ML022560252
| ML022560252 | |
| Person / Time | |
|---|---|
| Site: | Mcguire, Catawba, McGuire  |
| Issue date: | 09/04/2002 |
| From: | Cottingham A Duke Energy Corp, Winston & Strawn |
| To: | Kelber C, Rubenstein L, Austin Young Atomic Safety and Licensing Board Panel |
| Byrdsong A T | |
| References | |
| +adjud/rulemjr200506, 50-369-LR, 50-370-LR, 50-413-LR, 50-414-LR, ASLBP 02-794-01-LR, RAS 4835 | |
| Download: ML022560252 (41) | |
Text
qtj35 WINSTON & STRAWN 1400 L STREET, N.W., WASHINGTON, DC 202-371-5700 20005-3502 External Memorandum 35 W WACKER D0vmw CRmicAC, IL 800 01-0703 312-558-5800 200 PARK AvD.uE NHwYORK.WNY 101O -4193 212-204-6700 333 Sour GRAJo AvE 43 Rut Diu RKON.E Los ANlOLEs, CA 90071-1543 1204 GENcVA. SwRKZERLANo 213-615-1700 4 122-317-75-75 Z I AVWJ*U ViCTOR HUGO 75 1 18 PARts, FRANCE 33-1-53-e4-82-82 September 4, 2002 Ann Marshall Young, Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKETED USNRC September 10, 2002 (3:23PM)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Dr. Charles N. Kelber Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Lester S. Rubenstein Administrative Judge 4760 East Country Villa Drive Tucson, Arizona 85718 Re:
In the Matter of Duke Energy Corporation McGuire Nuclear Station, Units 1 and 2 Catawba Nuclear Station, Units 1 and 2 Docket Nos. 50-369-LR, 50-370-LR, 50-413-LR, 50-414-LR
Dear Administrative Judges:
To assure full distribution to the Licensing Board and parties to this proceeding of information potentially material to BREDL/NIRS Consolidated Contention 2, enclosed are the following documents:
"August 2, 2002, letter from M.S. Tuckman, Duke Energy Corporation, to the U.S. NRC, enclosing Duke's comments on Draft (plant-specific) Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants," for McGuire Nuclear Station, Units 1 and 2. (The NRC Staff forwarded a copy of Draft Supplement 9 to the GEIS to Duke by letter dated May 6, 2002, and provided Duke the opportunity to submit comments on that document.)
August 9, 2002, letter from M.S. Tuckman, Duke Energy Corporation, to the U.S. NRC, enclosing Duke's comments on Draft (plant-specific) Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants," for Catawba Nuclear Station, Units 1 and 2. (The NRC Staff forwarded a copy
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Administrative Judges September 4, 2002 Page 2 of Draft Supplement 9 to the GEIS to Duke by letter dated May 14, 2002, and provided Duke the opportunity to submit comments on that document.)
"August 8, 2002, letter from G.R. Peterson, Duke Energy Corporation, to the U.S. NRC, setting forth the Catawba Nuclear Station position re two Severe Accident Mitigation Alternatives ("SAMAs") identified in Section 5.2.7 of Draft Supplement 9 to the GEIS for Catawba Nuclear Station, Units 1 and 2.
"August 19, 2002, letter from H.B. Barron, Duke Energy Corporation, to the U.S. NRC, setting forth the McGuire Nuclear Station position regarding a SAMA identified in Section 5.2.7 of Draft Supplement 8 to the GEIS for McGuire Nuclear Station, Units 1 and 2.
Sincerely, Anne W. Cottingham Counsel for Duke Energy Corporation Attachments cc:
Service List (w/Enclosure)
Duke Duke Power 526 South Church St. EC07H Charlotte, NC 28202 A Duke Energy Company P.O. Box 1006 EC07H Charlotte, NC 28201-1006 M. S. Tuckman (704)382-2200 OFFICE Executive Vice President (704) 382-4360 FAX Nuclear Generation August 2, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Comments on draft plant-specific Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" McGuire Nuclear Station, Docket Nos. 50-369 and 50-370 By letter dated June 13, 2001, Duke Energy Corporation (Duke) submitted an Application to Renew the Facility Operating Licenses of McGuire Nuclear Station and Catawba Nuclear Station (Application). The staff has reviewed the information provided in the Environmental Report contained in the Application as well as the information provided in Duke letters dated January 17 and 31, 2002. By letter dated May 6, 2002, the staff forwarded a copy of the draft plant-specific Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" for McGuire and provided Duke the opportunity to submit comments.
Accordingly, please find Duke comments on draft Supplement 8 to NUREG-1437.
In addition to providing comments on the draft Supplement 8, Duke is also in the process of reviewing the conclusions contained in Section 5.2.7 of the draft Supplement 8. In this section, the staff concluded that one of the severe accident mitigation alternatives (SAMAs) related to hydrogen control in SBO sequences is cost beneficial under certain assumptions, which are being examined in connection with the resolution of GSI-189, "Susceptibility of Ice-Condenser and Mark HI Containments to Early Failure from Hydrogen Combustion During a Severe Accident."
Duke is in the process of reviewing this SAMA and plans to provide its position by a separate letter.
If there are any questions, please contact either Bill Miller at (704) 373-7900 or Bob Gill at (704) 382-3339.
Very truly yours, M. S. Tuckman Attachment
U.S. Nuclear Regulatory Commission Document Control Desk August 2, 2002 Page 2 Affidavit M. S. Tuckman, being duly sworn, states that he is Executive Vice President, Nuclear Generation Department, Duke Energy Corporation; that he is authorized on the part of said Corporation to sign and file with the U. S. Nuclear Regulatory Commission the attached comments on draft plant-specific Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants," and that all the statements and matters set forth herein are true and correct to the best of his knowledge and belief. To the extent that these statements are not based on his personal knowledge, they are based on information provided by Duke employees and/or consultants. Such information has been reviewed in accordance with Duke Energy Corporation practice and is believed to be reliable.
M. S. Tuckman, Executive Vice President Duke Energy Corporation Subscribed and sworn to before me this _,2,-
day of 2002.
Notary Pub ic My Commission Expires:
IJAJ 2-Z j 006
U.S. Nuclear Regulatory Commission Document Control Desk August 2, 2002 Page 3 xc: (w/ Attachment)
L. A. Reyes Regional Administrator, Region II U. S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303 D. B. Matthews Director, Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Senior NRC Resident Inspector McGuire Nuclear Station Senior NRC Resident Inspector Catawba Nuclear Station C. P. Patel Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 P. T. Kuo Program Director, License Renewal and Environmental Impacts Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 R. L. Franovich Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 R. E. Martin Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
U.S. Nuclear Regulatory Commission Document Control Desk August 2, 2002 Page 4 xc: (w/ Attachment)
Henry J. Porter Assistant Director, Division of Waste Management Bureau of Land & Waste Management S.C. Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, NC 27626 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 R. M. Fry Director, Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27609 North Carolina Electric Membership Corporation P.O. Box 27306 Raleigh, NC 27611 Saluda River Electric Cooperative, Inc.
P. 0. Box 929 Laurens, SC 29360
U.S. Nuclear Regulatory Commission Document Control Desk August 2, 2002 Page 5 bxc: (w/ Attachment)
Mike Tuckman EC07H Roberta Bowman EC06B Ken Canady EC08H Tom Harrall EC07I Jim Fisicaro EC05R H. B. Barron MGOIVP C. J. Thomas MGO1RC G. R. Peterson CNO1VP G. D. Gilbert CNO1RC R. L. Carpenter PBO1C B. J. Horsley PBO1C A. W. Cottingham (Winston & Strawn)
ELL ECO50 Catawba Master File CN04DM (NSD-0135.02)
McGuire Master File MGO1DM Duke License Renewal Team Paul Colaianni EC09N Terry Cox EC 12R Bob Gill EC12R Mary Hazeltine EC 12R Bill Miller EC12ZB Rounette Nader EC 12R Lisa Vaughn EC11X Debbie Keiser EC05Z Greg Robison EC12R Mike Semmler EC090 Comments on Draft Plant-specific Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" McGuire Nuclear Station, Units 1 and 2 Comments on Draft NUREG-1437, Supplement 8 McGuire Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.5 Aquatic Resources Comment Page Line Comment Number 1
2-19 19 Line reads:
"The primary fish caught in the nearshore littoral zone include sunfish (Lepomis spp.), carp (Cyprinus carpio),
and catfish including the blue catfish (Ictalurus furcatus),
snail bullhead (Ameiurus brunneus), white catfish (I.
catus), and flat bullhead (I. platycephalus). "
The inclusion of blue catfish as inhabitants of the nearshore littoral zone is incorrect as these fish are considered largely pelagic in nature and are only occasionally caught inshore. Additionally snail bullhead, white catfish, and flat bullhead are no longer found in significant numbers due in large part we believe by blue catfish and flathead catfish predation.
Correct the sentence to read, "The primary fish caught in the nearshore littoral zone include sunfish (Lepomis spp.),
largemouth bass, crappie, and carp (Cyprinus carpio).
Numbers of previously abundant catfish species like snail bullhead (Ameiurus brunneus), white catfish (I. catus),
and flat bullhead (I. platycephalus) have dwindled significantly due to suspected predation by blue catfish (Ictalurus furcatus), and flathead catfish (Pylodictis
_ _olivaris)."
2 2-19 27-29 Lines read:
"In 1999, 135 species of phytoplankton were collected, the dominant types being cryptophytes and diatoms (Duke 2001a)."
It is more accurate to use the words 'varieties and forms' instead of species. Correct the sentence to read "In 1999, 135 varieties and forms of phytoplankton were collected, the dominant types being cryptophytes and diatoms (Duke 12001a).", Page 1
Attachment I Comments on Draft NUREG-) 43 7, Supplement 8 McGuire Nuclear Station, Units 1 and 2 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment 2.2.5 Aquatic Resources, Page 2 Chapter Section Comment Page Line Comment Number 3
2-20 5-8 Lines read:
"....--and three mussel species-Carolina heelsplitter (Lasmigona decorata), dwarf threetooth (Triodopsis fulciden), and Carolina creekshell (Villosa vaughnaniana) could inhabit the region around McGuire (Table 2-1)."
Although the word 'could' is used in this sentence, it creates the impression these mussels might be found in the area. This likelihood is extremely remote due to the lack of flowing water habitats around McGuire. Concurrence with this professional judgment is even stated in the SEIS on page 4-36, lines 25-28, "As described in Section 2.2.5, the only Federally or State-listed threatened or endangered aquatic species with the potential to inhabit waters near McGuire, the Carolina heelsplitter (Lasmigona decorata),
is not present in the vicinity of the plant (Fridell 2001) and does not occur in impounded water."
Revise sentence to read "....--and three mussel species Carolina heelsplitter (Lasmigona decorata), dwarf threetooth (Triodopsis fulciden), and Carolina creekshell (Villosa vaughnaniana)- could inhabit the region around McGuire (Table 2-1), but practically speaking the probability is extremely unlikely because of lack of lotic environments."
Attachment I Comments on Draft NUREG-1437, Supplement 8 McGuire Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.5 Aquatic Resources, Page 3 Comment Page ILine jComment Number
_I_
_I_
Comment Page Line Comment Number 4
2-20 32-34 Lines read:
"Menhinick (1991) lists the highfin carpsucker from Lake Norman considerably north of the study area and lists only historic records for the Santee chub in Lake Norman, but north of the study area (Gaddy 2001)."
Although the above sentence is not factually incorrect, it leaves the impression that perhaps the highfin carpsucker and maybe even the Santee chub may exist in Lake Norman. It is well worth noting however that in the NC Heritage Program records the highfin carpsucker documentation is extremely sketchy and the EORANK (Element Occurrence Rank) designation is 0 (Obscure date, location, and/or quality of the occurrence is unknown) and the survey date is listed only as pre-1991.
The same paucity of rigorous documentation and species records is also true for the Santee Chub.
Revise sentence to read "Menhinick (1991) lists the highfin carpsucker from Lake Norman considerably north of the study area and lists only historic records for the Santee chub in Lake Norman, but north of the study area (Gaddy 2001). However, detailed and thorough historical documentation on both species in the NC Natural Heritage Program records is incomplete or non-existent and there have been no citings of these species at all in the recent past."
Attachment I Comments on Draft NUREG-1437, Supplement 8 McGuire Nuclear Station, Units I and 2 Chapter Section Offsite Land Use 2.2.8.3 Comment Page Line Comment Number 5
2-31 37 Cowan's Ford Wildlife Refuge should be Cowan's Ford Waterfowl Refuge.
6 2-33 1
Cowan's Ford Wildfowl Refuge should be Cowan's Ford I_
Wildlife Refuge.
7 2-33 2
Line should read: "... within an oxbow bend in the riverine section of Mountain Island Lake."
8 2-33 1-6 Section does not mention Crowder's Mountain State Park. Crowder's Mountain State Park is located approximately 24 miles south-west of McGuire.
Chapter 4.0 Environmental Impacts of Operation Section 4.4.4 Public Services: Transportation Impacts During Operations Comment Page Line Comment Number 9
4-29 19-25 McGuire's main entrance (west entrance) has been closed as a result of the events of Sept. 11, 2001. This will probably be a permanent closure. All entrance and exit traffic must use the east entrance with the traffic light., Page 4 Comments on Draft NUREG-1437, Supplement 8 McGuire Nuclear Station, Units 1 and 2 Chapter Section 5.0 Environmental Impacts of Postulated Accidents 5.2.2.1 Duke's Risk Estimates Comment Page Line Comment Number 10 5-6 23 Line reads:
"... comments received during the McGuire peer review process,...
Including the above phrase in this location may lead a reader to assume that the peer review comments were incorporated into Revision 2 of the PRA which was used for the SAMA analysis. This is not the case; the peer review occurred after Revision 2 was complete. Suggest that the reference to the peer review be deleted here.
11 5-8 22 0.006 should be 0.06.
12 5-8 23 0.0075 should be 0.07., Page 5 Comments on Draft NUREG-) 43 7, Supplement 8 McGuire Nuclear Station, Units I and 2 5.0 Environmental Impacts of Postulated Accidents 5.2.2.2 Review of Duke's Risk Estimates Comment Page Line Comment Number 13 5-10 22 The Revision 3 results provided at the time of the RAI response were preliminary and somewhat changed in the final approved version of Revision 3. Values from the final approved version of Revision 3 are provided in the following comment.
Table 5-5 The Revision 3 results provided by Duke at the time of the RAI were preliminary and somewhat changed in the final approved version of Revision 3. Values from the final approved version of Revision 3 are provided below.
The format for these values is the same as provided in the RAI response dated January 31, 2002.
Core Damage Frequency Initiator Contribution SEISMIC 8.9E-06 TORNSW 1.6E-06 FIRES 6.3E-06 Total External 1.7E-05 Internal Floods 5.4E-06 Transients 2.9E-06 LOCAs 8.8E-06 RPV Rupture 1.OE-06 SGTR 5.2E-07 ATWS 5.3E-07 ISLOCA 9.8E-07 Total Internal 2.OE-05 Total CDF 3.7E-05 SBO Frequency Contribution Total SBO Frequency 1.OE-05 Seismic 7.4E-06 Tornado 1.5E-06, Page 6 Chapter Section 14 5-11 Comnments on Draft NUREG-1437, Sup"plemnent 8 MicGuire Nuclear Station, Units 1 and 2 Chapter Section 5.0 Environmental Impacts of Postulated Accidents 5.2.2.2 Review of Duke's Risk Estimates Comment Page Line Comment Number 15 5-11 Table The seismic CDF listed under the column heading PRA, 5-5, Rev. 1 (IPE) is given as 1.1E-05. This is the value from line 18 the IPEEE not the IPE (1.4E-05). This should be more clearly identified in the table.
16 5-11 Table Table 8.1-1 of Revision 1 of the McGuire PRA (IPE),
5-5, lists the fire CDF as 8.1E-08, not 2.3E-07. The IPEEE line 20 estimate of the fire CDF is 2.3E-07. Clarify which value I and reference are intended.
Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.3.1 Potential Design Improvements Comment Page Line Comment Number 17 5-16 Table Line in Table 5-6 reads: "align reactor vessel (RV) 5-6 cooling/other Unit RN"...
The Duke table used RV cooling. In this case RV is not an acronym for reactor vessel. RV is the shorthand notation for the Containment Ventilation Cooling Water System. This description should be added to the RV entry on page xxiii Abbreviations/Acronyms.
18 5-16 Table The zeros in the CDF column should be replaced with 5-6 the CDF values from Table 4-2, found in Attachment K of the McGuire ER.
Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.4 Risk Reduction Potential of Design Improvements Comment Page Line Comment Number 19 5-19 27 The Revision 3 results provided at the time of the RAI response were preliminary and somewhat changed in the final approved version of Revision 3. Values from the final approved version of Revision 3 are provided Comment Number 14., Page 7 Comments on Draft NUREG-1437, Supplement 8 McGuire Nuclear Station, Units 1 and 2 Chapter Section 5.0 Environmental Impacts of Postulated Accidents 5.2.5 Cost Impacts of Candidate Design Improvements Comment Page Line Comment Number 20 5-21 28 The cost estimate provided by Duke ($205,000) is a per unit cost and should not be divided by 2.
5-17 Table 5-7 One of the major cost categories for the candidate modification is in the installation labor, primarily pulling cables. It was judged that finding a location for the diesel that would allow it to serve either unit would dramatically increase the cable pulling cost component.
As such, it was judged that having a diesel for each unit would be less expensive (given the low cost of the hardware) than pulling cables to both units from a single location.
21 5-21 29 Note that the pre-staged option was selected in order to provide confidence that the alignment could be established within a time frame that would allow mitigation for fast as well as slow station blackouts.
Without pre-staging, the time needed to power the igniters would be long and may not be effective for all sequences. The estimated benefit would be reduced by some amount if a pre-staged diesel was not assumed.
22 5-21 39 The cost estimate provided by Duke ($540,000) is a per unit cost and should not be divided by 2.
23 5-22 3-5 The sentence, "Duke further noted that..." should be modified. The discussion that Duke provided relative to powering the air-return fans was in the context of powering the igniters. The mixing afforded by the fans may or may not be significant to the effectiveness of PARs, but in any case Duke provided no position on the need for fans when using PARs.
24 5-22 9
replace "reactor vessel cooling" with "the Containment Ventilation Cooling Water System" 25 5-22 15-16 The two cost estimates, $275,000 and $291,000, are in the reverse order of the 2 SAMAs, (1) and (2), discussed earlier in the same paragraph. This may lead a reader to associate the costs incorrectly with the SAMAs., Page 8
Attachment I Comments on Draft NUREG-1 43 7, Supplement 8 McGuire Nuclear Station, Units 1 and 2 5.0 Environmental Impacts of Postulated Accidents 5.2.6.1 Duke Evaluation 5.0 Environmental Impacts of Postulated Accidents 5.2.6.2 Staff Evaluation, Page 9 Chapter Section Chapter Section Comment Page Line Comment Number 26 5-25 4
3.8 LE+08 should be 3.1E+08 See page 12 of Attachment K, McGuire ER.
Comments on Draft NUREG-1437, Supplement 8 McGuire Nuclear Station, Units I and 2 Chapter 6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management Section 6.1 The Uranium Fuel Cycle Comment Page Line Comment Number 28 6-6 25 This page presents a brief chronology of events that have occurred in the area of high level waste disposal subsequent to the GElS being published in 1996. The chronology ends at the President's recommendation in February 2002.
While it may seem a bit odd for this type of information to be contained in an environmental document, Duke believes that the chronology should remain in the SEIS and should be updated to reflect significant events that have taken place since then. For example:
"On April 8, 2002, Governor Guinn of Nevada issued a "Notice of Disapproval" regarding the recommendation of the President. As required by the Nuclear Waste Policy Act, the matter was then referred to the Congress.
Subsequently, [insert final decision of Congress and date]."
Chapter Section Appendix E Table E-1, Page 10
Duke Power DuPowe 526 South Church St. EC07H PftwfwerCharlotte, NC 28202 A Duke Energy Company P.O. Box 1006 EC07H Charlotte, NC 28201-1006 M. S. Tuckman (704) 382-2200 OFFICE Executive Vice Presuient (704) 382-4360 FAA Nuclear Generation August 9, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Comments on draft plant-specific Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" Catawba Nuclear Station, Docket Nos. 50-413 and 50414 By letter dated June 13, 2001, Duke Energy Corporation (Duke) submitted an Application to Renew the Facility Operating Licenses of McGuire Nuclear Station and Catawba Nuclear Station (Application). The staff has reviewed the information provided in the Environmental Report contained in the Application as well as the information provided in Duke letters dated February 1 and 8, 2002. By letter dated May 14, 2002, the staff forwarded a copy of the draft plant-specific Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" for McGuire and provided Duke the opportunity to submit comments.
Accordingly, please find Duke comments on draft Supplement 9 to NUREG-1437.
In addition to providing comments on the draft Supplement 9, Duke is also in the process of reviewing the conclusions contained in Section 5.2.7 of the draft Supplement 9. In this section, the staff concluded that two of the severe accident mitigation alternatives (SAMAs): one related to hydrogen control in SBO sequences is cost beneficial under certain assumptions, which are being examined in connection with the resolution of GSI-189, "Susceptibility of Ice-Condenser and Mark III Containments to Early Failure from Hydrogen Combustion During a Severe Accident" and a second SAMA related to the installation of flood protection around the 6900/4160 volt transformers. Duke is in the process of reviewing both of these SAMA and has provided its position in a separate letter dated August 8, 2002.
If there are any questions, please contact either Bill Miller at (704) 373-7900 or Bob Gill at (704) 382-3339.
Very truly yours, M. S. Tuckman Attachment
U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 2 Affidavit M. S. Tuckman, being duly sworn, states that he is Executive Vice President, Nuclear Generation Department, Duke Energy Corporation; that he is authorized on the part of said Corporation to sign and file with the U. S. Nuclear Regulatory Commission the attached comments on draft plant-specific Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants," and that all the statements and matters set forth herein are true and correct to the best of his knowledge and belief. To the extent that these statements are not based on his personal knowledge, they are based on information provided by Duke employees and/or consultants. Such information has been reviewed in accordance with Duke Energy Corporation practice and is believed to be reliable.
M. S. Tuckman, Executive Vice President Duke Energy Corporation Subscribed and sworn to before me this q "TI day of.2002.
Notary Publ c My Commission Expires:
,. fc 2 2 1 :2ZOV
U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 3 xc: (w/ Attachment)
L. A. Reyes Regional Administrator, Region II U. S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303 D. B. Matthews Director, Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Senior NRC Resident Inspector McGuire Nuclear Station Senior NRC Resident Inspector Catawba Nuclear Station C.P. Patel Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 P. T. Kuo Program Director, License Renewal and Environmental Impacts Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 R. L. Franovich Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 R. E. Martin Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 4 xc: (w/ Attachment)
Henry J. Porter Assistant Director, Division of Waste Management Bureau of Land & Waste Management S.C. Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, NC 27626 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 R. M. Fry Director, Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27609 North Carolina Electric Membership Corporation P.O. Box 27306 Raleigh, NC 27611 Saluda River Electric Cooperative, Inc.
P. 0. Box 929 Laurens, SC 29360
U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 5 bxc: (w/ Attachment)
Mike Tuckman EC07H Roberta Bowman EC06B Ken Canady EC08H Tom Harrall EC07I Jim Fisicaro EC05R H. B. Barron MGO1VP C. J. Thomas MG01RC G. R. Peterson CNO1VP G. D. Gilbert CNOIRC R. L. Carpenter PB01C B. J. Horsley PB01C A. W. Cottingham (Winston & Strawn)
ELL EC050 Catawba Master File CN04DM (NSD-0 135.02)
McGuire Master File MGO 1DM Duke License Renewal Team Paul Colaianni EC09N Terry Cox EC12R Bob Gill EC12R Mary Hazeltine EC 12R Bill Miller EC12ZB Rounette Nader EC 12R Lisa Vaughn ECI 1X Debbie Keiser EC05Z Greg Robison EC12R Mike Semmler EC090 Comments on Draft Plant-Specific Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" Catawba Nuclear Station, Units I and 2
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter Executive Summary Section Not Applicable Comment Page Line Comment Number 1
xix 12-14 The staff's conclusion statement contained in these lines contradicts the staff conclusion statement contained in Section 5.2.7, page 5-28, lines 20-21.
Chapter 1.0 Introduction Section 1.5 Compliance and Consultations Comment Page Line Comment Number 2
1-9 8
From Table 1-1, under Column reading "Permit Expiration or Consultation Date":
The permit expiration date is listed as "April 30, 2006".
The NPDES permit issue date was April 30, 2001, however the permit was not issued until well into the 5 year cycle. Therefore the expiration date on the permit is not the full 5 years from date of issue.
I Correct the permit expiration date to be "June 30, 2005".
Chapter Section 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment 2.1.2 Reactor Systems, Page 1 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.1.7 Power Transmission Systems Comment Page Line Comment Number 4
2-14 14 The term "conservation easements" should be replaced with "protection of rare species".
Duke does not currently have conservation easements with SCDNR for transmission ROWs.
Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.1 Land Use Comment Page Line Comment Number 5
2-14 34 "4916 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
6 2-14 35 The statement "Full pond was achieved in 1904..." is somewhat misleading. Construction of a much smaller dam was completed in 1904. This dam was completely covered by the current and much larger Wylie dam which resulted in a significantly larger reservoir.
Change the statement to read: "The lake was initially impounded in 1904. Present full pond was obtained in
!1924 with an increase in the dam height.
7 2-16 1
"Duke owns the land that underlays the lake..." is not entirely correct.
Change the statement to read: "Duke either owns the land under the lake or owns flood rights to the land under the lake".
8 2-16 9
The fenced cemetery referenced as part of-the site is not part of Catawba Nuclear site. The site is owned and operated by the Concord Cemetery Association., Page 2 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.1 Housing Comment Page Line Comment Number 9
2-27 24-25 From Table 2-4, under Column reading "Number of Personnel":
Currently reads:
Other - NC 95 Other - SC 96 In order to correctly reflect the number counts as given in Table 2-5, change to:
Other-NC 112 Other - SC 79 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.2 Public Services Comment Page Line Comment Number 10 2-32 24-25 Lines Read:
"There are 24 counties within the 80-km (50 mi) radius of the Catawba site: 13 in South Carolina and 10 in North Carolina. The 23-county area is served by 3 major interstate freeways."
Correct the sentences to read:
"There are 24 counties within the 80-km (50 mi) radius of the Catawba site: 11 in South Carolina and 13 in North Carolina. The 24-county area is served by 3 major interstate freeways."
-, Page 3 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.4 Visual Aesthetics and Noise Comment Page Line Comment Number 11 2-36 5
"4912 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.5 Demography Comment Page Line Comment Number 12 2-38 31 "4912 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
13 2-38 34 Duke owns eight (not nine) public recreational access locations on Lake Wylie and one additional access location immediately downstream of the lake. Of these nine access areas, only two (not 3) are leased to other operators.
Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.9.2 Historic and Archaeological Resources at Catawba Comment Page Line Comment Number 14 2-48 25 The Concord Cemetery is not located within the Catawba site, but adjacent to it. The cemetery is owned and operated by the Concord Cemetery Association.
15 2-48 37 The Concord Cemetery is not located within the Catawba site, but adjacent to it. The cemetery is owned and operated by the Concord Cemetery Association., Page 4
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.10 Related Federal Project Activities and Consultations Comment Page Line Comment Number 16 2-49 22 Line Reads:
"This lake was formed by impounding the water of the Catawba River, and full pond was achieved in 1904."
Correct the sentence to read:
"This lake was formed by impounding the water of the Catawba River in 1904."
17 2-49 24 "4912 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
Chapter 4.0 Environmental Impacts of Operation Section 4.1.2 Microbiological Organisms (Public Health)
Comment Page Line Comment Number 18 4-14 40-41 Statement reads: Based on Catawba-specific experience, a review of available technical literature on thermophilic organisms, and the fact that there is little heated This sentence is incomplete., Page 5 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.2.1 Duke's Risk Estimates Comment Page Line Comment Number 19 5-6 20 5.8E-05/ry should be 5.8E-05/yr Duke's reported risk estimates are base on a calendar year basis, not a reactor year basis. The capacity factor used in the PRA is 0.9.
20 5-6 25 "per reactor-year" should be "per year" 2 cases 21 5-7 17 Table 5 Heading "Frequency (per reactor-year)"
should be Frequency (per year) 22 5-8 23 "reactor-year" should be "year" 23 5-8 26 "per reactor-year" should be "per year" 24 5-9 2
"per reactor-year" should be "per year" 25 5-9 3
"per reactor-year" should be "per year" Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.2.2 Review of Duke's Risk Estimates Comment Page Line Comment Number 26 5-11 10 "per reactor-year" should be "per year", Page 6
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units 1 and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.3.1 Process for Identifying Potential Design Improvements Comment Page Line Comment Number 27 5-12 25 "per reactor-year" should be "per year" 28 5-12 29 "per reactor-year" should be "per year" 29 5-14 Table 5-5 Footnote (a) "per reactor-year" should be "per year" 30 5-14 Table 5-5 Footnote (b) "per reactor-year" should be "per year" 31 5-15 10 Table 5 The cost of enhancement provided by Duke for the back-up power to the igniters ($540,000) is a per unit cost and should not be divided by 2.
One of the major cost categories for the candidate modification is in the installation labor, primarily pulling cables. It was judged that finding a location for the diesel that would allow it to serve either unit would dramatically increase the cable pulling cost component.
As such, it was judged that having a diesel for each unit would be less expensive (given the low cost of the hardware) than pulling cables to both units from a single location.
32 5-15 22 Table 5 Delete Footnote (c)
Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.4 Risk Reduction Potential of Design Improvements Comment Page Line Comment Number 33 5-17 28 "per reactor-year" should be "per year" 34 5-17 29 "per reactor-year" should be "per year" 35 5-17 35 "per reactor-year" should be "per year", Page 7
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.5 Cost Impacts of Candidate Design Improvements Comment Page Line Comment Number 36 5-19 17
"$205,000 per site" should be "$205,000 per unit" see comment 28 37 5-19 24
"$540,000 per site" should be "$540,000 per unit see comment 28 38 5-19 " 27-29 The sentence, "In order to provide..." should be deleted as it is not appropriate to divide these costs by 2.
39 5-19 36-38 The sentence, "Duke further noted that..." should be modified. The discussion that Duke provided relative to powering the air-return fans was in the context of powering the igniters. The mixing afforded by the fans may or may not be significant to the effectiveness of PARs, but in any case Duke provided no position on the need for fans when using PARs.
Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.6.1 Duke Evaluation Comment Page Line Comment Number 40 5-22 34 3.8 1E+08 should be 3.1E+08 see page 12 of Attachment H, Page 8
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.6.2 Staff Evaluation Comment Page Line Comment Number 41 5-25 14 "30 percent" should be "24 percent" See Table 5-3 of the SEIS 42 5-25 29 "per reactor-year" should be "per year" 43 5-25 30 "per reactor year" should be "per year" 44 5-26 3-5 The discussion concerning NUREG/CR-6427 should more accurately characterize the insights from the NUREG. This NUREG provided a simplified level 2 analysis for the purpose of investigating the importance of DCH. The conservative assumptions applied in this analysis with regard to hydrogen generation and the probability of ignition make it useful for understanding the uncertainties associated with early containment failure probabilities. The NUREG should not be interpreted as the latest information with respect to a realistic or best-estimate evaluation of the potential for early containment failure as a result of hydrogen combustion during station blackouts.
45 5-26 3
"per reactor-year" should be "per year" 46 5-26 20 "per reactor-year" should be "per year" 2 cases 47 5-27 5 & 9 Table 5 $270,000 should be $540,000 and $102,5000 should be $205,000 The cost provided by Duke are per unit costs and should not be divided by 2 48 5-27 11-13 Table 5 Delete Footnote (a), Page 9 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management Section 6.1 The Uranium Fuel Cycle Comment Page Line Comment Number 49 6-6 25 This page presents a brief chronology of events that have occurred in the area of high level waste disposal subsequent to the GEIS being published in 1996. The chronology ends at the President's recommendation in February 2002.
While it may seem a bit odd for this type of information to be contained in an environmental document, Duke believes that the chronology should remain in the SEIS and should be updated to reflect significant events that have taken place since then. For example:
"On April 8, 2002, Governor Guinn of Nevada issued a "Notice of Disapproval" regarding the recommendation of the President. As required by the Nuclear Waste Policy Act, the matter was then referred to the Congress.
Subsequently, [insert final decision of Congress and date]."
Chapter Chapter 8.0 Environmental Impacts of Alternatives to Operating License Renewal Section Section 8.2.2.1 Oil and Natural-Gas-Fired (Combined Cycle) Closed-Cycle Cooling System Comment Page Line Comment Number 1
50 8-32 23 Reference to SCDNR should be replaced with SCDHEC, Page 10 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units 1 and 2 Chapter 8.0 Environmental Impacts of Alternatives to Operating License Renewal Section 8.2.3.1 Nuclear Power Generation - Closed-Cycle Cooling System Appendix E Table E-1, Page 11 Chapter Section Chapter Section
SDuke GARY R. PETERSON OPowere Vice President A Duke Energy Company Ctawba Nuclar Staton Duke Power CNOIVP / 4800 Concord Rd.
York, SC 29745 803 831 4251 803 831 3221 fax grpeters@duke-energy com August 8, 2002 U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, DC 20555-0001
SUBJECT:
Duke Energy Corporation Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Severe Accident Mitigation Alternatives
REFERENCE:
- 1) Letter, USNRC to Duke Energy Corporation Dated May 14,
- 2002,
SUBJECT:
Request for Comments on the Draft Plant-Specific Supplement 9 to the Generic Draft Environmental Impact Statement Regarding Catawba Nuclear Station, Units 1 and 2.
Gentlemen:
Section 5.2.7 of Reference 1 identifies two Severe Accident Mitigation Alternatives (SAMAs):
one to provide back-up power to the hydrogen igniters for Station Blackout (SBO) events and the other to install flood protection around the 6900/4160 volt transformers.
The NRC staff states that since these SAMAs do not relate to adequately managing the effects of aging during the period of extended operation, they need not be implemented.as part of license renewal pursuant to 10 CFR Part 54.
The staff intends to pursue these two SAMAs as current operating license issues.
Catawba has reviewed these two SAMAs and concurs with the NRC that these two SAMAs are not within the scope of license renewal and should be addressed separate from any license renewal proceedings.
This letter provides the Catawba Nuclear Station position on these two SAMAs.
For the first
- SAMA, concerning the installation of back-up power to the hydrogen ignition system during a SBO event, Catawba agrees with the NRC staff that depending on the design requirements there may be a cost-beneficial modification that provides sufficient alternative power during a SBO to the hydrogen ignition system.
The NRC staff has determined that this issue is sufficiently important for PWRs with ice-condenser containment and BWR Mark III containments that the NRC has made the issue a
Generic Safety Issue (GSI),
GSI-189 Susceptibility of Ice-Condenser and Mark III Containments to Early Failure from Hydrogen Combustion During a Severe Accident.
As part of the resolution of GSI-189, the NRC is evaluating potential www duke-energy corn
U.S. Nuclear Regulatory Commission Page 2 August 8, 2002 improvements to hydrogen control provisions in ice-condenser plants to reduce their vulnerability to hydrogen-related containment failures during a SBO.
This will include an assessment of the costs and benefits of various options.
Catawba will evaluate various possible plant design and procedural changes to address this issue.
- However, since this issue is being pursued by the NRC as a generic issue for ice-condenser and BWR Mark III containments, Catawba will monitor the NRC resolution of GSI-189 as a current operating license issue.
For the second SAMA, concerning the installation of flood protection around the 6900/4160 volt transformers, Catawba also agrees with the NRC staff conclusion in Reference
- 1.
Catawba is currently in the process of designing and scheduling the installation of flood protection for the 6900/4160 volt transformers for Units 1 and 2.
The current schedule is to have this modification completed by March 31, 2005.
Catawba will keep the NRC Staff informed on the progress of this modification and any changes to the schedule.
This is the only regulatory commitment contained in this letter.
Duke Energy and Catawba have been actively involved since before 1988 in the development of plant-specific probabilistic risk assessments (PRA),
individual plant examinations (IPE/IPEEE),
and component/system reliability studies to evaluate severe accidents at Catawba.
Risk insights from various Catawba risk assessments have been identified and implemented to improve both the design and operation of the plant.
These changes to the plant have been prioritized based on risk significance and implemented accordingly.
The implementation of such improvements has reduced the risk associated with major contributors identified by the Catawba PRA and has enhanced overall plant safety.
Consideration of the two issues identified in Reference 1 continues the activities previously taken by Duke Energy to use risk insights to continuously improve the safety of Catawba Nuclear Station.
If you have any questions regarding this submittal, please contact Randall D. Hart at 803-831-3622.
Sincerely, Peterson RDH/s
U.S. Nuclear Regulatory Commission Page 3 August 8, 2002 Xc:
L.A. Reyes U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,
SW, Suite 23T85 Atlanta, GA 30303 D.J. Roberts Senior Resident Inspector (CNS)
U.S. Nuclear Regulatory Commission Catawba Nuclear Station C.P. Patel (Addressee Only)
NRC Senior Project Manager (CNS)
U.S. Nuclear Regulatory Commission Mail Stop 08-H12 Washington, D.C. 20555-0001 R.L. Franovich Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 12-G15 Washington, D.C. 20555-0001 J.H. Wilson Senior Project Manager Office of Nuclear Reactor Regulation Mail Stop 12-D3 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
£Anne Cottingham, Esquire Winston and Strawn 1400 L Street, NW Washington, DC 20005
Duke Duke Energy Corporation Energy.-
McGuire Nudear Statin 12700 Hagers Ferry Road Huntersvil.e, NC 28078-9340 H. B. Barron (704) 8754800 OFFIcE Vice Presi&nt (704) 8754809 FAx August 19, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Duke Energy Corporation McGuire Nuclear Station, Units 1 and 2 Docket Numbers 50-369 and 50-370 Severe Accident Mitigation Alternatives
REFERENCE:
- 1) Letter, U.S. Nuclear Regulatory Commission to Duke Energy Corporation Dated May 6,
- 2002,
SUBJECT:
Request for Comments on the Draft Plant-Specific Supplement 8 to the Generic Draft Environmental Impact Statement Regarding McGuire Nuclear Station, Units 1 and 2 (TAC NOS.
MB2021 and MB2022).
Section 5.2.7 of Reference 1 identifies one Severe Accident Mitigation Alternative (SAMA) that would provide back-up power to the hydrogen igniters for Station Blackout (SBO) event.
The NRC staff states that since this SAMA does not relate to adequately managing the effects of aging during the period of extended operation, it does not need to be implemented as part of license renewal pursuant to 10 CFR 54.
The NRC staff intends to pursue this SAMA as a current operating license issue.
McGuire concurs with the NRC that this SAMA is not within the scope of license renewal and should be addressed separate from any license renewal proceedings.
McGuire concurs with the NRC staff that there may be a cost beneficial plant design modification that can provide alternative power to the hydrogen ignition system during a SBO event.
The NRC staff has determined that the hydrogen control issue is sufficiently important for PWRs with ice-condenser containment and BWR Mark III containments that the NRC has made the issue a Generic Safety Issue (GSI),
GSI-189 - Susceptibility of Ice Condenser and Mark III Containments to Early Failure from Hydrogen Combustion During a Severe Accident.
McGuire has begun evaluating possible plant design and procedure changes to find a cost-beneficial resolution for this SAMA issue.
U.S. Nuclear Regulatory Commission August 19, 2002 Page 2 Duke Energy has performed plant-specific probabilistic risk assessments (PRA),
individual plant examinations, and system/component reliability studies to evaluate severe accidents at McGuire.
Various design and procedure changes have been identified and implemented as a result of the above efforts.
These changes have reduced the risk associated with major contributors identified by the McGuire PRA and have enhanced overall plant safety.
Resolution of the SAMA issue identified in Reference 1 is consistent with the effort by Duke Energy to use risk insights to continuously improve the safety of McGuire Nuclear Station.
McGuire is cooperating with the NRC in resolving GSI-189 as a current operating license issue.
If you have any questions regarding this submittal, please contact P.T. Vu at 704-875-4302.
Very Truly Yours, H.B. Barron HBB/PTV/s
U.S. Nuclear Regulatory Commission August 19, 2002 Page 3 xc:
L.A. Reyes U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth St.,
SW, Suite 23T85 Atlanta, GA 30303 S.M. Schaffer Senior Resident Inspector (MNS)
U.S. Nuclear Regulatory Commission McGuire Nuclear Station R.E. Martin (Addressee Only)
NRC Senior Project Manager (MNS)
U.S. Nuclear Regulatory Commission Mail Stop 08-G9 Washington, DC 20555-0001 R.L. Franovich Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 12-G15 Washington, DC 20555-0001 J.H. Wilson Senior Project Manager Office of Nuclear Reactor Regulation Mail Stop 12-D3 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Anne Cottingham, Esquire Winston and Strawn 1400 L Street, NW Washington, DC 20005 R.M. Frye Director, N.C. Division of Radiation Protection 3825 Barrett Drive
- Raleigh, NC 27609-7221