ML20043E359
| ML20043E359 | |
| Person / Time | |
|---|---|
| Issue date: | 02/02/1990 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Carr, Roberts, Rogers NRC COMMISSION (OCM) |
| Shared Package | |
| ML20043E353 | List: |
| References | |
| FOIA-90-85 NUDOCS 9006120348 | |
| Download: ML20043E359 (33) | |
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MEMORANDUM FOR:
Chairman Carr Comissioner Roberts Comissioner Rogers Comissioner Curtiss Comissioner Remick FROM:
James M. Taylor Executive Director for Operadons g
SUBJECT:
RESULTS OF NRC MANAGEMENT MEETIM HELD JANUARY 22-23, 1990 The purpose of this memorandum is to provide the Comission with a sumary of discussions held at the January 22-23, 1990, NRC Senior Management Meeting, and to provide the Commission copies of letters to be sent to the licensees of plants that will be discussed at the February 15, 1990 Comission meeting.
As the Comission is aware, NRC senior managers meet approximately biannually to review the performance of operating nuclear power plants licensed by the NRC. These meetings are conducted to assure NRC is focusing its resources on plants and related issues of greatest safety significance.
Nuclear power plant performance was a major topic of discussion at this latest NRC Management Meeting. A sumary of the results of this discussion is presented in enclosu e 1.
By the close of business on February 12, 1990, the staff will mail the enclosed letters to the chief executive officers of licensees of plants in categories 1, 2, or 3 informing them of the staff's assessment of their plants and of the February 15, 1990, Commission meeting.
In addition, the staff plans to telephone each of 1.hese licensees on February 12 to advise them that their plar, will be subject to discussion at the February 15 meeting, thus giving them an opportunity to ottend if they 50 choose. Enclosure 2 contains copies of letters to be mailed to the licensees, enclose 3 is a summary of the January 22-23, 1990 NRC Senior Management Meeting, and enclosure 4 is a list of attendees at that j
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Please note that the information contained with this memorandum is sensitive and will be discussed at the February 15, 1990, comission meeting.
Following the meeting, the letters to licensees will be placed in the Public Document Room.
Original Signed By:
James M. Taylor James M. Taylor Executive Director for Operations
Enclosures:
1.
Sumary of Senior Management Meeting Results 2.
Letter to Licensees 3.
Management Meeting Sumary 4.
List of Attendees cc w/ enclosures:
SECY OGC Distribution:
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ENCLOSURE 1 Summary.of $enior Management.Neettee.Results Meetine. Dates Category.1 Cateeory.2 Category.1
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January 22-23 Browns Ferry Nine Mile Point 1&2 Pilgrim 1990 1.2 8 3 Calvert Cliffs 1&2 Peach Bottom 243 Surry 1&2 Turkey. Point 384 3
May 17-18, Browns Ferry Nine Mile Point 1&2 Sequoyah 1&2 1989 1,2 & 3 Peach Bottom 283 Fermi 2 Pilgrim Fort Calhoun
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Calvert Cliffs 1&2 Turkey Point 3&4 Surry 1&2 Category.1 Plants Removed from the List of Problem Facilities Plants in this category have taken effective action to correct identified problems and to implement programs for improved performance. No further NRC special attention is.necessary beyond the regional office's current level of monitoring to ensure improvement continues.
Category.2 Plants Authorized to Operate that the NRC Will Monitor Closely m
Plants in this category have been identified as having weaknesses that warrant increased NRC attention from both headquarters and the regional office. A plant will remain in_this category until the licensee demonstrates a period of improved performance.
Category 3 Shutdown Plants Requiring NRC Authorization te Operate and Which the NRC Will Monitor Closely Plants in this category have been identified as having signi'icant weaknesses that. warrant maintaining the plant in a shutdown condition.un'.11 the licensee can. demonstrate to the NRC that adequate programs-have both been established and implemented to ensure substantial improvement.
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ENCLOSURE 2 y
LETTERS TO LICENSEES e
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UNITED $TATES
. NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D, c. 30a46.
l Docket No. 50-293 4
Mr. Stephen J. Sweeney
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Chairman and Chief Executive Officer Boston Edison Company 800 Boylston Street Boston, Massachusetts 02199
Dear Mr. Sweeney:
= 0n January 22 and 23,1990, NRC sen'ior managers met to review the performance
-of' nuclear power _ plants licensed to operate by the NRC.
This meeting is conducted semiannually to focus NRC resources on those plants and related issues of greatest safety significance.
At this meeting, it tm, concluded Pilgrim has demonstrated sustained improvement sufficient to warrant removal from the category of plants 'that require increased attention from both NRC Headquarters and the Regional office.
A summary of the~ discussions held relating to Pilgrim is provided below:
Boston Edison has effectively implemented a comprehensive corrective action plan which addressed the root causes of their historical poor performance. The plant's performance during the early phases of-power ascension was marked by both equipment' problems and personnel error.. -The licensee has thoroughly evaluated these events and extracted important lessons learned.
Corrective actions have been largely effective 'in-11 dressing the. root causes of these events.
The later phases of power-
- a teension were well conducted including a planned outage in October :1989 I
' aid a shutdown from outside the control room. - The licensee has also t
effectively assessed 'its own performance and identified. areas - for continuing emphasis.
Three of these-areas, procedure upgrade, procedure adherence, and management self-assessment will be ~ the focus of ongoing Regional staff. oversight.
The licensee, State and local-officials' efforts in correcting Federal Emergency Management Agency (FEMA) identified planning deficiencies in the off-site. Eriergency Response Plans have significantly improved emergency preparedness. A full-scale emergency drill was conducted in October 1989, which satisfied the schedular exemption to conduct a drill within 120 days L
of - completion of power ascension.
However, because FEMA has not yet i
issued its exercise report nor reached conclusions on the previous planning deficiencies, the Regional staff will continue to monitor off-t-
site er.ergency preparedness progren.
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~ An NRC Commission meeting open to~ the public has been scheduled for February 15 1990, to review the results of the latest meeting of NRC managers.
Mr.
WilliamT. Russell,.theRegion-IAdministrator.-hasdiscussedthebasisforour conclusions ~with regard to the Pilgrim facility with members of your staff.
If'you have any questions, do not hesitate to call me.
Sincerely, James M. Taylor Executive Director for Operations ec:
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UNITED 8TATES.
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NUCLEAR REGULATORY COMMIS$10N eAsmwoTow, p.c.aosas e
Li Docket Hos.
50-277
$0 278 L
Mr. Joseph Paquette Chairman of the Board, Chief j
Executive Officer and President l
Philadelphia Electric Company 2301,Narket Street Philadelphia, PA 19101
Dear Mr. Paquette:
On January 22 and-23,1990, NRC scni,or managers niet to review the performance l'
of nuclear power plants licensed to operate by the NRC.
This meeting -is conducted semiannually to focus NRC resources on those plants and related issues of greatest safety significance.
At this meetin)ficient, it was concluded improvement sur to warrant Peach Bottom has demonstrated sustained removal from the category of plants that requ1re increased attention from both NRC Headquarters and the Regional office.
A summary of the discussinns held relating to Peach Bottom is provided below:
The overa'll performance of the Philadelphia Electric Company and the Peach Botton. Station in 1988 and 1989 is improved and is characterized by a overall safety culture.
During the Unit 2 phased power positive ascension,. the NRC, staff cicsely monitored plant operations, including 24 coverage durin!) key evolutions.
The approach to operations was hour controlled and caut'ous, with emphasis on doing the-job correctly the first time.
The effectiveness of the new Shift Managers in safely '
conducting operations was particularly noteworthy.
There has been a-posjuve change in attitude and approach to operations within the operaticos department.
The high quality operations of Unit 2 durin ascension formed the basis for fully. lifting the Shutdown Order og power March 1987.
The pip replacement outage and subsequent startup on Unit 3 were noteworthy in. their absence of significant events. The licensve's ability to assess its own perforn.ance, identify areas for further improvement ano-implement corrective action has repeatedly been demonstrated. This capability has significantly contributed to 'mproved performance and NRC cunfidence in both corporate and station management.
An NRC Consnission meeting open to the public has been scheduled for February 15,1990, to review the results of the latest meeting of-NRC managers.
Mr.
hilliam T. Russell, the Region 1 Administrator, has discussed the basis for our conclusions with regard to the Peach Bottom facility with members of your staff.
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'If you have any questions, do not hesitate to call me.
Sincerely.
James M. Taylor Executive Director for Operations e
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umTED STATES
. NUCLEAR REGULATORY COMMISSION c:AsHwavow.e.c. sones
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1 Docket Nos. 50-250 50-251 Mr. James L. Broadhead 1
Chairman of the Board and i
Chief Executive Officer Florida Power and Light Comparty Post Office Box 088801 North Palm Beach, FL 33408
Dear Mr. Broadhead:
On Janury 22 and 23,1990, NRC senjor managers met to review the performance of nuclea. power plants licensed to operate by the NRC.
This meeting is conducted semiannually to focus NRC resources on those plants and issues of At this meeting, it was concluded Florida Power greatest safety signifi:ance.(FPL) Turkey Point facility has demonstrated sustained and Light - Cor.'oany 5 removal from the category of plants that improvement sufficient to warrant require increastd attention from both NRC Headquarters and the Regional office, A' summary of NRC discussions held relating to Turkey Point is provided below:
p Performance of the Turkey Point plant has been discussed at NRC Senior Management Meetings since 1986.
At the last meeting, it. was noted that some positive -indications of improved overall performance had been p
identified at the Station but that concerns still existed with senior o
management stability ' and certain functional areas.
Senior management n
These changes have been changes and additions have reduced our concern.
in accelerating improved performance in the weak functional effectiveOverall performance has demonstrated that the programmatic changes made in response to NRC concerns and FPL self-assessments have been areas.
effectively implemented.
Performance over the past few years had been t
characterized by improving trends but the uccurrences of significant events during those periods indireted the need for additional attention.
successful and safe operations This past period was charncerized bylong-term plant enhancements, and resulting from revitalized management,The FPL management should continue to plac an improved safety culture.
priority attention on the safe operation of Turkey Point to assure that neither management nor staff become complacent about safety improvements l
attained.
n,eeting open to the public has been scheduled for An NRC Comission February 15, 1990, to review the results of the latest meeting of NRC managers.
has discussed the basis Mr. Stewart D. Ebneter, the Region II Administrator, f acility with members of l-for our conclusions with regard to the Turkey Point your staff.
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If you have questions regarding this matter, do not hesitate to call me, Since rely, g
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NUCLE AR REGULATORY COMMISSION l{#
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J'i Docket Nos.
50-220 50-410 Mr. John M. Endries President Niagara Mohawk Power Corporation 300 Erie Boulevard West Syracuse, New York 13202
Dear Mr. Endries:
On January 22 and 23,1990 NRC senior managers met to review the performance of nuclear power plants-licensed to operate by the NRC.
This meeting is conducted silmiannually to focus NRC resources-on those plants and related issues of greatest safety significance.
At this meeting, Nine Mile Point and 2 were categorized as continuing to require close monitoring.
Units 1 Plants in this category have been identified as having weaknesses that warrant increased NRC attention from both Headquarters and the Regional Office until the licensee demonstrates a period of improved performance.
A summary of the discussions held relating to Nine Mile Point Units 1 and 2 is provided below:
Siace the May 1989 Senior Management Meeting, sificant progress has been made in implementing corrective actions whico address the underlying root causes of prior poor performance.
An Integrated Assessment Team
-Inspection concluded that the Restart Plan-for Unit'l was in place, well disseminated and generally understood; however, the degree of implementa-tion of _ the. Plan varied.
NRC inspection observations indicate that additional work is needed to ensure all levels in the organization understand their roles and responsibilities related to new management policies and procedures.
Progress in making Unit I ready for restart has been slow as a result of a conservative approach to ensuring system readiness for fuel loading and underestimating the time needed to implement needed DC electrical system modifications. Operational performance in September and Octoter on Unit 2
. declined as a result of several avoidable human errors.
The licensee is reassessing the effectiveness of prior corrective actions in light of these errors.
As e result of the July 1989 Unit 2 Requelification Examination failurec, several programmatic changes and extensiva retrain-ing have been implemented.
The licensee efforts with respect to decontamination of the old radwaste building basement are proceeding.
An aggressive personnel expos: ire budget has been established for the decontamination.
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(ohn.M.Endries l-The licensee is planning to delay the Unit 2 refueling outage until August 1990 in -order to better plan the outage and minimiae overlap with the Unit 1 startu), which is currently estimated to begin in late April 1990.
- NRC concern-ias been expressed regarding the August 1990 timing of a licensee self-assessment related to effic ency and budget because of its potential to divert management attention during the planned power ascen.
sion of Unit-1 and the Unit 2 outage and-restart.
Independent close scnitoring and confirmation of read' ness of Unit 1. for restart will continue.
NRC concer'n was also expressed regarding the potential adverse impact of future management losses and the need for management succession planning and the development or recruiting of senior corporate and plant managers.
An NRC Commission meeting open to the public has been scheduled for February 15, 1990, to review the results of the latest meeting of NRC managers.
Mr.
William T. Russell, the Region 1 Administrator, has discussed the basis for our conclusions with regard to Nine Mile Point Units 1 and 2 with members of your staff.
If you have any questions, do not hesitate to call me.
Sincerely, James H. Taylor Executive Director for Oper.ations cc:
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NUCLEAR REGULATORY COMMISSION tAsNewTow.e, c, acess qt
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Docket Nos: 50 317 50 318 Nr. George V. McGowan Chairn,an of the Board and-Chief Executive Officer Baltimore Gas and Electric Company P.O. Box 1475 Baltimore, Maryland 21202
Dear Mr. McGowan:
E On January 22 and 23,1990, NRC senior managers met to review the performance i
of nuclear power pl6nts licensed to operate by the NRC.
This meeting is conducted semiannually to focus NRC resources on those plants and related issues of greatest' safety significance.
At this meeting, the Calvert Cliffs facility was categorized as continuing to require close monitoring.
Plants in. this category have been identified as having weaknesses that warrant increased HRC attention from both Headquarters and the Regional Office until the'licer,see demonstrates a period of improved performance.
A suninary of the discussions held relating to Calvert Cliffs is provided below:
Licensee performance has slowly improved since the May 1989 Senior lunagement Meeting. The licensee has focused its efforts on the short term, actions needed for restart of Unit 1.
As a result, longer term activities under the Performance Improvement Plan have proceeded at a slower pace than expected.
in October 1989, the licensee reported the short term actions needed for restart had been completed and were ready
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for NRC ' inspection. The NRC team inspection in November confirmed 1
I significant ' improvement in most areas; however, additional work is required to ensure adequate safety tagging, coordination and tracking of corrective actions, and follow up to ensure that new programs are effectively implemented. A recently-identified significant issue related to inadequate low temperature overpressure protection for the reactor vessel was also discussed.
Past organizational performance related to implementation of administrative controls to minimize the pressure transients was not satisfactory. The generic implications of this event with respect to implementation of past licensee commitments are to be resolved prfor to restart.
Readiness for. restart and the longer term Performance 1mprovement Plan will continue to receive close monitoring.
L An NRC Commission meeting open to the public has been scheduled for February 15, 1990, to review the results of the latest meeting of NRC managers.
Mr.
Willian T. Russell, the Region 1 Administrator, has discussed the basis for our conclusions with regard to the Calvert Cliffs facility with menbers of your staff.
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UNITED 8TATt8 T
I NUCLEAR REGULATORY COMMIS$10N 5YA8HlWeTON.O. C. 30004
- 6..a Docket Nos. 50-280 50-281 Mr. J. T. Rhodes, President and Chief Executive Officer Virginia Electric and Power Company P. 0. Box 26666 Richmond, VA 23261
Dear Mr. Rhodes:
On January 22 and 23,1990, NRC senior managers met to review the performance of ~ nuclear power plants-licensed to operate by the NRC.
This meeting is cond>cted semiannually to focus NRC' resources on those plants and issues of-greatest safety significance.
At this meeting, the Surry facility was categorized as requiring close monitoring.
Plants in this category have been identified as having weaknesses that warrant increased NRC attention from both Headquarters and the Regional Office until the licensee demonstrates a period of improved performance.
A summary of NRC discussions held relating to Surry is provided below:
Performance of the Surry plant has been discussed at the Senior Management Meeting since December 1988 as a result of NRC concerns related to significant events, escalated enforcement issues and lack of management agressiveness in pursuing resolution of issues.
Corporate and site ma.*agement changes, coupled with a reorganization to a dedicated nuclear departa nt, have had a positive impact on the station performance.
ProgranNtic changes reflect 'an aggressive approach to problem resolution. Equipment upgrades such as the service water modification and additions to the operations and maintenance staffs are contributing to improved operating performance in the short term.
Although performance has improved in most areas, Surry should concentrate on full implementa-tion of programmatic changes and corrective actions to demonstrate continued improvement for the long run.
An NRC Comn ission meeting open to the public has been scheduled for February 15, 1990, to review the results of the latest aseeting of NRC managers.
-Mr. Stewart D. Ebneter, the Region !! Administrator, has discussed the basis for our conclusicns with regard to the Surry facility with members of your staff.
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If you h' ave-any questions' regarding this matter, do 'not hesitate to call me.
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James M. Taylor Executive Director for Operations-cc: See next page
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Docket Hos. 50 259, 50-260, and 50-296 Mr. Oliver D. Kingsley, Jr.
Senior Vice President, Nuclear Power Tennessee Valley Authority 6N 38A-Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
Dear Mr. Kingsley:
Cn January 22 and 23,1990, NRC senior managers met to review the performance power pl6nts licensed to operate by the NRC.
This meeting is of nuclear conducted semiennually to focus NRC resources on those plants and issues of greatest safety significance.
At this meeting, Browns Ferry was oiscussed. It' was decided that it is appropriate to maintain Browns Ferry Units 1, 2,.and 3 in the category of plants that reovire NRC authorization to operate and receive Plants placed in this category are having or have
.close monitoring-by the NRC, had significant weaknesses that warrant maintaining the plant in a shutduwo condition until the licensee can demonstrate to the NRC that adequate programs have both been established and implemented to ensure substential improvement.
A summary of discussions held relating to Browns Ferry is provided below:
Engineering work at the site has recently shown an improved trend in both quality and timeliness. -However, your own verificatiun efforts are still showing areas requiring significant modification, thereby, resulting in a Improvements in other areas have further slippage in your restart effort.
approach to resolution of problems (fix instead of analyze),
occurred:
conservative approach to issues and stability of management organization.
In the area of operational readiness, we are -concerned about the error We also have concerns regarding opera-rate in performing surveillances.
tor. readiness as indicated in your 1989 requalification examination results.
The NRC staff's inspection program continues to find mixed results. While good results were obtained from the Appendix R
and maintenance inspections, surveillance and design change inspections were less These results cuntinue to confirm the staff's ongoing positive.
assessment that successful implementation of the Unit 2 programs is still a goal not yet achieved.
Other areas receiving enhanced staff attention i include equipment qualification and electrical design.
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'An NRC-Comission meeting. open to the public has been scheduled for February 15, 1990 to ~ review the results of the latest-meeting of NRC managers.
Mr.
Cretchfield, Associate Director for $>ecial Projects Of fice - of i
Dennis = M.
Nuclear Reactor Regulation,' has discussed the bas's for our concIunions with regard to the Browns Ferry facility with you or members of your staff.
If you have any. questions regarding this matter, please do not hesitate to call me.
Sincerely, James M. Taylor Executive Director for Operations cc:
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ENCLOSUREI NRC SENIOR MANAGEMENT MEETING $Ul@4ARY January 22-23,1990 Region V Focus.on.ticensee.perf0rmance
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Following the June 1985 loss of feedwater event at Davis-Besse one resulting
.NRCactionwasthatseniorNRCmanagersperiodicallymeettodIscussthe plants of greatest concern to the agency and to plan a coordinated course of action. This was the eighth such meeting. The last meeting was held in Region !!! in May 1989..The meeting in Region V was structured to review the status of the plants discussed at the last mMting and to review the performance of other plants to determine if tay changes should be made to the list of problem facilities.
In preparation for the meeting, NRR, in conjunction with the five regional offices, AEOD, and RES, preipated background documents on the plants to be discussed.
Inputs for each plant inc uded a summary of the most recent SALP and SALP history, a discussion of current operating experience, current NRC and Itcensee activities, and. performance indicator data. Data pertaining to safety significant hardware issues at the plants was also provided. This information was distributed to meeting attendees prior to the meeting. It provided the basis for review and discussion of each plant's performance and for senior management identification of those plants warranting increased NRC attention.
In reviewing the plants that have experienced significant performance problems, the NRC managers have set the following levels of categories of performance based upon plant actions to date to correct the problems and to achieve improved operations.
1.
Plants removed from the list of problem facilities.
Plants in this category have taken offective action to correct identified problems and to implement programs for improved performance. No further NRC special attention is necessary beyond the regional office's. current level of monitoring to ensure improvement continues.
2.
Plants authorized to operate that the NRC will monitor closely.
Plants in this category have been identified as having weaknessas that warrant increased NRC attention from both headquarters and the regional office. A plant will remain in this category uatil the licensee demonstrates a period of improved performance.
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Shutdown plants requiring NRC authorizatian to operate and which the-NRC will monitor closely.
Plants in this category have been identified as having significant weaknesses that warrant maintaining the plant in a shutdown condition until the licensee can demonstrate to the NRC that adequate p rams have both been established and implemented to ensure substant improvement.
The Following. Chart. Lists. Conclusions.frem.this.Neeting.and.fros.ths. Prev.ious Netting Meeting. Dates Category.3 CatendeQ Category.1 January 22-23 Browns Ferry Nir.e Mile Point 1&2 Pilgrim 1990 1,2 & 3 Calvert Cliffs, 1&2 Peach Bottom 2&3 Surry 1&2 Turkey Point 3&4 May 17-18, Browns Ferry Hine Mile Point 182 Sequoyah 182 1989 1,2 & 3 Peach Bottom 2&3 Fermi 2 Pilgrim Fort Calhoun Calvert Cliffs 1&2 Turkey Point 3&4 Surry 1&2 NRC senior management plans to review the status of all the reactors on an approximate 6-month frequency. Determinations will then be made to add or delete licensees from this list based on demonstrated performance. This program represents a concerted effort by the NRC senior management to focus NRC resources on those plants and issues of greatest safety significance and risk.
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S pe c i f i c.D i s cu s si on.of. problem. f acili ti es plants.that.have been.removao "ros.the. list.cf orobles. facilities pileria Pilgrim has been discussed-at each senior management meeting since April 1986 when the plant was shutdown and a Confirmatory Action Letter (CAL) issued for programatic weaknesses in several functional areas which were notcorrectedbyBostonEdisonCompany(BECo).
In response to the CAL, BEco implemented extensive organizational changes including the appoint-ment of Mr. Ralph Bird as Sen' or Vice President, Nuclear. Additional staff positions were also created and filled to alleviate shortages.
Extensive hardware modifications were initiated to improve plant reliability and a self-assessment program was developed. On December 30, 1988 the licensee was allowed to restart the plant. Early power ascension test program operations were marked with several problems involving failure to follow administrative procedures and control of maintenance activities.
The most significant event involyed RCIC system overpressurization which resulted in escalated enforcement and a civil penalty.
Immediately after the last senior management meeting plant operations continued to show some problems with procedure adherence and adequacy.
Three of ne four reactor scrams during this period were due to problems with procedure adequacy and adherence. Additionally, condensate pump suction piping was overpressurized due to a lack cf adherence to proper procedures. At every occasion, the licensee ~ performed a detailed self-assessment of-the problems and took prompt corrective actions to correct the individuals or procedures involved. As a result, problems significantly decreased toward the end of the power ascension program. The maintenance outage in October 1989 and a shut ~down from the outside control room were well controlled.
In December 1989, the licensee published a Final Assess-ment Report which concluded that improvements in the procedural support for routine evolution did not keep up with the' support provided to the test' program. This lack of support coupled with the long period of non-power operation resulted in inconsistent plant operations. Three areas of continuing management emphasis were, identified in the Final Assessment Report: procedure upgrades, procedure adherence and management self-assessment.
In October 1989 the licensee successfully conducted a full-scale emergency exercise, which included participation of the Comonwealth of Massachusetts and fulftiled the schedular exemption to conduct a. drill within 120 days of completion of power ascension. The NRC asse men
' concluded that the onsite or f he drill was' successful.
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FEMA has not yet issued an exercise report nor reached conclusions about the full resolution previous planning deficiencies.
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' Also, in October 1989 BEco settled three rate cases before the MassachusettsDepartmentofPublicUtilities(DPU). Theapreementis unique in-that a broad range of performance indicators wil be used to-apply financial rewards or penalties to the utility. These indicators include plant capacity factor, NRC SALP ratings, various NRC performance indicators, and two INP0 indicators. DPU has approved the agreement.
The use of such incentives is currently under NRC review. A major FERC rate case is still unresolved between Boston Edison and utilities that To date these activities have had contracted to purchase Pilp; rim power.notappearedtoaffectthequa1tyoflicen Based on the continued improvement shown by the licensee since the last senior management meeting and the effective self-assessment program, NRC management concluded that increased monitoring of licensee performance by-both NRC headquarters and Region I offices is no longer required. Region I will continue to provide close monitoring of the site with three resident inspectors. The NRC staff will continue to closely monitor offsite emer-gency preparedness progress and will periodically report the status to the Comission.
Peach Bottom.2&3 Peach Bottom has been discussed at each senior mansgement meeting since April 1986 due to a variety of problems. Ultimately, the NRC issued an Order suspending power operation on March 31, 1987 as the result of alle-gations concerning sleeping operators on shift. Following the plant shut-down Order, the licensee implemented extensive organizational and manage-ment personnel changes from the CEO to the shift managers, increased staff resources, and enhanced management's presence on shift through the shift manager program. On April 17,1989, the Commission voted to allow restart of Peach Bottom.
In June 1989 the NRC issued a Confirmatory Action Letter to document increased licensee commitments to quality as the result of an agreement with the Commonwealth of Pennsylvania. This agreement also provided for= increased st. ate oversight of the Peach Bottom facility.
The Unit 2 restart and low power operations were well controlled. Expanded NRC inspection coverage was provided during the restart activities. The Executive Vice President Nuclear Corbin McNeill, was personally very involved in plant activities. The line management oversight of plant activities was effective and demonstrated a conservative approach toward operations and plant safety. The new shift manager program was viewed as a positive initiative. As a result of this controlled approach, the 1987 order was terminated on October 5,1989. Unit 2 has experienced three scrams since startup; all were caused by equipment problems which could not be related to poor maintenance.
Unit 3 declared an Unusual Event on August 29,1989 when several circuit breaker control wires were found cut as the result of tampering. Licensee response to this event appeared to be cautious and conservative. Unit 3 was restarted on November 19, 1989 after successful completion of a pipe replacement outage and an NRC Readiness Assessment Team Inspection. The NRC provided around-the-clock coverage for the startup and portions of the power ascension test program and found the approach to be cautious and controlled with an emphasis on doing the job correctly the first time.
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Licensee activities since lifting the'1987 order continue to be directed towards improvement and indicate a different culture than previously -
-i existed at the utility. The 11cer.see is currently involved in an effort to upgrade surveillance procedures,. including human performance issues.
Self-initiated SSFIs are planned in 1990 begLnning with the electrical systems to provide a better understanding of the system design bases.
Recent personnel reassignments were made to broaden middle management experience and provide a larger pool of resources for selection of superintendents and plant managers. These activities have raised NRC confidence in licensee management, indicate a positive overall safety culture and justify removal from the list of plants requiring increased NRC monitoring by both headquarters and regional offices.
Turkey Point 3&4 Turkey Point was placed on the list of problem plants at the first senior managment meeting in April 1986. Since then, Turkey Point has remained a plant of concern and has been discussed at each senior management meeting i
due to an inability to correct problems and sustain improved performance.
Bep, inning-late in 1988, changes in onsite management's operating philosophy and attitude initiated culture changes so that operators began to accept accountability for the plant and its operation.
There are indications of increased management involvement in all aspects l
of Turkey Point's improving performance. The results of the SALP for the L
13-month period ending July 31, 1989, showed improvements resulting from that involvement. Operations and Maintenance / Surveillance received Category 2 ratings, up from 3s the previous period. Security remained a Category 3 but was rated with an improving trend. NRC has noted improve-ments in control room professionalism, teanwork, and communications.
Plant material condition is good and management has taken steps to iniprove plant reliability through improved plant equipment performance. The licensee
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took extensive and effective corrective action to overcome the problems identified during the March 1989 NRC-administered requalification exams in which 12 of 24 licensed operators and 3 of 6 crews failed. In September 1989, NRR conducted a review of the.11censee's design basis reconstitution process and found a generally effective and well implemented program.
Overall, site management has taken a conservative approach toward improving L
plant operations and has demonstrated competency in handling events affec-ting plant reliability. Based on these improvements, NRC senior management concluded.that continued increased monitoring of activities by both head-L L
quarters and the regional office is no longer warranted. Periodic management l
meetings between the NRC and the licensee continue to be. held on a bimonthly basis..
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Plants.autborized.to. operate,that.the JiRC wi.11.aositor. closely L
Nine. Nile. Point.1&2 NineMilePoint(NMP)hasbeendiscussedateachseniormanagementmeeting since June 1988. Unit I has been shut down since December 1987 and a Confirmatory Action Letter (CAL) was issued in July 1988 documentfng the licensee'scommitmentnottorestartwithoutNRCpermissIon.
Unit 2 restarted in April 1989 and completed its longest run in September 1989 when an automatic scram occurred during plant shutdown. Activities during' a two-week maintenance outage and subsequent power operations were marked by several personnel errors resulting in plant transients and reactor scrams.
NRC inspection activities have yielded mixed results at NMP-1. A $$FI followup inspection and special intimidation and harassment inspection showed clear improvements in these areas. After two inspections the E0P program was determined to be adequate. The Integrated Assessment Team Inspection (IATI) revealed that the NMP-1 Restart Action Plan (RAP) was the degree in place, well disseminated and generally understood; howeverTwoofthefiveunderlyingca of implementation varied.
management deficiencies had not been adequately addressed:
problem solving and setting standards for performance. The licensee established an Independent Assessment Group to overview RAP implementation and provide the Executive Vice President, Nuclear with valuable feedback on the process. An AIT "as sent to review the circumstances surrounding a contaminated Radwam v tiding. The licensee has subsequently established a cleanup pro ram with an aggressive personnel exposure v
budget for the decontamination. Progress in making Unit I ready for restart has been slow because of the licensee's cautious approach and underestimating the time needed to complete 125Vdc system modifications.
NRC inspection activities at NMP-2 indicate a declining performance trend-since the last senior management meeting. The requalification program was declared unsatisfactory during a recent NRC team inspection. Additionally, routine followup of events has identified several avoidable mistakes. As a result, the licensee has implemented a significant retraining effort with its operators and is reassessing previous corrective actions in deficient areas. The licensee has also recently made some management changes at NMP-2 to better support operations.
The New York Public Service Commission recently settled with Niagara Mohawk Power Corporation on a rate case proceeding-providing stability for HMP-2 funding. The settlement requires executive salary caps, corporate self-assessments, with financial incentives attached to the results, and a formal study on the viability of continued operations of NMP-1. Senior NRC management was concerned that the self-assessment was scheduled to coincide with.the completion of the NMP-2 outage and the NMP-1 power ascension program, diverting management attention from these key activities. Additionally, NRC senior management was concerned about the depth of HMPC management and their ability to manage two diverse plants. Continued close NRC monitoring is appropriate for both NMP-1 and NMP-2.
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Calvert Cliffs 142
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Ca,1,nyt. Miffs) as placed on r 1988 meetinfl. The lic see developed a long-tern Performance leprovement Plan (PIP)<nApril1989. Problems discovered during an NRC Special Teen Inspection (STI) conducted in March 1989 and plant events included poor work control, procedure adherence, and procedure adequacy. The $TI team 4
I also found an excessive emphasis on production over safety and quality of activities. Both units were shutdown in May 1989 because of a problem with Unit 2 pressurizer heater sleeve cracks. The problem was subsequently Letter (CAL) process used exclusively on Unit 2, but Confirmatory Action traced to a 89-08 was issued to document a licensee connitment not to restart either plant until a nun 6er of corrective actions had been taken, including resol tion of the Unit t pressurizer heater probles.
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In August 1989, Mr. C. H. Poindexter was named as Vice Chairman of the Baltimore Gas and Electric Board of Directors responsible solely for i
improv1rsg Calvert Cliffs operations. This elevated the Nuclear organira-tion to the direct attention of the board of directors. The li:ensee also conducted a self-assessment in the SALP functional areas and ) resented the findings to the NRC at the mid-SALP review in August 1989. Tie licensee appeared to be more self-critical of their performance than the NRC, but felt that tneir performance was turning around. The NRC concluded that activities at Calvert Cliffs did not provide an adequate opportunity to trend performance.
The NRC conducted an Operational Readiness Assessment Team (0 RAT) l l
inspection in November 1989.
Controls for the maintenance and surveillance areas were improved; however, the tighter controls had resulted in a significant >acklofi of maintenance activities which could impact the scheduled date for Un't I restart. Quality assur&nce and safety verification activities were generally improved and could support operations except for corrective action programs which were not well coordinated.
The operations area was im) roved with the exception of l
safety tagging, equipment control, and tie adequacy of operating procedures.
An NRC inspection also determined that licensee commitments for Low Temperature Over Pressure (LTOP) Protection were not properly implemented and that this deficiency should have been identified >y licensee analyses in 1987.
NRC senior meaagement was concerned that licensee 'nprovements were l
progressing more slowly than expected as indicated ')y the ORAT and LTOP inspection findings. The licensee has recently rcorganized the site to three management organizations with broad responsibilities that could cause overlapping functions and a lack of accountability. An NRC Calvert Cliffs Assessment Panel is still reviewing the licensee's PIP and a SALP Board will be convened in February 1990. Further inspections of the licensee's readiness for restart will also be required before release from CAL 89-08. Based on these activities, close monitoring of licensee activi-ties related to the readiness for restart and the longer term PIP is warranted.
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Surry.182 I
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Surry has,be i
nd was identified as a Category 2 plant at the May 1989 meeting as a sult of numerous events which resulted in escalated l
significant equipment problems and weaknesses that i
enforcementactions,breakdowninmanagementcontroYofcorrectiveactions.
demonstrated a major l
An escalated enforcement package composed of several Severity Level III violations and a $500,000 civil Penalty was issued on May 18, l'989, i
Significant management changes have been made starting in late 1988 and continuing through 1989.
i Surry, in general, has made progress since the last senior managment Lmprovements in the upgrade of their staff, the plant material meeting.
L condition, and efforts to develop accurate design basis documentt.tton are The licensee's primary focus has been on the restart of most notable.
both unitst however, the licensee has pursued several improvement projects including the development of design basis documents, a Maintenance and Operations Procedures Upgrade Program (M0 PUP) affecting about 7500 procedures, and an Administrative Control Upgrade Program (ACUP) involving about 350 administrative procedures. An emergency exercise conducted in November.
I 1989 was considered fully successful and significantly better than the two The latest Surry $ ALP period ended on June 30,1989.
previous exercises.
Surry received Category 3 ratings in Haintenance/$urve111ance Emergency Preparedness,PlantOperations,RadiologicalControls,andSafety Assessment / Quality Yerification.
The licensee restarted Unit 1 in June 1989. The restart was uneventful and professionally managed although difficulties were encountered in meeting technical specification requirements for control room habitability.
Although initially identified at North Anna in 1987, this problem was not The promptly reviewed by Surry and resolution delayed the Unit I restart.
licensee restarted Unit 2 in September 1989. During the Unit 2 restart, one automatic reactor trip resulted from equipment problems and one auto-Also during restart, Surry matic trip was caused by operator error.
experienced several problems with radiation area access control.
These problems appear to be a result of management expectations and requirements not being fully communicated, understood, and accepted by workers due to the complacent attitude of recent years.
k NRC senior managers concluded that further improveng,nts at Surry were g
require.d before decreased attention was warranted. [
Additional individual and team ins'pections will be planned a'round the'11censee's schedule for implementing, Management meetings will continue to be held programs 'and modifications.
frequently with the licensee.
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Shu tdown. p l a nt L. reeu t ri ne. NRC.a u t bor l a s t i on. to. Ope ra te. and, wh i ch. the. htC i
wq u.sioniser. c: oseh s
Browns.Ferr,y Browns Ferry has been of considerable concern to the NRC for the last six years.
In February le84 TVA initiated a Regulatory Performance Is.
provement Program (RPIP) at Irowns Ferry because of an unsatisfactory enforcement history. In 1985 the three units were shut down and defueled due to poor sal.P performance, significant enforcement actions, several operational events, equipment failures, and the inability of management to identify and correct problems.
Browns Ferry was identified as a Category 3 plant at the October 1986 senior management meeting.
Management changes continue to be made. A new Plant Operations Manager position was created and filled. Also, a new Compliance Manager was hired, i
J The licensee has targeted Unit 2 restart for mid May 1990. However,addi.
tional problems identified since the last meetin include an unsatisfactory lir,ensed operator requalificatico program and si nificant problems with procedures in the surveillance program.
Additio ally, TVA has significant
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modification woik remaining in the areas of seismic design (hanqers and supports) and electrical design (fuse and cable replacement). "hese prob-lem areas are expected to impact the restart schedule. Other problem areas being worked on by the licensee include a high number of personnel errors and various hardware issues.
A number of NRC inspections conducted since the May 1989 Senior Management meeting yielded mixed results. Good results were obtained from the Appendix R and m.:intenance team inspections, but surveillance and design change inspections weit less positive. A full scale emergency preparedness exercise was successfully conducted on November 1 wid 2,1989.
Progress at Browns Ferry appears to be slow, out improvements continue to be made.
NRC senior management decided that continued rating as a Category 3 plant was justified p.ending release for startup*after a j
4 complete readiness assessment.
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Additlocal. Topics. Discussed 1.
Discussions with the Chairman Chairman Carr attended the meeting on the morning of January 22,he and ace essed the managers on various topics. He was pleased with t his,vess made on the priority issues he identified at the beginning of pre tenure as Chstrman and urged first-line staff participat'on in revision of the NRC Five-Year Plan to build connitment to the Commission's i
goals. The Chairman emphssized career planning, employee training and f air appraisals as critical elements for ensuring an adequate supply'of qualified personnel to meet NRC needs of the future. He hoped that the staff's efforts for internal quality assurance would concentrate on improving the content of written documents, while minimizing the number of concurrences and amount of time s >ent on editorial reviews. He also encouraged the staff to bring to tie Commission's attention divergent views on issues to be considered by the Comission. Chairman Carr wants SALP reports to become more concise and timely in the future.
2.
Ma terials. licensees i
Six materials licensees were discussed at this senior management meeting. Each licensee had been previously discussed at the May 1989 meeting.
Safety Light Corporation of Bloomsburg, PA, was discussed because of staff concerns with site contamination and the financial ability of the licensee to pay for the cleanup. Operations ceased when DOE stopped shipping trit 1um to the sitet the company has made some arrangements to operate in Canada.
On August 21, 1989 the NRC issued an order to Safety Light Corporation to establish a $1 million trust fund for cleanup. The ASLB has subsequently stayed the order.
Combustion Engineering of Windsor, CT was discussed because of breakdowns in the management of radiation protection and nuclear criticality. The licenseeimplementedanIntegratedImprovementPlan(!!P)anddecidedto shif t fuel pellet productio.n to the Hematite facility. The Windsor, CT f acility will be decontaminated and used only for fuel element assembly.
Radiai,lon Sterilizers, Inc. of Decatur, CA, and Westerville, OH, was discussed because of contamination problems in Decatur caused by leaking Cs-137 WESF capsules. Only one cesium chloride cassule had failed at Decatur, but several were found to be deformed. Tae cassules will all be shipped back to the DOE facility at Hanford, WA, when siipping casks have been certified.
Based on the number of capsules at the facilities, their transfer to Hanford, WA, should take approximateb one year.
3M Company was discussed because of inadequate management oversight and quality control on the production and distribution of static eliminators which led to widespread incidents of leakage and contamination in 1988.
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'I All of the static eliminators have been recalled and field investigation l'
and decontamination work has been completed. The static eliminator distribution license has been suspended and all of 3M's material license 4
activities have been examined. 3M has made improvements in its product QC by establishing an independent organization dedicated to QCg however, senior management involvement is still limited and some problems continue.
Advanced Medical Systems (AMS), Inc., was discussed because of contamination at the facility in Cleveland, OH, and required plant modifications. There have been no major operetional changes at the facility sine.e the last meeting. The plant modifications are in progress and actions were taken to decontaminate the facility to reduce the radiation levels. A contami.
nation control program has been established and the AM$ material license has been renewed.
NJ, was discussed to update NRC United States Testing Company of Hoboken,f their corrective action program.-
management on the implementation status o m
The plan appears to be effectively implemented to ensure proper management of current activities. However,"the Department of Transportation recently fined the licensee for improper shipment of radioactive materials.
3.
NRC Inspector Fitness for Duty i
10CFR50.26, " Fitness for Duty Program " required licensees to implement their programs by January 3, 1990.
NRC inspectors are exempt from the Manual Chapter 4161, Drug Policy Statement (gram outlined in the NR licensee's program and covered by an NRC Pro1987),DrugTestingManual (1988)andDrugTestingPlan(1988). The EDO discussed the provisions of the NRC Fitness for Duty (FFD) program and compared it to the industry p.aogram. The FFD program has been implemented for all non-bargaining unit employees and negotiations are in progress with NTEU for mandatory bargaining unit employee participation. Guidance to the regions on NRC FFD program implementation for inspectors was provided by NRIt memora m on Standards of Conduct (dated Jur,e 22,1989) andFitnessforDuty(datedDecember26, 1989).
4.
NRC Internal Quality Assurance (QA) Program As a followup from the last senior management meeting, the EDO, Office Directors and Regional Administrators conducted several meetings on development of an internal NRC QA program.
It was decided that each office should develop its own QA function because of the diversity of processes and products within the NRC. Regional QA programs should be similar. The NRR program includes 13 quality criteria and has been implemented on a trial basis resulting in improvement in NRR management controls and product quality.
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3 5.
Timing of Diagnostic Evaluations with SALP The timing of an AE00 Diagnostic Evaluation in close proximity to the end of a SALP period has the potential for sending mixed signals to the licensee, inefficiently using NRC resources and creating an unnecessary burden on licensees responding to both the SALP and Diagnostic Evaluation j
reports. ThePaloVerdeDiagnosticEvaluationwasconductedjustafter j
the end of the SALP period and the SALP report was issued during the inspection. The Arkansas Nuclear One (AN0) Diagnostic Evaluation was I
conducted shortly before the end of the SALP period and the results were i
incorporated into the SALP process and report. The degree of flexibility j
in SALP schedules was discussed. NRC senior management decided that Diagnostic Evaluations must be scheduled to support senior managemer.:
meeting deliberations and that coordination between AE0D and the regions regarding potential interactions with SALP should minimize impacts.
6.
Employment Guidance for NRC Personnel As a followup item from the last senior management meeting, NRR drafted a policy statement, " Actions When NRC Employees Consider Employment with Regulated Entities." The purpose of the policy statement is to provide guidance for compliance with 10CFR2 for avoiding conflicts of interest without infringing on NRC employees' rights. The proposed degree of notification and action required by management depends on whether or not the employee is directly involved with the regulated entity being considered for employment. Several questions arose concerning the definition of regulated entities, direct involvement and how to implement proposed actions.
It was decided that further review by NRR and OGC should occur before issuing the policy statement for review.
7.
DOE High Level Waste (HLW) Program Changes impact on Waste Confidence l
Decisions l
NMSS provided a history of the DOE and Congressional activities concerning l
HLW from 1982 to the present. The recent DOE report (November 29,1989) provides plans to have a repository in operttion before the year 2010 and monitored retrievable storage (HRS) ava11abit by 1998. Congressional hearings are expected on the newly proposed slip of 7 years in the HLW repository schedule. Such a major slip may pese a challenge to the NRC Waste Confidence Finding, although recently prcoosed changes in that finding saw the repository available as late as the year 2025. The NRC Waste Confidence Finding sees safe storage of speit fuel for at least 100 years which is based on 40-year life of the plant, 20-year license renewal and 30-year storage period.
8.
NRC/ EPA 0'verlapping Responsibilities NMSS discussed the interface issues between the EPA and the NRC as well as how these issues arose from legislation, court orders and vested authorities of the two agencies. The major areas of concern included the 18 1
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Clean Air Act, Below Regulatory Concern, HLW and LLW Stanerdh Urat:m l
Mill Tailing regulations and use of the Superfund for site cleanup.
Interface problems have arisen between the agencies because of different 4
risk management approaches, enforcement strategies and methods of imple-menting regulations. Historically, there has been inadequate integration and a general lack of understanding between the agencies. Several areas of improvement are currently being considered, including legislative Memoranda of Understand 1nn, joint task forces, interchanging changes,d third party resolution o" conflicts. SECY 89-383, dated staff an December 27,1989, outlines key NRC concerns in this area.
9.
Maintenance Effectiveness Indicator Development TheMaintenanceEffectivenessIndicator(MEI)isderivedfromINP0NPRDSdata I
to identify changes in failure rates for selected systems and components
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dominating outages. The systems and components were selected for plant groupings by NSSS and plant size. These failure rates can then be trended for use with maintenance cause codes and overall indicators to assist in assessing licensee maintenance program trends. The sensitivity of the indicator to reporting consistency and accuracy was discussed.
It was noted that the ME! data trends are affected by refueling cycles. Different characteristics are observable at different plants. A trial program is l
being conducted with a group of utilities through NUMARC to examine limitations of the data and relationship between reported component failures and the NRC definition of raintenance.
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- 10. NRC Response to Abandoned Radiocctive Material in Public Abandoned radioactive material has been found in all NRC regions and the response by the states has been varkd. NRC Regional Officers are l
neither equipped nor located to effectively retrieve and store material.
NMSS is pursuing resolution with DOE and progress has been made identifying the issues and seeking pertinent legal advice. A draft MOU is being prepared between DOE and the NRC.
In the interim DOE has agreed to support specific requests from the NRC on a case by-case basis when an emergency exists.
- 11. Licensing a Uranium Enrichment Facility Louisiana Energy Services (LES) Inc. was formed to develop a uranium enrichment facility using gas centrifuge technology. The partners in the project are Duke Power, Louisiana Power and Light Northern States Power Inc., and Urenco. LES Inc. will utilize a patented Co., Fluor Daniel, from Urenco which will,also be a minority owner and the foreign technology principal supplier of equipment. A site has been selected near Shreveport, LA, and operations are scheduled to begin in 1995. Several major issues remain to be resolved in the licensing of this facility including national energy and security policy questions about foreign ownership, international agreements and safeguards of equipment and material. The licensing pro-ceeding is expected to be very similar to a Part 52 proceeding since the centrifuge plant is essentially a complete standard design.
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- 12. Guidelines for Removal of Plants from the NRC Watchlist t
The proposed guidelines outlined in NRR Memorandum dated November 1, 1989 ware reviewed and discussed at the meeting. These guidelines were developed from a historical review of the reasons for removing plants from previous i
watchlists and were organized into four general criteria:
(1)rootcause of problems identified and corrected. (2) improved silf-assessment and problem resolution, (3) licensee management organization and oversight, and(4)NRCassessmentcomplete. A checklist expanding these criteria will undergo further review and development and the ED0 will promulgate the guidance when fully developed.
13.
Identification of Good Performing Plants Several plants were recomended as candidates for a list of plants with sustained outstanding safety performance. However, only a few achieved 1
this recognition using the criteria established by the NRR Memorandum plant should be:
(1)one thatagoodperforming'ormerand(2)oneatwhich dated November 30, 1989 the NRC would publicly announce as a good per the NRC would reduce the inspection effort. Based on these criteria, the following plants were selected as good performers:
Yankee Rowe Kewaunee Prairie Island 1 and 2
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Calloway Other plants discussed with ongoing noteworthy performance, but without reduced inspection:
Diablo Canyon 1 and 2 St. Lucie 1 and 2 Susquehanna 1 and 2
- 14. OfficeofInvestigations(01)ReportTimeliness,ReferralsandEnforcement l
A new O! report format is being developed for implementation before the next senior management meeting. The new report format will provide a brief summary of conclusions with less narrative t5an before. Statements of evidence will also be attached to the report for supporting information.
01 Field Offices are signing out the reports if no element of w111 fulness is determined by the investigations. 01 requested that referrals include sufficient information to initiate an investigation and that the staff keep them informed if additional information changes the nature of the potential violation being investigated. Future prioritization and schedulin'g meetings for investigations may be delegated to the 01 Field Offices from headquarters to provide better response to Regional Admini-strators and more efficiently utilize resources. 01 will investigate whether the Comission needs to approve these proposed changes based on the previous approval of guidelines for 01 initiation, establishment of priorities and termination of investigations.
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e ENCLOSURE 4 I
NRC Senior Management Meeting January 22-23,1990 Region V i
LIST.0F. ATTENDEES 4
J. Taylor E00 H. Thompson, DEDS T.Murleyk,NRR J. Sniere NRR F.Mirap11a,NRR J. Part ou,.4RR D. Crutchfield, NRR E. Jordan, AE00 R. Bernero, NMS$
1 E. Be:kjord RES J.Scinto,dGC B. Hayas, 01 W. Russell, RI 1
S. Ebneter, RI!
A. Davis, Rll!
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R. Martin, RIV J. Martin, RV l
J. Lieberman, OE T. Gody, NRR T. Martin, R111 J. Dyer, OEDO l
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