ML20217M369

Insp Rept 50-482/98-07 on 980330-0403.No Violations Noted. Major Areas Inspected:Operational Status of Licensee Emergency Preparedness Program

ML20217M369
Person / Time
Site:	Wolf Creek
Issue date:	04/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217M365	List: ML20217M361 ML20217M369
References
50-482-98-07, 50-482-98-7, NUDOCS 9805040494
Download: ML20217M369 (16)

See also: IR 05000482/1998007

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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REG!ON IV

Docket No.: 50-482

License No.: NPF-42

Report No.: 50-482/98-07

Licensee: Wolf Creek Nuclear Operating Corporation

l Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane, NE

Burlington, Kansas

Dates: March 30 through April 3,1998

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inspector (s): Thomas H. Andrews, Emergency Preparedness Analyst

i Margaret Kotzalas, intern

Approved By: Blaine Murray, Chief, Plant Support Branch

Attachment: Supplemental Information

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9805040494 900430

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EXECUTIVE SUMMARY

Wolf Creek Generating Station

NRC Inspection Report 50-482/98-07

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This routine, announced inspection focused on the operational status of the licensee's

emergency preparedness program. Emphasis was placed on changes that had occurred since

the last routine emergency preparedness inspection.

Plant Succod

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The emergency preparedness program was properly implemented. All events reported

to the NRC operations center since July 1996 were properly evaluated and classified.

The emergency preparedness training program was implemented satisfactorily. The

emergency planning staff was well trained and maintained good awareness of industry

issues. The performance improvement request process effectively tracked resolution of

emergency planning issues in need of corrective actions. The emergency preparedness

program audits were performed by qualified personnel and were of proper scope and

depth.

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The maintenance of emergency response facilities was generally good. However, some

issues related to equipment and supplies used in the emergency cabinets were

identified. Three self-contained breathing apparatus bottles, one in the control room and

two in the fire brigade locker had low air pressure. The bottle in the control room had

approximately 2000 psi, and the two bottles in the fire brigade locker had approximately

3000 psi. Full pressure for these bottles was 4500 psi and the surveillance procedure

required replacement of bottles with less than 3000 psi (Section P2).

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The process for review of changes to documents and plant design contained sufficient

guidance that included an assessment of the need to perform a 10 CFR 50.54(q) review.

Changes to the emergency plan were properly incorporated into procedures. Licensee

controls were adequate to ensure that changes to the emergency plan and oplementing

procedures were submitted to the NRC in a timely manner (Section P3).

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Crew performance during simulator scenarios was satisfactory. A performance

weakness was identified involving one crew that failed to properly assess plant

conditions which required upgrading to a general emergency. The second crew properly

declared the emergency but required 18 minutes to assess plant conditions, exceeding

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the 15 minute goal. A strength was identified regarding crew turnover briefing technique

(Section P4).

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Reoort Details

IV. Plant Support

P1 Conduct of Emergency Preparedness Activities (93702)

The inspectors reviewed licensee events and assessed the appropriateness of the

emergency action levals used to classify events, timeliness of notifications, and i

effectiveness of action item identification and resolution. All events reported to the NRC I

operations center since July 1996 were propMy evaluated and classified. There were l

no emergency declarations between July 22,1996, and March 30,1998. I

P2 Status of Emergency Preparedness Facilities, Equipment, and Resources I

a. Insoection Scope (82701-02.02)

The inspectors toured the emergency response facilities and reviewed equipment

inventories to determine if they were adequately maintained, technically adequate, met

NRC requirements, licensee commitments, and were appropriately incorporated into the

emergency plan and implementing procedures. Licensee offsite communication circuits

were included in this determination.

b. Obsemations and Findinas

The inspectors toured the control room, auxiliary shutdown panel rooms, technical

support center, operations support center, emergency operations facility, and alternate

emergency operations facility. Selected procedures located in the facilities were

checked to confirm they were the latest revision. The inspectors conducted a

communication test between selected phones and the NRC Operations Center to confirm

that phone circuits were operational. With the exception of the attemate emergency

operations facility, all emergency response facilities were single-use facilities and

maintained ready for use. The alternate emergency operations facility located in

Emporia, Kansas, was found to be easily accessible and offered adequate space and

communications equipment for use as a backup facility.

The licensee maintained emergency preparedness supplies and kits in the control room,

operations support center, and emergency operations facility. The inspectors observed

l the condition of equipment and supplies stored in these locations. Inspectors observed

that three self-contained breathing apparatus bottles, one in the control room and two in

the fire brigade locker, had low air pressure. The bottle in the control room had

approximately 2000 psi and the two bottles in the fire brigade locker had approximately

3000 psi. Full pressure for these bottles was 4500 psi and the surveillance procedure

required replacement of bottles with less than 3600 psi. The licensee quickly replaced

these bottles with bottles filled above the required pressure.

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The inspectors reviewed the licensee's procedures and inspection records to determine if

the bottles with low pressure constituted a regulatory concern. The bottles were

inspected on a monthly basis and were due to be inspected within 2 days from the time

they were discovered. There were no indications that the bottles contained low pressure

during the previous inspection. One of the bottles was in a case with an inventory seal,

indicating that the case had not been opened since the inspection. Therefore, it was

determined that these bottles had lost pressure since the previous inspection. The

licensee indicated that the issue would be reviewcJ to determine if additional actions

were nerassary.

The inspectors asked the shift superintendent questions regarding the use of the

self-contained breathing apparatus and about the location of replacement air bottles.

The individual identified several areas in the plant where replacement bottles could be

found. Based upon discussions with personnel responsible for maintaining these bottles,

it was determined that some of the locations listed by the shift superintendent were not

valid locations. After this was discussed with the licensee, plant personnel were

informed via an E-mail message regarding the location of spare air bottles for self-

contained breathing apparatuses. The licensee's response addressed the inspector's

concems.

The inspectors toured the warehouse where the air bottles were refilled. The area

around the air compressor was properly maintained. The individual accompanying the

inspectors was qualified to fill these bottles and was very knowledgeable regarding the

process.

The licensee maintained silver-zeolite cartridges for air-sampling during emergencies.

Based upon observations at other facilities, silver-zeolite cartridges had a shelf-life

expiration date. The inspectors noted that the cartridges used by the licensee did not

have a shelf-life expiration date. The licensee investigated procurement records and

provided a letter from the vendor stating that the cartridges had an indefinite shelf-life as

long as the package seal was not broken. The package seal for the licensee's cartridges

had not been broken.

The licensee contacted the vendor to determine why other licensee's had shelf-life dates

on their silver-zeolite cartridges. The vendor informed the licensee that as of

February 1998, the estimated shelf-life for silver-zeolite cartridges was 10 years. A major

portion of the licensee's silver-zeolite cartridge inventory, 80 of 100 cartridges, were

approximately 15 years old.

The licensee learned that the vendor had not informed all of their customers of the

change in estimated shelf-life. The vendor was providing a copy of the letter regarding l

the revised shelf-life only with new purchases. Therefore, the licensee was unaware of j

this change until the issue was raised by the inspectors.  !

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The licensee initiated procurement of new cartridges to replace the 80 affected

cartridges. Because the remaining supply of silver-zeolite cartridges was very limited,

the licensee developed a contingency plan regarding how the remaining cartridges would

be dispersed and used if an emergency were to occur prior to the delivery of the new

supply. Details regarding this contingency plan were distributed to health physics

technicians and other staff to ensure that personnel responding to an emergency would

know of this temporary change. The inspectors determined that the licensee's actions i

regarding identification of the problem, procurement of new cartridges, and development i

of a contingency plan prior to the arrival of the new cartridges were very good.

c. Conclusions

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The maintenance of emergency response facilities was generally good. However, some

issues related to equipraent and supplies used in the emergency cabinets were

identified. Three self-contained breathing apparatus bottles, one in the control room and

two in the fire brigade locker, had low air pressure. The bottle in the control room had

approximately 2000 psi, and the two bottles in the fire brigade locker had approximately

3000 psi. Full pressure for these bottles was 4500 psi, and the surveillance procedure

required replacement of bottles with less than 3600 psi. Response to the discovery of

the revised shelf-life of silver-zeolite cartridges was very good. i

P3 Emergency Preparedness Procedures and Documentation

a. Insoection Scooe (82701-02.01)

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The inspectors reviewed:

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The licensee's process for identifying changes to the plant and to documents that '

require an assessment of the emergency plan impact (Procedure Al 26A-003,

" Regulatory Evaluations [other than 10 CFR 50.59)," Revision 0, and Procedure

AP 26A-003, " Screening and Evaluating Changes, Tests, and Experiments,"

Revision 3).

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The licensee's program for tracking exercise objectives, drills, and exercises to

determine if the required elements were properly scheduled.

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The licensee's process for documenting annual reviews of and changes to

emergency action levels by state and local agencies.

b. Observations and Findinos

The inspectors reviewed procedures to determine the process used by the licensee to

ider,tify changes that required a review of the impact upon the emergency plan. Through

discussions with the licensee, the inspectors determined that the process was known

and understood by people who perform these reviews.

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The inspectors ensured transmittal records for plan and procedure changes were correct.

Based upon a review of selected records, the inspectors determined that the licensee

submitted copies of the changes within 30 days of implementation. The inspectors noted

that one proposed plan change had been submitted to the NRC for prior approval and j

that the licensee was waiting on NRC response regarding this change. The inspectors I

confirmed that the proposed changes had not been implemented. The inspectors

confirmed that changes to the plan were incorporated into the procedures.

The licensee produced documentation for the review of emergency action levels with

offsite agencies. Letters of agreement were reviewed as required by the licensee's

emergency plan. The plan required annual and biennial renewal. The inspectors

observed that the review of the letters of agreement was well documented during the

year that the letters were not renewed. For the year that the letters were renewed, the

review of the letters of agreement was " implied"in that there was no specific

documentation to show that the review was performed. The licensee contended that

because the letter was renewed, other than to confirm that the terms did not reflect a

reduction in capability, no documented review was required.

One letter that was supposed to be renewed in 1997 was not renewed until January

1998. The licensee had contacted the organization in June and realized that in

December, the organization had not responded. Due to the holidays at the end of the

year, the licensee experienced difficulty finding the appropriate person to obtain the

revised letter. The licensee stated that their program was being changed to ensure that

the process was tracked with longer lead times. The inspectors determined that the

licensee's actions were appropriate,

c. Conclusions l

The process for review of changes to documents and plant design contained sufficient j

guidance that included an assessment of the need to perform a 10 CFR 50.54(q) review. l

Changes to the emergency plan were properly incorporated into procedures. Licensee

controls were adequate to ensure changes to the emergency plan, and implementing

procedures were submitted to the NRC in a timely manner.

P4 Staff Knowledge and Performance in Emergency Preparedness ,

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a. Insoection Scoce (82701-02.04)

The inspectors observed the performance n' two operating crews using a scenario

developed by the licensee and ran on the plant-specific control room simulator. The

inspectors assessed the ability of control room teams to recognize accident conditions,

declare emergencies using the appropriate emergency action levels, perform offsite

notifications, initiate protective actions for onsite personnel, and to make protective

action recommendations to offsite agencies.

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b. Observations and Findings

As part of the routine training cycle, the licensee developed a scenario using the control

room simulator to challenge the operating crews and to demonstrate their proficiency in

controlling the plant and implementing the emergency plan. The scenario involved three

emergency classifications:

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Ned: Based upon an unsuccessful automatic trip of the

plant with a successful manual trip of the plant

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Site area emergency: Based upon loss of coolant inside containment

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General emergency: Based upon unexplained containment pressure

decrease indicating loss of the containment barrier

The scenario was scheduled to run approximately 90 minutes with approximately

30 minutes between each emergency classification. The inspectors' observations

focused upon event assessment, classification, notification of offsite authorities,  !

notification of onsite personnel for assembly / evacuation, dose assessment, and

protective action recommends.tions.

Both crews performed very wel! up to the point of the general emergency declaration.

Supervisory oversight, internal communications, event recognition and classification, and

the notification of offsite agencies were performed well. The use of three-part

communications by both crews was consistently applied throughout the scenario.

Habitability of the control room was monitored by a health physics technician. Dose I

projection calculations were property performed by a chemistry technician on each crew.

Both crews showed good awareness by anticipating that the escalation to a general

emergency would likely involve the loss of containment. However, at the point where the

decrease in containment pressure was identified, one crew attributed the decrease to the

operation of the containment coolers. Therefore, a general emergency was not declared. l

In the scenario, there were approximately 2000 cubic feet per minute leakage from the

containment. Pressure was decreasing approximately 1 pound every 10 minutes, even

though temperature inside containment was increasing. Containment coolers operate to

reduce the pressure by reducing the temperature. Because containment temperature

was continuing to increase, the pressure decrease could not be attributed to the

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operation of the containment coolers.

Because this crew did not declare a general emergency, key elements of the emergency

plan associated with the general emergency Om..fication of offsite agencies and

protective action recommendations) were not demonstrated.10 CFR Part 50,

Appendix E.IV.F.2.g, requires that deficiencies or weaknesses identified during drills or

exercises shall be corrected. The review of corrective measures to be taken by the

licensee was identified as an inspection followup item (IFl 50-482/9807-01).

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The second crew declared the general emergency but exceeded the goal of 15 minutes

to assess the plant conditions to make the declaration. The declaration took 18 minutes.

This was 3 minutes longer than the goal provided in Emergency Preparedness Position

No. 2 issued by the Office of Nuclear Reactor Regulation on August 17,1995.

Emergency Preparedness Position No. 2 provided guidance to NRC staff conceming

timeliness of classification of emergency conditions by a licensee to classify an event

and declare an emergency once indications are available to control room operators that

an emergency action level had been reached or exceeded. This document established a

basis for a 15-minute goal for declaring events. In determining a reasonable period of

time for operators to assess and classify an emergency condition, several factors

goveming the classification process were considered. These were: (1) the inherent

need to rapidly communicate emergency conditions to offsite authorities, (2) the

obligation of licensees to have adequate personnel available at all times for assisting the

shift supervisor / emergency director in classification of emergencies, and (3) the use of

objective and unambiguous criteria for classification.

Emergency Preparedness Position No 2 stated that the 15-minute goal may be used as

one of the guidelines for triggering further, more detailed staff evaluation of a licensee's

performance in responding to an actual event. This document emphasized that the 15-

minute guideline is not a regulatory requirement but that it may be used by the staff in its

followup evaluation. Other factors could be considered were classification level, safety l

significance of the event, historical performance of the licensee in event classification,

and root cause for the delay.

The inspectors considered the following factors:

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Classification level: General emergency

+ Safehr sianificance Loss of the final fission product barrier, release in

progress and protective action recommendations

were delayed

- Historical oerformance: The failure of the first crew to declare the general

emergency

According to the licensee, management expectations were met in that the correct

declaration was made. The inspectors acknowledged that the 3 extra minutes delay

would not significantly affect the protective action recommendation process. Had the

performance of the first crew not been considered, then this issue would likely have only

been a discussion item with the licensee. However, the inspectors considered that the

delay was the result of the second crew having trouble assessing plant conditions. The

difference between the first and second crew was that the second cre'n declared the

general emergency. The performance of the second crew regarding timeliness matters

was not considered a weakness or deficiency. However, the inspectors pointed out that

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there may have been a common factor associated with assessing plant conditions for

both crews. I

c. Conclusions

Crew performance during simulator scenarios was satisfactory. A performance  !

weakness was identified involving one crew that failed to properly assess plant

conditions that required upgrading to a general emergency. The second crew properly

declared the emergency but required 18 minutes to assess plant conditions, exceeding

the 15 minute goa!. A strength was identified regarding crew tumover briefing technique.

P5 Staff Training and Qualification inEmergency Preparedness

a. Insoection Scoce (82701-02.04)

Using Inspection Procedure 82701, the inspectors reviewed training records for key i

emergency response personnel and reviewed emergency drill / exercise documentation.

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b. Observations and Findinos

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The inspectors selected 7 positions within the Emergency Response Organization and l

reviewed the training records of 14 people who fill those positie.m. The positions I

included duty emergency manager, dose assessment supervisor, emergency operations I

facility administrative assistant, maintenance emergency coordinator, onsite survey team

director, operations support center chemistry technician, and health physics network

communicator. It was determined that all 14 people had received training required by

Emergency Plan Procedure EPP 02-1.2, " Training Programs," Revision 22, and that all

qualifications were current. The use of monthly table tops and/or drills was considered a

strong element of the EP training program.

The licensee provided three methods forjob incumbents to comment on the quality and

content of the training received. These included:

. Use of Form APF 30E-002-01, "End of Course Training and Instructional Quality,"

was available to trainees following all training classes.

. Writing a performance report efter the table top exercises that identified issues to

be reviewed prior to the next exercise.

. Preparing a performance improvement request to initiate the routine corrective

action process.

There was also a method available for team leaders to provide input on training needs.

During the duty emergency managers / duty emergency directors meeting, oversight of

generic emergency plan training issues would be discussed as the need arose.

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Feedback from emergency response organization trainees and supervisors was routinely

solicited for improvements and additional training needs. The emergency preparedness

training program effectively addressed the subelement of program feedback.

The inspectors observed that emergency planning staffing had been reduced from 10 to

6 positions since the last inspection. The inspectors reviewed work assignments and

determined that the major program areas were assigned to individuals with either primary

or secondary responsibilities. The redundancy of assignments appeared to be sufficient

to ensure that the program would be properly maintained. The inspectors determined

that the reduction in staffing did not adversely impact the performance of the

organization.

The emergency planning staff received training on the specific tasks required for their

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positions. For example, maintenance of instructor certification, qualifications for

procedure writing,50.59 and 50.54(q) evaluations are some of the requirements of the

staff positions. The training for these tasks was provided by other departments such as

operations, engineering, and training. In addition to in-house training, the staff attended

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industry-sponsored seminars and courses.

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The inspectors reviewed the process used by the licensee to track respiratory protection

qualifications of on-shift personnel. The inspector determined that the licensee did not

require fit-testing for self-contained breathing apparatuses. The licensee based this

upon OSHA regulations that stated that positive pressure devices did not require

fit-testing. However, after further review, the licensee discovered that the OSHA I

regulations had been recently changed. The new regulations required fit-testing of all

tight-fitting face-piece respirators, which included self-contained breathing apparatuses.

The licensee recognized that they were still in the implementation period for the new

l regulations and stated that their program would be modified to be consistent with these

new requirements,

c. Conclusions

The emergency preparedness training program was satisfactority implemented.

Reduction in staffing of the emergency planning department did not adversely impact

performance of the department. Emergency planning staff was well trained and

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P6 Emergency Preparedness Organization and Administration

a. Insoection Scoon (82701-02.06)

The inspectors evaluated emergency planning's use of the performance improvement

l request process. The following performance improvement requests were reviewed:

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970300, dated January 1,1997

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972820, dated September 16,1997

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. 972827, dated September 17,1997

l- . 972893, dated September 24,1997

. 970671, dated March 3,1997

- 970672, dated March 3,1997

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. 970674, dated March 3,1997

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= 970675, dated March 3,1997

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b. Observations and Findinas -

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j The performance improvement request process was used to track issues identified

l during drills, other forms of training, and self-assessment reports inspectors reviewed

l nine performance improvement requests and determined that the system worked

effectively for emergency planning and that appropriate actions were taken to address ,

the issues.

c. Conclusion

The performance improvemen'. aquest process effectively tracked resolution of

emergency planning issues in need of corrective actions.

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P7 Quality Assurance in Emergency Preparedness Activities

a. Insoection Scone (82701-02.05)

Using Inspection Procedure 82701, the inspectors reviewed the following

self-assessment reports:

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SEL 96-062, "Onsite Emergency Plan Training," February 18,1997 I

. K-481, " Radiological Emergency Preparedness Program," October 16,1997

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b. Observations and Findinas

The inspectors reviewed the self-assessment reports and determined that they met the

requirements of 10 CFR 50.54(t). The audit team members included individuals from the

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emergency response organization and employees of other licensed nuclear power

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facilities.

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l The inspectors reviewed the reports to determine if the offsite interfaces were assessed

as part of the audits. The inspectors observed that the audit for 1997, dated October 16,

1997, did not contain a discussion regarding the assessment of the offsite interfaces.

The licensee produced a supplemental correction sheet showing where they had

discovered this omission on January 5,1998. The supplemental text discussed the

assessment. The licensee confirmed that this information had been transmitted to offsite

agencies in a timely manner after the omission was discovered. The inspectors were ,

satisfied with the licensee's assessment of the offsite interfaces, the documentation of )

the assessment, and the actions taken to make the information available to the offsite

agencies following discovery of the omission from the audit report.

c. Conclusions

The emergency preparedness program audits were performed by qualified personnel

and were of proper scope and depth.

P8 Miscellaneous Emergency Preparedness issues (92904)

P8.1 (Closed) IFl 50-482/9613-01: Exercise weakness - Formulation of orotective action

recommendations

While observing a simulator scenario during a 1996 inspection, the inspectors observed

that a note in Emergency Plan Procedure EPP 01-10.1," Protective Action

Recommendations," Revision 11, was misinterpreted. As a result, a recommendation to

evacuate John Redmond Reservoir was not made. They also observed that dose rates

rather than integrated doses were used to evaluate protective action recommendations.

During this inspection, the inspectors reviewed the licensee's corrective actions and

observed the performance of the control room staff during the simulator scenarios during

this inspection. This followup item was closed based upon the demonstrated i

performance of the second shift crew.

P8.2 (Closed) IFl 50-482/9623-02: Emeroency olannino exercise

The resident inspectors observed the unannounced off-hours emergency drill of i

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October 30,1996. The drill was unsuccessful due to late staffing of the technical support

center. This followup item was closed based upon the review of the corrective actions

and successful performance regarding the staffing within 30 minutes in recent drills.

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V. Management Meetings ,

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X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at an exit

meeting on April 3,1998. The licensee acknowledged the findings presented. During the exit

meeting, licensee management stated that they would likely request a meeting with NRC

management to discuss the characterization of the findings and to discuss the inspection

process used. No information provided to the inspectors during the inspection was identified as

proprietary or confidential information.

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ATTACHMENT

SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED

Licensee

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T. East, Superintendent, Emergency Planning l

J. Johnson, Manager, Resource Protection

B. McKinney, Plant Manager

C. Redding, Licensing Specialist

C. Warren, Chief Operating Officer

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F. Ringwald, Senior Resident inspector  ;

B. Smalldridge, Resident inspector '

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INSPECTION PROCEDURES USED

IP 82701 Operational Status of the Emergency Preparedness Program

IP 92904 Followup - Plant Support

IP 93702 Prompt Onsite Response to Events at Operating Power Reactors

ITEMS OPENED. CLOSED. AND DISCUSSED 1

Ooened

50-482/9807-01 IFl Crew failed to property assess plant conditions to declare a

general emergency (Section P4)

Closed

50-482/9613-01 IFl Exercise weakness - Formulation of protective action

recommendations (Section P8.1)

50-482/9623-01 IFl Emergency planning exercise (Section P8.2)

Documents Reviewed

Plant Documents

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Radiological Emergency Response Plan, Revision 58

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Procedures

Al 26A-003 Regulatory Evaluations (other that 10 CFR 50.59) Revision 0

AP 26A-003 Screening and Evaluating Changes, Tests, and Experiments

Revision 3

Emergency Planning implementation Procedures

EPP 01-1.0 Control Room Organization Revision 15

EPP 01-2.1 Emergency Classification Revision 18

EPP 01-2.3 Accident Assessment and Mitigation Revision 6

EPP 01-4.7 Nuclear Plant Information System Revision 6

EPP 01-6.1 Personnel Accountability and Evacuation Revision 13

EPP 01-7.2 Computer Dose Calculations Revision 19

EPP 01-10.1 Protective Action Recommendations Revision 15

EPP 01-13.1 Emergency Response Organization Callout Revision 5

EPP 02-1.2 Training Programs Revision 22

EPP 02-1.3 Drills and Exercises Revision 13

EPP 02-1.9 Maintenance of Emergency Facilities & Equipment Revision 7

EPP 06-007 Emergency Notifications Revision 0

Performance improvement Requests

970300, January 1,1997

972820, September 16,1997

972827 September 17,1997

972893, September 24,1997

970671, March 3,1997

970672, March 3,1997

970673, March 3,1997

970674, March 3,1997  !

970675, March 3,1997

/ Audits and Assessments

SEL 96-062, "Onsite Emergency Plan Training," February 18,1997

K-481, " Radiological Emergency Preparedness Program," October 16,1997

Drill & Exercise Reports

Letter to Emergency Response Organization dated November 5,1996

Letter to Emergency Response Organization dated January 29,1997

Letter to Emergency Response Organization dated February 28,1997

Letter to Emergency Response Organization dated June 6,1997

Letter to Emergency Response Organization dated August 12,1997

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Letter to Emergency Response Organization dated December 16,1997

Letter to Emergency Response Organization dated January 6,1998

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