ML20043F769

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Forwards Charter for Augmented Insp Team Insp as Result of Inadvertent Single Train Injection Event at Facility
ML20043F769
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/14/1990
From: Crutchfield D
Office of Nuclear Reactor Regulation
To: Chamberlain D
Office of Nuclear Reactor Regulation
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ML20043F764 List:
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FOIA-90-141 NUDOCS 9006180107
Download: ML20043F769 (16)


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UNITE D STATES w /! NUCLEAR REGULATORY COMMISSION -{ i wAsmNGTON, D C. 20666 i g 4 4 MEMORANDUM FOR: Dwight Chamberlain. Leader Comanche Pe6k Augmented Inspection Team j FROM: Dennis M. Crutc;' field, Associate Director l for Special Projects ^ Office of Nuclear k0 actor Regulation

SUBJECT:

AUGMENTED INSPECTION TEAM CHARTER After being briefed on the March 12, 1990 inadvertent single train injection event at-Comanche Peak Steam Electric Station, Unit 1, NRR senior management determined that an Augmented Inspection Team (AIT) inspection shall i be conducted. You have been designated as Team Leader. Enclosed is the charter l for the Augmented Inspection Team delineating the scope of this inspection. / fMh h 14 Dennis M. Crutchf efd, Ass ate Director for Special Projects Office of Nuclear Reactor Regulation

Enclosure:

AugmentedLInspec.+.m Team Charter j f [8j61s@ 7 900503 TAYLOR 90-142 PDR

Qd' AUGMENTED INSPECTION TEAM CHARTER COMANCHE PEAK INADVERTENT SINGLE TRAIN INJECTION ON MARCH 12, 1990 The Augmented Inspection Team (AIT) is to perform an inspection to accomplish the following: 1. Using the information developed by CPPD Site Inspectors, conduct a thorough review of the sequence of events associated with the inadvertent single train injection at Comanche Peak Unit 1 on March 12, 1990, and the subsequent tiRC notification. 2. Review (Go expected consequences of the event had it occurred at full power, Wit.vould have bees *he cooldown rate and flows associated with Inadvertent actuation of Safety injection Train A? 3. Review the cause of the safety injection signal and the reason Train B did not initiate. 4. Review the plant systems and equipment response to'the event. 5. Review the operators' vesponse to the event, including human factors and procodural deficiencies (e.g. did they meet the criteria for starting the P.CP). 6. Review the cold over-pressure mitigation system setpoints with regard to unnecessary challenges of the PORVs. 7. Review the thoroughness of the licensee's investigation of the event. 8. Provide a Preliminary Notification upon initiation of the inspection and an update on the conclusion of the inspection. 9. Prepare a special inspection report documenting the results of the above activities within 30 days of the start of the inspection.

T M ella Q Iernin8 F' W Friday, March la,1990 I l NRC begins study 1 of ' unusual eventC at Comanche Peak - By Randy La Ldtis h *#r8W heelkmathw happened, as weil as what the inci; dent could mean when the plant' ne US Nuclear Regulatory Com. reaches higher temperatures for nor. I i mission on Thursday launched its inal operations. Mr, Gilliland said. own review of an electrical malfunc. NRC inspectors also will look at p tion this week at 'lV Electric's Co. how the plant's other systems in-manche Peak nuclear power plant teracted with the malfunctiotimg i near Glen Rose, component, how the plant's oper'a, . The NRC said its action did not tors responded and how well TU signal increased concern over the in. Electric did in its review of the inct. cident Monday afternoon, the first dent, he said. " unusual event" at the 59.1 billion Mr. Manroe said TU Electric' is , plant about 85 miles southwest of checking other diodes for possible 3

Dallas, S

defects, but results are not in. 4 Comanche Peak is running tests Citizens monitonag the plant wel. y I at low power in anticipation of start. comed the NRC review, i ing full operations later this year. "I'm glad to see it." said Juanita c! f' [.O i The NRC formed an eight mem, Ellis, president of Dallas based Citi, t k* f " ber panel, called an augmented in, zens Association for Sound Energy. F,.g' I spection team, to conduct a threeday "I think it shows they are being very j review of the incident.The team will cautious." inspectors need to find ce ?. ' p'E ? report in about one month, NRC out whether other diodes or other spokesman Joe Gilliland said. components are faulty,she said. ;' & y' "When the event first happened, Betty Brink, a member of Cit 12 ens - L the NRC knew it was going to follow for Fair Utility Regulation in Fort F: it up," Mr. Gilliland said. "This is just Worth, said the incident may have ' the way we decided to do it." - been more serious than TU Electrie 7," cf Utility and NRC officials initially or the NRCindicated.

1 attrihted the problem to a power if plant operators' procedure's foi Ica in some instruments. But TU dealing with the incident were' -

!Gectric spokesman Mark Manroe wrong, the problem is bi;1ger than a said Thursday that the company's re, single faulty diode, she said. 'Te'r'e ' view found a faulty diode - a tiny concerned because it shouldn't be,an electrical component - that di. on-thejob training situation,"'she 'E rected a signal to the wrong safety said. system. The diode has been replaced. The NRC and TU Electne said the s he said, malfunction is not expected to cause' ' l -- Re signal automatically a major delay in " going critical,"'the ' triggered emergency safety injection start of the self sustaining chain re-pumps that supplied water to cool action that will power the plant. N.u. the nuclear reactor. Company and clear fuel was loaded Feb. 914 and NRC official: said there was no dan. workers bolted the reactor's head in ger of a radiation release. place Feb.16. 1 The NRC classified the incident Lowpower tesung probably wQl'. I as an " unusual event," the least se. Continue for two months before the rious of four categories of nuclear chain reaction can be started, Mr., N-plant problems. Manroe said. "We're not going to te i \\ The NRC team will examine what hasty in any way."

4. L f* '**g UNITED STATES NUCLEAR REGULATORY COMMISSION s \\..... Office of Governmental and Public Affairs, REGION IV 611 Ryan Plaza Drive, Suite 1000, Arlington, Texas 79011 L g RIV: 90-27 FOR IP91EDIATE RELEASE

Contact:

Joe Gilliland (Thursday, March 15,1990) . Telephone: 817/860-8128(Office) SPECIAL NRC INSPECTION TEAM REVIEWING INCIDENT AT COMANCHE PEAK L The Nuclear Regulatory Comission staff has formed a special inspection team which will review the circumstances of an inadvertent emergency cooling system actuation earlier this week at the Comanche Peak Steam Electric Station near Glen Rose, Texas. The eight-member team, which is beginning its work today (March 15), is expected to spend three days at the plant. A written report will be issued in about a month. The unexpected cooling water injection into the Comanche Peak Unit I core occurred Monday afternoon, March 12, while pre-operational activities were under way. Although the unit has loaded fuel and is licensed for low-power testing, a self-sustaining chain reaction has not yet been started in the reactor core. In addition to reviewing the sequence of events of the incident itself, the NRC team will examine such things as the implications for operations at L higher temperatures associated with normal power levels; the interaction of l other plant systems; and the response of plant operators. Also to be assessed is the work of a TV Electric task force which has analyzed the event and concluded that it was caused by a malfunctioning electrical component. NRC forms augmented inspection teams like this one when they are warranted by matters of special technical or regulatory significance. It is not expected at-this time that the inspection will have a major impact on Comanche Peak's pre-startup work. Hi ft 1 \\ g 1

i COMANCHE PEAK AIT INADVERTANT SINGLE TRAIN INJECTION MARCH 12, 1990 Team Composition Team Leader Dwight Chamberl ain, RIV Reactor Systems Chu Liang Operations (Human Factors) Ted Sy:manski I&C Iqbal Ahmed Mat er i al s Barry.Elliot-Project Manager Mel Fields Operator Licensing Dave Graves Resident Inspector (Waterford) Steve Butler Actions Team Charter Jim Lyons PN Dwight Chamberlain Press Release Joe Gilliland Event Sequence Bill Johnson Operator Interviews Bob Latta l 9 Q

.+ ~ n 2 Charters-1. Using the information developed by the CPPD Site Inspectors, conduct a thorough review of the sequence of events ~ associated with the inadvertant single-train injection'at Comanche Peak' Unit i on March 12, 1990, and the subsequent NRC notification. Sequence of events. reviewed and understood. Appropriate notifications were made. t 2. Review the expected consequences of.the event had it occurred at full-power. What would have been the cooldown rate and flows associated with inadvertant actuation of Safety Injection Train A? Reviewed analyses and witnessed a simulator re-creation of the event. At full power, the event would have been milder because of better thermal conditions: similar to and bounded by the loss of feedwater event. 3. Review the cause of the safety injection signal and the reason Train B did not initiate. Concur with TU Electrics failed diode caused Train A to actuate. TU is evaluating system enhancements. 4. Review the plant systems and equipment response to the event. TU is performing a detailed evaluation of the system and equipment response. Hampered by continuning problems with the event recorder. Except for diode failure, the other systems and equipment appear to have operated properly. 5.- Review the operators' response to the event, including human factors and procedural deficiencies (e.g. did they meet the criteria for starting the RCP). Operator response was good. Re-creation on the simulator was within two minutes of the actual event. RCP start conditions probably OK. Would-have had less trouble with decay heat. Operators were aware of the LTOP conditions. 6. Review the cold over pressure mitigation system setpoints with regard to unnecessary cha11anges of the PORV's. Setpoints reviewed and appear appropriate. There is a competing effect on the RCP seal differential pressure.

1 ~ 7. Review the thoroughness of the licensee's investigation of the event. TU evaluation thorough and should be complete by about April-1. Staff should follow-up on TU's findings. AFW' design change may involve questions about the adequacy of the design change process. NRR~should review the design change ~ for the AFW flow control va l ve. ', 8. Provide a Preliminary Notification upon initiation of-the inspection and an update on the conclusion of the inspection. l PN 90-07 issued 3/15. 9. Prepare a special inspection report documenting the results of the above activities within 30 days of the start of the i inspection. Conference Calls March 17 at 2:30 pm Chamberlain (site) H00 Bill Madingly Crutchfield Warnick Gwynn Grimes Lyons AIT complete on saturday (3/17) at 1:30 pm and will exit I monday (3/19) at :2:00 pm. L a 1 l

\\t, EVENT

SUMMARY

FOR CHAIRMAN During.startup testing on March 12,.1990,. an unexpected actuation of a single train of the safety injection system occurred. At the time, the unit was in Mode 4 at 250*F and-380 psig. About ) 9000-gallons of coolant was injected during the transient. The reactor coolant pumps were shutdown during the transient because of pressure oscillations across the pump seals. Auxiliary Feedwater initiated and Steam Generator #1 exceeded the Hi-Hi-level (82%). After safety injection was terminated, one reactor coolant pump was restarted. The pressure increase caused the Cold Over-Pressure Mi ti gation System to open a ' power-operated relief _ valve for approvimately five seconds. The unit stabilized at about - 187' F in Mode 5. An Augmented Inspection Team was sent to the site on March 15, 1990 to review the event. The team agreed with TU Electric's conclusion that the single-train injection was caused by a diode failure in the safety injection actuation circuit coincident with routine maintenance on the Containment Particulate Iodine Gas Monitor. The team reviewed the sequence of events and witnessed .a re-creation of the event on the simulator. Because of plant conditions at the time, the event was similar to and bounded by a loss of feedwater transient at full-power conditions. The team concluded that the operator response to the event was-appropriate. The unit resumed Mode 4 conditions on March 16, 1990. TU Electric is continuing their analyses of the event and development.of lessons learned. The AIT presented its findings to TU Electric during an exit on March 19, 1990. } l f ~ 1 l

VTM;J-M W U189 FCOM $1TE-1.1 CENSING PAgg,gg3 MQR 18to 17tet PROM NOSP'IVAL pmeg.sen M CPSE8-r,NBAGENCY $/12/90 News meloese No. 3 Isoved: 8 p.m. At 4 all p.m. the Unusual Event at Unit 1 of the Comanche peak nuoloar power plaat was terminated. It has been confirmed that no actual plant conditions existed which would have' led to a valig estety system aettvatten, plant pressures and tanperatures have been ad$ueted to allow a' detailed investiention-into the equipment maifumeties which caused the safety system activation, plant tenditions are stable. These was No radioactive release. The Unusual Event had been declared at 2:20 p.m. An Unusual Svent is the 1e444 serious of the four nuclear pewer piaat esergeney levels set by the Nuclese _ Regulatory Commissien. l L-y i ~

h 90-07 L COMANCHE PEAK UNIT 1 \\ INADVERTENT SAFETY INJECTION l MARCH 12,-1990 FROBLEM INADVERTENT. ACTUATION OF SAFETY INJECTION SYSTEM, CAUSE FAILURE OF AN ELECTRICAL CIRCUlT COMPONENT, p SAFETY SIGNIFICANCE UNNECESSARY CHALLENGE TO SAFETY RELATED SYSTEM, l DISCUSSION o REACTOR IN MODE 4, 250 F, 380 PSI, NO DECAY HEAT, BUBBLE IN l PRESSURIZER, o AT 2:01 P.M. ON MARCH 12, 1990, SAFETY INJECTION (SI) TRAIN "A" DISCHARGED APPR0XIMATELY 9000 GALLONS OF WATER INTO THE CORE DURING A NINETEEN MINUTE PERIOD, H o SI TRAIN "B" DID NOT ACTUATE, OPERATORS SECURED ALL RCPS BECAUSE OF FLUCTUATIONS IN SEAL DIFFERENTIAL PRESSURE INDICATION, SI SIGNAL WAS RESET WITHIN 10 MINUTES, SAFETY INJECTION WAS SECURED WITHIN 19 MINUTES-FOLLOWING COMPLETION OF E0P FOR " REA L TRIP AND SAFETY INJECTION" - o THE SI CURRENTLY APPEARS TO HAVE BEEN CAUSED BY THE FAILURE OF AN ISOLATION DIODE (SEE ATTACHED DIAGRAM), o -DURING THE EVENT: l RCS TEMPERATURE DECREASED FROM 250 F TO 187 F'AND PRESSURIZER LEVEL INCREASED FROM 25 PERCENT TO 94 PERCENT, TWO TRAIN "A" CONTAINMENT SPRAY PUMPS RECEIVED INITIATION L L

SIGNALS, TRAIN "A" RHR PUMP STARTED, "B" TRAIN PUMP ALREADY RUNNING, TRAIN "A" EDG STARTED BUT-DID NOT LOAD, AUXILIARY FEEDWATER INITIATED TO STEAM GENERATORS (SG)

"1" AND "2", o ' LEVEL IN SG "1" INCREASED AB0VE THE HI HI LEVEL SETPOINT OF 82 PERCENT TO 89 PERCENT DUE TO OPERATOR ERROR, CONTACT: N, FIELDS SIGEVENT:

REFERENCE:

10 CFR 50,72# 17953 'g[ 7I

1 COMANCHE PEAK UNIT 1-90-07 t ( 0 LOW TEMPERATURE OVERPRESSURE PROTECTION WAS ACTUATED WHEN OPERATORS RESTARTED RCP "4". RCS PRESSURE INCREASED FROM 350' PSI T0 420 PSI.- ONE PRESSURIZER PORV OPENED AND RESEATED IN'S SECONDS. FOLLOWUP ~ o AIT IS BEING DISPATCHED TO THE SITE. o LICENSEE IS PREPARING A TEST PROCEDURE T0.TRY AND DUPLICATE THIS

EVENT, o

REGION MONITORING LICENSEE'S EFFORTS: WILL REVIEW TEST PROCEDURE, WILL' REVIEW ROOT.CAUSE EVALVATION, AND WILL REVIEW OPERATOR ACTIONS DURING EVENT, t h J 4 /

Y - j o COMANCHE PEAK. UNIT 1 3 90-07

4.

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y ...W l 0 i N SWLEChwC cF858 EMBRSINCY 3/12/90 News Releste Noe & resued 4:10 p.m. At 2:30 p.m. TV slectrie doolated an Unusual Event at Unit 1 of the Comanche peak nuclear power plant, the-Unusual Svent was declared due to cotivation at about 2 p.m.. of automatic protection systems for Unit i due to a power supply malfunetten in the power supply to sortata instruments, L Unit 1 was at lett topperature sad pressure, oenducting pre-startup l-

testing, The seteter was not operating and continues to be in-a

' safe condition. Vait i Le still under construction. Local, state and federal officials have been notified of the Unusual svent and are being kept informed of plant conditions.- ha ' Unusual tvent is the least-serious of the four nuclear power plant . emergency nevels set by the Nuclear Regulatory Connie 41on. Comanche peak'is a two-unit power plant located five miles north of glen Rose, Texas. Each unit will be able to generate i 1,130 megawatts of electricity, i 's, a 0 0 . a

a-O e 'a. 3... ' WMTR Fort Worth Stee.Telegreen / Tuesday JLM., March 13.13) Malfunction Plant occurs at From Page 1i nuclearplant and cooling water was at its proper By STAS JONu ."The water level was Ane," Wiew Ha**"

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said, "It looks at this point like an TV Electnc reacting to an equip-equipment malfunction which staned rnent malfunction, yesterday declared the safety injection system." that an " unusual event" had occurred Dave Fiorelli. a TU spokesman in at Comanche Peak nuclear power riant. Dallas, said the utihty issued the "unu. the Grst since the plant was hcensed sual event" declaration, the least se, nous of the four nuclear power plant Feb.8. A Nuclear Regulatory Comrnasion emergency leveis, at 2:20 p.m.- olhvial monitonng the plant said the The esent wascanceled at 4:25 p.m. declaration stemmed from an eleetncal Fiorelk said. after plant otheials as. problem that caused backup cooling sured themsches that an electrical water to be autumatically injected into problem, rather than a safety problem. the Unit I reactor, was insolved. The backup sptem normally isn't Joe Gilhiand. a spokesman for the 1 used unless the reactor is overheating or NRCs Region lyin Arlington,said the water pressure is low. Joel Wiebe, the utility was required to repon the prob-NRCs semor project inspector at the fem because an emersexs $9 tem was plant,5,iid the reactoe was completely involved. shut dowti hefore the incident occurred i.N! ore on PLAh'T on Pase 141 l L L x s

~_ __ ~ Dallas Times Herald Tuesday, Maren 1"3, l9'90.. ~ ~~'" a tomanche Peak has first emergency By Jim Morris system. Local, state and federal offt. ellt said, or tne ruts stRAto stair - clats were notined immediately, he "We take this problem senously at said. Comanche Peak and will mvest'gute The Comanche Peak nuclear pow-The event, which occurred dunng it fully." he said. "but... It was er plant expenenced its first " unusual testir.2, ended at (25 p rn. after plant relattvely minor problem that pre. event" Monday after an equipment of6cials determmed the safety sys-sented no risk whatsoever to pla.nt malfunction caused safety related tem "was activated as a result of workers or the general public." cooling water to enter the plant's equipment malfunction as opposed to Comanche Peak, which has cost Unit I reactor core, TU Electne offi-actual plant conditions," horelli said, more than $9 billion and taken more cials said. The flow of cooling water began than 15 years to build, is in Somer. An unusual event is the least sen-about 2 p.m. and was stopped 10 veil County, about 80 miles south-ous of four levels of emergency at a minutes later, he said. west of Dallas. nuclear plant. TU Electric spokesman Although nuclear fuel was loaded Fioreth said the malfunction "may Dave Fiorellt said the event was de. into Urut I last month, the reactor or may not" delay the issuance of a clared at 2:20 p.m. after a power sup-has not had its first chain renetion. full. power operaung license by the ply interruption to certain instru. Monday's event, therefore, was less ments activated the reactor's safety senous than it might have been, Fior. Please see PLANT, A 13 port on the meident within 30 P ANT days. Gilliland said the malfunction From A.11 apparently sent a signal to the re-actor's emergency equipment that there was overheating, over-l Nuclear Regulatory Commission. pressurization, or botn. in the The utility, which received a li-core. That signal caused a pump eense Feb. 8 to load fuel and op-that was already etreulating wa. erate Comanche Peak at low ter through the core to begin in. power, had hoped to generate jecting it with emergency cooling commeretal electricity from Unit water, he said. 1 by August. Unit 2, about 86 Fioreth said there were 212 un. percent complete, is expected to usual events at U S. nuclear pow-produce power by 1992. er plants in 1988. "They are more Juanita Eihs, president of Citi. likely to occur at units in the zens Association for Sound Ener-startup and early operations i gy and a member of the Coman-phase than in more mature che Peak Operations Review umts." he said. Committee, said lyonday's inci-Said Gilliland: " Nationwide, an dent is "of concern to her. . unusual event' is not all that un. "However, as I understand usual." it...it seems that once this power Because Unit I had not had its supply failure led to the safety first chain reaction, it contained injection system kicking in, it no irradiated fuel, there was no worked correctly and shut the radioactive contarnination in its plant down, which is what you'd systems and there was no " decay want to happen," Ellis said. "I heat" - heat left over after the thmk it's to be expected that cer-core has been operatmg - Gilli-tain things are going to happen land said. when they are doing tests. It's "An unusual event at an oper-something that we'll want to get ating plant would have had more Information on and we'll broader implications," he said. I follow," However, he said the NRC will Nuclear Regulatory Commis-be "very much interested in find-sion spokesman Joe Gilliland ing out the cause of the inci-said TU Electne must Ole a re-dent. l

Tuesday, March 13, 1990 die Saltas ponmgew iyplant l incident N plant event posed i reported l no danger, officials say I l Coattaued from Page 174. technical plant specifications, ac. for esir Utuity Regui tivai>on of the safeiy gum,s re.

Officials say event i i

tion in Fcrt Worth. "I would cor, quired the utility to declare an "un. =" > "~~ ' 2:2o P. e=o co'>rr - i 'a* 6e f-fui a raan - local, state and federal officials, in. i, m~ sed no danger l lease if the fuel had been hot and g-fissioning. But they haven't done ciuding county judges. Emergency l strens wm not sounded rte eveni 1 By David Real that yet, so we're fortunate in that ended at 4:25 p.m., '!V Electric i sw we st N ow'.u mq" sense." sp kosman David Fiorcillsaid. The Comanche Peak nuclear plant { J a Ellit pruMont d tM Mr. Gilliland said the declara. experienced its first " unusual eventMonday, but there was never any dan Cittrens Association for Sound En. tion of an unusual event was not "EY IU D'U*s. $std her group' uncommon for a new plant being ] ger of radlation release, utt!!ty and llS. I . "8 Prepared for start.up. Had the reac. ) ' Nuclear Regulatory Commission offt-the w co t tor been operating at full power, he incident occurred but pleased that said, the incident still probably I cials said. The unusual event - the least se-rious of four categones the NRC uses to thsa ey eptpmW worked as m. i would have been classtiled only as i an unusual event, rate nuclear meidents - began at 2.01 TU Electric officials said work-Mr. Gilliland said the NRC will p.m. Monday when the power supply ers were testing temperature mes. closely monitor a utility Investiga. source to some plant instruments failed.

  • surmg instruments for the reactor tion group that was set up to evalu.

NRC spokesman Joe Gilliland said. when the incident occurred ate and analyse the incident, The malfunction in the electrical cit. The power loss triggered the Mr. Macroe said 212 unusual i cuitry automatically started emergency, emergency system, which pumped events were reportedin 1988 for the safety injectmn pumps, which began, 9.000 to 14,000 gallons of water into 108 operating reactorsin the United . supplying chemically treated water to, the reactor system, TV Electric States, or about two per reactor. He cool the reactor,officiais said. spokesman Mark Monroe said. The said that because of the testing pro-Mr. Gillitand said that about to min., utes after the event began, workers pumps were reset and turned off at grams under way at the Comanche 2:10 p.m. Peak plant, the unusual event was determined that there was no actual, Senior NRC project inspector not unexpected. threat and turned the emergency Joel Wiebe said the reactor, which "We don't want to have them. pumps off. had been heated to nearly 250 de-and we don't try to have them. but The event at the plant,about 85 miles southwest ol Oatlas near Glen Rose, olf t. grees in earlier testing, was cooled they're something you can expect to to 180 degrees by the water. Normal happen," Mr. Manroe -said. "Now ctally ended about two hour *. later. operating temperature for the reac-our job is to see exactly what hap-Mr. Gillttand said there was little re. i for will be 557 degrees. pened and why it did happen." he diation danger because the reactor had, Mr. Wiebe said that, according to said. not yet gone " critical." meaning no sus, i tained nuclear chain reaction had oc i curred to produce potentially harmful

  • i radioactive elements i

On Feb 8. TU Electric. which oper. i ates the 59.1 billion nuclear plant.. received a license to load nuclear fuel i i ' nto the Unit t reactor and conduct low i i i i power testing Workers loaded nuclear [ fuel Feb.911, and the reactor head was [ l boltedinto place Feb.16. Nuclear energy opponents said the incident worried them. "I think tt sounds pretty serious." said Betty Brink, a member of Cititens lease see N. PLANT on Page 20A. \\ .}}