EAs- 96-509; 97-031; 97-113; 97-191 - Indian Point 2 (Consolidated Edison Company of New York, Inc.)
May 27, 1997
EAs 96-509; 97-031; 97-113; 97-191
Mr. Stephen E. Quinn
Vice President - Nuclear Power
Consolidated Edison Company of
New York, Inc.
Indian Point 2 Station
Broadway and Bleakley Avenues
Buchanan, New York 10511
||Notice of Violation and Proposed Imposition of Civil Penalities - $205,000; and Exercise of Enforcement Discretion (NRC Inspection Report Nos. 50-247/96-80; 96-07; 96-08; 97-03)
Dear Mr. Quinn:
This letter refers to four NRC inspections conducted between October 27, 1996 and April 5, 1997, at your Indian Point 2 nuclear facility. The findings of these inspections were discussed with you and members of your staff during several exit meetings, the last of which was held on April 28, 1997. These inspections included an Integrated Performance Assessment Process (IPAP) of your facility, as well as three routine resident inspections. The related inspection reports were sent to you previously. On March 14, 1997, a Predecisional Enforcement Conference was conducted with Mr. S. Bram, yourself, and members of your staff, to discuss the violations identified during the IPAP inspection and resident inspection 96-07, as well as the causes of those violations and your corrective actions.
An additional apparent violation identified in NRC Inspection Report 96-08, issued on March 12, 1997, was not discussed during the enforcement conference, but was previously discussed with you at a management meeting in the Region I office on February 19, 1997. That meeting was in response to the January 31, 1997, Confirmatory Action Letter (CAL) that the NRC issued after you shut down the reactor because three of the four safety-related main feedwater regulating valves (MFRVs) were discovered to be physically bound and unresponsive to control signals. An apparent violation identified in NRC Inspection Report 97-03, issued on May 1, 1997, also was not discussed at the conference since it had just been recently identified. This violation involved the failure to identify the actuation of multiple fire dampers in the control building from March 4-6, 1997, until it was identified by the NRC resident inspectors. The NRC reviewed your corrective actions in this matter and, based on the discussions which the staff had with Con Edison management on March 7-9, 1997, concluded that we have all the information necessary to make an enforcement decision in this matter. On April 22, 1997, you informed Mr. C. Cowgill of the NRC Region I office that you agreed that another enforcement conference was not needed to discuss either of these issues.
Based on the information developed during the inspections, the information provided during the March 14, 1997, enforcement conference, and the information provided during the February 19, 1997, management meeting held to discuss your follow-up to the CAL, nine violations of NRC requirements are being cited and are described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (Notice). Six of the violations involve the failure to identify and/or correct significant conditions adverse to quality that existed at your facility. These six violations are set forth in Section I.A of the Notice. Another violation being cited, which was described in Inspection Report 96-80, involves the failure to assure appropriate fire protection of components in the event of a fire at the facility, as required by Appendix R. This violation is set forth in Section I.B of the Notice. The other two violations, related to procedural adequacy and adherence, are set forth in Section II of the Notice.
With respect to the six corrective action violations set forth in Section I.A of the Notice, one of the violations involved the buildup of the abrasive grit in the feedwater system, after the grit was used during a refueling outage in April 1995, to prepare the inner surface of the high pressure turbine. That buildup led to the malfunction of the main feedwater regulating valves in January 1997, in that the valves failed to close on demand. This violation is considered particularly significant because such grit was found in other areas of the feedwater system in June 1995. At that time, the grit was determined to be the cause of the failure of a heater drain tank pump, in that it caused significant damage to the internal components of the pump. However, notwithstanding these prior indications of grit in the system, your staff did not aggressively evaluate the entire system to determine the extent of the problem, and as a result, three of the four main feedwater regulating valves, as well as another heater drain pump, malfunctioned in January 1997. Given the significance of not responding properly to the 1995 event, as well as the resultant failure of regulating valves, this specific violation set forth in Section I.A(1) of the Notice is classified individually at Severity Level III in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.
A second violation in Section I.A of the Notice involved Con Edison's failure to identify the inadvertent actuation of multiple fire dampers in the control building from March 4-6, 1997, until it was brought to management's attention by the NRC resident inspectors. This violation is considered significant due to the multiple missed opportunities available for members of your staff to identify and address this problem. For example, a nuclear plant operator, a security guard and two other individuals had identified that damper(s) had actuated, but no follow-on corrective action was taken. This event revealed weaknesses in your organization relative to the use of problem identification tags, maintenance of a proper questioning attitude by personnel, and logging and communication of event information in the control room. Given the number of missed opportunities for identifying and addressing this equipment problem, and the significance of this violation, this specific violation, set forth in Section I.A(2) of the Notice, is also classified individually at Severity Level III in accordance with the Enforcement Policy.
In addition to the failure to take adequate corrective actions to preclude the grit intrusion event, as well as the failure to identify the actuation of the fire dampers, other instances of failure to promptly identify and correct significant conditions adverse to quality were identified, which could have resulted in degradation or inoperability of safety-related equipment. These findings are described in Section I.A.(3) of the enclosed Notice. Specifically, (1) an adequate root cause analysis was not done in response to repeated surveillance test failures associated with the turbine driven auxiliary feedwater pump steam admission valve and the auxiliary feedwater (AFW) pump discharge flow control valves, and damage was subsequently identified internal to these valves; (2) there was preconditioning of the turbine driven auxiliary feedwater pump by blowing down the steam traps prior to surveillance testing such that the pump was not tested in the condition it would see during an unanticipated start, and an adequate engineering review was not performed to support pump operability; (3) there were multiple surveillance test failures associated with alternate safe shutdown system power transfer switches for certain service water pumps; and (4) there was untimely identification of degradation of the primary auxiliary building filter/fire deluge system control panel and associated circuits such that the system was incapable of performing its design function. These findings further demonstrate that you have not consistently taken timely, thorough, and aggressive actions to identify and correct deficient equipment conditions, and management oversight, at times, has been ineffective in assuring such aggressiveness. These four violations are classified in the aggregate as a Severity Level III problem in accordance with the Enforcement Policy.
The violations in Section I.A of the enclosed Notice are of further concern because once resolutions to problems had been developed, the implementation of corrective actions was slow in a number of cases. Also, your quality assurance organization and your safety review committees were inconsistent in their ability to identify problem areas, as noted in the NRC March 31, 1997 letter transmitting the latest Systematic Assessment of Licensee Performance (SALP) for Indian Point 2. Furthermore, adequate recognition and resolution of these violations did not occur until after the NRC persistently questioned your staff concerning the adequacy of the corrective actions for these problems. These violations demonstrate the need for, and importance of, management fostering a safety culture and work environment wherein personnel are self-critical and possess a low threshold for identifying and correcting problems, and management is actively involved in verifying the timeliness and effectiveness of the corrective actions.
The violation in Section I.B of the Notice involves a condition in which fire protection features were not provided to limit fire damage so that one train of a system necessary to achieve and maintain hot shutdown was free of fire damage. Specifically, certain normal safe shutdown instrumentation and the corresponding alternate safe shutdown instrumentation would be subject to fire damage from the same fire. The two diverse methods, which are utilized to monitor pressurizer pressure and level and steam generator level, are 1) the normal instrumentation channels which are electrical devices, and 2) the alternate safe shutdown system, which is pneumatic with air/nitrogen providing the motive force for the indication. Your review indicated that the same fire could disable both systems. This violation is also classified at Severity level III in accordance with the Enforcement Policy because a postulated fire, in the absence of additional evaluation, could so damage equipment that shutdown could not be achieved and maintained using the applicable equipment identified in the fire hazards analysis.
With respect to Violations I.A(1), I.A(3)a.-d., and I.B, a base civil penalty in the amount of $50,000 is considered for each Severity Level III issue in accordance with the Enforcement Policy in effect at the time these violations occurred. With respect to violation I.A(2), the base civil penalty in the amount of $55,000 is considered for a Severity Level III violation.1 Since Indian Point 2 has been the subject of escalated enforcement actions within the last 2 years,2 the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy for each of the Severity Level III issues. Credit for identification is not warranted for Violations I.A(1), I.A(2), and I.A(3)a.-d. because the failures to take appropriate corrective actions for these adverse conditions were identified by the NRC. Credit for your short-term corrective actions is warranted for Violations I.A(1), I.A(2), and I.A(3)a.-d. These actions included extensive equipment repair, replacement and testing; changes to surveillance testing processes; more formal root cause analysis programs, processes and techniques; more formal post event critiques; and retraining of personnel. The NRC intends to follow your actions closely to judge their effectiveness.
Regarding the violation in Section I.B of the Notice, credit for identification is warranted because the violation was identified by your staff. Credit for corrective actions is not warranted because your initial corrective actions were not comprehensive nor timely in that your initial modification (i.e., a nitrogen bottle with a hose available for installation in the event of a fire), did not comply with Appendix R because installation of this arrangement in response to a fire is considered a repair. Further, that initial modification lacked adequate pressure relief capability. Your permanent modification, which consisted of supplying nitrogen to the appropriate valve from an upstream tap, was not completed in a timely manner.
Therefore, to emphasize the importance of identification and correction of significant conditions adverse to quality, I have been authorized, after consultation with the Office of Enforcement to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (Notice) in the total amount of $205,000 for the violations in Section I.A and I.B ($50,000 each for Violations I.A(1), I.A(3)a.-d., and I.B, and $55,000 for Violation I.A(2).
Overall, the penalties described above reflect the NRC concern about current station performance. The violations indicate a marked decline in the overall effectiveness of management oversight, and reflect a tolerance of problems rather than aggressively identifying and correcting problems. This concern is further heightened by the fact that one of the systems identified, namely the AFW system, is particularly important to plant safety from a standpoint of increased risk involved during periods of system degradation or inoperability. The fact that many of these issues were not pursued by your staff until there had been substantial interaction with the NRC adds to the seriousness of these issues.
Another violation of Appendix R, involving the potential for hot shorts as a result of fire damage to cables associated with both the pressurizer power operated relief valve (PORV) and block valves (a high/low pressure interface), was also identified during the inspection. The cables for both PORV solenoid operated valves (SOVs) and their associated block valves are routed in the same fire area and are contained within trays that contain cables of similar size and voltage which are normally energized. A fire in the affected area could result in hot shorts that could cause spurious opening of a PORV and prevent closure of the associated block valves. This deficiency is a violation of 10 CFR Part 50, Appendix R, Section III G.2, that requires one of the redundant trains needed to achieve and maintain hot shutdown be free of fire damage. Normally, escalated enforcement action would be considered for this violation. However, in order to recognize your efforts in identifying problems affecting safety and to give credit for prompt correction of this problem, I have been authorized, after consultation with the Office of Enforcement, to exercise discretion and not issue a Notice of Violation in this case in accordance with the criteria in Section VII.B.3 of the enforcement policy. This decision is based on the fact that this case involved an old design issue which (1) was identified as a result of a voluntary initiative by engineering to resolve a potential discrepancy noted during an IPE evaluation; (2) was corrected, including the planned addition of an interlock to the PORV block valves and the scheduled installation of isolation switches for the PORVs in the AFW building; and, (3) was not likely to be identified (after the violation occurred) by routine licensee efforts such as normal surveillance or quality assurance (QA) activities. Accordingly, no Notice of Violation is being issued.
The two violations of NRC requirements in Section II of the enclosed Notice are classified individually at Severity Level IV.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).
ORIGINAL SIGNED BY
Hubert J. Miller
Docket No. 50-247
License No. DPR-26
Enclosure: Notice of Violation and Proposed Imposition of Civil Penalties
C. Jackson, Manager, Nuclear Safety and Licensing
B. Brandenburg, Assistant General Counsel
C. Faison, Director, Nuclear Licensing
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
Director, Electric Division, Department of Public Service, State of New York
W. Stein, Secretary - NFSC
F. William Valentino, President, New York State Energy Research and Development Authority
J. Spath, Program Director, New York State Energy Research and Development Authority
NOTICE OF VIOLATION
PROPOSED IMPOSITION OF CIVIL PENALTIES
Consolidated Edison Company of New York, Inc. Docket No. 50-247
Indian Point Nuclear Generating Station Unit 2 License No. DPR-26 EA Nos. 96-509; 97-031; 97-113; 97-191
During NRC inspection No. 96-80 conducted from November 12-22, 1996, NRC inspection No. 96-07 conducted from October 27 through December 21, 1996, NRC inspection 96-08 conducted from December 22, 1996, through February 15, 1997, and NRC inspection 97-03 conducted from February 16, 1997, through April 5, 1997, for which several meetings were held, the last of which was on April 28, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
I. VIOLATIONS ASSESSED A CIVIL PENALTY
A. VIOLATIONS RELATED TO INADEQUATE IDENTIFICATION AND CORRECTION OF ADVERSE CONDITIONS
10 CFR Part 50, Appendix B, Criterion XVI requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment are promptly identified and corrected. For significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective actions taken to preclude repetition.
(1) Contrary to the above, between June 1995 and January 26, 1997, measures were not established to assure that a significant condition adverse to quality was promptly identified and corrected. Specifically, on January 27, 1997, three main feedwater regulating valves (MFRVs) and one low-flow feedwater regulating valve failed in the open position. The MFRVs serve a safety-related function as part of the feedwater isolation system. The cause of the failures was the introduction of sandblasting grit material used in the high pressure turbine during the 1995 refueling outage. A June 1995 failure of a heater drain tank pump was recognized to be due to this same grit intrusion. However, after the June 1995 event, adequate corrective action measures were not taken to identify the extent of the impact, root causes, and preclude repetition of the grit intrusion in a timely manner.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $50,000.
(2) Contrary to the above, between March 4-6, 1997, measures were not established to assure that a significant condition adverse to quality was promptly identified and corrected. Specifically, on March 4, 1997, fire dampers in the control building inadvertently actuated after maintenance personnel drilling through an electrical box came in contact with control wiring for the damper actuation system. However, this actuation of the fire dampers was not identified and corrected by Con Edison personnel, despite multiple opportunities to do so, until the problem was identified by the NRC resident inspectors on March 6, 1997. These multiple opportunities include identification of damper actuation by an nuclear plant operator (NPO), a security guard, a Support Facilities Supervisor (SWS) and a watch engineer, but no follow-on corrective action was taken. The proper functioning of these dampers impacts on the operability of multiple pieces of safety-related, risk significant equipment in the control building, such as the 480 V switchgear and the 120 V AC & DC systems.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $55,000.
(3) Contrary to the above, measures were not established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment were promptly identified and corrected, and that for significant conditions adverse to quality, the measures did not assure that the cause of the conditions were determined and corrective actions taken to preclude repetition, as evidenced by the following examples, each of which constitutes a separate violation:
a. From April through October 1996, the steam driven #22 AFW pump failed three consecutive quarterly tests due to low discharge pressure. The quarterly testing procedure required the removal of condensate from the AFW steam supply lines prior to the test, the quantity of which could not be measured due to discharge into a common drain line. Thus, increased valve leakage from PCV-1139, #22 AFW pump steam admission valve, could not be detected. Over the previous two years, valve stroke time of PCV-1139 also increased and leakage past the seat was observed since June 1996 and found to be increasing after the frequency of the steam supply line blowdowns were increased in November 1996. However, measures were not taken to assure that the significant condition adverse to quality was corrected and its repetition precluded until subsequent inspection of the valve internals on December 21, 1996, identified extensive damage.
b. On July 31, 1996, the steam driven AFW pump discharge flow control valve (FCV) FCV-405A, failed open on demand and FCV-405B and D stroked only 75% open during IST testing. This was the third consecutive FCV-405A valve failure during performance of this test and the fourth time this valve had failed to open since the 1995 refueling outage. Valves FCV-405 B/C/D and FCV-406 A/B/C also had multiple failures to stroke as required. However, measures were not taken to assure that the significant condition adverse to quality was corrected and its repetition precluded until subsequent disassembly of the FCV-405 and FCV-406 series valves identified "basket" damage, as well as galling and cracking of the trim package seal retaining ring.
c. On July 12, 1996, the NRC identified that the Primary Auxiliary Building, Containment Purge, and Boric Acid Building Charcoal Filter Deluge System had been inoperable for an undetermined period of time. Moreover, the control room annunciator alarm had been alarming intermittently since February 1996. However, measures were not taken to assure that the condition adverse to quality was promptly identified and corrected in that the alarm response procedure which required operators to be dispatched to the system control panel to determine the cause was apparently not followed as the system was identified by the NRC to be inoperable.
d. On December 3, 1996, the Appendix R Alternate Safe Shutdown (ASSS) power supply transfer switch for service water pump (SWP) No. 24 failed to close during multiple attempts during a surveillance test. Five previous similar failures to transfer during testing occurred with this switch and the adjacent No. 23 SWP ASSS power supply switch since 1993. Even though these failures occurred while other equivalent switches functioned satisfactorily, these two switches remained in-service, and measure were not taken to assure that the condition adverse to quality was corrected.
This is a Severity Level III problem (Supplement I).
Civil Penalty - $ 50,000.
B. VIOLATION OF APPENDIX R
10 CFR Part 50, Appendix R, Section III.G.1 requires, in part, that fire protection features shall be provided to limit fire damage so that one train of systems necessary to achieve and maintain the hot shutdown condition is free of fire damage.
Contrary to the above, as of July 21, 1996, it was determined that fire protection features were not provided to limit fire damage so that one train of systems necessary to achieve and maintain hot shutdown was free of fire damage. Specifically, both the normal safe shutdown instrumentation and the alternate safe shutdown instrumentation that provide indication of pressurizer pressure and level, as well as steam generator level, would be subject to fire damage in certain fire areas and could be rendered inoperable by the same fire. Either the normal or the alternate instrumentation is needed to achieve and maintain hot shutdown.
This is a Severity Level III violation (Supplement I).
Civil Penalty - $50,000.
II. VIOLATIONS NOT ASSESSED A CIVIL PENALTY
Technical Specification Section 6.8.1. requires that written procedures be implemented covering activities referenced in Regulatory Guide 1.33, November 1972.
A. Regulatory Guide 1.33 requires written procedures for startup, operation, and shutdown of safety-related systems including the feedwater system, from the main feedwater pumps to the steam generators.
Contrary to the above, on January 26, 1997, during conduct of a plant shutdown with three stuck main feedwater regulating valves, water level in the three steam generators was controlled by varying the speed of the main feed pumps. At the time of the shutdown, this method of control was not proceduralized, even though sufficient time was available (i.e., about 12 hours) to issue a temporary procedure change to the feedwater system operating procedure, as required by Station Administrative Order 133, Section 5.1, to recognize this control method.
This is a Severity Level IV Violation. (Supplement I)
B. Regulatory Guide 1.33 requires administrative procedures for procedure use. Station Administrative Order (SAO) SAO-133, section 5.1.1, requires that all Station Nuclear Safety Committee (SNSC) approved procedures shall be followed. SAO-460, a SNSC approved procedure, section 4.13 requires that safety evaluations prepared by an outside contractor shall be given cover sheets, assigned safety evaluation numbers and be processed for review in accordance with sections 4.10 and 4.11 which includes a SNSC review.
Contrary to the above, following identification of sandblasting grit in the 21 Heater Drain Tank failure, at Consolidated Edison's request on June 22, 1995, Westinghouse issued an analysis of the effects of sandblasting grit on the secondary side of the Steam Generators. This analysis was used by engineering personnel as the basis for the conclusion that there was no impact on the safety related Steam Generators as a result of the grit intrusion. This conclusion was documented in the Open Item Report closeout. As a result, this analysis was, in effect, used as a safety evaluation justifying safety related equipment operability. However, the requirements of SAO-460, specifying a safety evaluation number, cover sheet and processing, were not conducted and no SNSC review was performed.
This is a Severity Level IV Violation (Supplement I)
Pursuant to the provisions of 10 CFR 2.201, Consolidated Edison Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the receipt of this Notice of Violation and Proposed Imposition of Civil Penalties (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalties proposed above, or may protest imposition of the civil penalties, in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalty due that subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: Mark Satorius, Deputy Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident Inspector at the facility that is the subject of this Notice.
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR.
Dated at King of Prussia, Pennsylvania
this 27th day of May 1997
Page Last Reviewed/Updated Thursday, March 25, 2021