ML040430624
| ML040430624 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar  |
| Issue date: | 02/12/2004 |
| From: | Chernoff M NRC/NRR/DLPM/LPD2 |
| To: | Scalice J Tennessee Valley Authority |
| Chernoff, M H, NRR/DLPM, 301-415-4041 | |
| References | |
| TAC MB8019 | |
| Download: ML040430624 (13) | |
Text
February 12, 2004 Mr. J. A. Scalice Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
SUBJECT:
WATTS BAR NUCLEAR PLANT, UNIT 1 ISSUANCE OF AN AMENDMENT TO REVISE THE UPDATED FINAL SAFETY ANALYSIS REPORT REGARDING SEISMIC QUALIFICATION OF MAIN CONTROL ROOM DUCTING (TAC NO. MB8019)
Dear Mr. Scalice:
The Commission has issued the enclosed Amendment No. 50 to Facility Operating License No. NPF-90 for Watts Bar Nuclear Plant, Unit 1. The amendment approves changes to the Updated Final Safety Analysis Report to update the quality assurance criteria and the basis for the seismic qualification for the round flexible ducting and triangular ducting, constructed of duct board, and associated air bars, installed as part of the suspended ceiling air delivery system in the main control room. This amendment is in response to your application dated March 12, 2003, as supplemented on April 1 and November 21, 2003.
A copy of the safety evaluation is also enclosed. Notice of issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Margaret H. Chernoff, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-390
Enclosures:
- 1. Amendment No. 50 to NPF-90
- 2. Safety Evaluation cc w/enclosures: See next page
ML040430624 OFFICE PDII-2/PM PDII-2/LA EMCB IROB OGC PDII-2/SC NAME MChernoff BClayton SE Input TBoyce RHoeffling MLMarshall for:
AHowe DATE 02/12/04 02/12/04 10/14/03 10/14/03 2/28/04 02/12/04
TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-390 WATTS BAR NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 50 License No. NPF-90 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Tennessee Valley Authority (TVA or the licensee) dated March 12, 2003, as supplemented by letters dated April 1 and November 21, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, by Amendment No. 50, Facility Operating License No. NPF-90 is hereby amended to approve changes to the Watts Bar Unit 1 Updated Final Safety Analysis Report (UFSAR) Sections 3.2.1, 3.2.2.7, and 3.7.3.18, Tables 3.2-2a and 3.2-6, and Figure 9.4-1. These changes reflect the revised quality assurance criteria and basis for qualification of the main control room ventilation system ducting as set forth in the application for amendment by TVA dated March 12, 2003, as supplemented by letters dated April 1 and November 21, 2003.
3.
This license amendment is effective as of the date of its issuance. Implementation of the amendment is the incorporation into the next UFSAR update made in accordance with 10 CFR 50.71(e), of the changes to the description of the facility as described in TVAs application dated March 12, 2003, as supplemented by letters dated April 1 and November 21, 2003, and evaluated in the staffs Safety Evaluation attached to this amendment.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by M L Marshall for/
Allen G. Howe, Chief, Section 2 Project Directorate II Division of Project Licensing Management Office of Nuclear Reactor Regulation Date of Issuance: February 12, 2004 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 50 TO FACILITY OPERATING LICENSE NO. NPF-90 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-390
1.0 INTRODUCTION
By letter dated March 12, 2003, as supplemented on April 1 and November 21, 2003, the Tennessee Valley Authority (TVA, the licensee) submitted a request for approval of changes to the Updated Final Safety Analysis Report (UFSAR) for Watts Bar (WBN), Unit 1. The changes would update the quality assurance criteria and the basis for the seismic qualification of the round flexible ducting and triangular ducting, constructed of duct board, and associated air bars installed as part of the suspended ceiling air delivery system in the main control room. The licensee is revising the Technical Specification Bases to reflect this change.
The supplemental letters provided clarifying information that did not expand the scope of the original amendment request and did not change the initial proposed no significant hazards consideration determination.
2.0 REGULATORY EVALUATION
The Control Building Heating, Ventilating, and Air Conditioning system (including ducting) is designed to maintain the temperature and humidity of the main control room, and is designed to function during normal plant operation, accident conditions, and postaccident recovery conditions. The regulatory requirements directly applicable to the seismic qualification of this system are Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, General Design Criterion 1, Quality Standards and Records, and General Design Criterion 2, Design Bases for Protection Against Natural Phenomena; 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants; and 10 CFR Part 100, Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants.
General Design Criterion 1 requires that structures, systems and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. This criterion requires that a quality assurance program be established and implemented to provide assurance that these structures, systems and components will perform satisfactorily in service. Appendix B to 10 CFR Part 50 establishes the quality assurance (QA) requirements that apply to activities affecting safety-related functions of structures, systems and components.
General Design Criterion 2 requires that structures, systems, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, et al., without loss of capability to perform their safety functions. The earthquake for which these plant features are designed is defined as the safe shutdown earthquake (SSE). It is based upon an evaluation of the maximum earthquake which produces the maximum vibratory ground motion for which structures, systems, and components important to safety are designed to remain functional.
Appendix A to 10 CFR Part 100 contains the requirements for the determination of the SSE.
The regulations specify that certain structures, systems, and components important to safety be designed to withstand the SSE and remain functional. The engineering method used to ensure the required safety functions are maintained involves either a suitable dynamic analysis or qualification test, except where it can be demonstrated that use of an equivalent static load method provides adequate conservatism.
Section 3.2.1 of NUREG-0800, Standard Review Plan, describes the review process used by U.S. Nuclear Regulatory Commission (NRC) staff for reviewing an applicants proposed seismic classification of structures, systems, and components which are important to safety and designed to withstand, without loss of function, the effects of an SSE. The review also covers identification of structures, systems and components that are not required to remain functional following a seismic event, but whose failure could reduce the functioning of any Category I structure, system or component to an unacceptable safety level, or result in incapacitating injury to control room occupants.
To meet the requirements of General Design Criterion 2 and 10 CFR Part 100, Regulatory Guide 1.29, Seismic Design Classification, is used. It provides guidance for seismic qualification of components. It describes an acceptable method of identification and classification of those structures, systems and components that should be designed to withstand an SSE. Regulatory Guide 1.61, Damping Values for Seismic Design of Nuclear Power Plants, provides damping values acceptable to the NRC staff to be used in the elastic modal dynamic seismic analysis of Seismic Category I structures, systems, and components.
Compliance with the above requirements and guidance assures that the structures, systems and components important to safety that are required to function during an SSE are properly classified as seismic Category I and will function during such events enabling accomplishment of the safety functions described above.
3.0 TECHNICAL EVALUATION
The licensee stated the safety-related ducting for the Control Building Heating, Ventilating, and Air Conditioning System is classified as Seismic Category I in accordance with Regulatory Guide 1.29. The seismic classification for this system is discussed in the UFSAR. The licensee determined that the round flexible ducting, triangular ducting (constructed of duct board) and associated air bars installed as part of the suspended ceiling air delivery system in the main control room were not qualified to the Seismic Category I classification described in the UFSAR for the Heating, Ventilating, and Air Conditioning System. The licensee stated that the procurement documents for the flexible and triangular ducting did not specify seismic requirements for the components. This led to the conclusion that the air delivery components had not been seismically qualified per the guidance in Regulatory Guide 1.29, and had not been procured and installed in accordance with quality assurance requirements applicable to Seismic Category I components.
In its March 12, 2003, submittal, the licensee proposed a change to the UFSAR to state that the air delivery components are qualified to limited seismic requirements, and that the components have been analyzed to ensure the ducting will remain in place, the physical configuration will be maintained such that flow will not be impeded, and the ducting pressure boundary will not be lost. In support of this qualification change, the licensee proposed an alternate set of criteria for compliance with 10 CFR Part 50, Appendix B, which included the activities necessary to establish and confirm the quality and suitability of the equipment for its intended application.
The licensee also proposed alternate seismic qualification criteria and analysis methodology.
3.1 Quality Assurance Criteria The licensee stated that the round flexible ducting, triangular ducting, and associated air bars installed as part of the suspended ceiling air delivery system were not designed, procured, and installed in accordance with the Appendix B QA Program applicable to Seismic Category I structures, systems, and components. The licensee is proposing to classify these air delivery components as Seismic Category I(L) with position retention and air flow delivery requirements.
The NRC staff requested the licensee to discuss and compare key elements of the proposed alternate limited QA requirements with the elements of a program meeting the criteria of 10 CFR Part 50, Appendix B, applicable to safety-related components.
The licensee provided a comparative discussion of the alternate QA requirements in the TVA Nuclear QA Plan (NQAP) for Seismic Category I(L) pressure boundary and position retention items and activities versus those in the TVA NQAP for safety-related items and activities. The licensee provided appropriate justification for each identified difference between the two sets of requirements for the seismic qualification of the WBN suspended ceiling and air delivery components. The licensee stated that both NQAP processes produce similar end products (i.e., seismically qualified installation, design output drawings, maintenance and test requirements, and seismic qualification reports). The licensee concluded that, based on the comparison, the alternate QA activities outlined are adequate to ensure safe function in the areas important to seismic qualification.
The NRC staff reviewed the discussion provided by the licensee and concluded that the justifications provided in the comparative discussion are based on reasonable and practical considerations. Based on its review, the staff finds the proposed alternate criteria would establish and confirm the quality and suitability of the equipment for its intended application.
The staff finds that the proposed quality standards are commensurate with the importance of the safety functions to be performed, and meet the requirements of General Design Criterion 1 and 10 CFR Part 50, Appendix B.
3.2 Seismic Qualification Criteria and Methodology 3.2.1 Evaluation The licensee proposed that the seismic qualification of the suspended ceiling and the air delivery components be accomplished by rigorous time history analysis using the ANSYS computer code. The licensee stated that the methodology for the seismic qualification of the WBN main control room air delivery components and suspended ceiling was chosen based on the existing design configurations at WBN. The analysis was performed using the ANSYS computer codes capability for time history analysis and carefully selected linear and nonlinear elements to simulate the suspended ceiling with attached triangular ducts.
The NRC staff evaluated the adequacy of the licensees time history analysis methodology.
The evaluation included the (1) adequacy and reasonableness of the analytical approach for the seismic qualification; (2) comparability of the seismic analysis methodology adopted to those previously approved by the staff for other WBN component analyses; (3) definition and application of the time history input motions; (4) basis for the selected damping value in the analysis; (5) adequacy of the ceiling/air delivery system modeling and material characterization of system components; (6) appropriate use of seismic analysis codes and design standards; (7) adequate consideration of ceiling/air delivery components integrity and design margins; and (8) accounting of the variability in material properties and load magnitudes.
The NRC staff questioned whether the time history analysis methodology currently used for the qualification of the air delivery components is identical to that previously approved by the staff, and requested the licensee to justify any elements of the current methodology that are different from those previously approved by the staff. The licensee stated that the nonlinear finite element time history analysis methodology used for seismic qualification of the suspended ceiling and air delivery components applies the same basic structural analysis methods as used for seismic analyses of the seismic Category I ice condensers and fuel racks at WBN. The current analyses for the ceiling/air delivery system are not identical to those previously implemented, but they were performed by an industry expert using QA verified software.
Consequently, the quality and accuracy of the current analysis results are expected to be equivalent to those of the previously approved nonlinear time history seismic analyses for seismic Category I equipment assemblies at WBN.
The NRC staff requested the licensee to discuss key assumptions and limitations of the ANSYS program that are applicable to the full model and how the assumptions and limitations are integrated into the suspended ceiling model. The licensee indicated that the features of the suspended ceiling and air delivery components model include, in addition to modeling aspects customarily included in the conventional linear structural models, nonlinear element types to represent gaps and sliding, with friction, across the gaps, and geometric nonlinearity effects.
The licensee stated that there were no additional assumptions/limitations to the ones described in the submittal. The licensee further stated that modeling was done in a manner consistent with the ANSYS user manuals. ANSYS is a general-purpose finite element software, with extensive modeling and solver capabilities. ANSYS, Inc., supports a 10 CFR Part 50 Appendix B compliant QA verification program (including verification problems and error notices). ANSYS has been widely used in nuclear, aerospace, maritime, oil and gas, and electronics industries to solve linear and nonlinear structural stress and dynamics problems.
Such wide use of the software over the last several decades provides a level of additional assurance of the quality and verification of the software.
The NRC staff evaluated the overall conservatism of the licensees seismic qualification analysis and specifically requested the licensee to discuss key aspects of the analytical nonconservatism mentioned in regards to a transient dynamic finite element analysis of the air delivery components. The staff also requested the licensee to explain how the overall effect of the nonconservative seismic response results are adequately accounted for in the seismic qualification of the suspended ceiling and air delivery system. The licensee stated that the nonlinear time history analysis (i.e., the transient dynamic finite element analysis) provides more realistic results (closer to actual response) than would be obtained from linear elastic response spectra analysis. For example, the linear elastic analysis criteria would require assumption of: (1) low structural damping, and (2) no gaps, impact loads, internal friction or other nonlinear effects. For the suspended ceiling, where the luminous panels represent a large portion of the overall mass (in the order of 70 percent of the total suspended mass) and undergo sliding against friction within the ceiling grid, use of standard linear elastic analysis methodology would result in a significantly conservative prediction of the response. Since shake table testing of the entire assembly would be impractical, due to the size and complexity of the assembly, nonlinear time history analysis was chosen as the best available alternative.
The licensee further stated that the key factor in seismic qualification of the air delivery components is demonstration that the aluminum air bars remain structurally stable and provide continuous support for the triangular ducts. That fact is demonstrated directly in the ANSYS model analysis results.
The licensee stated that at the level of seismic response implied by the WBN SSE, with a peak ground acceleration of 0.18 g, the response of the ceiling structure will involve significant nonlinear behavior resulting in significant damping in excess of that typically used in structural design. The NRC staff requested the licensee to discuss the basis for the above statement and, as available, provide a quantitative or an earthquake experience based justification for the assertion. The licensee stated that Regulatory Guide 1.61 specifies a damping of 7 percent of critical for bolted steel structures subject to an SSE. On this basis, 7 percent damping should be used for a structure consisting of just the air-bars and the intersecting tee-bars bolted together (i.e., the grid without the luminous panels that (a) account for roughly 70 percent of the total suspended mass and (b) are subject to sliding against friction within the grid panels). The licensee indicated that the main control room ceiling at WBN is constructed such that significant nonlinear behavior and associated increased damping are expected.
The licensee stated that no sudden failure or loss of integrity of the main control room triangular ducting is expected and the duct seismic response should be ductile in nature. The staff requested the licensee to provide the basis for this conclusion. The licensee indicated that the triangular ducts are made of fibrous glass material. Fibrous glass ducts of this type are subjected to Underwriters Laboratories (UL) 181 Standard for Factory-Made Air Ducts and Air Connectors tests including structural integrity tests. The tests clearly indicate that the material is quite flexible and ductile (not brittle) and that the duct is structurally capable. The tests also indicate that the duct is durable. Field inspection of the ducting indicates that it is identical to the UL 181 listed material. Also, since the UL 181 standard has been available since 1961, it is reasonable to assume that the material conforms to UL 181 requirements. However, documentation is not available that unequivocally establishes that fact. Since the triangular ducting material is quite flexible, the triangular ducts will readily conform to the very small deformation of the supporting air bars indicated by the analyses without any structural damage to the triangular duct or the reinforced tape between triangular duct sections. This behavior and performance are further supported by seismic experience data.
The licensee concluded that the 10-inch diameter duct sections with spiral wire/fabric construction should maintain their structural integrity and full functional capability under an SSE.
The staff requested the licensee to provide pertinent vendor test data to support the above conclusion. The licensee indicated that there is extensive seismic testing with similar flexible hoses, in addition to extensive seismic experience data for various different types of ducts, including flexible round ducting. This information consistently demonstrates that the critical seismic failure mode for flexible ducting is structural damage in cases where the amplitude of relative end movements exceed the deformation capacity provided by the geometric configuration of the duct run or when the end connections are inferior. The seismic relative end movement demand for this application is much less than the end movement capacity of the flexible ducts. Hence the licensee concluded that the relative displacement on the order of less than 1 inch between the end points pose negligible demand for the flexible duct.
3.2.1 Evaluation Results Based on its review of the licensees submittal and the additional information provided by the licensee, the NRC staff determined that the licensees implementation of the ANSYS analysis for seismic qualification of the ceiling/air delivery system is consistent with applicable provisions of the Standard Review Plan and is, therefore, acceptable. The staff finds that the licensee has performed a rigorous and realistic nonlinear finite element analysis for the seismic qualification of the control room suspended ceiling and air delivery system. The staff concurs with the licensees justification for selection of the damping values and finds the selected damping values in the ANSYS analysis acceptable. The staff finds that the licensee has presented reasonable justification to conclude that no sudden failure or loss of integrity of the main control room triangular ducting is expected and that the duct seismic response should be ductile in nature. The staff finds that implementation of an analysis with the seismic margins demonstrated in the licensees analysis is an adequate basis for concluding that the ceiling/air delivery system will perform its pressure retention and air delivery functions following an SSE.
The staff evaluation included the technical soundness of the justification for the proposed use of the alternate QA criteria; adequacy and reasonableness of the analytical approach for the seismic qualification of the control room ceiling/air delivery system; comparability of the seismic analysis methodology to those previously approved for other WBN component analysis; basis for the selected damping value in the analysis; adequacy of the ceiling/air delivery system modeling and proper material characterization of the system components; realistic load definition and application; appropriate use of seismic analysis codes and design standards; adequate consideration of ceiling/air delivery components integrity and design margins; variability in material properties and load magnitudes; and logical evaluation of the ANSYS analysis results. The staff finds that the use of ANSYS nonlinear finite element seismic analysis code as implemented by the licensee is an appropriate and adequate way to seismically qualify the ceiling/air delivery system components. Both the seismic response results obtained and the conclusions drawn are conservative and acceptable.
As described in the preceding sections, the staff concludes that the licensees submittal is based on a comprehensive nonlinear finite element seismic qualification analysis, supported by operating experience based justifications, and is, therefore, acceptable. The staff finds that the seismic qualification proposed by the licensee, as supported by the licensees analysis, satisfies the regulatory requirements for ensuring the components are designed to withstand the effects of a seismic event, as required by 10 CFR Part 50, General Design Criterion 2, and 10 CFR Part 100, Appendix A.
4.0
SUMMARY
As discussed in Section 3.1 of this Safety Evaluation, the staff concludes that the proposed alternate QA criteria proposed by the licensee are acceptable means of compliance with 10 CFR Part 50, Appendix B, QA criteria. As discussed in Section 3.2, the staff finds that the seismic analysis described in the licensees submittal is an appropriate and adequate means of seismic qualification of the ceiling/air delivery system components. Based on its review, the staff finds that there is adequate assurance that the ceiling/air delivery system components are capable of withstanding the effects of earthquakes without loss of capability to perform necessary safety functions and, thus, meets the acceptance criteria in 10 CFR Part 50, General Design Criteria 1 and 2, and 10 CFR Part 100, Appendix A, and, therefore, this amendment is acceptable.
The licensee is revising the appropriate UFSAR Section 3.2.1, Seismic Classifications; Section 3.2.2.7, Heating, Ventilation, and Air Conditioning (HVAC) Safety Classification; Table 3.2-2a, Classification of Systems having Major Design Concerns related to a Primary Safety Function; Table 3.2-6, TVA Heating, Ventilation, and Air Conditioning Classifications; and Figure 9.4-1, Control Building Flow Diagram - Heating, Ventilating, Air Conditioning Air Flow. Section 3.7.3.18, Seismic Qualification of Main Control Room Suspended Ceiling and Air Delivery Components, is being added to the UFSAR. The licensee will submit the revised UFSAR in accordance with the requirements of 10 CFR 50.71(e). The licensee is also revising the appropriate Technical Specification Bases to reflect the seismic qualification criteria of these components. The staff has no objection to these changes.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (68 FR 18286). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: David Jeng Date: February 12, 2004
Mr. J. A. Scalice Tennessee Valley Authority WATTS BAR NUCLEAR PLANT cc:
Mr. Karl W. Singer, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. James E. Maddox, Vice President Engineering & Technical Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. William R. Lagergren Site Vice President Watts Bar Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, TN 37381 General Counsel Tennessee Valley Authority ET 11A 400 West Summit Hill Drive Knoxville, TN 37902 Mr. Michael J. Fecht, Acting General Manager Nuclear Assurance Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Mark J. Burzynski, Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Paul L. Pace, Manager Licensing and Industry Affairs Watts Bar Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, TN 37381 Mr. Larry S. Bryant, Manager Watts Bar Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Spring City, TN 37381 Senior Resident Inspector Watts Bar Nuclear Plant U.S. Nuclear Regulatory Commission 1260 Nuclear Plant Road Spring City, TN 37381 Rhea County Executive 375 Church Street Suite 215 Dayton, TN 37321 County Executive Meigs County Courthouse Decatur, TN 37322 Mr. Lawrence E. Nanney, Director Division of Radiological Health Dept. of Environment & Conservation Third Floor, L and C Annex 401 Church Street Nashville, TN 37243-1532 Ms. Ann P. Harris 341 Swing Loop Road Rockwood, Tennessee 37854