ML20207J662
| ML20207J662 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/31/1986 |
| From: | PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20207J660 | List: |
| References | |
| IEB-85-003, IEB-85-3, NUDOCS 8607290213 | |
| Download: ML20207J662 (18) | |
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4 REPORT ON
., SAFETY-RELATED MOTOR-OPERATED VALVE SWITCH SETTING REVIEW AND TESTING PROGRAM FOR TROJAN NUCLEAR PLANT (IN RESPONSE TO IE BULLETIN 85-03)
JULY 1986 MM/rn 5811k.0786 B607290213 860715 4 PDR ADOCK 0500 0
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' s TABLE OF CONTENTS INTRODUCTION l.
- 2. SCOPE DEFINITION
- 3. DESIGN BASIS REVIEW
- 4. VERIFICATION PROGRAM APPENDICES A. VALVE DATA
SUMMARY
B. VALVE SWITCH SETTING VERIFICATION PROGRAM MILESTONE DATES C. VALVE SWITCH SETTING VERIFICATION PROGRAM BLOCK FLOW DIACRAM l
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1.0 INTRODUCTION
On November 15, 1985, the NRC Office of Inspection and Enforcement issued I2 Bulletin 85-03: " Motor-operated Valve Connon Mode Failures During Plant Transients Due to Improper Switch Settings". The purpose of the bulletin was to " request licensees to develop and implement a program to ensure that switch settings on certain safety-related motor-operated valves are selected, set, and maintained correctly to accommo-date the maximum differential pressures expected on these valves during both normal and abnormal events within the design basis". For all holders of operating licenses and construction permits, IEB 85-03 calls for six action items to be addressed for motor-operated valves in the high pressure coolant injection and emergency (or auxiliary) feedwater systems that are required to be tested for operational readi-ness, in accordance with 10CFR50.55a(g). The valves are fur-ther selected on the basis of the Westinghouse Owners Group Safety-Related MOV Program issued in April 1986.
1 The following sections document the design basis operating conditions for the selected valves and defines a program to
, review and, if needed, revise switch settings, test the valves to verify the new settings, and develop, or revise procedures for future testing and maintenance.
The report represents the first phase of the required work and l satisfies Action Item e of IEB 85-03. The second phase ,
! includes the balance of the required action items.
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2.0 SCOPE DEFINITION The valves affected by this effort are located in the high pressure coolant injection and auxiliary feedwater systems.
High pressure coolant injection, as defined by the generic Westinghouse Owner's Group methodology, includes those l
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portions of the Chemical and Volume Control System (CVCS),
through the Centrifugal Charging (CC) pumps and the Boron Injection Tank (BIT), and the Safety Injection (SI) system, that are required to function in order to establish a flow path from the Refueling Water Storage Tank (RWST) to the Reactor Coolant System (RCS) during the injection phase after a design basis accident. This excludes the Accumulators and the Residual Heat Removal system, as well as containment sump recirculation after depletion of RWST contents. Although the SI system is not considered a high pressure injection system at Trojan, it is included here for conservatism. Systems and components involved in RCS cooldown after high pressure injec-tion are not included in the IE Bulletin 85-03 scope of work.
Several motor-operated valves bounding the flow path are not required to function during the high pressure injection mode of operation and are not included here. These valves include MO 8802A&B, MO 8924, MO 8807A&B, MO 8112 and MO 8100 (the last two are in the reactor coolant pump seal return flow path').
This is consistent with the Westinghouse methodology.
Based on this definition, the motor-operated valves required for accident mitigation and selected for review are:
Valve No. Service MO 8806 SI Pump Suction MO 8923A,B SI Pump Suction MO 8821A,B SI Pump Discharge to Cold Leg MO 8835 SI Pump Discharge to Cold Leg MO 112D,E CC Pump Suction from RWST l MO 8106 CC Pump Normal Charging to Cold Leg MO 8105 CC Pump Normal Charging to Cold Leg i
MO 8803A,B CC Pump Discharge through BIT MO 8801A,B CC Pump Discharge through BIT MO 112B,C CC Pump Suction from VCT MO 8111 CC Pump Minimum Recirculation MO 8110 CC Pump Minimum Recirculation MO 8814 SI Pump Minimum Recirculation MO 8813 SI Pump Minimum Recirculation
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4 The Auxiliary Feedwater System (AFW) provides a reliable source of feedwater to the steam generators in the event that main feedwater flow is lost. The motor-operated valves reviewed included all those associated with establishing a flow path from a water source to the steam generators as well as the valves related to assure proper operation of system i components. The following valves were included:
Valve No. ,
Service NO 3060A,B Service Water to Driver Coolers No 3045A,B Service Water to AFW Pump Suction CV 3004A1 ,A2 AFW Pump Discharge Control B1,B2,C CI2 Di,D2 MO 3071 Turbine Driver Trip and Throttle NO 3110 Turbine Driver Steam Inlet
- MO 2947A,B Motor-Driven AFW Pump Discharge Control
- Although the motor-driven AFW pump is non-Jafety-related, the discharge control / isolation valves are safct.y-related and have been included.
1 3.0 DESIGN BASIS REVIEW To determine the maximum pressure drop acrosa cach valve, an extensive review of system and component operating and failure modes was conducted to identify the scenario that would result in the extreme conditions. This included a search of applicable design documents as well as a review of the UFSAR and plant procedures. Key documents reviewed were:
- a. Updated Final Safety Analysis Report Chapter 6, Engineered Safety Features Chapter 9, Auxiliary Systems Chapter 10, Steam and Power Conversion System Chapter 15, Accident Analyses
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- b. Plant Operating Manual Operating Instructions General Operating Instructions Emergency Instructions Emergency Contingency Actions
- c. Wectinghouse Owner's Group Safety-Related MOV Program Final Report, WOG-86-168, dated April 7, 1986.
- d. Equipment Vendor Documents Engineering Data Sheets For each motor-operated valve addressed, the following identifies the valva drawing location, describes the conditions under which the valve would be called upon to open and close, describes the scenario that causes the saximum differential pressure (dP) across the valve to occur, and lists the resulting maximum pressure drop. These values are also summarized in Appendix A.
3.1 MO 8806 [UFSAR Figure 6.3-1, C-2], common SI pump suction; normally open.
OPEN This valve is closed only for stroke testing during cold shutdown conditions. The valve must be able to open against a full RWST head of water with atmospheric pressure on the downstream side. The elevation differ-ence betwecn RWST and the valve is about 35', tank height is about 40'; therefore, maximum dP = 75' = 33 psid.
open CLOSE This valve must be able to close to isolate the RWST from the discharge of the RHR pumps during the traasfer to cold leg recirculation mode of operation as a pre-cautionary measure in the event of backleakage through check valve 8926 (sir.gle passive failure). For this scenario, the dP across MO 8806 could be as high as the RHR pump discharge head. Using the shutoff discharge 4
head as the limiting case, maximum dP 1,,, = 204 psid.
(This is conservative since it assumes no elevation head on the tank side of the valve, and cold water temperature).
3.2 MO 8923A&B (UFSAR Figure 6.3-1, B-2), individual SI pump suction from RWST; normally open.
OPEN These valves are closed only for stroke testing and pump isolation for maintenance. The valve must be able to open against a full RWST head of water. The elevation difference between the RWST and the valve is about 35'.
So, as for MO 8806, the maximum dP , = 33 paid.
CLOSE These valves must be capable of isolating one of the safety injection pumps from the flow path given a passive failure in that train. During cold leg recirculation, the dP across the valve could be as high as the RHR pump shutoff head, or maximum dP y ,, = 204 psid.
i 3.3 MO 8821A&B [UFSAR Figure 6.3-1, B-5), individual SI pump discharge; normally open.
OPEN/ These valves must be able to allow train separation during CLOSE the recirculation phase of safety injection. The dif-ferential pressure developed could be as high as the shutoff head of safety injection pump. Maximum dP , f y ,, =1520 psid.
l 3.4 MO 8835 (UFSAR Figure 6.3-1, C-6), common SI pump discharge; normally open.
OPEN/ This valve is cycled only in cold shutdown for inservice CLOSE testing. It is closed while in hot standby or hot shut-down as a test boundary to determine SIS check valve leakage. Maximum dP is based on the shut off head of the
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safety inj.ection pump. Maximum dP open/ closed = 1520 psid. This is the expected value should an SI occur while performing the check valve leakage test.
3.5 MO 112D&E [UFSAR Figure 9.3-14, C-5), charging pump suction from RWST; normally closed.
OPEN/ These valves serve the centrifugal charging pumps as CLOSE NO 8806 serves the safety injection pumps. However, the elevation difference between RWST and the valve is less (16 feet in lieu of 35 feet). For conservatism, the same values were used. So, maximum dP = 33 psid, and open maximum dP ,,= 204 psid.
3.6 MO 8105, MO 8106 [UFSAR Figure 9.3-14, F-7], charging pump, normal discharge to the RCS; normally open.
OPEN/ These valves must be able to isolate the RCS from the CLOSE CiCS, with maximum dP produced by the discharge head of the charging pump. Using the shutoff head as limiting case, maximum dP en/close = 2700 psid.
3.7 MO 8803A,B [UFSAR Figure 6.3-1, C-4], charging pump discharge BIT inlet; normally open.
OPEN/ These valves must be able to open with a maximum CLOSE pressure difference approaching the shutoff head of the charging pump. Therefore, maximum open/close = 2700 psid.
3.8 MO 8801A,B [UFSAR Figure 6.3-1, D-6), charging pump discharge BIT outlet; normally closed.
OPEN/ These valves nust be able to open with a maximum l CLOSE pressure difference approaching the shutoff head of the charging pump. Therefore, maximum dP open/close = 2700 psid.
At Trojan, either MO 8803A,B or MO 8801A,B may be deleted with the removal of the Boron Injection Tank, planned for 1987.
3.9 MO 112B&C [UFSAR Figure 9.3-14, E-6], charging purp suction from VCT; normally open.
OPEN/ These valves close upon receipt of a safety injection CLOSE signal (SIS). The maximum dP across the valve is defined by the Volume Control Tank (VCT) design pressure of 75 psig plus elevation height of the VCT above the valves (less than 30'). So, maximum dP e / 1 se = 90 psid.
3.10 MO 8110, MO 8111 [UFSAR Figure 9.3-15, C-3], charging pump minimum recirculation; normally open.
OPEN These valves must be opened to provide the miniflow requirements of the centrifugal charging pump. The dP developed could approach the shutoff head of that pump.
So, maximum dP = 2700 psid.
CLOSE These valves must close to ensure adequate high pressure injection flow upon SIS. Again, maximum dP could So, maximum dP approach pump shutoff head. 1 e" 2700 psid.
3.11 MO 8813, MO 8814 [UFSAR Figure 6.3-1, F-2], SI pump minimum recirculation; normally open.
OPEN These two valves must be opened to provide the miniflow reluirements of the safety injection pump. Maximum dP ,
= 1520 psid.
CLOSE These valves must close to isolate miniflow so that high pressure injection switchover to recirculation may pro-ceed. In the worst case, dP will be equal to the pump developed shutoff head. Maximum dP lo e = 1520 psid.
D 3.12 MO 3060A [UFSAR Figure 10.4-2, Sheet 1, A-7], MO 3060B [UFSAR Figure 10.4-2, Sheet 1 C-7], service water to AFW equipment cooling; normally closed.
OPEN/ When emerscncy conditions arise, these valves will open CLOSE to supply service water to the pump and driver oil coolers and the diesel driver jacket water heat exchanger. Note that MO 3060B will open automatically whenever the diesel-driven auxiliary pump (P102B) starts. On the other hand, the auto mechanism is dis-connected for MO 3060A at Trojan and the valve is locked closed. Therefore, this valve may be deleted from the review. dP developed could be as high as the service water booster pump discharge head. (It is not reasonable to assume shutoff head conditions, since the service water system has a multitude of branches that would all have to be isolated simultaneously.) Maximum dP , f y ,, = 100 psid (conservative).
3.13 MO 3045A&B (UFSAR Figure 10.4-2, Sheet 1 A-7], service water to AFW pump suction; normally closed.
OPEN/ These valves will be opened in the event of loss of CLOSE supply water from Condensate Storage Tank (CST). dP developed could be as high as the discharge head of the service water booster pump. As for MO 3060A,B, the maximum dPopen/close = 100 psid.
3.14 CV 3004A1 & A2 [UFSAR Figure 10.4-2a, Sheet 2 F-5),
CV 3004B1 & B2 [UFSAR Figure 10.4-2a, Sheet 2, F-4],
CV 3004C1 & C2 [UFSAR Figure 10.4-2a, Sheet 2, F-3),
CV 3004D1 & D2 [UFSAR Figure 10.4-2a, Sheet 2, F-2), AFW pump discharge control; normally open.
OPEN/ These valves are used to regulate auxiliary feedwater CLOSE flow. Upon receiving a high-flow signal from a flow element in each line, the corresponding motor-operated valve will close. The dP developed could be as high as the AFW pump discharge head. Since the potential for pump / driver overspeed prevails during startup, the resultant maximum pressure (2160 psig) must be con-sidered. This is considered conservative as proper equipment maintenance should prevent significant over-speed from occurring. Using the coincident shutoff head and maximum overspeed, a pressure of 2160 psig in addi-tion to the elevation difference between the valve and the top of the condensate storage tank, approximately 20 feet, results in a maximum dP , f y g, = 2170 psid.
3.15 MO 3170, MO 3071 [UFSAR Figure 10.4-3, B-4), AFW pump turbine driver steam inlet; normally open (MO 3170), normally closed (MO 3071).
OPEN/ MO 3170 maintains 500 lb/hr of high pressure steam to CLOSE the trip and throttle valve, MO 3071, and through the 3/4" warmup line to the drain condenser. The maximum upstream pressure is determined by the steam generator relieving pressure. The downstream side pressure is atmospheric. Maximum main steam relieving pressure is approximately 1285 psia. Therefore, maximum dP en/close = 1270 psid.
3.16 MO 2947A,B [UFSAR Figure 10.4-2, Sheet 1, H-6], motor-driven AFW pump discharge control; normally closed.
OPEN/ These valves regulate the auxiliary feedwater flow to the CLOSE steam generators during plant startup and shutdown Maximum dP is a result of pump shutoff head plus static elevation difference. Therefore, maximum dP = 1785 psid.
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3.17 NOTES The design basis valve pressure drops developed above reflect maximum theoretical static conditions. They are judged conservative in that they assume system design basis conditions simultaneous with the occurrence of an accident. The values assume maximum pressure on one side of the valve with no pressure (atmospheric) on the other side. Both automatic and manual action of the valves have been included.
Transient peak pressures, resulting from valve or pump operation or from pipe ruptures, were not analyzed. The design basis values listed were sufficiently conservative to accommodate transient conditions.
Where elevation heads are a factor in the maximum differential pressure values, a specific gravity of one is assumed for conservatism.
4.0 VERIFICATION PROGRAM The balance of effort (the second phase) necessary to fulfill the requirements of IE Bulletin 85-03 will be carried out over the next 16 months and includes the following main activities:
- a. Establish correct switch settings for affected valves.
- b. Change incorrect switch settings and test the valves under actual or simulated conditions.
- c. Develop, or revise as necessary, procedures to set and maintain switch settings.
A schedule for completing the key elements of the activities listed above is submitted in Appendix B with milestone dates identified. Appendix C graphically displays the main activities in the program.
The following provides a detailed description of the program activities as outlined above.
f 4.1 Establish Switch Settings Initially, the new dP values developed in the first phase of the effort (Section 3.0 above) will be compared to the existing valve specifications to establish the suitability of the present installations. Any discrepancies will be brought to the original valve vendor's attention to determine if modifications are required.
Both valve and operator vendors will be consulted extensively in this part of the program. The valve vendor will be requested to assist in determining the correct stem thrust and torque requirements based on the new maximum dP values. Subsequently, the operator vendor will be relied upon to review the valve vendor's data and assist in establishing tne correct switch settings. The torque bypass switch will be set to preclude the torque switch tripping before the valve has fully lifted off the seat.
Motor overload switch setpoints will also be established with l,
input from the appropriate vendors.
The new switch settings will be compared to the actual settings after a detailed plant walkdown. Any discrepancies will be documented and reviewed with the vendors. Sim'altaneous reviews of design documents, such as drawings, data sheets, valve specifications and line tables, will be conducted to detect and eliminate inconsistencies.
Current methods for selecting valves and establishing valve operator setpoints consistent with system design conditions will be reviewed (with vendor input) and revised as deemed neces-sary. The analytical methodology applied to establish the new
4 switch settings will be recorded and included in valve test and maintenance procedures.
Discrepancies between new valve data and existing values will be analyzed to determine the operability of the current installa-tion. If operability is questionable, the appropriate justifi-
- cation for continued operation will be developed. The vendors
- will be consulted to verify operability or to establish necessary modifications.
Additionally, the performance history will be reviewed to establish indications of damaged valve components. Plant personnel will be consulted to verify maintenance and operating history and to identify future plans for significant work on the affected valves. All necessary modifications will be made (with vendor input) before implementing the new switch settings and testing to ensure proper performance of the valves.
4.2 Valve Testing The valve switch settings will be revised where required (valve modifications made, if necessary) as established in Section 4.1 above, and the revised switch settings will be properly
- recorded. Subsequently, all reviewed notor-operated valves will be tested to demonstrate operability under the extreme operating conditions established in Section 3.0.
The valve testing will be conducted using diagnostic detection l
equipment applying simulated design conditions where duplicating actual design conditions is impractical. Where testing with the maximum differential pressure cannot practicably be performed, alternative testing and justification of its acceptability will be provided.
Complete stroke testing will be conducted to verify that all the correct switch settings have been implemented.
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4.3 Develop Procedures Existing motor-operated valve maintenance and test practices will be reviewed and revised as necessary. Vendor input will be obtained in developing a practical procedure that ensures con-tinued valve operability for all design basis conditions. This includes documentation of valve switch setpoint changes and the methodology used in establishing the setpoints, as well as requirements to conduct periodic tests to verify the correct implementation of the new settings.
4.4 Final Report A written report will be submitted at the end of the program.
The report will verify completion of the required activities, as identified in IE Bulletin 85-03, summarize the findings of updated valve design bases as compared to the existing installa-tions, and describe changes made and tests conducted with associated results.
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4 APPENDIX A VALVE DATA
SUMMARY
Valve Data Valve Operator Design Basis dP Valve Manufacturer / Tag No. Manufacturer /Model/ Open Close ID Type / Size Rating Motor HP/ RPM Valve Function (psi) (psi)
HIGH PRESSURE INJECTION MD 8806 Copes Vulcan /8GM92FB/ Limitorque/Spe-0/ Safety Injection Pmp 33 204 Cate/8"/150# 2 HP/3600 RPM Suction from RWST MD 8923 Copes Vulcan /6GM92FB/ Limitorque/SMB-00/ SafetyInjectionPunp 33 204 A,B Gate /6"/150# 1.33 HP/3600 RPM Suction frctn RWST MD 8821 Velan/4GM77FH/ Limitorque/SMB-00-25 Safety Injection Pmp 1520 1520 A,B Gate /4"/900# 1.6 HP/1800 RPM Discharge to Cold Leg MO 8835 Velan/4GM78FN/ Limitorque/SMB-0-40/ Safety Injection Punp 1520 1520 Cate/4"/1500# 2.6 HP/1800 RPM Discharge to Cold Leg MO 112 Copes Vulcan /8GM92FB/ Limitorque/SMB-0/ Centr Charging Pump 33 204 D,E Gate /8"/150# 2 HP/3600 RPM Suction frcm RWST MD 81% Velan/3GM70FN/ Limitorque/SMB-00-25 Centr Charging Punp 2700 2700 Gate /3"/1500# 1.6 HP/1800 RPM Nonnal Charging to RCS MD 8105 Velan/3GM78FN/ Limitorque/SMB-00-25 centr Charging Pump 2700 2700 Gate /3"/1500# 1.6 HP/1800 RPM Nonnal Charging to RCS
- MO 8803 Velan/4GM78FN/ Limitorque/SMB-0-40/ Centr Charging Pump 2700 2700 A,8 Cate/4"/1500# 2.6 HP/1800 RPM Discharge through BIT
- MO 8801 Velan/4GM78FN/ Limitorque/SMB-0-40/ Centr Charging Pmp 2700 2700 A,B Gate /4"/1500# 2.6 HP/1800 RPM Discharge through BIT MO 112 Copes Vulcan /4GM92FB/ Limitorque/SMB-00/ Centr Charging Pump 90 90 B,C Gate /4"/150# .66 HP/1800 RPM Suction from VCT MO 8111 Velan/2TM78FN/ Limitorque/SMB-00-15 Centr Charging Pmp 2700 2700 Globe /2"/1500# 1 HP/1800 RPM Minimum Recirculating MD 8110 Velan/27M18FN/ Limitorque/SMB-00-15 Centr Charging Punp 2700 2700 Globe /2"/1500# 1 HP/1800 RPM Minimum Recirculating MO 8814 Velan/2TM78FN/ Limitorque/SMB-00-15 SafetyInjectionPump 1520 1520 Globe /2"/1500# 1 HP/1800 RPM Mininun Recirculating MO 8813 Velan/2TM78FN/ Limitorque/SMB-00-15 Safety Injection Punp 1520 1520 Globe /2"/1500# 1 HP/1800 RPM Mininun Recirculating
- Either MO 8803A&B or MO 8801A&8 may be removed along with the removal of the Boron injectiontank.
o APPENDIX A (conc 1) e VALVE DATA SUMARY Valve Data Valve Operator Design Basis dP Valve Manufacturer / Tag No, Manufacturer /Model/ Open Close ID Type / Size Rating Motor HP/ RPM Valve Function (psi) (psi)
- MO 3060 Fisher /9520/ Limitorque/SMB-000/ Service Water to Purip 100 100 B B. Fly /6"/ 5 ft Ib/1000 RPM Driver Coolers MD 3045 Pacific Valve / - Limitorque/SMB-00-10 Service Water to AFW 100 100 A&B Gate /6"/150# .66 HP/1800 RPM Purup Suction CV 3004 Fisher /ED/ Globe / Limitorque/SMB-000/ AFW Discharge Control 2170 2170 Ai,A2 3"/900# 1800 RPM By,B2 Cj,C2 MD 3071 Schutte-Koerting/ Limitorque/SMB-000/ Turbine Driver Trip 1270 1270 Gate /4" .144 HP/1000 RPM and Throttle MD 3170 Anchor Valve / - Limitorque/SMB-0-40/ Turbine Driver Steam 1270 1270 Globe /4"/600# 2.6 HP/1800 RPM Inlet MD 2947 Anchor Darling / Gate / Limitorque/SM-0-40/ Motor-Driven AFW Punp 1785 1785 A88 6"/900# 2.6 HP/1800 RPM Discharge Control
- MD 3060A is currently locked closed and no longer in service, i
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APPENDIX B SCHEDULE MILESTONE DATES MOTOR-OPERATED VALVE SWITCH SETTING VERIFICATION PROGRAM (IE BUT.LETIN 85-03)
Date
- 1. Submit valve design bases and implementation July 15, 1986 program to NRC (first phase)
- 2. Start second phase July 15, 1986
- 3. Complete establishing new valve switch settings Nov 1, 1986 Order new parts, as required
- 4. Complete special plant valve test procedures Mar 1, 1987
- 5. Start valve testing Mar 1, 1986
- 6. Complete revising switch settings June 1, 1987
- 7. Complete valve testing July 15, 1987
- 8. Complete new test / maintenance procedures Sept 15, 1987
- 9. Submit completion report to NRC Nov 15, 1987
, Appendix C BLOCK FLOW DIAGRAM FOR
. MOTOR-OPERATED VALVE SWITCH SETTING PROGRAM (IE BULLETIN 85-03)
IDENTIFY VALVES TO BE REVIEWED, ESTABLISH DESIGN BASIS OPERATING MODE AND RESULTANT MAXIMUM dP VALUES
\ NO DETERMINE REQUIRED IS EXISTING VALVE %s DESIGN SPECIFICATION , ? MODIFICATIONS AND ADEQUA IMPLEMENT YES g
WITH VENDOR ASSISTANCE ESTABLISH NEW VALVE SWITCH SETTINGS o
CONDUCT DETAILED VALVE WALKDOWN U
U ARE NO REVISE SETPOINTS, REVIEW DESIGN DOCUMENTS FOR CONSISTENCY AND EXISTING SETPOINT ; MODIFY COMPONENTS CORRECTNESS, AND CORRECT? AS NECESSARY REVIEW / DEVELOP PLANT TEST AND MAINTENANCE PROCEDURES YES g
TEST VALVES AT
- - SIMULATED DESIGN ==
CONDITIONS U
SUBMIT REPORT TO NRC
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