ML20107F338
| ML20107F338 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 11/01/1984 |
| From: | Dieckamp H GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20107F324 | List: |
| References | |
| SP, NUDOCS 8411050440 | |
| Download: ML20107F338 (38) | |
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00CKETED UNC November 1, 1984
- di II"! -2 &,7 gg UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In,the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP
) (Restart-Management Remand)
(Three Mile Island Nuclear )
+
Station, Unit No. 1) )
TESTIMONY OF HERMAN M. DIECKAMP
. My name is Herman M. Dieckamp. I am president and chief operating officer of General ~Public Utilities and of the GPU Service Corp. GPU is a holding company, whose subsidiaries ;
Jersey Central Power and. Light, Metropolitan Edison, and Pennsylvania Electric are the owners of Three Mile Island. I am a director of'all of GPU's subsidiaries.which also include 1
GPU Nuclear and the GPU Service Corp. At the time of the acci-
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- dent at-TMI-2, I held these same positions with the exception
- of director of GPU Nuclear which did not.then exist. In the intervening time since the accident, I was the chairman and chief executive officer of GPU Nuclear from its inception until February 1984. GPU-Nuclear became the approved operating
. Licensee of TMI in January, 1982.
5 0
a I graduated from the University of Illinois in 1950 with a Bachelor of Science Degree in Engineering Physics. After school I joined North American Aviation which became Rockwell International. My work experience started with radiation dam-age to materials and progressed to reactor development in sodi-um cooled reactors, space reactors, and fast breeder reactors.
In 1970, I became president of the Atomics International Divi-sion of Rockwell International. I joined General Public Utilities in 1973 and was within a period of about one year ap-pointed to the positions I held at the time of the accident.
The purpose of my testimony is to provide information in response to the Appeal Board's view expressed in the ALAB-772 that:
The record -----[is]--- incomplete with re-gard to the circumstances surrounding a mailgram sent by GPU president Herman Diec r eamp to Congressman Morris Udall.
In its discussion of this subject the Appeal Board noted:
Moreover, the scope of the Board's inquiry is relatively limited. As we pointed out at note 103, supra, the focus should be on:
(1) Whether _a_nyone interpreted the pressure spike and containment spray, at the time, in terms cf core damage, and (em-phasis in original)
(2) Who or what was the source of the infor-mation that Dieckamp conveyed in the mailgram?
i The Licensing Board in a prehearing conference order on July 9, 1984 added a third facet:
(3) Whether, when, and how any interpreta-tion of core damage was communicated to Mr. Dieckamp.
This testimony addresses my knowledge about the questions that have been raised concerning my May 9, 1979 mailgram to Congressman Udall.
By way of background, on May 7, 1979, Congressman Udall, Chairman of the Subccamittee on Energy and the Environment of the House Committee on Interior and Insular Affairs, a number of subcommittee members, local congressmen, subcommittee staff, and NRC Commissioner Victor Gilinsky visited Three Mile Island.
I had been in communication with committee staff to arrange the visit and participated in the briefing and the tour. I have not been able to reconstruct the specific agenda or recall all of the participants but I do recall the tour of the TMI-2 con-trol room that was conducted by Mr. James Floyd who was at that time TMI-2 supervisor of operations. In the course of that tour which took the form of a general recreation of the acci-dent and operator action, Mr. Floyd made mention of a pressure spike which occurred about 1:50 p.m. on March 28, 1979 and also noted that the pressure spike had initiated the containment building spray. As I recall, he identified the containment building pressure recorder and discussed the conclusion that s
b the pressure spike was not a spurious electrical signal because spray initiation required coincidence of at least two pressure indicators. He also stated that the pressure spike and the op-erator action to turn off the containment spray was in toll view of an NRC inspector. (It should be noted that Mr. Floyd was not on the TMI site at the time of the pressure spike).
This portion of the tour was reported on with some detail in an article in the New York Times on the next day, May 8, 1979.
The article was entitled " Lag in Reporting Reactor Damage Laid to Experts" and stated in the lead sentence:
A technician from the Three Mile Island nu-clear plant told Congressmen today that con-trol room personnel and Federal inspectors knew that the plant's fuel core was seriously damaged two days before the damage was for-mally reported and the seriousness of the accident made public.
The pressure spike was cited as the basin for this state-ment. A copy of the May 8, 1979 !!ew York Times article is at-tached.
I was disturbed by the article because my own awareness indicated that the reporting of the pressure spike and its sig-nificance reflected the actual delayed recognition of the se-verity of core damage that had occurred during the accident.
As a result, I sent a ma11 gram to Congressman Udall with a copy to Commissioner Gilinsky that stated my belief:
o There is no evidence that anyone interpreted the ' pressure spike' and the spray initiation in terms of reactor core damage at the time of the spike nor that anyone withheld any information.
A copy of the mailgram is attached.
The mailgram reflected my own understanding of the posi-tive discovery and interpretation of the pressure spike. I first became aware of core damage beyond local failed fuel when I was informed of the pressure spike, the postulated mechanism of a hydrogen " explosion", and the reaction of zirconium and water as the source of hydrogen. This information came to me sometime on Friday, March 30, 1979. Prior to this time, my conversations with state, NRC, and company personnel and my at-tendance at the Herbein congressional visitors briefing on March 29, 1979 had given me a sense of local and limited fuci damage. At no time ou March 28 or 29 did anyone mention to me core temperatures in excess of 2000*F, pressure spike, circon-ium-water reaction, hydrogen, or core damage beyond failed fuel.
On March 28, 1979, I was in Hartisburg, Pa. for a meeting with the Pennsylvania Public Utilities Commission. My recol-lection of specific interactions and ir ormation opportunities during March 28 and immediately thereafter can be summarized as follows:
s March 28, 1979
- 1) At 9:00 a.m. on March 28, 1979, W. Creitz gave me the first notification of problems at TMI-2. My notes indicate a feed pump trip at 4:00 a.m.; reactor trip; primary (pressure) relief; (drain tank) disk rupture; 30,000 gallons (of water relieved to the containment building basement); and 1# pressure (in the contain-ment building). Creits also mentioned failed fuel. I indicated that that would not seem possible if the emergency systems worked as intended. I gained the impression that the emergency systems had functioned as intended.
- 2) Shortly after talking with Creitz, I talked with R.C.
Arnold who was in Parsippany, N.J. I remember asking him about the emergency systems and failed fuel but I did not get the sense that Arnold possessed added knowledge about the situation.
- 3) At about 9:15 a.m., I made a brief statement concern-ing TMI-2 to the Pennsylvania Public Utilities Com-mission (PaPUC).
- 4) I attended a press briefing by Lt. Gov. Scranton and staff at about 11:00 a.m. I left this briefing with a sense of reassurance that the plant's emergency systems had functioned properly.
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-i :' 5) I'made further comment on TMI-2 to-the PaPUC at about
, noon. I think I spoke with Creitz and/or Arnold just
. prior to these,second comments.
- 6) I spoke with some members of the Lt.1 Governor's staff-at about 2:00 p.m. I learned nothing about the sta-tus of the plant but heard some comments about radia-tion measurements.- I am unable to reconstruct the specifics of the comments but I was puzzled that the
-comments did not make a lot of' sense to me. I had hoped to sit in on the briefing.of the Lt. Governor by TMI personnel but I was asked to leave.
- 7) At'about 2:30 p.m., I encountered Herbein, Miller and Kunde;' on the steps of the Pennsylvania State Capi-
- tol. They were on their way to brief the Lt. Gover-
.nor. Our conversation was extremely brief. I ex-pressed concern about the absence of senior people from the plant. I recall no detailed discussion of plant parameters or' conditions but gained the impres-sion-that the plant was stable.
8). .Sometime"in the-.early evening, after returning to my home in New Jersey,.I spoke with R.C'. Arnold. He told me about' the plant having been taken solid'and the-starting of a reactor. coolant pump. I recall no detailed discussion of plant parameters or a sequence of events throughout the day.
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March '29; 1979 4
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- 1) oon Thursday morning, March 29, 1979, I met briefly with R.C.-Arnold in' order to review and sign out a memorandum establishing a task force to investigate
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and analyze what was then thought to have been a se-uvere plant transient.
-2) During the afternoon I attended a briefing for a group of Congressmen at the TMI visitor's center.
Mr. Herbein's comments (which were transcribed) served as my first overall briefing as well. I do not recall having synthesized the various portions of that-briefing into a real understanding or insight into the' extent of core damage. I was satisfied that the plant was shut down, being cooled, and stable.
3)~ At the visitor's center, I spoke briefly with'R.
Vollmer of the NRC. He informed me about core thermocouples that were still. reading higher than the
-coolant temperature. We mused about fuel damage and local. flow blockage. I~did not get a sense-of any-thing ominous.
- 4) While at the visitor's center, I also spoke with some ic members'of the task force that I had authorized' ear-lier in the morning. I have'no recollection of any specific detail from those conversations.
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<5). Afterireturning to New Jersey in the early evening of March 29, 1979,- I' spoke with R.C. Arnold. I think it was then that he gave me an increased awareness of the open PORV and interruption of high pressure in-jection. We agreed that Arnold should.go to the site to work with Herbein. I still did not sense the full Lextent of the situation.
March 30, 1979 Starting.on Friday March 30 and continuing for the next
. seve ral~- days , I gained an explicit understanding of the first recognition of the meaning of the pressure spfke, the confirma-tion of-hydrogen, and a rough quantification-o: the degree of
. core damage deduced by analysis of the zirconiem-water reac-tion. .My communications with site and GPU personnel and with various. individuals around the country in the period of March 30-and beyond were too numerous to recall in detail.
I recall'that my awareness ofLthe degree of core ~ damage
' increased abruptly on Friday, March 30 when I was informed of
.the pressure spike. In telephone conversations with personnel at the-site, most likely Mr. R.C.. Arnold, I was told of the
_ pressure. spike recording being broughtJto the attention of the GPU task' force during the night of March 29. The task force postulated a zirconium-water reaction as the source of the hy-drogen. The presence of hydrogen was recognized as being
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consistent with the abnormal pressure-volume behavior of the primary system. The postulate also caused the plant staff to
.take steps to'take a containment building gas sample and to
- take steps to. permit operation of the h'ydrogen recombiner. The first containment building gas sample was taken at about 4:00 a'.m. on March 31. Records' indicate that the initial calcula-tion of the non-condensible gas in the primary system were com-
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pleted at about 0300 on March 30, 1979. The volume of the
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non-condensible gas-in the primary system was measured by observing the system pressure change associated with a change in.the water volume in the primary system.
I moved to the site'on the afternoon of Saturday, March
- 31. Thereafter, I was in routine conversation with key members g
of the plant staff, the task force,'the NRC, and the Industry Advisory Group that had been formed. In these interactions I
-became aware of the confirmation of hydrogen N 'ough the analy-
, sis of the_ containment building gas sample (s) which contained hydrogen and showed a' depletion in the normal atmospheric oxy-
_ gen concentration. This depletion along with the residual hy-
'drogen afforded the first indication of the amount of reacted-zirconium-and thus the first quantitative indicator of the de-gree of core damage.
During the first few weeks of April, I remained at the site. I~was directly involved in the concern about the poten-
'tial explosivity of the hydrogen bubble, the primary cooling
n 1
, I
_ +
system vulnerability to high conce.ntrations of non-condensible and/or' dissolved gas, and the strategies employed to remove the hydrogen'from the reactor primary system. I availed myself of the-early GPU operators' interviews, sat in on preliminary re-views.:of.the sequence of events, participated in' status reviews with the onsite NRC staff,. coordinated tite activities of the Industry Advisory. Group and generally participated in the man-
-agement'of the accident.
During the third week in April I drew upon this awareness and the developing learnings, including the G. Miller report based on a taped conversation and reconstruction of the day of the accident by a. number of key TMI personnel, to assemble atestimony for presentation to the Nuclear Regulation Subcommit-tee'of'the Senate Committee on Environment and Public Works
-(Hart' Committee).
Prior to May,9, 1979, I did not conduct any exhaustive in-vestigation'of the pressure spike and its interpretation. I i-
~~
had given the subject considerable attention in the course'of
' preparing the Hart Committee testimony because the spike, its
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identification with the zirconium-water reaction, the ve.rifica-Ltion an'd quantification of the hydrogen, and the subsequent
_ analysis of the-degree of fuel cladding reaction was a mean-ingful way_to illustrate the difficulty in recognizing the scale of the accident ahd~the time necessary to derive enough information for some quantification of the degree and nature of
'the core damage.
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From the considerable information available to me prior'to.
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May19,,1979, I had a very. clear understanding of the delayed' N
recognition:and-interpretation of the pressure spike. I also
-heard or saw no indication that on March 28 the pressureLspike
.had.been properly-diagnosed as the. product of a zirconium-water
. reaction or that the pressure spike-caused-the plant staff to
' change-or adopt a strategy for bringing the plant to cold shut-;
down that recognized.the presence of hydrogen or non-conden-sible gas. Prior to May 9, 1979, I knew that a pressure spike had: in some way been observed by numerous individuals on the .
day of the accident,.but my overall awareness. caused'me to con-cludeothat no one recognized the s'ignificance of.the spike as a dire'ct' indicator of'or as-a direct measure of core damage on March'28.
~
In preparing the'mailgram I did not conduct or cause to be
.& ~
conducted any additional inquiry into the facts beyond my own
~ knowledge, nor do I remember consulting with'anyone on the con--
~ tent of the'mailgram. 'My~ knowledge'on-May 9 of the pressure
. spike i and ?its'-interpretation along_ with my general understand-c.
L ing of the accident and'the operator response, gave me a sense
~~'of--confidence and a sense of need to respond-to what I consid-ered.to-be misinformation in the New York Times article ~.
Since.ILsent the mailgram on May 9, 1979, there have been several~ investigations which have led to disclosure of addi-tional"information?on:the pressure spike and the awareness of
.]
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L_
v F, s 6-It --and ' its signif.icance . I have reviewed this information includingJspecific interviews of individuals. The testimony of Chwastyk, Mehler and Illjes has been focused on as evidence of:
(1)-the identification'on the day of the accident of hydrogen as a cause of the pressure spike; (2) the.prohibitien of equip-ment l operation in containment as a further indicator that hy-drogen had been identified; and (3) awareness of core damage.
My reading of Mehler's testimony indicates to me that he is uncertain about the timing of equipment limitations. In this regard, I am= influenced by the fact that there is objec-tive data inLthe form of-a control room log book entry at about
- 9:00 p.m.~ on March 29 concerning " sparking potential". Fur-ther,'my reading of Mehler's statements is that he has consis-tently testified that hydrogen was never mentioned on March 28. -
- On. October _30, 1979, he testified:
No, the word (hydrogen) to my knowledge never entered into any-conversation until it came out.in the. press. And that was the first time I1 heard the word hydrogen mentioned.
Now, if'you readLthrough my transcripts, that~
word is mentioned a lot because the tran-scripts were made after March'30 and everyone knew-it was hydrogen.
The-time uncertainty of-the relevant testimony is illus-
- trated dramatically by the May 23, 1979 testimony of Illjes who recalled the discussion of a hydrogen explosion and the simul-taneous operation of electrical equipment as occurring when the
, containment pressure recorder chart was removed in order to n-, - - -
make~a copy-at about 8:00 p.m. on March 28, 1979. The physical evidence demonstrates tha't the chart was not removed until
- March'29,-1979.
Of the three, the testimony.of Chwastyk is the most sug-gestive that the pressure spike was related to core damage on the day of'the accident. It is significant.to note when ap-praising the accuracy of the mailgram that the first interview of Chwastyk tookLplace on May 21, 1979, 12 days after the mailgram. In that NRC interview Chwastyk refers.to the pres-sure spike as being the result of "some-kind of explosion" and states that he did not understand the cause. He makes no men-tion in his May 21, 1979 interview of hydrogen. In Chwastyk's October 11, 1979 and October 30, 1979 NRC depositions he re-feres to a hydrogen explosion'and' correlates.its occurrence
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with the operation of a valve,but does not identify any assess-
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ment of,. core damage or non-condensible gas. In this regard, the October 30, 1979:SIG deposition of Chwastyk includes the ,
following exchange:
Q - Do you remember forming any opinion or thought in your own mind on Wednesday about how substantial the damage must have been to the core to generate that great deal of.hy-drogen? Is that something that you thought about at all? What was your reaction to that?
A- I thought about it, and I think from the time that it dawned on me what had happened Lin the reactor building, I knew we had sus-tained some core damage. How severe it was, I tried to stay away from thinking about how severe or unsevere the accident was, simply a
i because~I don't-know. I don't want to make
.any conjecture. At the. time, remember, I had
.other things that I just did-not have the time to waste thinking about what ifs essen-
~tially.
It.isn't untilfa September 4, 1980 NRC interview that Chwastyk
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mentioned "zirc-water ~ reaction"'in relationship to "some core damage".
-In my, judgment interview does not reflect an under-E
' standing:of the zirconium-water reaction and its core damage
_ implications. It contains.the following exchange:
.Q - Is that another way of saying, what is
. the basis of your conclusion that there was zirc water reaction?
A - Let.me answer this way. I don't know of anything specifically during from the time that I got-there until the spike that would
. lead me to believe that we had zirc-water re-action. But what happened previous to that was so unclear that it was a possibility.
My determination that it was a hydrogen ex-
.plosion due to zire water reaction, I could
- not come up with any other explanation that would explain what I had seen take place, and
.that was the simultaneous pressure spike with
'the operation of the valve and the loud. noise heard.
I just had nothing in my background that could tell me or that could suggest that it was anything other than an explosion, simply the way it acted plus the fact that it led to the zirc water because I did not where else
, we could get anything to explode.
Mv' reading of the post-mailgram statements does not pro-
. vide meiwith absolute proof of the state of knowledge on the day of the accident but neither does it undermine my belief in O
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- 3. ... ..
the accuracy'of the' judgment expressed in the mailgram. While Chwastyk's later> testimony mentions:the link between the pres-sure spike and core. damage', I don't find any. meaningful discus-sion of the conditions necessary for a' zirconium-water reaction
-nor doil: find any attempts uto infer the type or degree of . core
' damage. iI cannot conclude that Chwastyk " interpreted the pres-s
-~'ure spike and spray. initiation in terms of reactor core damage at-the-time of the spike.'" My readings ofLthese individuals'
- statements,Ltoo,;is impacted by the various' investigators' re-actions,to all the' statements before them.
s In: November'of 1979,'the NRC~ staff's. investigation of the accident,' NUREG-0600-stated at 4.42:
No. statements that have been obtained indi-cate that anyone present postulated that the pressure spike,was due to the rapid burning of hydrogen.
The NRC's Special-Inquiry Group repcrted in NUREG/CR-1250-
'in: January 1980 at page 42:
The'true nature of the pressure spike wills not be generally recognized until Thursday
~.(March 29) evening.......
e The Special-Inquiry Group's Vol. II, Part 3, at page 908 states:
Except -- for ' Chwast'yk' s te st'imony, no other ev-
-idence indicates that anyone'in the control room realized on March 28 that there might I have'been a hydrogen explosion in the reactor building.....
w=_.-_______-___-______-____-_-__-
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The NRC's Investigation ~into Information Flow During the
' Accident at Thrse Mile Island, Jan. 1981, NUREG-0760 reviewed "added'information:and' states.at page 28:
They (the. investigators) conclude that Chwastyk's recollection of the cause of the s spike is in error. The investigators con-
-clude that. hydrogen was not discussed as a cause-for'the pressure spike on March 28, .
- 1979; there was no acknowledged cause for the spike on that date. It isLconcluded that the order not to-restart electrical equipment was given-on some date subsequent to March 28, 1979.
These independent investigations.and their conclusions ar-
- rived at after the date of the mailgram and based on additional
. information provide direct support for the thrust of the-1 mailgramostatement. While the SIG takes Chwastyk's testimony.
at face'value, I cannot conclude from his sequence of inter-views and depositions that he understood the source of the
-pressure spike or that he recognized its implications on the day of th'e accident. I,am forced to conclude that his post-ac-cident learnings haveibeen incorporated into his recollection
- of the day of.the accident.
n It is interesting to-note that the only other report on this subject,'the Majority Staff. Report of the Committee on In-e
. terior.and Insular-Affairs of the'U.S. House of Representa-
..tives,_ dated-March 1981, with the benefit of the cumulative-testimony'and analysis, makes no explicit finding.on the-mailgram.
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'The latter portion of the Mailgram statement "cnd no one 0
withheld any information"' refers to the pressure spike and its interpretation. It was my conclusion that the pressure spike and its-meaning was'not understood on the day of the' accident
' Eand consistent with that conclusion it was my further belief that no one'made a conscious decision to withhold information p about the spike.
The Special Inquiry Group examined the " assessment and dissemination of information" and reported its findings in the
' January, 1980 Report. Subsequently the SIG principals reported
. to the NRC on the result of a review of specific questions posed by Congressman Udall on January 21 and February 4, 1980.
A number of'these' questions relate directly to the matter of the.mailgram and relevant " evidence". In a Memorandum to Chairman-Ahearne on March 4, 1980, the SIG principals reported r
that their review "tends.to corroborate the Report's overall l findings". The SIG Report had concluded:
The evidence failed to establish that Met Ed management or'other personnel willfully withheld information.from the-NRC. There is
-no question that plant information conveyed from the-control room to offsite organiza-tions_throughout the day was incomplete, in some instances delayed, and often colored by-
-individual interpretations of plant status.
Indeed, information conveyed by Met Ed, NRC and B&W employees in the control room to their own managements.and offsite organiza-
-E tions was in many cases incomplete and even inaccurate.
However, based on the evidence, we could not conclude that the-causes of this breakdown in
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'informat' ion. flow went.beyond confusion,l poor.
communications, and a failure by those-in the
- control room, including NRC and B&W
. employees,- to_ comprehend or interpret the available information, a failing shared to some extent by offsite organizations as well.
O O O
~1 I was-interviewed on the matter of the mailgram on September'12, 1980, by NRC investigators who prepared NUREC 0760. In'that. interview, I stated, "I still consider the-
- statement that I_made on May 9th to be accurate". In a public meeting before'the NRC Commissioners on October 14, 1981, I was
~ questioned by' Commissioners Gilinsky and Bradford about the fmailgram. I1said then, "I' believed that the mailgram was cor-rect'on-May 9th. I believe that it.is correct as of today".
, _ 'Today in 1984 my belief is-the same. In my own assessment iofithe accuracy of'the mailgram, I focus on.the thrust of the
- mailgram statement -- namely,.no one~ interpreted -- rather than
- the "no evidence" introductory phrase. -I continue to believe
'that the evidence and independent analysis thereof support the
-thrust of the mailgram statement. In making this statement I recognize that.the mailgram phrase "no evidence" can if taken literally. indicate a measure of absolute knowledge that goes
!beyond the= reasonable basis that I possessed for my judgment andLmy belief. By the same token, the " evidence" that is some-
~
times cited was not only adduced.after the mailgram but does not rise to the level of substance necessary tx) justify a
.E
C responsible questioning of my integrity. I respectfully ask this Board to make a definitive finding in this matter.
i o e THE M'Y 8 UM TIMES, TUESDAY, MAY 3,1979 LagmReportmg , ,
RedtorDamage ,
LaidtoExperts .
Lag m. Reporting Laid to Experts
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MIDDLETowN, Pa., May 7- A tecik ramelamad From Page Al $"g",'IY m as
, egg !! ti h rs t
nician from me Dree Mile Islane nu. .
not believing their instruments and rad clear plant tale visattag r=d-- Floyd, the technician, told the touring understanding what they meaat. "It was' today that --- i guam r.. - Congressmen that the gas explosion had a very unusual situation to find yourself Federal iaap='ws anew anat me pIIIRT been clearty monitomd by the control in "he remarked.
naeb enre was sensuary samassa swo room instruments in full view of both The group was taken to the base of the days before the damage was formaHy se. plant operators and the N.R.C. Inspec. 190. foot.high reactor containment build.
ported and me seriousness et me accioent tors, whom he did not identify. "We as. ing, where John G. Herbein, a Metropoli.
sumed they knew what we were doing " tan Edison vice president, pointed at the i -
made maoHC. .
Jisa Floyd, a control recen supervisor, he added. buge , circular concrete structure and told members of a Bouse energy subcom. He said the explosion had triggered an said: We figure there are about 400,000
"# that inspectors from the Nuclear automatic fire control spray inside the gallons of radioactive water in the base.
reactor building that had to be turned off et of this building." He indicated an l Regulatory Commh wm stan&ng by operators, again la full view of the i"maginary line on the structure, saying, by as the tracing needle on a reactor pas. commist oninspectors. It's up to about the six. foot level."
sure suonitoring gaugeleapes. In Washington, Frank Ingram, a com. De Congmsse, who wre rmiving That exalled " pressure spike," mission spokesman, said that existing the first full tour of the stricken plant
! caused by an explosion of hydrogen in the regulations might require plant opera. since President Carter arrived at the reactor vessel and showing that the reac. tors and Federal inspectors to report height of the crisis, were shown a variety ser core itself had been damaged, was re.
safety incidents to N.R.C. officials "de. of systems vader construction designed pending on the cireurnstances." But he 2 guarante s that the reactor can be cord corded at 1:58 P.M. Wa'a-t=y. March tinuousT cooled without taking radioac.
3 about10hoursafterthestartof thena. said the circumstances of this incident Mrm by the 8 i tion's most senous nuclear accident. ' ,",]ta y y y{ also e i m$. n of' the i Reported 2 Dayslater sider whether any reporting requirement Gemal PubHe Utmuss Capwation, existed of ed. Me.ropolitan f.dison's parent compan
- * *** said thm was at least one known Ny not awam of the @h unta Ny, Mr. I said commission could impose penalties for infractions of its stanc:of human error-two valves on a March N, whenit was fwmany reponed regulations ranging fro a an " enforce. backsp water system closed during a test by the Metropolitas E& son Company
- were never reopened. Yet, he said, the ment letter" requinng a correction of the operator which operates the reactor. Company of* who had closed the valves indl.
infraction to revocation of an operating H.
fleials have said the significance of the cense and fines up to 325,000.
ca ed on a check list that he had reopened l
event was not reallaea unm mm. 'Distorbing* to Udall "w'e have the name of this person. We In another dmmpet m a gmwing At Middletown, Representative Morris have interviewed him. His response was, cumosm our nuclear poww, PrisNt K. Uda!!, Democrat of Arizons, who is 'I thought I completed that,'" and re.
l Carter told orgaalzers of yesterday's an. chairman of the subcommittee, said the cPened the valves Mr.Diechamp said.
tinuclear demonstration that shutting i disclosure was extremely disturbing. Commission officials told the Congress.
down all the nation's nuclear generating "The fact that there was an explosion men that the plant was now stable and plants, as the protesters were demand. that first mor ung and that the company that no more radioactivity was being ing, was '.*out of the question," but he knew about it certainly should have been pleased from it than frocn a normal oper.
added that his Administration was trying reported to the Governor, who had evacu. ating plant.
staan responsibility,"he said. After the tour, Mr. Udall told report.
m minimiae me need fw nuclear W. Victor Gilinsky, a comcrission member ers: You get inside one of these things Senator Edward M. Kennedy told constit.
who came along on the tour, said he was and you realize how enormously complex uents that he favored a moratomns on concemed about the report that N.R.C. and complicated they are. Maybe the building new nuclear plants and a thor. inspectors on the site may have known technology is so complex it's beyond the ough examination of all existing reactor. about the explosion two days before their ability of even we!!. intentioned people to (Page A18.] Juperiors, control. The future of nuclear power At the crippled nuclea generster, Mr. y "This is the first I have heard that they hangs in doubt." -
.. .- Pobserved it at the time it happened " Mr.
Castisundee Page Alt Chluasm3 hGilinsky said. "It will be a subject of gmetaculous review."
, Mr. Floyd attempted to reconstruct the night of the accident for the visitors. "A
! lot of things happened real quick," he l f said.
M He showed the Congressmen a yellow IJ tag dangling from a control board instru.
ment that be said might have covered a J el{ #, k - light showing that a crifical valve was-f"#
ck. sed instead of open.
. .b He said that control room operators sp.
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SHAW, PITTMAN, PoTTs & TROWBRIDGE WWE
a paavaamsme or peorassiona6 consonanons esoo w STREET. N. W.
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retax WASHINGTON O. C. 20036 vstscopics s o-as es isnawuw wem acas saa-ioes a eraaies November 1, 1984 .a, ,aa io.
TELEpwoMC (2oal eaa 'o78 aoas saa-iooo waitra s oister otat numeca (202)822-1084 Lynne Bernabei, Esq.
Government Accountability Project 1555 Connecticut Avenue, N.W.
Suite 202 Washington, D.C. 20036 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit 1)
Docket No. 50-289
Dear Lynne:
With respect to the documents requested by TMIA relative to the Unit 1 and Unit 2 leak rate issues, Licensee has made arrangements to begin making documents available for TMIA's in-spection and copying on November 2, 1984. Initially, some 15 boxes of documents will be made available to TMIA. While Li-censee is continuing to assemble documents for production, it was decided not to wait for all documents before beginning pro-duction. The documents will be available in a facility located l at:
Middletown East End Warehouse Co, Inc.
532 East Emaus Street Bldg. 22 Middletown, PA 17057 (see attached map)
The documents have been placed in the Harrisburg area rather than in Washington at TMIA's request. Licensee has no facilities in downtown Harrisburg in which to place the docu-ments, although I understand that would be more convenient for Ms. Bradford. Licensee had rented at considerable cost a fa-cility in downtown Harrisburg for the documents on the mailgram issue, but with the expectation that the cost would be incurred for a relatively short discovery period. On the leak rate issue, there is no schedule and Licensee anticipates that the
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< SHAw, PITTMAN PoTTs & TRowennoce
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Letter to Lynne Bernabei, Esq.
November 1, 1984 Page 2 documents will need to be ava'ilable for months. Hence, Licens-ee for the leak rate documents is using a facility already at its disposal in the Harrisburg area where the costs are not ex-cessive given the length of time the facility will likely need to be maintained.
The facility will be available from 12 noon to 8:00 p.m.,
Monday through Friday. To make arrangecents for access, con-tact John Wilson, Esq., or Robert Schmicker, Esq., at (201)263-6136 no later the 3:00 p.m. on the previous business day so that arrangements can be made to have the facility staffed. Since the entrance gate to the warehouse complex is locked in the evening and the person staffing the room will need to wait for TMIA representatives at the entrance gate, it is necessary that any scheduled arrival after 5:30 p.m. be at the prearranged time.
There are three classes of documents which require further discussion. One relates to the FSAR's for Unit 1 and Unit 2 which were provided to the Grand Jury. The second relates to personnel files which were produced to the Grand Jury. The third concerns miscellaneous sample logs which were submitted to the Grand Jury. Please contact me to arrange a time to dis-cuss these subjects.
Sincerely, Ernest L. Blake, Jr., P.C.
Counsel for Licensee i
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CCtKETEg U%?C DRAFT
- /-d'Pk:$i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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BEFORE THE' ATOMIC SAFETY AND LICENSING BOARD
'Innthe Matter of ).
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP
) (Restart-Management Remand)
(Three Mile' Island Nuclear )
-Station, Unit No. 1) )
MODIFIED STIPULATION OF PARTIES
. ON MAILGRAM EVIDENCE On September 21, 1984, Licensee and TMIA entered into a Stip-ulation of Parties on Mailgram Evidence. They agreed that docu-ments' listed in the st'ipulation would be admitted into evidence without objection. The NRC Staff joined in the stipulation on
- S'eptember 26,- 1984. The parties also agreed that the stipulation Lwould not foreclose further stipulation with respect to the admis-
'sibility of documents.
The parties have now. agreed to modify the list of stipulated documents that may pertain in whole or part to the Dieckamp
'Mailgram issue. Accordingly, the undersigned parties, Licensee,
-NRC Staff, and TMIA (lead intervenor on this issue), hereby enter into the following modified stipulation, which supersedes the pre-
-vious-stipulation. The parties stipulate as follows:
L: ,
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l'. LAt the evidentiary hearing presently scheduled to convene on November 14, 1984, the below listed documents or
, portions of documents shall be admitted into evidence without objection. All listed documents are admitted only in so far as they contain information within the scope of the Dieckamp mailgram issue, such scope as determined by the presiding Li-censing Board-in'this proceeding. Some listed documents (no-tably NUREG-0760 and the Report of the Majority Staff of the Committee on Intarior and Insular Affairs as well as a number of individuals' statements or depositions) are recognized to include information beyond the scope of the Dieckamp mailgram
' issue, but are to be admitted'in their entirety because rele-vant and material information therein are intertwined with irrelevant or immaterial information.
Met Ed Chronology dictated by H. McGovern (March 29, 1979)
Met Ed Interview of C. Faust (March 20, 1979).
-Met Ed Interview of E. Frederick (March 30, 1979).
NRC Meeting.(March 30, 1979).
TMI Nuclear Power Plant Accident: Hearings Before the Subcommittee on Nuclear Regulation of the Senate Committee on Environment and Public Works, 96th Cong., 1st Sess., Parts 1 and 2 (1979).
Met Ed Interview of E. Frederick (April 6, 1979)
Met Ed Interview of C. Faust (April 6, 1979)
NRC Interview of G. Miller ( April 11, 1979)
' Statement by G. Miller et al. (April 14, 1978)
Met Ed. Interview of J. Flint (April 20, 1979)
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m - NRC~ Interview of C.; Faust (April 21, 1979).
[ -NRC. Interview of D. Berry (April 21, 1979)
NRC-Interview of J. Flint (April 23, 1979)
NRC Interview of W. Zewe (April 23, 1979)
NRC Interview of M.:Ross (April 25,-1979)
Met Ed Interview of B. Mehler (April 25, 1979)
NRC-Interview of G. Kunder (April 25, 1979)
INRC Interview of J. Higgins (May 1,.1979)
NRC-Interview of L.~ Rogers (May 4, 1979)
-Men Ed Interview of H. McGovern-(May 4, 1979)
-NRCLInterview of R. Benselt (May.7, 1979)
.. NRC. Interview of G. Miller (May 7,'1979)
- Statement by W..Raymond.(May 8, 1979)
NRC Interview of L. Wright (May 9, 1979)
NRC Interview of J. Logan (May19, 1979)
.NRC Interview of.R.-Arnold (May 9, 1979)
NRC Interview of J. Herbein (May 10, 1979)
Accident at Three Mile Island: Oversight Hearings before a Task Force of the Subcommittee on Energy and the Environment of the House Committee on Interior and Insular Affairs,.96 Cong., 1st Sess.',. Parts.1 and 2 (1979)
.NRC. Interview of G. Kunder (May 17, 1979) l NRC Interview of W. Marshall (May.17, 1979)
NRC' Interview of B. Mehler (May 17,-1979)
NRC Interview of M. Ross (May 19, 1979)
NRC1 Interview of I. Porter (May 21, 1979)
NRC Interview of'J.'Chwastyk (May 21, 1979)
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'NRC Interview of'T. .Illjes (May'23, 1979)
NRC Interview of G. Kunder (May 23, 1979)
NRC Interview of-D. WeaverJ(May 24; 1979)
Third Meeting of the President's Commission on the Accident at Three Mile Island: Testimony 'cn1 G.
Miller (May 31, 1979)
' NRC Interview of J. ~ Hilbish (May: 31, 1979)
'NRC Interview of D. Croneberger (June 1,.1979)
.NRC. Interview of G. Capadanno (June.1, 1979)
NRC Interview of'll Wilson.(June 1, 1979)
~NRC. Interview.of G.-Lehmann (June 1, 1979)
NRC Interv'iew of R. Keaten (June 1, 1979)
.- NRC Interview. of J. Thorpe (June 1, 1979)
NRC : Interview o'f ' R. Lentz (June 1, 1979)
NRC Interview of T. Broughton'(June 11, 1979)
NRC Interview-of J. Moore (June 11, 1979)
LNRC Interview of J. Abramovici (June 11, 1979)
~ Statement of L. Rogers (June 12, 1979)
'NRC' Interview of T. Wright (June 15, 1979)
NRC-InterviewLof N. Bennett.(June 19,. 1979)
NRC Interview'of W..Yeager-(June 20, 1979)
Kemeny Commission Interview of J. Flint (June 30, 1979)
'NRC' Interview of.J. Flint (July 2, 1979)
NRC Interview of'I. Porter (July.2, 1979)
.NRC'Intert ew of R..Bensel (July 5, 1979)
.NRC Interview of G. Kunder (July 11, 1979)
NRC Interview of C. Mell (July 14, 1979)
</ i NUREG-0600 (July, 1979) pages 1 to lii (Preface and Acknowledgement) pages I-3-1 to I-3-43 (Management Actions During Accident) pages I-4-1 to I-4-81 (Significant Events During Accident)
Kemeny Commission Interview of J. Herbein (July 19, 1979)
Hart Comm.- Interview of W. Creitz (Aug. 14, 1979)
Hart Comm. Interview of H. Dieckamp (Aug. 15, 1979)
Hart Comm. Interview of J. Herbein (Aug. 21, 1979)
Hart Comm. Interview of B. Mehler (Iug. 22, 1979)
Hart Comm.-Interview of C. Mell (Aug. 22, 1979)
Hart Comm. Interview of I. Porter (Aug. 22, 1979)
Hart ~Comm. Interview of E. Frederick (Aug. 22,.1979)
LHart Comm. Interview of G. Kunder (Aug. 22, 1979)
Hart Comm. Interview of R. Arnold (Aug. 23, 1979)
Hart Comm. Interview of J. Higgins (Aug. 24, 1979)
NRC Interview of J. Hilbish (Sep. 5, 1979)'
NRC Interview of Faust, Frederick, Scheimann, and Zewe (Sep. 11, 1979)
NRC Deposition of G. Hitz (Sep. 12, 1979)
NRC Interview of J. Logan (Sep. 12, 1979)
NRC Interview of J. Floyd (Sep. 13, 1979)
NRC Deposition of J. Higgins (Sep. 13, 1979)
Hart Committee Interview of E. Frederick (Sep. 14, 1979)
NRC Deposition of G. Kunder (Sep. 18, 1979)
NRC Deposition of M. Ross (Sep. 18, 1979)
NRC Deposition of J. Herbein (Sep. 19, 1979)
NRC Interview of G. Miller (Sep. 20, 1979) n
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-NRC' Interview of R.-Arnold (Sep. 24, 1979)
Hart Comm. Interview of G. Miller.(Sep. 28, 1979) -
NRC : Interview of H. Dieckamp . (Oct. 3, 1979)
- NRC Deposition of L. Rogers (Oct. 11, 1979)
- NRC Deposition of J. .Chwastyk (Oct. 11, 1979)
NRC Deposition of B. Mehler (Oct. 11. 1979)
~
. NRC Deposition of D. Neely (Oct. 12, 1979)
Hart lComm. Interview of M. Benson (0,ct. 15,'1979)
JHart Comm. Interview of J. Gilbert (Oct. 16, 1979)
Hart Comm. Interview of'W. Marshall (Oct. 17, 1979)
Hart Comm. Interview of G. Miller (Oct. 18, 1979)
. NRC Interview of W. Creitz (Oct. 23, 1979)
NRC Deposition of G. Miller (Oct. 29, 1979)
NRC Deposition of M. Ross (Oct' 30, 1979)
NRC Deposition of I. Porter (Oct. 30, 1979)
NRC Deposition of B. Mehler.(Oct. 30, 1979)
'NRC Deposition of-J. Chwastyk (Oct. 30, 1979) i Hart Comm. Interview'of L. Rogers-(Nov. 5, 1979)
Hart Comm. Interview of W. Zewe (Nov. 15, 1979)
Hart Comm. Interview of J. Herbein (Nov. 15, 1979)
SIG Interview Memo of W. Lowe (Dec. 4, 1979)
-Hart Comm. Interview of G. Miller (Dec. 19, 1979)
NUREG/CR-1250: Report of the Special Inquiry Group (Jan. 1980)
Vol. I, pages 1-x (Intro) '
Vol. I,fpages 42-43 (The Thud)
Vol II, Part 3, pages 894-913 (Reporting of Critical Information)
L r
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J-SIG Interview Memo of W. Marshall (Feb. 22, 1980)
SIG' Interview memo of R. Bensel (Feb. 22, 1980)
. Memorandum from Rogovin/Frampton to Chairman Ahearne (March 4,- 1980)
Subcommittee on' Nuclear Regulation of the Senate Committee on Environment and Public Works, " Report to the U.S. Senate: Nuclear Accident and Recovery at Three Mile. Island" (June:1960) pages 1-5_(Introduction) pages93-160 (The First Day)
NRC Interview of J. Flint (Sep. 2, 1980)-
.NRC Interview of L. Rogers (Sep. 2, 1980)
NRC Interview of H. McGovern (Sep. 3, 1980)
NRC Interview of J. Gilbert (Sep. 3, 1980)
. NRC Interview of D. Berry (Sep. 3, 1980) with notes attached.
NRC Interview of B. Mehler (Sep. 3, 1980)
NRC Interview of L. Wright (Sep. 3, 1980)
NRC Interview of J. Chwastyk (Sep. 4, 1980)
NRC Interview.of G.-Kunder (Sep. 3, 1980)
NRC. Interview'of'W. Zewe (Sep. 4, 1980)
NRC Interview of J. Herbein (Sep. 5, 1980)
NRC Interview of R. Arnold (Sep. 5, 1980)
NRC Interview of C. Miller (Sep. 5, 1980)
NRC Interview of H. Dieckamp (Sep.12,.1980)
NRC Interview of M. Ross (Sep. 24, 1980)
NRC Interview of I. Porter (Sep. 24, 1980)
NRC Interview of M. Benson (Sep. 24, 1980)
NRC Interview of T..Illjes (Sep. 24, 1980) r u_ __
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NRC :Inherview: of N. Bennett (Sep. ' 29, :1980)
- NRC' Interview of;J.fGilbert1(Sep. 30, 1980)
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LNRCl Interview of..J.'Higgins-(Oct. 7,-1980)
- -a ,
NRC Interview of;D. Neely (Oct..i, 1980)
^
NRC. Interview'of W. Raymond-(Oct. 7,: 1980) iNRCEDeposEtion of E. Frederick (Oct. 9,1 1980)-
~
!NRC: Deposition of'C. Faust (Oct.
9, 1980)
NRC-Deposition of-J.-Scheimann (Oct 9, 1980)-
f;, cNRC Deposition'of W. Conaway (Oct. 9, 1980) i; _ 'NRC Deposition of J.-Logan (Oct 16,-1980)
'NRC Deposition of A'. Miller;(Oct. 28, 1980).
J
- e. NRC Interview of'G. Miller:(Nov. 10, 1980).
/NUREG-0760 (Jan. 1981). .
NRC' Interview.of D.:Neely-(Jan'. 13, 1981)'
" Majority Siaff of the. House Committee on Interior and Insular Affairs,'" Reporting oflInformation Concerning.the-Accident at Three Mile Island) l(March,11981).
~
- 2. 1For, purposes-of the evidentiary hearing presently sche'dul'ed.to commence about November-15, 1984,'the parties
_ stipulate:that in-retrospect, . if all the in-core thermocouple 2
-readings h'd a been available and ha'd been examined, it-might-p have been recognized that'the 2000*F~ temperature indicated-b th'at the . core :was;within :the range :in which an autocatalytic p . Eexothermic zircalloy-steamireaction could occur.
l.-
- lThe/ signatory. parties"have agreed'that acceptance of this
[~ . stipulation 1by.the Licensing Board will bind the-parties at the.
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evidentiary hearing and further obviates TMIA's calling Dr. Henry
-Myers as a witness in the captioned proceedings. Licensee has agreed'in the captioned proceedings not to depose Dr. Myers, and not to seek documents from Dr. Myers, TMIA or NRC related to Dr.
Myers on the Dieckamp mailgram-issue. Licensee further has agreed
~
to withdraw a number of outstanding interrogatories to TMIA (namely, Interrogatory Nos. 13 and 19 of Licensee's Second Set of Interrogatories to TMIA and Interrogatory Nos, 1 through 18, 21, and 22 of Licensee's Third Set of Interrogatories to TMIA.)
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Ernest L. Blake, Jr.
Counsel for Licensee Lynne Bernabei Counsel for TMIA Jack-Goldberg Counsel for NRC Staff
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UNITED STATES OF AMERICA 0;; p._ .
' NUCLEAR REGULATORY COMMISSION 03hW
'64 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD f'yF '2 Q.7 7 In the' Matter of ) ng4 ' tG jfj,. *
) Docket.No. 5022893t
-' METROPOLITAN EDISON COMPANY ) (Restart-Management Phase)
(Three Mile. Island Nuclear )
' Station, Unit No. 1). )
CERTIFICATE OF SERVICE .
I hereby certify that copies of Testimony of Herman M.
Dieckamp,-Testimony of. William W. Lowe, Testimony of Thomas Leroy-Van.Witbeck and Testimony of E. L. Zebroski, dated .
. November 1, 1984, were served on those persons on the attached
~
Service List by deposit in the United States mail, postage pre-paid,.this 1st day of November, 1984.
V. hah, Ernest L. Blake, Jr., P.C.
Counsel for Licensee DATED: November 1, 1984 4
4.
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{l1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
'BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289 SP
) (Restart Remand on Management)
-(Three Mile Island Nuclear ) ,
Station, Unit No. 1)' ) r SERVICE LIST Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Commission Administrative Judge
. Washington,-D.C. 20555 John H. Buck.
Atomic Safety & Licensing Appeal Board Thomas M. Roberts, Commissioner U.S.' Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission '
Washington,.D.C. 20555 Washington, D.C. 20555 James K. Asselstine, Commissioner Administrative Judge.
Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal
. Washington, D.C. 20555 Board Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission-Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. ^20555 Administrative Judge Ivan W. Smith, Chairman Lando W. Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board- U.S. Nuclear Regulatory Commission
. U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 e
he-
e \
Administrative Judge Mr. Henry D. Hukill Gustave A.-Linenberger,.Jr. Vice President Atomic Safety & Licensing Board GPU-Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.
20555 Middletown, PA 17057 Docketing and Service Section (3) Mr. and Mrs. Norman Aamodt Office of the Secretary R.D. 5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C. 20555 Ms. Louise Bradford Atomic Safety'& Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Hartisburg, PA 17102 Washington, D.C. 20555 Joanne Doroshow, Esquire '
Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North ~ Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C. 20002 Washington, D.C. 20555 Lynne Bernabei, Esq.
Gover ment Accountability Jack R. Goldberg, Esq. (4)
Office of the Executive Legal '
.555 Connecticut Avenue ashington, D.C. 20009 t- U.S Nuc ear Regulatory Commission Washington, D.C. 20555 Ellyn R. Weiss, Esq.
Harmon, Weiss & Jordan Thomas Y. Au, Esq. 2001 S Street, N.W., Suite 430 Office of Chief Counsel Washington, D.C. 20009 ;
Department of Environmental Resources Michael F. McBride, Esq.
505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.W.
Harrisburg, PA 17120 Suite 1100 .
Washington, D.C. 20036 '
William T. Russell Michael W. Maupin, Esq.
Deputy Director, Division Hunton & Williams of Human Factors Safety 707 East Main Street Office Of NRR P.O. Box 1535 Mail Stop AR5200 Richmond, VA 23212 U.S. NRC Washington, D.C. 20555
.