ML20006G158

Forwards Response to & Comments on Initial SALP Rept 50-423/88-99 for Period 880601 - 891015.Procedures Revised to Permit Operators to Adjust Area Monitors to Reduce Nuisance Alarms

ML20006G158
Person / Time
Site:	Millstone
Issue date:	02/21/1990
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B13452, NUDOCS 9003050236
Download: ML20006G158 (19)

Text

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General Offices

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HAR50RD, CONNECTICUT Mi41-0270 (203) 665-5000 February 21, 1990 Docket No. 50-423 4

B13452 RE: SALP U.S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, DC 20555

Reference:

. (1) -W. T. Russell letter to E. J. Mroczka, Systematic Assess-ment of Licensee Performance (SALP) Initial Report

1. 50-423/88-99, dated January 17, 1990.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 3 Systematic Assessment of Licensee Performance (SALP)-

The NRC recently forwarded the SALP Board Report (Reference (1)) for Millstone Unit No. 3 covering the period of June 1, 1988 through October 15, 1989.

Subsequent to . receipt of the SALP Board Report, a meeting was' held. on.

January 22, 1990 between members of the Staff and members of Northeast Nuclear Energy Company (NNECO).

The purpose cf this letter is to respond to and coment on the f.indings of ths-SALP Board with particular emphasis on- the Board recommendations for- the individual evaluation categories. The responses- to the Board's recommendations for Millstone Unit No. 3 are contained in Attachment A.

'NNEC0 takes very seriously the ratings and recommendations given- by the Board as an input into the . continuing process of evaluating and improvirg our overall performance. As reflected by our comments and observations during the January 22, 1990 meeting, we generally concur with the Board's observations and conclusions, and.previously have taken or are taking steps to address the concerns identified. It remains our objective to achhve' Category I ratings in all' functional areas for subsequent SALP evaluations and the attachment to this letter describes some of the steps we will be taking to fulfill that objective.

We trust that the actions presented in the attachment addressing the concerns of the SALP Board and our general comments will be considered in subsequent SALP evaluations. We will be updating you regarding the status of imple-menting the corrective actions discussed herein at a mid-cycle SALP review meeting presently scheduled in late April to early May 1990 in the Region I offices.

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U.S. Nuclear Regult. tory Commission B13452/Page:2 February 21',-1990--

Please feel free 10 contact us if any questions arise on these matters or if.

additional clarifi:ation is needed.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY E.J.Voczka // l Senior Vice President cc: W. T. Russell, Region I Administrator D. H 'Jaffe, NRC Project Manager, Millstone Unit No. 3 W. J. Raymond, Senior Resident inspector, Millstone' Unit Nos. 1, 2, and 3

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Attachment A Northeast Nuclear Energy Company

' i;: 'l Millstone Unit No. 3 l Response to SALP Report

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Attachment A q B13452/Page 1 l A. functional Area: PLANT OPERATIONS l

l ikutrd Recommendation:

-- Reduce nuisance alarms (Repeat Recommendation) 1 Runonse:

Reducino Nuisance Alarms NNECO recognizes the desirability of reducing the nuisance alarms asso-ciated with radiation monitors. The nuisance alarms from spiking have i been eliminated for the control building radiation monitor. NNECO will j continue focussing attention on the next level of priority. The efforts i to reduce nuisance alarms already taken include: )I o Changing default parameters to eliminate unnecessarily restric- I tive alarm setpoints.  ;

o Changing procedures to allow operations personnel to adjust area monitors as conditions change background readings, o Reviewing all alarmed annunciators periodically by plant 4 management to address maintenance requirements, o Employing schedules to ensure that maintenance required to eliminate alarms during plant shutdowns is performed. l 0 Conducting monthly management progress reviews on the entire

" blackboard" project to ensure that the schedule is maintained.

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, NNEC0 will continue to review all alarmed annunciators for their a) pro-priateness an 31ack board concept.g3jo effectively use its resources to support the .

LER Ouality ,

NNECO acknowledges the Staff's concerns regarding Licensee Event Reports 1 (LERs). The LERs with personnel errors as a root cause are being reviewed by plant management to identify potential common problem areas.

We will work to foster an operating environment for the entire plant staff that minimizes personnel errors. The plant staff fully recognizes the importance of correcting potential trends prior to the trend developing safety significance. Future LERs will be reviewed regarding any indication of adverse trends.

(1) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, Elimination of Unnecessary Alarms, dated August 3,1989.

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Attachment A.

B13452/Page 2

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Fire Protection Prooram Imolementation i

NNECO management is increasing its attention to the fire protection area.

In addition to the steps noted in the SALP report to reduce instances of fire protection program problems, the recent station reorganization will permit the plant staff to bring more management attention to the fire protection area. Stepped up communications related to fire protection will increase the plant staff's sensitivity and awareness of fire 3rotec-tion requirements. We believe this increased attention will result in a smoother, more effective fire protection program.

Operator Reaualification NNECO has acknowledged that significant improvements to the licensed operator requalification training prograin would be prudent and has implemented changes as follows: j o Requalification training content has been revised to address l procedural and policy changes as well as correct - weaknesses  !

noted during the September 1989 requalification examinations.

o Line management has formalized operational policies by l implementing an Emergency Operating Procedure Rules of Usage i Document and by providing increased guidance on management expectations with respect to operator performance. These policies are being implemented through increased line manage-ment involvement in the training process. ,

o Line management is routinely participating as an evaluator

, during simulator examinations. Additionally, simulator l instructor training has been enhanced to emphasize examination l L techniques. This training has been provided to training L department instructors who participate on simulator examination t teams and is planned for management evaluators. ,

e o increased guidance on appro)riate Job Performance Measure (JPM) examination techniques has seen provided to JPM evaluators.  :

1 These improvements have been effective based on the preliminary results of NRC requalification examinations administered from February 5 through February 14, 1990. During the exit meeting the lead NRC examiner noted D that the requalification had achieved ' Satisfactory" status and identi-

fled the following improvements.

o There was increased operational consistency between the crews being evaluated. i l 0 The increased participation in the examination process by line management was obvious and enhanced the effectiveness of the examination critiques.

o NNECO evaluator performance was greatly improved.

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• . B134SP/Page3 During these examinations, both the NNECO and NRC examination teams identified some areas where additional improvements would be beneficial.

,o lhese areas will be aggressively addresset.

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Attachment A B13452/Page 4 f

B. Functlonal Area: RADIOLOGICAL CONTROLS  !

! Board Recommendation:

- Expedite the return to service of the steam generator blowdown  !

monitor.  !

Response

The design charege required to make the monitor operable was approved in  !

December 1989. The necessary material is on site and the design changes -l to the system and restoring the monitor to service will be accomplished by february 28, 1990. While the current design change will improve operating conditions in the blowdown sample system, it is possible that ,

additional modifications may be necessary. System performance will be  !

evaluated following the changes to determine if further modifications are required. If subsequent design changes are required, they will be  :

initiated expeditiously. t The NRC noted a concern regarding the contaminated tools that were l transported offsite. This issue has been extensively reviewed by NU  ;

since the discovery of the Millstone Unit No. I hydrolaser event in May '

1989. The Northeast Utilities contamination program evaluation recognizes that this issue is of programmatic concern at a Station level  ;

rather than at individual unit level.

l To date over 500,000 tools and components have been individually

inspected as part of the contamination assessment survey program. This survey has been conducted in over 50 individual locations, in 15 cities. -

and over a 2 state geographic area. This survey has been staffed with 16 additional vendor Health Physics Technicians to augment the station staff in this program. To date, this survey has expanded approximately 30,000 manhours (15 man-years)toconduct. ,

l Northeast Utilities management has recognized that the Millstone Station j contamination control program is not acceptable in its current configuration. A Contamination Control Management Task force delivered a formal report on December 31, 1989 listing 15 recommendations for potential program improvement. The Task Force report recommendations are currently being assessed by the Director, Unit Services for program implementation. The contamination program actions to date, and potential program initiatives, were recently reviewed by the Site NRC Inspector and Region 1 NRC Health Physics Inspector during the week February 12-16,  ;

p 1990.

In conclusion, NNECO agrees with the Staff's assessment of our perfor-  :

mance in this functional area. We acknowledge the need to address the issues identified as having room for improvements, and will continue to strive for better performance.

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C. Functional Area: MAINTENANCE /SVRVEILL.ANCE  !

Board Recommendation: None j Response: l The Staff noted that three reactor trips and one ESF actuation could have been avoided through increased attention in preparation and in review of i plant procedures. We recognize the need to strive for constant improve-ment in plant procedures. A major upgrade effort is currently underway l to improve plant procedures. The procedures are being revised to comply >

with a writer's guide which follows closely industry lead initiatives to '

improve both clarity and readability. Additionally, NNECO seeks to ,

address root causes with each weakness found and to upgrade all related .

procedures. An aggressive procedure change policy is in effect to ensure that unclear or incorrect procedures are corrected prior to use. NNECO .

is confident that these measures will result in fewer avoidable tran- i sients.

NNECO agrees with the SALP report finding that the plant review of -

procedures against surveillance requirements was effective in reducing the number of missed surveillances. The procedure inadequacies found since the initial. review have all been reexamined for generic concerns i and none have been found. Each case appeared to be unique. A case in point is the example provided in the report. The method used to test the MSIVs did not verify that both redundant reactor protective system (RPS) .

trains actuate the main steam isolation valves (MSIVs) within the required time limit. The procedure review did not identify this inade. t quacy because the technical specification only requires the main valve to shut within the required time limit and does not address individual train testing. This inadequacy was reviewed for generic implications and was ,

found to be a unique case since the MSIVs are the only valves which have ,

different operating characteristics for different trains. If further I procedure inadequacies are found, the plant will continue to use them to i l

evaluate the adequacy of the initial review process.

l It should be noted that in December 1989, during a plant shutdown, MSly testing demonstrated that the valves would shut within the allowed time period. The surveillance procedure has been revised to verify opera-bility of each MSIV train during future testing.

At the SALP meeting on January 22, 1990, the NRC Staff referred to a i

recent NNECO request for Enforcement Discretion related to E-Bar h surveillance and asked whether we have a similar problem elsewhere in the Millstone Unit No. 3 Technical Specifications. At present, NNECO is reviewing the existing Technical Specifications and changes determined to be necessary will be submitted to the NRC by August 30, 1990.

In addition, Applicable Technical Specifications for Millstone Unit l Nos, I and 2 and the Haddam Neck Plant are being reviewed and changes I

determined to be necessary will be submitted to the NRC by October 30, 1990.

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B13452/Page 6 r

i In conclusion, NNECO agrees with the Staff's assessment of our perfor- ,

mance in this functional area. We acknowledge the need to address the ,

issues identified as having room for improvement, and will continue to ,

i strive for better performance.  ;

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D. Functional Area: EMERGENCY PREPAREDNESS I Board Recommendation: None i

Response

The NRC noted a concern which involved improvements in the audit proce dures needed to address program resources and assure the independence of auditors performing the annual program review. The same concern was [

noted bywas theaddressed NRC in the Millstone Unit Nos'. I and27, 2 SALP This concern in our letter dated November 1989I gport.

In conclusion, NNECO agrees with the Staff's assessment of our perfor- ,

mance in this functional area. We acknowledge the need to address the .

issues identified as having room for improvement, and will continue to ,

strive for better performance.

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(2) E. J. Mroczka letter to U.S. NRC, Millstone Unit Nos. I and 2 SALP, dated November 27, 1989.

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E. Functional ~ Area: SECURITY AND SAFEGUARDS i Board Recommendation: None I i

Response

The NRC noted a concern in regard to the personnel turnover rate within I the contractor security force and repetitive events noted in the security j event reports.

As detailed in our response to the Millstone Unit No I and 2 SALP Board ,

findings, actions taken to reduce turnover rate has been successful. The  !

NRC recognizes that we continue to pursue this issue. In the Millstone Unit No. 3 SALP Report, the NRC notes that " Contractor and licensee efforts were successful to reduce the turnover rate to 18% in the January ,

I to September 1, 1989 period." '

The issue of repetitive reportable events involving inattentiveness has i been pursued aggressively and actions taken to address these types of events have been successful. The proactive approach taken on the back  !

shifts with increased radio checks, post rotations, and increased super-visory checks of solitary posts have reduced these types of events. The i continued emphasis on the elimination of long term compensatory posts -

also reduces the potential for these types of events.  ;

In response to a Notice of Violation, NNECO committed to vitalize the  ;

area of concern and to reexamine all vital area barriers from a security perspective. The work to vitalize the area was accomplished in 1989.

• The reexamination of vital area barriers is in progress and is scheduled to be completed by the end of the first quarter of 1990.

At the SALP meeting on January 22, 1990, the NRC Staff asked what kind of performance indicators we use to monitor the readiness of the security  ;

l force. The following information is provided in response to that question.

A program of random quizzes of guard force members has been in place since early 1989. The results of the quizzes, conducted by the Training Department, are trended. Where adverse trends are noted, actions such as informational memos to the guard force or changes to  !

the training program for Security personnel are implemented.

Additionally, the NNECO Security Shift Supervisors are tasked with '

observing the performance of the contract guard force to ensure compliance and readiness. This process is formalized in a security departmental instruction and performance observations, positive, and negative, are addressed in writing to the contract guard force management.

Drills are conducted on all shifts for all contingency procedures. .

The drills are critiqued by the individual players as well as the designated observers. All drill critiques are reviewed by the

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Attachment A B13452/Page 9  ;

i security contractor training staff as well'as the licensee Security +

Supervisor-0perations to evaluate the need for radifications to the training program or to response procedures. ,

o At the SALP meeting on January 22, 1990, the NRC Staff brought to NU's attention an eavesdropping incident at a nuclear facility and asked l

whether we were susceptible to this problem and if so, what actions are or will be taken to avoid it. The following information is provided on behalf of all four of NU's Nuclear Plants in response to that question.

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.The relative ease of purchasing equipment to accomplish such commu-nication monitorini) does leave the station susceptible. Although ,

the matter is stil' under review, certain programs already in place  ;

serve to minimize the effects of such monitoring. Specific items include training in proper radio protocol and etiquette, use of a ,

I signal code to ensure clarity while minimizing information being

• transmitted, and procedures to address loss of communication through l

equipment failure or jamming, in conclusion, NNECO agrees with the Staff's assessment of our perfor-I mance in this functional area. We acknowledge the need to address the - '

I issues identifi3d as having room for improvement, and will continue to '

strive for better performance.

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F. Functional Area: ENGINEERING / TECHNICAL SUPPORT )

Board Recommendation: None

Response

The SALP report identified two trips resulting from inadequate trash ,

removal from the intake structure screens. As stated in the SALP report, the plant established a task force to address intake structure problems.

The task force recommendations have resulted in some immediate and long term actions. These long term actions represent a considerable commit- ,

ment of resources which is indicative of NNECO's commitment to improving  ;

the reliability of its units.  ;

The SALP report also identified a recurrent failure of the main feedwater pump mechanical seals. This problem exemplifies the commitment of engineering support to solving operational problems. This problem was  ;

identified during the initial startup. Prior to commercial operation, the booster pumps were added to improve seal water flow to the main  ;

feedwater pump seals. By the first refueling outage, a piping change was designed and implemented. After experiencing more seal failures, further design changes were prepared for the second refueling outage. Material changes were made to one of the seals and seal performance is presently being monitored to determine the need for future changes. This phased replacement permits the evaluation of inservice performance and minimizes the possibility of hidden deficiencies prodtcing a systemic failure.  ;

In conclusion, NNECO agrees with the Staff's assessment of our perfor- ,

mance in this functional area. We acknowledge the need to address the '

issues identified as having room for improvement, and will continue to strive for better performance. .

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, Attachment-A B13452/Page 11 G. Functional Area: SAFETY ASSESSMENT / QUALITY VERIFICATION Board Recommendation:

Licensee: Continue to improve accuracy and completeness of licensing submittals. Improve accountability and schedules for timely implementa- l tion of QA findings. Further emphasize solicitation and resolution of -

employee concerns.

Response

Submittals to NRC During the past year, NNECO has continually strived to provide comprehen-sive, thorough and technically sound submittals. We believe a prime ,

example of this has been an amendment request related to the containment integrated leak rate test technical specification. The NRC Staff  ;

verbally noted that this submittal was technically thorough and accurate and represents an excellent example of a license amendment submittal. In ,

addition, NNECO has provided information required to satisfy one license condition and six safety evaluation report commitment items requiring submittal of additional information.

As stated in our letter dated September 14,1989,(3) NNEC0 will continue to place emphasis on the multidiscipline sign-off process associated with all correspondence with the NRC to ensure accuracy of submittals. In '

that regard, an updated guidance document will be issued to the Nuclear Engineering and Operations (NEO) Staff, which will reinforce our aware-ness of responsibilities related to quality, accuracy, thoroughness and  ;

the safety ethic required in our communications with the NRC.

Implementation of OA Findinas In response to the Board recommendation to improve accountability and schedules for timely implementation of QA findings, NNEC0 has revised the governing procedure, NE0 3.07 " Response to Audit Findings" in December 1989 and this procedure includes the following:

o Response due dates will be mutually established at the post audit conference, o Quality services department (QSD) supervisors will be able to grant only one extension - any further requests will be at the Director -  ;

QSD/Vice President level.

(3) E. J. Mroczka letter to U.S. NRC, SALP, dated September 14, 1989. ,

,a e Attachment A 813452/Page12 o Inadequate responses will follow the same process. QSD supervision will attempt the first resolution - any further resolutions will be at the Director - QSD/Vice-President level.

o QSD will issue a status report every six months. As results improve, the report frequency would be reduced to once per year.

Resolution of Emoloyee Concerns We have also evaluated the NRC's recent comments and suggestions regarding the resolution of employee concerns. Substantial efforts have been and are being ex> ended to be responsive to the NRC's perspective. In particular, an en1anced Nuclear Safety Concerns Program (NSCP) has been instituted. The NSCP has, as its foundation, the corporate nuclear safety ethic, which is articulated in the following two documents:

1. NU's Corporate Nuclear Policy - dated April 4,1986.

2. NE&O Policy Statement No. 1 - Revision 2 dated September 22, 1989.

Copies of these documents are included as Enclosures 1 and 2 for your informa-l tion.

The enhanced NSCP is the subject of separate correspondence which will be submitted to you during February 1990. This corresaondence will provide additional detail regarding measures taken to address the perspectives of the NRC SALP Board.

Monitorina of Annroved Vendors l

! The NRC noted a weakness in licensee monitoring of approved vendors. Enhance-ments to the approved suppliers list and monitoring of approved vendors have been implementeq4)via August 14, 1989.

program revisions identified in our letter dated Additionally, Northeast Utilities (NU) procures equiv-l alent ASME Section III stamped replacements from vendors having NU approved 10CFR50, Appendix B quality programs, including third party inspection by an authorized nuclear inspector in accordance with Generic Letter 89-09, when N stamped replacements are not available.

ISEG Recommendations The NRC identified a weakness in the station implementation, follow-up and tracking of the independent safety engineering group (ISEG) recommendations, f', NNEC0 has opted to implement the NRC's suggestion to develop a formal tracking system. The following elements will be incorporated into our tracking program:

J. Mroczka letter to U.S. Nuclear Regulatory Commission, (4) E. ASME Compliance, dated August 14, 1989.

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.* . ' ' Attachment A B134S2/Page 13 o All ISEG reports are to be forwarded to the Millstone Station Nuclear Director, the applicable Unit Director and appropriate Department Head (s). .

o Due dates for the implementation of recommendations will be determined during the review process for the ISEG evaluation, j

o Plant Operation staff will provide a formal response to disposition the ISEG recommendations.

Procedures will be changed to reflect this new mode of operation. .

Exoerience from other NU Nuclear Units The NRC noted a concern regarding applying experience from other NU nuclear units. The Station Director is responsible for ensuring that events which occur, or conditions which are uncovered, at one of the Millstone Units are 4 reviewed by the other two units. This process is typically initiated by, and documented through the Station Controlled Routing program. Written responses ,

concerning applicability and action to be taken are required when a)propriate. '

Such assignments are typically triggered by an official report of tie event or condition, e.g., Plant Incident Report, NRC Inspection Report, and so on. An excellent example of this process is the Station response to NkC Inspection ,

Report No. 50-336/89-13, concerning Allegations at Millstone Unit 2; all three units were required to review and respond to applicable items in this report.

Specific example noted concerned format and usage of Emergency Operating Procedures (E0Ps) at Millstone Unit No. 1. Millstone Unit No. I and No. 3 are significantly different in rules of usage and in format on E0Ps since they follow their respective user groups. Millstone Unit No. 3 works more closely .

with the Haddam Neck plant and other Westinghouse plants concerning E0P usage.

Attempts are made to extract applicable lessons from all types of plants; however, the applicability is not always clear. While attempts are made to make procedures and policies as consistent as practical at Millstone, the need to follow the approved Emergency Response Guidelines (ERGS) as a basis for E0Ps resulted in a conscious decision to have each unit adhere to a writer's guide and rules of usage consistent with their respective user group. All Millstone Unit No. 3 license holders were licensed by the NRC using E0Ps based on revision 1 or revision lA of the Westinghouse ERGS.

Millstone Station uses a number of other vehicles to share lessons learned I among the three units. The Nuclear Safety Engineering group performs in-depth reviews of Millstone and industry events, providing feedback tte the units and l to station management. Millstone has been a participant in the INP0-sponsored i Human Performance Evaluation System (HPES) since its inception; HPES reports '

are distributed to all three Millstone units when appropriate. Daily station l management meetings include briefings of events (Plant Incident Reports, i personnel injuries, etc.) and issues (evaluation inspection results, lessons I learned) which may be pertinent or of interest to multiple groups across the l Station. And routine meetings among the four Station / Unit Directors and among counterparts across the units (e.g., Operations or Maintenance Managers),

result in the timely sharing of current events when such information is

, , .e ' Q Attachment A B13452/Page 14 important to the safe and efficient operation of the Station. NNECO will continue to place importance on the sharing of information and lessons learned among the three Millstone units and considers this an area of significant

_ improvement in the past few years.

In conclusion, NNECO agrees with the Staff's assessment of our performante in this functional area. We acknowledge the need to address the issues identi-fied as having room for improvement, will continue to strive for better performance.

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CORPORATE NUCLEAR POLICY It is the policy of Northeast Utilities system companies to operate our nuclear plants in a safe and efficient manner, to l

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meet.all regulatory requirements, and to achieve INPO Benchmarks of Excellence while providing dependable, economic electrical power to our customers. We will do this by establishing clearly stated engineering and operational requirements, by providing adequate qualified staff and material resources to implement these requirements, and then ensuring that everyone does the right job right the first time in accordance with these requirements.

The Senior Vice President Nuclear Engineering and Operations is responsible for carrying out the implementation of this policy. Ali corporate functions shall appropriately support implementation of this policy as defined by the Senior Vice  :

President Nuclear Engineering and Operations. ,

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President and Chief Operating Officer 2/1.54

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1 of 1 NEO Poliev Statement NUCLEAR PIANT SAFETY Northeast Utilities is dedicated to safe nuclear plant operation. Safe operation requires recognition of the potential radir, logical hazard t inherent in nuclear power technology. To ensure that our plants continue to perfore safely, it is essential that a safety ethic be set throughout our entire organization. A true safety ethic recognizes:

• A prevailing state of mind focusing on safety; l

• An insistence on sound technical bases for actions;

• A disciplined approach to all work activities; l

• Adherence to all procedures;  ;

• A continuous, rigorous self criticism of performance; ,

• Timely response to employee safety concerns.

Each NU Nuclear plant shall be operated, modified and maintained in  ;

l accordance with Federal, State, Local and industry assessments and standards. NRC SALP ratings and INPO assessments and ratings are key independent measures validating that our plants are operated, modified, tested, and maintained safely. Activities affecting nuclear plant safety shall be subject to independent review by one or more of the following independent internal bodies:

• NU Quality Services Department

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• Unit and Site Nuclear Review Boards a Nuclear Safety Engineering Branch These oversight activities do not replace line functions' responsibility to do the right job right the first time, The overall accountability and responsibility for the safety of NU nuclear plants lies with the Senior Vice President of NEO. Specific responsibility for day to day operation, testing and maintenance lies with the Vice  ;

President, Nuclear Operations, The Vice President, Generation Engineering and Construction, and Vice President, Nuclear and Environmental Engineering are responsible for engineering, construction and technical support activities. These three NEO Divisions, functioning together, are responsible and accountable for nuclear plant safety.

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E, J. 6 94fka [/ Date Senior Vice President Nuclear Engineering & Operations IP1-2.07A

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