ML19260D939

Forwards Addl Info on Shift Technical Adviser & Technical Support Ctr Per NRC 800206 Request

ML19260D939
Person / Time
Site:	Sequoyah
Issue date:	02/07/1980
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Rubenstein L Office of Nuclear Reactor Regulation
References
NUDOCS 8002120640
Download: ML19260D939 (18)

Text

..s .

TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 374o1 400 Chestnut Street Tower II February 7, 1980 Director of Nuclear Reactor Regulation Attention: Mr. L. S. Rubenstein, Acting Chief Light Water Reactors Branch No. 4 Division of Project Management U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Rubenstein:

In the Matter of the Application of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 On February 6, 1980, IVA received an informal request from the NRC for the following additional information on the Shift Technical Advisor (STA) and the Technical Support Center (TSC).

Shift Technical Advisor

1. Type and extent of traini g for the short term

2. Qualification of STA applicants

3. Responsibilities and duties of the STA

4. Duties of the Nuclear Experience Review Panel (NERP)

5. Communication between the STA and NERP Technical Support Center Means for ensuring that employees in the TSC had access to the various plant parameters in response to the NRC request, the fallm?ing information is being forwarded for NRC review.

Shift Technical _ Advisor The qualification of STA's and their responsibilities and duties are specified in the enclosed TVA Division Procedures Manual (DPM No. N7A15). Another Division Procedures Manual (DPM No.

N72A39) is enclosed which provides the requested information o.1 NERP. This DPM is in draft form and will be revised to specify that appropriate licensee event reports will be sent from NERP to the STA, Plant Operations Staf f, and the training center.

The short-te rm training for STA included 112 hours0.0013 days <br />0.0311 hours <br />1.851852e-4 weeks <br />4.2616e-5 months <br /> of academic \

training an. 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of simulator training.

\

1951 001 An Equal Opport Employer

@0 M20 $O

Director of Nuclear Reactor Regulation February 7, lH 3 Academic Training Technical Specifications, Safety Analysis Report, Operating Instructions, Abnormal Operating Instructions, Reactor Coolant System, Chemical Volume Control System, Residual lleat Removal System, Primary / Secondary Containment, Ice Condensers, Contain-ment Spray Systems, Bbin Steam and Steam Dump Systems, Condensate System, Feedwater and Auxiliary Feedwater Systems, Emergency Raw Cooling Water Sy< tem, Component Cooling Water System, Reactor Protection System, Engineered Safety Features Actuation System, and Site Radiological Emergency Plan Simulator Training Thirty hours of normal operations including startup, shutdos., and power ascension Thirty hours of abnormal operations including accident analyses recogni-tion, instrument failure, and degraded core operation Technical Support Center To ensere that TSC employees have access to control room information, a porcable closed circuit television camera will be stored in the TSC. During an emergency, a hand-held camera will be maintained in the control room to relay pictures of the control room to a monitor located in the TSC. Communications between the TSC and the control room are availabic to ensure that the camera is focused on the appropriate monitors as requested by TSC staff.

Very truly yours, TENNESSEE VALLEY AUT110RITY m:

L.' M. Mills, Manager Nuclear Regulation and Safety Enclosures 1951 002

.- r- DRAFT

.. JH:CLT .

8 1/21/80 ENCLOSURE Those listed J. R. Calhoun, Director of Nuclear Power, 716 EB-C REVIEW OF NUCLEAR PLANT OPERATING EXPERIENCE REPORTS - DPM N72A39 1.0 Purpose TVA's nuclear program can benefit from the operating experience of other nuclear plants if we systematically and conscientiously review sources of industry operational information. This review can detect pctential problems before they occur at a TVA plant and find new ideas for solving existing problems and improving plant operation. This division procedure establishes a system to ensure review of operating experience reports, to document their applicability to TVA plants, to ensure proper disposition of all applicable items, and to provide periodic discussion of interdisciplinary and major technical problems among responsible division management.

2.0 Nuclear Experience Review Panel A Nuclear Experience Review Panel (NERP) shall be f ormed to oversee the implementation of this procedure. The panel shall consist of the following members:

Chairman, Assistant to Director (Programs & Administration)

Members, Chief, Reactor Engineering Branch Chief, Controls and Test Branch 1951 .

003

Chief, Nuclear Maintenance Branch Chief, Outage Management Branch Supervisor, Design Review Staff Supervisor, Nuclear Operations Staff Supervisor, Reliability Programs and Planning Staff Supervisor, Quality Assurance Staff Representative, Division of Engineering Design Representative, Office of Power Quality Assurance Staff Secretary, _apervisor, Management Compliance Unit The panel shall meet at least quarterly as scheduled by the Chairman.

An agenda for each meeting will be developed by the Chairman and sent to each member approximately two weeks prior to the meeting. In developing the agenda, the Chairman should consider the following categories for topics of discussion:

1. A general review of problems in meeting the requirements of this procedure.

2. NERP items of an interdisciplinary nature which should receive attention from or could be of interest to the entire panel.

3. Sbjor technical issues facing the nuclear industry (whether they are NERP items or not).

4. Fhjor problems experienced at TVA plants which could be of interest to or eventually affect organizations other than the responsible one.

1951 004

Memberc of NERP may be assigned responsibility for presentations on particular topics at the meetings. These assignments will be shown on the agenda. Other supervisors within NUC PR or other TVA organizations may be invited to make presentations on major technical issues. Members should review and be prepared to answer questions on open NERP items assigned to their respective organizations.

3.0 Dissemination of Material The NERP Secretary is responsible far dissemination of operating ex-perience information for review by the technica) staffs and branches.

The following sources of information shall be received by NERP Secretary and distributed to the appropriate organizations for review.

NRC Inspection and Enforcement Operatinn Experience NRC Current Events, Power Reactors Nuclear Power Exnerience Nuclear Safetv Vendor information letters NRC Inspection and Enforcement - Bulletins to plant superintendents NRC Circulars NRC Information Notices EPRI Reports - Technical Summaries Additionally, all division supervisors and engineers, who periodically read industry trade journals, attend technical meetings, or communicate with vendors, other nuclear utility personnel, or any other nuclear industry representatives, should look for operational problems which 1951 005

could affect TVA's nuclear plants and also new ideas or proposals which could improve the operation of TVA's nuclear plants. Any items which fit this description should be sent to the NERP Secretary for distribution to the appropriate organizations for review.

4.0 Review of BSterial All material distributed by the NERP Secretary requires a prompt review within the assigned organization. This review shall consider whether each assigned item could be applicable to any TVA nuclear plant, even if it is still under construction. A written response shall be made to the NERP Secretary concerning the applicability of each item with a brief justification. ,

An item which is determined to be app 14 cable to a TVA plant will be assigned a unique number as described in Section 5.0 and tracked until its final disposition. For nonapplicable items, the justification may contain nothing more than "this equipment (or design) is not found in TVA plants" but, in any case, must be adequate to indicate that the problem has been invectigated. For example, "we wou.d not operate the system in such a manner" is not an adequate justification but "the RRR operating procedure (01-74) for Browns Ferry which is the only TVA plant with a similar system prohibits operation in the mode described in the LER" is an adequate justification for nonapplicability of an item.

1951 01D6 In addition to indicating the applicability of each item, the reviewer should recommend in his response to the NERP Secretary whether the

item should be sent to the nuclear plants for information, and, if so, which plants. The fallawing types of items should generally be sent to the plants:

1. Descriptions of problems involving or resulting from operator error.

2. Significant transient events whether caused by equipment failure, operator error, or any other reason.

3. Operational problems which resulted from equipment failure if the equipment is similar to that in a TVA plant.

The NERP Secretary shall maintain a tracking system to ensure that a response is received on all iters distributed for review. If a response is not received within one month of initial distribution, the NERP Secretary shall send periodic followup notices to the responsible organization with copies to the Chairman, Nuclear Experience Review Panel until the response is received.

1951 007 5.0 Trackine and Disposition of NERP Items When the review of an item, as described in Section 4.0, determines that it is applicable to a TVA nuclear plant or the JVA nuclear program in general, the item shall be assigned a unique number by the NERP Secretary and shall be entered into the NERP item tracking system which will be maintained by the NERP Secretary. The tracking system shall contain a brief description of the item, the source of the item, the person responsible for the item, and a section for updating the resolution

a6-status of the item. The NERP Secretary shall ensure that the open NERP items list is updated quarterly, approximately two weeks prior to the scheduled NERP meeting. A copy of the updated open NERP items list will be sent to NERP members for review several days prior to the scheduled meeting.

Prompt resolution of NERP items is the responsibility of the technical organizations with NUC PR. They shall obtain information from the plants and assistance from EN DES, vendors, or other TVA organizations as necessary to ensure satisfactory resolution of assigned items. When the solution has been determined for a NERP item, the assigned technical organization is then responsible for implementation of any necessary changes. This implementation may be in the form of a division procedure, a design change request, or other appropriate means. A memorandum shall be written to the Chairman, NERP documenting and justifying the resolution and implementation of changes on all NERP items. The ,

Chairman shall review and approve the justification before the item is closed.

1951 008

ENCLOSURE Page 1 N79A15 F TENNESSEE VALLEY AUT110RITY Division of Nuclear Power P Division Procedures Manual To: Assistant Director (Operations)

Assistant Director (Maintenance and Engineering Services)

Plant Superintendents, All Nuclear Plants

" Chief, Nuclear Training Branch f Chief, Reactor Engineering Branch From: J. R. Calhoun, Director of Nuclear Power 9

Subj ec t: Sil1FT TECllNICAL ADVISOR (STA) - DPM NO. N79A15 F

References:

1. NUREG-0578, "IMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations," dated July 1979 F 2. Memorandum to All Operating Nuclear Power Plants from

~

Harold Denton, Director, NRR, NRC, " Discussion of Lessons Learned Short-Term Requirements," undated--received by y the Division of Nuclear Power the week of October 29, 1979 1.0 Purpose This procedure describes how the requirements for t'm Shift Technical 5" Advisor (initially presented in reference 1 and clarified in reference 2) will be met by TVA and assigns responsibility within the division for their implementation.

2.0 Assignment of Responsibility ]g ((} 2.1 The Assistant Director for Operations shall have overall responsibility for implementing all requirements associated F with the STA. 2.2 As assigned by the Assistant Directr. or Operations, the Reactor Engineering Branch shall uevelop a program plan for F meeting the requirements for STA. This plan shall include specific management recommen.'/ tons to achieve the following:

1. Selection and training of personnel for STA to go on shift at Browns Ferry and Sequoyah Nuclear Plants by January 1, 1980.

2. Upgrading of training to meet full qualification requirements for STA by January 1, 1981.

7 The Reactor Engineering Branch shall have direct responsibility for working with the plant staffs to ensure that sufficient personnel exist to meet the requirements for STA. In plants n==

Page 2 N79A15 . 1/7/80 -- in which sufficient people do not exist, the Reactor Engineering Branch will take the lead in securing additional candidates cither from within TVA or by outside recruiting, rx. The Reactor Engineering Branch shall develop the training =_; ' requirements and overall scope of instruction for the STA such that the Nuclear Training Branch can develop a training program. 2.3 Each plant superintendent shall have engineering positions on his plant staff designated for STA. The number of positions for each plant shall equal (5 + the number of units). At __ Browns Ferry and Sequoyah Nuclear Plants, each position shall %6 be filled by January 1, 1980, and fully trained by January 1, 1981 or fuel loading, whichever is later. Other STA positions should be filled in a timely manner based on expected issuance --- of an operating license and training requirements. lie shall develop a shift rotation schedule to provide continuous shift coverage by an inplant STA who can be in the control room of ,,, operating plants within 10 minutes of notification, lie shall ensure that personnel who serve ac, STA's meet the minimum qualification requirements as prescribed below. 2.4 The Nuclear Training Branch shall provide a training program ,__ which is operational by February 1; _ 1980, and which is capable of training engineers to meet the qualification requirements ,_. for the STA by January 1, 1981, ot fuel loading, whichever is later. Specific training in the following areas will be necessary. 2.4.1 Nuclear Plant Systems a--

                                                                                    ~

A. Basic Components s=. B. Reactor Coolant System j] C. Emergency Core Cooling Systems D. Residual lleat Removal Systems E. Containment Systens F. Control Rod Drive Systems G. Fuel llandling Systems --- 11 . Secondary Side and Auxiliary Systems 2.4.2 Power Plant Operation A. Startup B. Shutdown - C. Power Operation ,-. D. Integrated System Response

T'. . Page 3 N79A15 1/7/80 0 2.4.3 Transients and Accidents A. Licensing Basis Transients and Accidents F a 1. Assumptions

2. Conservatisms

3. Minimum equipment taken credit for B. Transient and Accident Recognition and Operatot Action

1. FSAR Chapter 15 events M

2. Instrumentation failures

3. Degraded conditions of system availability 2.4.4 Limiting Conditions for Operation A. Technical Specification Definition J. Technical Specification Bases 2.4.5 TVA Operational Practices A. Job Assignments and Responsibilities T B. TVA rbergency Plan y C. Document Familiarization D. Clearance Procedures

                                                                                         ]

E. Plant Safety Practices and Procedures 2.4.6 The Nuclear Training Branch will also be responsible for providing an annual retraining program and F,,. schedule which will be coordinated with the central office and the plants by November 1, 1980. 3.0 Requirements Each nuclear plant will be staffed with a crew of trained engineers for continuous shift coverage who meet the following qualifications F; and who perform the following specific duties. 3.1 Qualifications for Personnel Filling the Positions of Shift Technical Advisor 3.1.1 By January 1, 1980 By January 1, 1980, or by issuance of ar e operating license, whichever is later, individuals who~ fill P the positions of Shif t Technical Advisor (STA) shall satisfy the following minimum qualifications.

  .A

. Page 4 N79A15 1/7/80 __

1. Must have a bachelor's degree in nuclear engineering or the equivalent.

2. Must have qualified as a shift nuclear engineer under the respective plant nuclear engineer __

training program. ._ ,

3. Must have received a minimum of traintag in each of the following areas.

a. Transient and accident recognition and operator action. __

b. Limiting conditions for operation and their h""

bases

c. TVA Radiological Emergency Plan

d. Shif t assignments and responsibilities ,

3.1.2 By January 1, 1981 By January 1, 1981, or by ssuance of an operating e.,, license, whichever is lat , individuals who fill the positions of Shift Tc inical Advisor (STA) shall satisfy the following minimum qualifications.

1. Must have a bachelor's degree in nuclear engineering or the equivalent.

                                                                                       ^

2. Must have qualified as a shift nuclear engineer training program.

3. Must have successfully completed all training described in section 2.4.

4. Must have been certified by a panel consisting of the following:

a. A licensed SRO 1 012,

b. Representative cf the Reactor Engineering Branch

c. Representative of Nuclear Operations Staff 3.2 Duties of the Shift Technical Advisor ,.,

STA duties shall consist of the following:

1. Control room advisor to the shift engineer on off-normal [C[

events. This includes analyses and preparation of scram reports.

2. Advisor to the shift engineer on allowable conditions for inoperable equipment and equipment out of service.

p. . .

f.. . . Page 5

                                                                   .                   N79A15 1
       .              3. Advisor to the shift   engineer on operating experience fr/7/80 om F

other plants. p 4. Advisor to shift engineer as requested on unscheduled maintenance of equipment and post-maintenance testing (this duty will become effective January 1, 1981). 3.3 Retraining for Shift Technical Advisor - Each Shif t Technical Advisor will cc n,lete a retraining program annually consisting of classroom and s.mulator time as well as i continuous updating on plant procedures. 4.0 Implementation

 .:f The following assignments are made for the purpose of implementing the requirements of Shift Technical Advisor.

4.1 Chief, Nuclear Training Branch 4.1.1 The requirements of Section 2.4 are directed at developing a fully qualified Shift Technical i Advisor by Janum 1, 1981, at the operating plants. Toward this object.ive, you are requested to submit to the Assistant Director for Operations by February 1, 1980, a training plan which defines the scope of training center and inplant instruction and which gives an overall schedule for trair.ing Browns Ferry and Sequoyah personnel during calendar T year 1980. The complete training program should be submitted for review to the Assistant Director g,. for Operations by February 15, 1980. 4.1.2 The qualifications given in section 3.1.1 - (3) describe the minimum training requirements for STA which must be met by January 1, 1980. Recognizing that those engineers who serve as STA's on January 1, 1980, will basically come from existing plant personnel, assess immediately the availability F. of both PWR and BWR short courses to provide a part of this training. These courses will be needed between now and January 15, 1980, in order for TVA to meet their near-term commitments for STA. 4.1.3 An annual retraining program as required by section 3.3 for the Shift Technical Advisor should be F" suLmitted for review to the Assistant Director for Operations by November 1, 1980. F 4.2 Chief, Reactor Engineerir.g Branch 1951 013 4.2.1 The requirements of section 2.4 are directed at developing a fully qualified Shift Technical Advisor by January 1, 1981, at the operating plants. Toward P this objective, you are requested to provide direct assistance to the Chief, Nuclear Training Branch in formulating the content of this training program.

Page 6 N79A15 1/7/80 4.2.2 The qualifications given in section 3.1.1 - (3) describe ___ the minimum training requirements for STA which must be met by January 1, 1980, et the operating plants. To augment the Nuclear Training Branch's presentation of --' short courses towards meeting this objective, you are requested to work closely with the Chief, Nuclear Training Branch, in contacting the appropriate orgaal-zations in Westinghouse and General Electric to obtain __. additional near-term training in the fundamentals of plant transients and transient recognition. Toward meeting the objective: 1. manning the STA 4.2.3 positions by January 1, 1980; 2. continuing to provide p.,i station nuclear engineering and startup testing support; and 3. providing the training required to meet the ,_. January 1,1981, requirements, you are requested to work closely with the plant superintendents to determine how nuclear engineers currently on, or assigned to, the plant staffs can best be utilized. You are re- """ quested to take the lead in recruiting additional manpower as needed. 4.3 Superintendents, Nuclear Power Plants 6^- 4.3.1 Appendix I contains the job description for the position of Shift Technical Advisor. We request that immediate steps be taken to advertisc and fill JTA positions at Browns Ferry Nuclear Plant and Sequoyat Nuclear Plant; other STA positions should be filled in a timely manner ,_. based on expected issuance of an operating license and training requirements. 4.3.2 To meet the qualification requirements of 3.1.1 - (2) and 3.1.2 - (2), you are requested to develop and implement an inplant qualification program for nuclear engineers assigned to shift coverage. This qualification program should include but not be limited to training in the following areas: 4.3.2.1 General Areas """

1. Plant orientat- in and familiarization

2. Review of plant manuals, instructions and drawings

3. Overview of plant systems - ==*

4 Plant testing and inspection programs (surveillance, ASME - Inservice, pumps and valves; initial startup or startup b following refueling; and balance of plant survel .cnce) one

4 Page 7 N79A13 1/7/80

-               5. General employee training (instructions -

gj preparation, use and control; security, health physics, etc.) 4.3.2.2. Specific Areas

1. Reactor coolant systems f amiliar; zation

2. Reactor protection / control systems familiari-zation m

-- 3. Reactivity control systems familiarizatien

4. Emergency core cooling systems familiarization

5. Nuclear instrumentation systems (SRM, IRM, PR, and incore systems (fixed and movable))

familiarization f

6. Nonnuclear instrumentation (NSSS thermal . i hydraulic monitoring) familiarization

7. Core monitoring with respect to safety limits and their relationship with reactor protection r 8.

system design requirements, reactor protection system setpoints, and technical specifications Familiarization with vendor core follow and/or

• fuel management methods including fuel warranty requirements or recommendations

9. Special nucleat materials control, accountability, T. and licensing

10. Fuel and core component handling (incore and i; out-of-corc)

11. Computers familiarization (Online - Offline process and digital)

12. Familiarization of NSSS vendor-supplied computer software anNor offline computer software for core monitoring nr analysis

13. Familiarization with the general operating instructions for startup, normal operation, f and shutdown

14. Other topics could include vendor methods for reduction of incore instrumentatica data, cycle

{ length predictions, reactivity balances, and process computer nuclear performance calculations F 1951 015

Page 8 N79A15 1/7/80 __ t,,3.3 Becwns Ferry . ;1nt and Sequoyah Nuclear Plant - Given your cu'. /els of inplant personnel who meet tSe educationa. au shift nuclear engineering qualifi- -- cation requirements, develop a schedule for the release of there personnel during 1980 for Training Center in-struction recognizing that the STA function must be _ continucusly met. Identify to the Chief, Reactor __. , Engineering Branch, your major problems in this area as soon as possible. Other plants - Given your levels of inplant personnel who meet the educational and shift nuclear engineering quall-fication requirements, develop a Lehedule for the releanc __ of these personnel for Training Center instruction recog-nizing the STA function must be met before issuance of an kU' operating license. Identify to the Chief, Reactor Engineering Branch, your plans and major problems in -- meeting the requirementsiof this DPM by January 15, 1980. 5 -

                                              \                         ~

m

                                                \

f '

                                                                      /   1 J.*R. Calhoun E3 '

TDK:MLG Attachment pm

                                                                             ~~

M M FMME 1951 016 ._. pone sumus

                                                                             =

Page 9 N79A15 1/7/80 0 Reactor Engineer / Shift Technical Advisor SD-4 F u Supervision Received Under the direct supervision of the Power Plant Results Supervisor, grade M-5, who defines the scope of work and the results expected and reviews progress within the guidelines. Proceeds independently in accordance with outlined plans, standard practices, license requirements, r and plant instructions. While serving in the capacity of shif. technical advisor, he is under the functional supervision of the shif t engir.eer responsible for his assigned shift. Duties and Rosponsibilities Performs responsible professional engineering work in nuclear safety, plant fuel manage:.ent, and nuclear plant equipment performance. May be assigned to a specific nuclear unit as unit cognizant reactor engineer. In this capacity, he performs the following duties and responsibilities. Develops control requirements for optimum core power distriLution consistent with fuel management requirements. Directs and develops on-yo line and off-line computer application in areas such as core performance and fuel warranty. Prepares detailed plans for reactor refueling and r subsequent testing requirements for plant startup. Reviews operating and replacement criteria for in-core detectors, control rods, flow orifices, and neutron poisons. Reviews applicable nuclear surveillance testing and evaluates results. Reviews plant operating data and reco cends P necessary action to prevent or correct any condition that may affect

  .a    the safe, reliabje, and efficient operation of the plant. Prepares detailed maneuvert and applicable documentation for fuel and saurce handling. Maintain cognizance of nuclear systems which may affect the safety of the plant. Provides technical guidance to operations personnel to minimize impact of systems taken out of service for scheduled maintenance and post-maintenance testing.

May be assigned shif t coverage as a shif t technical advisor. In this capacity, he performs the following duties and responsibilities. Provides advice as requested by th shift engineer in the event of an accident or i. aormal operational condition. Provides advice as requested by the shift engineer on allowable conditions for inoperable equipment and equipment out-of-service. Evaluates the operating history of the F- plant (equipment failures, design problems, operations errors, etc.) and Licensee Event Reports from other plants of similar design with suitable dissemination of the results of such evaluations to other F members of the plant staff. Acts as an advisor to shift engineer as requested on unscheduled maintenance of equipment and post-maintenance testing. Performs engineering evaluation of continuing adequacy of plant operational quality assurance, plant operating procedures, and P" plant cmcrgency procedures. Maintains cognizance of current fuel integrity and evaluates the impact of plant operations on fuel performance. Prepares reports as requested on plant status. Functions as the test engineer during initial startup and startup following refueling. f 1951 017

Page 10 N79A15 1/7/80 ' Supervision Over Others Directs the work of lower grade employees who may be assigned to him. Qualifications Shall have a minimum of a bachelor's degree in nuc. car engineering or --- the equivalent and 4 years of applicable experienct related to the design or operation of a nuclear plant. At least one year of the above 4 years' experience must be in-plant experience related to core performance calculations, core physics ht-testing, nuclear instrumentation calibration, in-core fuel management, and other station reactor engineer f unctions. --- Shall have knowledge in the r.rea of fuel failure mechanisms and the detection of these mechanisms in the off-gas system, the reactor

                                                                                  ~~~

coolant se y system, and process radiation monitors. Shall have extensive knowledge in the areas of plant response to transients and accidents and technical specification content with p"f emphasis on the bases for limiting conditions for operation. Shall have significant training in plant systems and operating procedures,

                                                                                  '~~

including reactor simulator training in transient and accident response. 14u s t have the ability to apply expertise in a coordinated effort with persons of various disciplines under both routine and emergency situations. .-- N SWWWEB M M I951 0Ib,

                                                                                 -}}