1 e.

Chief Nuclear Officer l

NRC Recula4ory Impact Survey PALISADES Quest 9onnaire sheet 1.

Type of inspection, audit or evaluation:

INPO Evaluations (Not training accreditation) l 2.

Based on actual experience over the past several years, about how often is this activity conducted?

1 year.

3.

Operations / Construction areas covered:

FP, nrocurement, doc control, nutaranlannine, HP/ radiological /ALARA, non accredited training, other 4.

Extent of the activity (how many people, for how long) in-15 neonie tv v ve-ve.

r 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads 66% avg.

(numberinvolved) 6 b.

Plant Manager abt c.

Corporate Department Heads 9%

(numberinvolved) h d.

Corporate Vice Presidents ib%

(numberinvolved) 1 e.

Chief Nuclear Officer b%

NRC Regulatory Imooct Survey PALISADES Questsonnaire sheet 1.

Type of inspection, audit or evaluation:

ANT (Arerienn Nuclest Insurers) 2.

Based on actual experience over the past several years, about how often is this activity conducted?

1 Year.

3.

Operations / Construction areas covered:

nw eie g. training. Health Physien, Wintenance, ouality Assurance, Document Control 4.

Extent of the activity (how many people, for how long) 2 for-1 week a

1 5.

Approximate percentage of total time (on an annual basis) which tne following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads M5 avg.

(numberinvolved) 2 b.

Plant Manager 4 kt c.

Corporate Department Heads 25 (numberinvolved) 2 d.

Corporate Vice Presidents (numberinvolved) e.

Chief Nuclear Officer 1

l

1..

r^C Reeula",ory Emmact Survey Quest'onna' re Sheet NSNS 3

1 1.

Type of inspection, audit or evaluation:

ma (nuM anr Mutuni 1.imited),

er othar non-ANT irrurare.

1 r

2.

Based on actual experience over the past several years, about how often j

is this activity conducted?

e p var vent l

l 3.

Operations / Construction areas covered:

Fire Protection, Maintenance, overations.

i 4

4.

Extent of the activity (how many people, for how long) i verson for o %ve.

l 4

5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 4.b5 (numberinvolved) 1 b.

Plant Manager l

c.

Corporate Department Heads P

(numberinvolved) 1 d.

Corporate Vice Presidents,

(numberinvolved) e.

Chief Ituclear Officer 1

1 I

1

1 NRC Regula"ary :,esect Survey Quest'onna' re Sheet NSEES 1.

Type of inspection, audit or evaluation:

st nt a nf vi-bienn -

DNR monitoring teres / NPDES Permit 2.

Based on actual experience over the past several years, about how often is this CCtivity Conducted?

1-2 times per year.

3.

Operations / Construction areas covered:

uanity Pwvri es. vnvi rnneent ni,

neerrat i nne. Trai n1 nc. Vni nt annnea 4.

Extentoftheactivity(howmanypeople,forhowlong) 1-2 veople f'or 1-P dnys 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 4 M (numberinvolved) 2 4

b.

Plant Manager c.

Corporate Department Heads (numberinvolved) d.

Corporate Vice Presidents (numberinvolved) e.

Chief Nuclear Officer

NRC Reeula wry ::mpact Survey PAU SADES ouest'onna9re sheet 1.

Type of inspection, audit or evaluation:

m et. Pna - mercency Prernr.4rere 2.

Based on actual experience over the past several years, about how often is this activity conducted?

1m Yan-3.

Operations / Construction areas covered:

herrency Planninc. Health thvnten 4.

Extent of the activity (how many people, for how long) 1 veryn for 9 an-9 5.

Approximatepercentageoftotaltime(onanannualbasis)whichthe following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 61% avg.

(numberinvolved) h b.

Plant Manager c.

Corporate Department Heads / b5 avg (number involved) 1 (numberinvolved) d.

Corporate Vice Presidents e.

Chief Nuclear Officer l

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?

NRC Regula",ory Lapact $urvey pnIstcEs 4

Quest'onna re sheet i

j 1.

Type of inspection, audit or evaluation:

MTOSHA i

l 2.

Based on actual experience over the past several years, about how often is this activity conducted?

1 var ; vants i

1 l

3.

Operations / Construction areas covered:

safety'and Health j

i i

4.

Extent of the activity (how many people, for how long) 1 person b day 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads z bc (numberinvolved) 1 l

b.

Plant Manager (numberinvolved) c.

Corporate Department Heads (numberinvolved) d.

Corporate Vice Presidents e.

Chief Nuclear Officer

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C C Reeulae,ory Lasect Survel PALISADES ouest'onna' re sheet 1.

Type of inspection, audit or evaluation:

Pelf-Anseremente (CSFI. CLHP, i

j Monthly Offsite Review) 2.

Based on actual experience over the past several years, about how often is this activity Conduf.ted?

From 1 to h per year i

l-3.

Operations / Construction areas covered:

procurement, outace plannine, security, maintenance. EP, dore/ALARA, C & HP 4

Extentoftheactivity(howmanypeople,forhowlong) core group of h (SSFI full time) i 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads Sh% avg.

(numberinvolved) 6 b.

Plant Manager 4%

c.

Corporate Department Heads 2.45 (numberinvolved)

L d.

Corporate Vice Presidents 4.4%

(numberinvolved) 1 e.

Chief Nuclear Officer J

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i NRC Regula",ory moact Survey pg73g3 ouest' onna' re sheet 1.

Type of inspection, audit or evaluation:

DiPO Trnininc Acere31tation 2.

Based on actual experience over the past several years, about how often is this activity conducted?

s vrnern.s everv two years 3.

Operations / Construction areas covered:

I&c. operations. Maintenance.

Technical, NP training, Tech Staff 4.

Extent of the activity (how many people, for how long) 12 people for a week.

5.

Approximatepercentageoftotaltime(onanannualbasis)whichthe following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads 633% avg.

(number involved) h b.

Plant Manager 2%

c.

Corporate Department Heads 1b%

(numberinvolved) b d.

Corporate Vice Presidents h%

(numberinvolved) 1 e.

Chief Nuclear Officer l

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['

C C Assulae.ory moect Survey PEISADES Quest' onna' re 5heet l

1.

Type of inspection, audit or evaluation:

mF>ac j

ant n collection, neatines. vers tion st atement e enr NFr initintiven i

i 2.

Based on actual experience over the past several years, about how often is this activity conducted?

25 tinan ver vant 1

I 3.

Operations / Construction areas covered:

various l

l 4.

Ertent of the activity (how many people, for how long) no site visit activities I

I I

5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 2%

(numberinvolved) h i

j b.

Plant Manager' x l

c.

Corporate Department Heads it (numberinvolved)

P d.

Corporate Vice Presidents M (number involved) 9 j

e.

Chief fluclear Officer i

j

NRC Reeula",ory Lasact Survey PALISADES ouestuonneure sneet 1.

Type of inspection, audit or evaluation:

other operationna/censtruction Audits, Inspections, evmbntion no+ previously covered (speci M (!!OD heview 2eam/ Corporate Safety Group Auaits, corporate 1.nvironmental Audit.

2.

Based on actual experience over the past several years, about how often is this activity conducted?

3.

Operations / Construction areas covered:

Efficiency improvement. soil contamination 4.

Extent of the activity (how many people, for how long) i person for 3 L days on soil contamination.

5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads 44%

(numberinvolved) 2 b.

Plant Manager b%

c.

Corporate Department Heads (numberinvolved) d.

Corporate Vice Presidents (numberinvolved) e.

Chief Nuclear Officer o

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NRC Reeulae,ory :.asect Survey sig noek Point ouest'onna'.re sheet 1.

Type of inspection, audit or evaluation:

Pnutine i:Rc Insreetien (naciaent S P rien) 2.

Based on actual experience over the past several years, about how often is this activity conducted?

w ?m iner eti-n war rte e vent 3.

Operations / Construction areas covered:

verinus 4

Extent of the activity (how many people, for how long) 1-2 people fer h kvr (Facinni 1-P people for varyine time periods (Resident) 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement bafore, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 5%

(numberinvolved) 6 b.

Plant Manager 3%

c.

Corporate department Heads 2%

(numberinvolved) h d.

Corporate Vice Presidents 2%

(numberinvolved) 1 e.

Chief Nuclear Officer b5

NRC Regulatory Impact Survey Big Rock Point ouestionnair" 5heet 1.

Typa of inspection, audit or evaluation:

NRC Te e Tnspections 8, PALP 2.

Based on actual experience over the past several years, about how often is this activity conducted?

about once a year (tro Appx R. CRDR) plus SALP 3.

Operations / Construction arvas covered:

Various 4.

Extent of the activity (how many people, for how long) 2-3 people er L evs 5.

Approximatepercentageoftotaltime(onanannualbasis)whichthe following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads _ 1%,,

(numberinvolved) 6 b.

Plant Manager 1%_

c.

Corporate Department Heads 4%

(numberinvolved) h d.

Corporate Vice Presidents b%

(numberinvolved) 1 e.

Chief Nuclear Officer 4 4%

NRC Reeulae,ory Lasect Survey sig Rock Point Questnenna' ire Sheet 1.

Type of inspection, audit or evaluation:

NRC Required QA Audits 2.

Based on actual experience over the past several years, about how often is this activity conducted?

N 18 per year 3.

Operations / Construction areas covered:

operations, Emergency Pinnning, C&HP, Mnintennnee, Fire Protection, Enyironmental Modifications.

Corrective Action Locumen+; Control 4.

Extent of the activity (how many people, for how long)

Each Audit is W people for h dnys.

5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 9%

(numberinvolved) 6 b.

Plant Manager Ic c.

Corporate Department P" us 4%

(number invohed) h d.

Corporate Vice Presidents < 4",

(numberinvolved) 1 e.

Chief Ituelear Officer 1

i

w NRC Regular,ory Impact Survey Big Rock Point questLonnaire 5heet 1.

Type of inspection, audit or t' valuation:

TNPo Evaluntion 2.

Based on actual experience over the past several years, about how often is this activity conducted?

once everv v is months 3.

Operations / Construction areas covered:

Operations. Maintenance.

Trainine. Health Physics. Chen stry. Engineering. Operating Experience, Administration 4.

Extent of the activity (how many people, for how long) 12 people for 2 weeks S.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plar.t Department Heads _55 (numberinvolved) 6 b.

Plant Manager 55 c.

Corporate Department Heads 25 (number involved) _ 1 d.

Corpor&te iice Presidents Ikt (nual:ec involved) 1 e.

Chief Nuclear Officer 4%

NRC Reculatory Lasect Survey Big Rock Point owestionna' ia sheet 1.

Type of inspection, audit or evaluation:

American Nuclear Insurers (ANI) 2.

Based on actual experience over the past several years, about how often is this activity conducted?

a 1 year for h days 3.

Operations / Construction areas covered:

Operations. TrainingsHealth Physics, Maintenance. Quality Assurance. Document Control 4.

Extentoftheactivity(howmanypeople,forhowlong) 1 person for h hys 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads b%

(numberinvolved) 6 b.

Plant Manager <b%

c.

Corporate Department Heads 2%

(numberinvolved) 2 d.

Corporate Vice Presidents N/A (numberinvolved) e.

Chief Nuclear Officer n/A g

1 J

i l

NRC Reculanory "moect Survey Big Rock Point Quest'onw re sheet 4

l 1.

Type of inspection, xdit or evaluation:

wMent vutuna u.itea 0:ML) l 2.

Based on actual experience over the past several years, about how often is this activity conducted?

M2 a year 3.

Operations / Construction areas covered:

Fire Protection. Maintenance.

Onerations 4.

Extent of the activity (how many people, for how long) a re~en rer

.u..,

5.

Approximate percentage of total time (on an annual basis) which the following mtnagers must spend in direct involvement before, during, and in response to the activity described in Item fl.

I a.

Plant Department Heads 4 Le (numberinvolved) 3 l

b.

Plant Manager 4 kc c.

Corporate Department Heads P5 (numberinvolved) 1 d.

Corporate Vice Presidents (numberinvolved)' -

e.

Chief Nuclear Officer I

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NRC Regulatory Imosct Survey Big Rock Point Quest'onnaire sheet 1.

Type of inspection, audit or evaluation:

State - DNR Monitoring 4

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Teams j

~2.

Based on actual experience over the past several years, about how often is this activity conducted?

?.

a 9 -.e vor v ar i

3.

Operations / Construction areas covered:

Health Phvntes, Envtrenmental, nrereH enn. Traindnc. Maintenance

]

4.

Extent of the activity (how many people, for how long) 1 person for o Asvo.

i 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads <b%

(numberinvolved) 1 b.

Plart Manager c.

Corporate Department Heads (numberinvolved) d.

Corporate Vice Presidents (numberinvolved) e.

Chief Nuclear Officer -

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NRC Recul44ory Impact Survey sig Rock Point Quest' onnaire sheet l

l 1.

Type of inspection, audit or evaluation:

state /ma - Emercency i

p-orn co.r s l

2.

Based on actual experience over the past several years, about how often is this activity conducted?

41 a year 3.

Operations / Construction areas covered:

Emergency Planning, and Manith Physics 4.

Extent of the activity (how many people, for how long) _1 person for tvn dnys l-S.

Approximatepercentageoftotaltime(onanannualbasis)whichthe I

following managers must spend in direct involvement before, during, and

)

in response to the activity described in Item fl.

a.

Plant Department Heads < 4%

(numberinvolved) 1 b.

Plant Manager < 4%

c.

Corporate Department Heads < b%

(numberinvolved) 1 d.

Corporate Vice Presidents (numberinvolved) e.

Chief Nuclear Officer l

a

  • O NRC Regula1ary !apact Survey Big Rock Point Quest onnaire sheet 1.

Type of inspection, audit or evaluation:

MIOSHA 2.

Based on actual experience over the past several years, about how often is this activity conducted?

I visit in last s years 3.

Operations / Construction areas covered:

sarety and Health 4.

Extentoftheactivity(howmanypeople,forhowlong) i person b day 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item #1.

a.

Plant Department Heads 4.b%

(numberinvolved) 1 b.

Plant Manager 4 4%

c.

Corporate Department Heads (numberinvolved) d.

Corporate Vice Presidents (numberinvolved) e.

Chief Nuclear Officer i

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NRC Reculatory impact Survey Questionna' ire sheet Big Rock Point 1.

Type of inspection, audit or evaluation:

eu, e--

.r r eerp g uni nt enwe. c r, FP. v-+ >n v nerni+ a Pev9vn )

2.

Based on actual experience over the past several years, about how often is this activity conducted?

1 per year plus monthly visits 3.

Operations / Construction areas covered:

Electriel System. Core Spray, Maintenance. C & HP, Emercency Planning 4.

Extent of the activity (how many people, for how long) various 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads at (numberinvolved) 6 b.

Plant Manager 1%

c.

Corporate Department Heads 4 Le (numberinvolved) h d.

Corporate Vice Presidents 4 Lc (numberinvolved) i e.

Chief fluclear Officer l

ll

NRC Regula",ory Espect $urveY Eig Rock Point ouestsonna're 5heet 1.

Type of inspection, audit or evaluation:

M O - Training Accreditation 2.

Based on actual experience over the past several years, about how often is this activity conducted?

5 procrres evary two vents 3.

Operations / Construction areas covered:

All traininc procrams 4.

Extent of the activity (how many people, for how long) 32 reople for a week 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Departrant Heads P%

(numberinvolved) 6 b.

Plant Mantja 1%

c.

Corporate Department Heads 144 (numberinvolved) h d.

Corporate Vice Presidents b%

(numberinvolved) 1 e.

Chief Nuclear Officer

.6, NRC Raoula%ry ::ssect Survey EIG ROCK Pon!T ouestuonna're 5neet 1.

Type of inspection, audit or evaluation:

I;inanc data collection, meetings, position statements for NRc initiatives 2.

Based on actual experience over the past several ;raars, about how often is this activity conducted 7 25 times per year 3.

Operations / Construction areas covered:

various 4.

Extent of the activity (how many people, for how long) no site visit activities 5.

Approximate percentage of total time (on an annual basis) which the following managers must spend in direct involvement before, during, and in response to the activity described in Item fl.

a.

Plant Department Heads 2%

(numberinvolved) h b.

Plant 14anager 2%

c.

Corporate Department Heads 1%

(numberinvolved) 2 d.

Corporate Vice Presidents 1%

(numberinvolved) 2 e.

Chief fluelear Officer

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