ML20235F870
| ML20235F870 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/1987 |
| From: | Paul Prescott, Stone J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235F850 | List: |
| References | |
| REF-QA-99900317 NUDOCS 8707140018 | |
| Download: ML20235F870 (14) | |
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ORGAN 3ZAT10N: COOPER ENERGY SERVICES GROVE CITY, PENNSYLVANIA REPORT INSPECTION INSPECTION NO.: 99900317/87-01 DATE! 03/30-0473/R7 nN 9TTF HnflDR-51 CORRESPONDENCE ADDRESS: Cooper Industries Cooper Energy Servi,ces ATTN: Mr. F. Bruce Stolba, Vice President and General Manager 150 Lincoln Avenue Grove City, Pennsylvania 16127 ORGANIZATIONAL CONTACT:
W. H. Allen Lambert, Manager of QA TELEPH0hE hUMBER:
(412) 458 900n NUCLEAR INDUSTRY ACTIVITY: Original equipment manufacturer of standby diesel generators for nuclear service. Current sales in parts, repair and service only. No current orders for standby diesel generators at comercial nuclear facilities.
ASSIGNED INSPECTOR:
A Y
P. J. Prescott, Program Develop:nent and Reactive ate InspectionSection(PDRIS)
OTHERINSPECTOR(S):
E. H. Trottier, NRR M. Schuster, Consultant, BNL APPROVED BY:
A W%Y
'b E nes C. Stone, Chief, IS, Vendor Inspection Branch Date a
M INSPECTION BASES AND SCOPE:
A.
BASES:
10 CFR 21 and 10 CFR 50, Appendix B.
SCOPE: This inspection was significant 10 CFR 50.55(e) performed in response to two recent and B.
reports involving Cooper standby diesel generators.
In addition, the purpose of this inspection was to verify corrective and preventive actions taken in response to findings of the previous NRC inspection (86-01, July 28-August 1, 1986).
PLANT SITE APPLICABILITY: Byron 1and2(50-454.,455); Braidwood 1 and 2 (50-456,457); Cooper (50-298); Nine Mile Point 2 (50-410); Palo Verde 1, 2, and 3 (50-528,529,530); South Texas 1 and 2 (50-498, 499).
8707140018 870708 PDR GA999 EMVCOIN 99900317 PDR
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ORGANIZATION: COOPER ENERGY SERVZCES GROVE CETY, PENNSYLVANIA REPORT INSPECTION N6 - QQQnn117/A7-01 RESULTS:
PAGE 2 of 12 A.
VIOLATIONS (1) Contrary to 10 CFR 21.31, Cooper Energy Services (CES) issued Purchase Orders (P0s) 532190275 dated January 1, 1983, 532190034, dated January 1, 1984, 3921G6372, dated June 23, 1986, and 3921G6941, dated October 17, 1986 to a subvendor (Vander Horst Corporation of Olean, New York) for the plating of critical parts without specifying that the provisions of 10 CFR 21 apply.
4 (Critical parts are defined as safety related.)
(87-01-01)
B.
HONCONFORMANCES (1) Contrary to CES Quality Control Procedures QCP-10-6, Section 4.1.2, l
and QCP-10-13, Section 3.2, a document that was of significant value in maintaining, reworking, repairing, replacing, or modifying an item or that could have been of significant value in determining the cause of an accident or malfunction of an item (Work Order Fonn #451) was not maintained until the item to which it pertained was decommissioned from service.
(87-01-02)
(2) Contrary to CES Quality Control Procedure QCP-10-15, Section 4.11, no calibration frequency requirements were provided for the hardness
)
testing equipment in Inspection Procedure ISP-5-2.
(87-01-03)
(3) Contrary to CES Quality Control Procedure QCP-10-6, Section 4.5.2, and CES Material Specification SE-89-2N, no certificate of conformance j
was available for plating repairs performed by a subvendor, Vander Horst Corporation of Olean, New York.
(87-01-04)
C.
UNRESOLVED ITEMS (1) CES stated that its design drawings would be revised to delete
" NOTE 7," which allows production personnel to waive stress relief requirements (without documentation) for connecting rods being used in safety-related applications.
(2) CES stated that it would provide an interim memorandum requiring that
)
10 CFR 21 be applied to all critical / safety-relsted purchase orders.
It also indicated that the appropriate procedures would be revised to include 10 CFR 21 requirements.
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ORGANIZAT10N: COOPER ENERGY SERVICES GROVE CITY, PENNSYLVANIA REPORT INSPECTION
?
Nn - 4Qonn117/P7-01 RESULTS-PAGE 3 of 12 D.
ST/.TUS OF PREVIOUS INSPECTION FINDINGS (1) Inspection No. 86-01 (July 18-August 1, 1986) fionconformance 86-01-01 (Closed):
The NRC inspectors found out-of-date procedures and an out-of-date procedures index in the heat treat area office. Specifically, d
Procedures HT-17N and HT-18AN were cited as being out of cate according to the Standards Manual for Engineering Material Specifica-tions Index.
(These out-of-date heat treat procedures were the subject of Nonconformance B.1 identified during the previous inspection in March 1984, Report No. 99900317/84-01.)
In closing this open item, the inspector reviewed the revision status of the Material Specifications Index (November 3, 1986) and compared the revision status of several procedures against the revision date tabulated in the index. The following presents a summary of this rev1ew:
Procedure No.
Rev. Date Index Rev. Date Status HT-3N 4/15/75 4/75 Current A-1AN 9/5/75 9/75 Current A-5BN 4/21/75 4/75 Current HT-17N 11/12/84 11/84 Current HT-18AN 2/21/85 2/85 Current As shown above, CES has taken effective corrective and preventive actions to control the revision status and use of metallurgical procedures.
(2) Inspection No. 99900317/84-01 (March 12-16, 1984)
Nonconformance 11 (Closed):
Technical evaluations to determine deportability as a 10 CFR 21 itet (component defect) were not being completed within the 30-day require-ment specified in CES Procedure QCP-10-14. " Quality Requirements for Reporting of Deficiencies."
The inspectors reviewed the latest revision to QCP-10-14 (Rev. 3 dated October 29,1986) and found that the section addressing evalua-tions of potential component deficiencies has been revised. The
ORGAN 8ZAT10N: COOPER ENERGY SERVfCES GR0VE CITY, PENNSYLVANIA REPORT INSPECTION NO Q0000117/A7.01 RFSUITS!
PAGF 4 of 19 30-day requirement for Product Engineering "to evaluate the noncon-formance and determine if a deficiency existed" has been deleted from Section 4.2.2 of QCP-10.14. This is in recognition of the fact that, occasionally, it is not possible to establish the root cause of a deficiency within 30 days.
It should be noted, however, that CES has demonstrated strict adherence to the requirement to notify the NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> that "a product deficiency exists such that a major reduction in the degree of protection to public health and q
safety will occur."
4 As shown above, CES has taken adequate corrective and preventive action to resolve this nonconformance.
E.
OTHER FINDINGS AND COMMENTS The purpose of the inspection conducted on March 30 - April 3, 1987 was l
to review the evaluation and root cause analyses performed by CES for several recent and significant engine failures at commercial nuclear power plants. The current status of these analyses follows:
(1) Connecting Rod Failure On December 23, 1986, engine 3B at Palo Verde Nuclear Station suffered a catastrophic failure of the number 9 master connecting rod. Both the master (9R) and articulated (9L) rods were ejected from the engine, along with their pistons and the counterweights.
Using the hot oil mist in the sump for fuel and drawing air in through the hole in the engine case, the engine continued to run after the incident for approximately 50 minutes at reduced speed.
Plant personnel finally stopped it by spraying fire suppression foam into the oil sump through the hole in the case.
Examination of the pieces of the 9R (master) connecting rod showed clear evidence of a fatigue failure, with the initiation point at the center oil hole between the articulated rod pin bore and crank pin bore.
A metallographic examination revealed that both pin bore surfaces had been plated to a depth of approximately 1/16 inch (0.062 inch).
Research by CES into the manufacturing history of this rod showed that it had been overbored during machining and was iron plated (by a subcontractor) to bring it back into dimensional tolerance.
This rod (and three others) were overmachined in the articulated and/or crank pin bore at about the same time in 1978-1979. These connecting rods, and five more that underwent " cosmetic" iron
ORGAN 12ATION: COOPER ENERGY SERVICES GROVE C1TY, PENNSYLVANIA REPORT INSPECTION Nn. Qoonn917/R7.01 pFS1H TS-par,F R nf 17 plating, were probably the last such parts iron plated. CES field service representatives had learned of engine distress in a two-cylinder gas compressor in 1977-1978.
Investigation pointed to iron plating as a contributing cause. Thus, CES discontinued iron plating in 1978-1979.
It is now clear that iron plating, because of its crystal structure (face-centered cubic), does not possess enough slip planes to be d
sufficiently ductile. A more ductile material would possess a body-centered cubic crystal structure). The low ductilit iron plating, in the presence of a stress concentration (y of the the oil hole between the crank pin and articulated pin bores), can cause it to crack even under relatively light loads. In addition, micrographic examination of the fron plating showed definite columnar grain i
orientation. This columnar grain orientation may be a result of a lack of proper plating process control.
To explore further the circumstances surrounding this failure, the by the connecting rod at normal (600-rpm) port for the loading seen inspector reviewed the stress analysis re andoverspeed(660-rpm) conditions. Using the combined rod assembly and master rod inertia loading, and a stress concentration factor of 2.0 for the oil hole geome'ry, the minimum cyclic fatigue factor (CFF) occurs at the minimum material thickness (cross-sectional area) between the l
articulated rod pin bore and the crank pin bore. The CFF value at this point is 2.98 at 600 rpm and 2.56 at 660 rpm. All other regions of interest typically have a more conservative value for l
CFF.
l These CFF values are significantly above the CES target value of j
2.25, which is a judgment factor based on material and machining I
variations, unknown load factors (operctor errors), and calculational variations. However, CFF values at CES can range from 1.8 to 2.5.
i Designing this engine with a minimum CFF of 2.25 appears to l
represent a significant margin above the " perfect knowledge" value t
of 1.0.
A CFF of 2.56 (at 660 rpm) in the area between articulated
)
and crank pin bores that contains the oil hole where the break initiated is approximately IC above the standard CES CFF of 2.25 for such an engine part. The standard CFF of 2.25 is, in turn,125%
l above the perfect knowledge value of 1.00.
3 On the basis of the hRC inspector's review of the failed engine parts and the investigation conducted by the licensee (Arizona Public 1
Service Company), its materials consultant, and CES it appears that
ORGANIZATION: COOPER ENERGY SERVICES GROVE CITY, PENNSYLVAh!A REPORT INSPECTION wn - oponn117/R7 n1 RESULTS:
pAGE 6 of 12 the minimum fatigue factor selected by CES was prudent and that the margins above its established minimum were significant.
It appears that the connecting rod failure experienced at Palo Verde Nuclear Station was caused by electroplated iron in the area of a stress concentration (radius of oil hole).
(2) Procurement 5
The NRC inspectors examined several procurement records to determine whether CES procedures and their implementation met the requirements of 10 CFR 21, and if the applicable quality requirements were specified on the CES critical component purchase order forms. Those requirements are imposed on subvendors supplying CES with manufac-turing services or materials used in the manufacturing process. As part of the review, the inspectors examined four purchase orders i
placed with the Vander Horst Corporation for the plating of critical (safety-related)enginecomponents. While reviewing these purchase 1
orders, the inspector determined that CES had issued these purchase orders without specifying that the provisions of 10 CFR 21 were applicable. The purchase orders (P0s) were 532190275 dated January 1, 1983, 532190034 dated January 1, 1984, 3921G6372 dated June 23, 1986, and 3921G6941 dated October 17, 1986. Before the conclusion of the inspection, CES personnel presented to the NRC inspector an inter-office memorandum dated March 19, 1987, which states:
All "N" Code, critical parts purchase orders must contain a reference to 10 CFR 21, Reporting of Nonconformances. Quality Control is requesting the following change to the standard verbiage for these purchase orders.
Material to be supplied on this purchase order is deemed to be a " Critical"/" Safety Related" part for Standby Diesel Engine Generator Sets in Nuclear Power Plants. 10 CFR 21, " Reporting of honconformances",
and the enclosed procurement drawings and specifications apply. All required documentation shall be shipped with and/or in advance of the product, and shall be legible and reproducible. Failure to comply with the above is cause for rejection of your product.
CES personnel informed the NRC inspectors that a review of all P0 files would be completed and that the above statement would be made an attachment to every applicable subvendor's P0.
Violation (87-01-01) was identified in this area.
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ORGANIZATION: COOPER ENERGY SERVICES GROVE CSTY, PENNSYLVANIA REPORT INSPECTION en. ooonn917/n7_n1 RESULTS:
PAGE 7 of IP (3) Documentation The NRC inspectors reviewed Material Review Request (MRR) 2912 dated October 26, 1979, and all associated documentation. MRR 2912 was initiated to document a deviation that occurred at CES during the machining process of a crank shaft bore for the connecting rod that failed at the Palo Verde Nuclear Station in December 1986.
MRR 2912 was generated to iron plate the base material per Material
(
Specification SE-89-2N and inspect the completed iron plating process in accordance with Quality Control Inspection Plan QC/IP-SVG-17.
During a review of the supporting documentation for MRR 2912, the inspectors noted that Work Order 89998 issued December 5,1978 and referenced _on QC/IP SVG-8 was not included as part of the completed i
work package. CES personnel stated that Work Order 89998 may have been discarded because the Record Retention Section in the Quality Assurance Manual was misinterpreted and that this section has been revised to include the work order fonn as a lifetime document.
Nonconformance item (87-01-02) was identified in this area.
(4) Calibration The NRC inspectors reviewed Sections QCP-10-15 and ISP-5-2 of the CES quality control procedures and compared their requirements with calibration records for the equipment used during the inprocess inspection of various components being manufactured. Section 4.11.1 of QCP-10-15 requires that calibration frequency be in accordance with Inspection Procedure ISP-5--2.
The inspector reviewed ISP-5-2 but found no reference to calibration frequency.
In discussions with CES personnel, the inspectors learned that Inspection Procedure ISP-5-2 was being.evised and that a reference to calibration frequency would be included in the new revision.
Nonconformance (87-01-03) was identified during this part of the inspection.
(5) Certificate of Compliance The NRC inspectors reviewed Material Review Request (MRR) 17053 and all associated documentation. MRR 17053 was initiated to document a deviation that occurred at CES during the machining process of the crankshaft bearing for critical class piston connecting rods I
utilized in safety-related application at the Palo Verde Nuclear
__a
ORGANIZATION: COOPER ENERGY SERVfCES GR0VE C1TY, PENNSYLVANIA REPORT INSPECTION Nn - QQQnn117/A7-01 RESULYS:
PAGE 8 of 12 Station. MRR 17053 was generated to iron plate the base material per CES Material Specification Procedure SE-89-2N. The NRC inspectors reviewed Material Specification Procedure SE-89-2N, Paragraph 3.1, which requires, in part, that vendors perfonning plating in accordance with SE-89-2N provide CES with a certificate of compliance. On the basis of the documentation reviewed, the NRC inspector could not determine that a certificate of compliance had been issued by Vander Horst Corporation to CES.
f Nonconformance itam (87-01-04) was identified in this area.
(6) Stress Relief Requirements The NRC inspectors reviewed MRR 10328 and all associated documenta-tion. MRR 10328 was initiated to document CES' upgrading of its commercial-grade piston connecting rods to a critical component that would permit use in safety-related applications.
In reviewing Detail Drawing MSV-4-2A, the inspectors found a drawing note (Note 7) that allowed production personnel to waive stress relief requirements for the connecting rod. However, the inspector was unable to determine whether or not production personnel had performed a stress relief process on the connecting rod.
In discussions with CES personnel, the inspector learned that Note 7 would be removed from the detail drawing and that the procedures would be revised to require documentation of the process performed.
Unresolved Item C.1 was identified in this area.
(7) Procurement The NRC inspectors examined CES procurement procedures to determine whether their implementation met the requirements of 10 CFR 21 and whether the applicable quality requirements were specified on the CES critical component purchase order forms. These requirements are to be imposed on subvendors supplying CES with manufacturing services or materials used in the manufacturing process.
The NRC inspectors noted that the procedures did not adequately specify that the requirements of 10 CFR 21 be applied to all critical / safety-related purchase orders.
In discussions with CES personnel, the inspectors was advised that the procedure would be revised to include 10 CFR 21 requirements.
Unresolved Item C.2 was identified in this area.
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ORGANIZATION: COOPER ENERGY SERVICES GROVE CITY, PENNSYLVANIA REPORT INSPECTION fJo - QQ Qnn*t17 / A7-01 RESULTS:
PAGE 9 of 12 (8) Starting Air Filter Bowl Failure On January 24, 1987, a standby diesel generator at Unit 1 of Houston I
Lighting & Power Company's South Texas Project failed to start. The engine was undergoing preoperational testing to establish that it could successfully perform a required series of 23 - consecutive starts when the failure to start occurred.
The licensee found that the cause of the failure to start was the loss of starting air, which was caused by both in-line air filter bowls falling off the filter.
In checking the starting air filters on the remaining two Unit I standby diesel generators, the licensee found that three of four valves were loose, (EachunitatSouth Texas Project has three standby diesel generators; each diesel generator has two redundant air start lines, with a filter in each line.)
Initial information received from the licensee indicated that the air filter bowls were supplied without an opt,ional C-clip to lock the bowl in place.
On checking with the subvendor who supplied the assembly (Norgren Filter Corporation), CES established that such a locking device is neither available, nor needed.
The filter is supplied with a deformable gasket (0-ring) made of either Buna-N or Viton. The 0-ring was found in place on the filter bowls. Thus, it is concluded that the air filter bowls were not properly tightened after installation and then engine vibration caused them to looien further.
(9) Rocker Arm Failurer Over the last 18 months, there have been 11 incidents of valve rocker arm failures of CES standby diesel generators at nuclear power plants. With one exception, Palo Verde, all rocker arms failed on engines at Commonwealth Edison plants.
The inspectors examined CES Laboratory Report #763, which details the analysis conducted by the CES staff metallurgist of the failed Palo Verde rocker arm.
In addition, the inspectors reviewed photographs of the failed part taken in the CES laboratory.
ORGANIZATI0f:: COOPER ENERGY SERVICES GROVE CITY, PENNSYLVANIA REPORT INSPECTION kn - coonn'<17 /p?_ n1 RESULTS-PAGE 10 of 17 The rocker arm failed in the summer of 1985.
It was cast by CES in accordance with Specification No. M-40N. Although the material composition did not meet the recommended chemical content, the mechanical properties are specified as dominant and were well exceeded. The tensile test bar machined from the broken casting had a tensile strength of 41,000 psi. The rocker arms require a tensile strength of approximately 3000 psi during normal service. Thus, the material strength of the rocker arm was fully satisfactory.
Visual examination of the rocker arm showed evidence of scuffing where the rounded top of the push rod seats into the underside of the rocker arm. Scuffing can occur if excessive clearance is set i
into the valve train during adjustment.
(The maximum clearance that can be absorbed by the hydraulic valve lifter is 0.125 inch; the value train is usually set with an initial mid-range gap of 0.000 to 0.070 inch.) Because gray cast iron does not absorb significant impact loads, failures caused by impact are typical and have occurred in the past when valve clearance was excessive.
As stated above, the remaining 10 rocker arm failures occurred at nuclear stations operated by Commonwealth Edison Company. The failures are evenly split between Byron and Braidwood Stations; j
the most recent failure that preceeded the inspection occurred j
at Braidwood Station on 143rch 29,1987.
Although the root cause of all failures is yet to be determined, the following is known as of this date:
a.
Both rocker arms (intake and exhaust) are found failed approximately 80% of the time.
b.
The crosshead (cam roller and follower assembly) also is found seized in approximately 50% of the rocker arm failures.
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c.
The presence and guidance of CES field service engineers
)
does not seem to affect rocker arm failures.
d.
Ninety percent of the failures have occurred on engines that had 100-200 hours accumulated run time.
(One engine had 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> accumulated.)
]
ORGANIZATION: COOPER ENERGV SERVICES GROVE C1TY, PENNSYLVANIA REPORT INSPECTION wn. QQonn117/97_n1 RESULTS:
PAGE 11 of 12 Technical information disseminated by CES has not affected the failure rate.
Initially, it was thought that the Valve Tappet Adjustment (Hydraulic Lifters) procedure found in the CES technical manual lacked sufficient detail. Upon review by the inspectors, it appears that the procedure is adequate for use by suitably trained, qualified and experienced maintenance personnel. A technical bulletin prepared and distributed by CES discussed required clearances to avoid crosshead seizures.
/
Past engine specifications required a 0.002 to 0.004-inch clearance between the crosshead body and the crosshead bushing.
Because seized crossheads were discovered concurrent with broken rocker anns, it was thought that a larger crosshead to bushing clearance might alleviate the seizures. Thus, CES increased the recommended clearance to 0.002 - 0.006 inch. This had no noticeable affect on broken rocker arms - with or without seized crossheads. CES is in the process of returning to the previous specification for crosshead bushing clearance.
As was noted for the Palo Verde Nuclear Station rocker arm failure, valve clearance in excess of the ability of the hydraulic lifter to l
absorb it will lead to impact failures of rocker arms. This is thought to be the cause of two rocker arm failures, both of which occurred at Byron Station; November 1985 and May 1986.
Investigations by CES and licensees continue. As stated above, the root cause of these failures is yet to be determined.
(10) Fuel Injection Line Fitting Failure On February 8,1987, engine 2A at Palo Verde Nuclear Station sustained some superficial damage as a result of a fuel oil fire caused when fuel injection line SR separated from its fuel injector while the engine was running.
The fuel injection line that separated had been purchased as a "made-up spare" from CES.
(Nonnally, the line and fittings between the fuel injection (" jerk") pump and fuel injector are made to fit
)
the engine either during manufacturing process or in the field.)
i Investigation by CES revealed that these newly available made up spares were not correctly assembled by CES.
In particular, the nut i
intended to set and crimp the internal pressure sealing ferrule was insufficiently tightened so that the ferrule did not set itself into the fuel injection tube. Since for field installation it can be t
ORGAN 1ZATION: COOPER ENERGY SERVICES GROVE CITY, PENNSYLVANIA REPORT INSPECTION wn. Qqonr117/A7-01 RESULTS:
PAGE 12 of 17 assumed that the ferrule is already set, the field torque specifica-tion is intended for making a secure mechanical connection only, not for setting the ferrule into the outer surface of the fuel injection tube. Thus, the fuel injection line pulled out during engine operation.
After all made-up spares that had been installed (20 on 6 engines) were removed at Palo Verde, they replaced them with fuel lines and d
fittings that were assembled using its own procedure and method to set the ferrule and ensures a satisfactory mechanical connection.
The key variable to be taken into account is fuel oil pressure (8,000 to 9,000 psig).
In addition, there are subtleties involving fuel line harmonic vibrations, clearances between the end of the fuel injection line and either the fuel injector or fuel injection pump body, and the construction detail of the nut that sets the ferrule and makes the mechanical connection.
In any case, the fitting should be capable of withstanding an internal fuel oil pressure of approximately 15,000 psig.
The inspector reviewed CES specification drawings of the nut (Drawing SF-312 issued February 1, 1940) and the ferrule (Drawing SF-338-5 issued in 1946), as well as the SAE thread standards that are based on the Weatherhead (tubing and fitting manufacturer)
ERMETO ferrule and nut.
In addition, it should be noted that Bendix Corporation also supplies nuts that are slightly different from the CES Weatherhead-based nut.
After a careful review by CES and the successful installation of approximately 31,000 fuel injection lines of this design since about 1940, it has been determined that the failure at Palo Verde was caused by the incorrect assembly of replacement fuel injection lines at CES. The past (and current) method of installing fuel injection lines on engines under production is unchanged. CES is satisfied that although field assembly of fuel injection lines can be problematic, there is no evidence of a fundamental design or procedural deficiency.
I 4-9 Cooper Energy Services July 8, 1987 cc w/ enclosures:.(continued)
Niagara Mohawk Power Corporation ATTN: Mr. B. J. Hooten.
Executive Director - Nuclear Operations 300 Erie Boulevard West Syracuse, New York 03202 Arizona Public Service Company ATTN: Mr. E. E. Van Brunt, Jr.
Executive President Arizona Nuclear Power Project P. O. Box 52034 Phoenix, Arizona 85072-2034 l
Houston Lighting & Power Company ATTN: Mr. J. H. Goldberg Group Vice President, Nuclear P. O. Box 1700 Houston, Texas 77001 DISTRIBUTION:
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(continued)
Niagara Mohawk Power Corporation ATTN: Mr. B. J. Hooten Executive Director _ Nuclear Operations 300 Erie Boulevard West Syracuse, New York 03202 Arizona Public Service Company ATTN: Mr. E. E. Van Brunt, Jr.
Executive President c
Arizona Nuclear Power Project P. O. Box 52034 Phoenix, Arizona 85072-2034 Houston Lighting & Power Company ATTN: Mr. J. H. Goldberg Group Vice President, Nuclear P. O. Box 1700 f!custon, Texas 77001 DISTRIBUTION:
IE:09 NRC PDR VPB Reading DRIS Reading JGPartlow BXGrimes LParker (2)
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