ML20217M369
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: |
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
l PDR ADOCK 05000482
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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 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
! - 970673, dated March 3,1997
. 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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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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