Information Notice 1992-39, Unplanned Return to Criticality During Reactor Shutdown: Difference between revisions
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| issue date = 05/13/1992 | | issue date = 05/13/1992 | ||
| title = Unplanned Return to Criticality During Reactor Shutdown | | title = Unplanned Return to Criticality During Reactor Shutdown | ||
| author name = Rossi C | | author name = Rossi C | ||
| author affiliation = NRC/NRR | | author affiliation = NRC/NRR | ||
| addressee name = | | addressee name = | ||
Revision as of 05:45, 14 July 2019
UNITED STATES NUCLEAR REGULATORY
COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555 May 13, 1992 NRC INFORMATION
NOTICE 92-39: UNPLANNED
RETURN TO CRITICALITY
DURING REACTOR SHUTDOWN
Addressees
All holders of operating
licenses or construction
permits for nuclear power reactors.
Purpose
The U.S. Nuclear Regulatory
Commission (NRC) is issuing this information
notice to alert addressees
to recent events involving
unplanned
returns to criticality
caused by the cooldown of the reactor coolant system during reactor shutdowns.
It is expected that recipients
will review the information
for applicability
to their facilities
and consider actions, as appropriate, to avoid similar problems.
However, suggestions
contained
in this information
notice are not NRC requirements;
therefore, no specific action or written response is required.Description
of Circumstances
The licensees
for the following
plants recently experienced
unplanned criticalities
during reactor shutdowns:
the Monticello
Nuclear Generating
Plant, the Big Rock Point Nuclear Plant, and the Grand Gulf Nuclear Station.Monticello
On June 6, 1991, an unplanned
criticality
occurred at the Monticello
Nuclear Generating
Plant during a reactor shutdown when an unanticipated
cooldown occurred in conjunction
with rod insertion.
The licensee initiated
this shutdown to repair a leaking safety-relief
valve shortly after the plant was returning
to power following
a refueling
outage.Since this shutdown occurred shortly after the cycle startup, the reactor did not generate sufficient
decay heat to produce the steam needed to supply the normal steam system loads and still maintain pressure in the reactor. As control rods were being inserted using notch insertion, the reactor coolant system pressure and temperature
began to decrease.
As long as the operator continued
to insert control rods, the reactor remained subcritical.
However, when the operator stopped inserting
control rods to review and evaluate plant conditions, the cooldown continued, adding sufficient
reactivity
to overcome the negative reactivity
from the insertion
of control rods and causing the reactor power to increase.
The reactor power continued
to 92050_*,, C j'A i / 1 ( / /CDQc
K)IN 92-39 May 13, 1992 increase until an intermediate-range
monitor (IRM) tripped on a high-high
flux setpoint, causing a reactor scram.Further details of the event may be found in Licensee Event Report 50-263/91-15 or NRC Inspection
Report 50-263/91-13.
Big Rock Point On November 30, 1991, an unplanned
criticality
occurred at the Big Rock Point Nuclear Plant during a reactor shutdown when a cooldown occurred in conjunction
with a rod insertion.
The event occurred during a scheduled
shutdown for a refueling
outage.After taking the main turbine off line and bringing the reactor to a subcritical
condition, the licensee delayed actions to continue inserting control rods while changing shifts. However, the reactor coolant system continued
to cool down because the normal steam system loads were removing heat. The cooldown added sufficient
reactivity
to eventually
overcome the effects of the control rods, and the reactor returned critical.
The operators noticed the condition
in approximately
2 minutes and took the appropriate
actions to return the reactor subcritical.
Further details of the event may be found in Licensee Event Report 50-155/91-OO9-orJNRC-Inspection-Report
50-155/91-25.
_ _ _Grand Gulf On December 30, 1991, an unplanned
criticality
occurred at the Grand Gulf Nuclear Station during a reactor shutdown when a cooldown occurred in conjunction
with a rod insertion.
The event occurred during a scheduled shutdown for a maintenance
outage to replace a recirculation
pump shaft. To minimize the release of plated-out
radioactive
material from the fuel cladding and channels to the reactor coolant system, a slow power reduction
and a slow cooldown were prescribed
for this shutdown.The slow power reduction
and the effects of an earlier outage minimized
reactor decay heat and xenon peaking. The operators
were driving rods into the core individually
because gang drive for the control rods was unavailable.
This made the reactivity
insertion
slower than normal. The operators
inserted rods to reduce flux to range 3 on the IRMs and stopped rod insertion
in order to perform a source range monitor surveillance.
Indicated
power reached IRM range 1. However, the reactor coolant system continued
to cool down because the normal steam system loads were removing heat. In order not to affect the source range monitor surveillance, the shift supervisor
elected to not insert control rods and alerted the operators
to the possibility
of a return to criticality
as the cooldown continued.
The reactivity
added by the cooldown eventually
overcame the effects of the control rods. The reactor returned to a critical condition, and reactor power increased
on a reactor period between 300 to 800 seconds. The operators, having been trained on a similar event at another BWR, were monitoring
the condition
and expected the power to increase to the point of adding heat, where the fuel and moderator
temperature
coeffi-cients would halt the reactor power increase.
As the power increased, the
IN 92-39 May 13, 1992 reactor operator ranged the IRMs to prevent a reactor scram. Power level remained on scale. The power increase was terminated
with the IRMs reading on range 7 and 8. The operators
completed
the source range monitor surveillance, then resumed inserting
rods and successfully
completed
the shutdown.Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
The experience
at Monticello, Big Rock Point, and Grand Gulf indicates
that shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control if inadvertent
recritica- lity is to be prevented.
These events emphasize
the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.
Further, accepting
recriticality
without prior management
approval and procedures, i.e., an ad-hoc approach, raises concerns due to the lack of opportunity
for contin-gency planning.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Va&res'E.Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices
z I-0.<OD n; co> 0 m Z.4-m rn o 0 0 z Z G2-cn a En z* om o) Z en q-n M 0n a 0 n a -h <-Attachment
1 IN 92-39 May 13, 1992 Page I of 1 LIST OF RECENTLY ISSUED NRC INFORMATION
NOTICES Date of Information
information
Notice No.92-38 1 92-37 92-16, Supp. 1 I 92-36' 92-35 Subject Implementation
Date for the Revision to the EPA Manual of Protective
Action Guides and Pro-tective Actions for Nuclear Incidents Implementation
of the Deliberate
Nisconduct
Rule Loss of Flow from the Re-sidual Heat Removal Pump during Refueling
Cavity Draindown Intersystem
LOCA Outside Containment
Higher Than Predicted
Ero-sion/Corrosion
in Unisol-able Reactor Coolant Pres-sure Boundary Piping Inside Containment
at A Boiling Water Reactor New Exposure Limits for Airborne Uranium and Thorium Increased
Instrument
Response Time When Pressure Dampening Devices are Installed Issuance 05/12/92 05/08/92 05/07/92 05/07/92 05/06/92 Issued to All holders of OLs or CPs for nuclear power reactors, non-power
reactors and materials
licensees
auth-orized to possess large quantities
of radioactive
material.All Nuclear Regulatory
Commission
Licensees.
All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.All holders of OLs or CPs for nuclear power reactors.-u 0 rn>mD-C > 0 u) D-D2 zzz>0 92-34 92-33 I CP -'05/06/92 All licensees
whose opera-tions can cause airborne concentrations
of uranium and thorium.04/30/92 All holders of OLs or CPs for nuclear power reactors.(Operating
License Construction
Permit
IN 92-39 May 13, 1992 reactor operator ranged the IRMs to prevent a reactor scram. Power level remained on scale. The power increase was terminated
with the IRMs reading on range 7 and 8. The operators
completed
the source range monitor surveillance, then resumed inserting
rods and successfully
completed
the shutdown.Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
The experience
at Monticello, Big Rock Point, and Grand Gulf indicates
that shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control if inadvertent
recritica- lity is to be prevented.
These events emphasize
the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.
Further, accepting
recriticality
without prior management
approval and procedures, i.e., an ad-hoc approach, raises concerns due to the lack of opportunity
for contin-gency planning.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager. Original Signed by Nhedes E, Rossi Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices*SEE PREVIOUS CONCURRENCE
OFC RIII ADR4-5:PD4-1 SC:DOEA:OEAB
ADM:RPB C:DST:SRXB
C:DOEA:OEAB
NAME GWright* PO'Connor*
RDennig* JMain* RJones* AChaffee*DATE 03/11/92 03/17/92 03/11/92 03/11/92 03/13/92 04/13/92 OFC C:DOEA:OGCB
D X, NAME CBerlinger*
DATE 04/21/92 05/ 7/92 DOCUMENT NAME: IN 92-39 IN 92-XX April xx, 1992 Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
The experience
at Big Rock Point, Grand Gulf, and Monticello
indicates
that shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control if inadvertent
recriticality
is to be prevented.
These events emphasize
the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.
Further, accepting
recriticality
without prior management
approval and procedures, i.e., an ad-hoc approach, raises concerns due to the lack of opportunity
for contin-gency planning.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices*SEE PREVIOUS CONCURRENCE
OFC RIII ADR4-5:PD4-1 SC:DOEA:OEAB
ADM:RPB C:DST:SRXB
C:DOEA:OEAB
NAME GWright* PO'Connor*
RDennig* JMain* RJones* AChaffee*DATE 03/11/92 03/17/92 03/11/92 03/11/92 03/13/92 04/13/92 OFC C:DOEA:OGCB
D:DOEA NAME CBerlinger*
CRoss tD DATE 04/21/92 /9 OFFICIAL RECORD COPY DOCUMENT NAME: IN DENKIG
IN 92-XX April xx, 1992 Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
Once a reactor has been placed in a subcritical
condition
during a plant shutdown, it is of primary importance
that the reactor be maintained
in that subcritical
condition.
Raising the range of the IRMs in the event of recriticality
can be inappropriate
if the licensed operators
do not have management's
oversight, training, and specific procedures
for this.The experience
at Grand Gulf and Monticello
indicate that slow shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control and require the operator and management
to give careful attention
to avoid recriticality.
The events at Monticello
and Big Rock Point also highlight the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices*SEE PREVIOUS CONCURRENCE
OFC RIII ADR4-5:PD4-1 SC:DOEA:OEAB
ADM:RPB C:DST:SRXB
C:DOEA:OEAB
NAME GWright* PO'Connor*
RDennig* JMain* RJones* AChaffee*DATE 03/11/92 03/17/92 03/11/92 03/11/92 03/13/92 04/13/92 OFC C:DO J f D:DOEA NAME CBerlinger
CRosswa'y DATE f/;11/9 2/ 92 OFFICIAL RECORD COPY DOCUMENT NAME: IN DENNIG
IN 92-XX March xx, 1992 Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
Once a reactor has been placed in a subcritical
condition
during a plant shutdown, it is of primary importance
that the reactor be maintained
in that subcritical
condition.
In the event of recriticality, promptly inserting
control rods and terminating
the cooldown are more conservative
actions than raising the range of the IRMs to prevent scram while waiting on the changing temperature
to reverse the direction
of the power. Raising the range of the IRMs in the event of recriticality
can be inappropriate
if the licensed operators
do not have management's
oversight, training, and specific procedures.
The experience
at Grand Gulf and Monticello
indicate that slow shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control and require the operator and management
to give careful attention
to avoid recriticality.
The events at Monticello
and Big Rock Point also highlight the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR IV t'/ ' f'(301) 504-1307 4.f, Attachment:
List of Recently Issued NRC Information
Notices*SEE PREVIOUS CONCURRENCEC
OFC RIII ADR4-5:PD4-1 SC:DOEA:OEAB
ADM:RPB C:DST:SRXB
C:D0EA:OEAB
NAME GWright* PO'Connor*
RDennig* JMain* RJones* AChaffee DATE 03/11/92 03/17/92 03/11/92 03/11/92 03/13/92 q1/t3/92 OFC C:DOEA:OGCB
D:DOEA NAME CBerlinger
CRossi DATE / /92 / /92 OFFICIAL RECORD COPY DOCUMENT NAME: IN DENNIG
IN 92-XX March xx, 1992 Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
Once a reactor has been placed in a subcritical
condition
during a plant shutdown, it is of primary importance
that the reactor be maintained
in that subcritical
condition.
In the event of recriticality, promptly inserting
control rods and terminating
the cooldown are more conservative
actions than raising the range of the IRMs to prevent scram while waiting on the changing temperature
to reverse the direction
of the power. Raising the range of the IRMs in the event of recriticality
can be inappropriate
if the licensed operators
do not have management's
oversight, training, and specific procedures.
The experience
at Grand Gulf and Monticello
indicate that slow shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control and require the operator and management
to give careful attention
to avoid recriticality.
The events at Monticello
and Big Rock Point also highlight the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, 'RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices*SEE PREVIOUS CONCURRENCE
OFC RIII ADR4-5:PD4-1 SC:DOEA:OEAB
ADM:RPB C:DST:SRXB
C:DOEA:OEAB
NAME GWright* PO'Connor (OK RDennig* JMain* RJones* AChaffee DATE 03/11/92 3 /17/92 Xis 192 03/11/92 03/13/92 / /92 OFC C:DOEA:OGCB
D:DOEA NAME CBerlinger
CRossi DATE / /92 / /92 IN 92-XX March xx, 1992 Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
Once a reactor has been placed in a subcritical
condition
during a plant shutdown, it is of primary importance
that the reactor be maintained
in that subcritical
condition.
Since recriti-cality has not been avoided, promptly inserting
control rods and terminating
the cooldown are more conservative
actions than raising the range of the IRMs to prevent scram while waiting on the changing temperature
to reverse the direction
of the power. Raising the range of the IRMs in the event of recriti-cality can be inappropriate
if the licensed operators
do not have management's
oversight, training, and specific procedures.
The experience
at Grand Gulf and Monticello
indicate that slow shutdowns
in situations
with low decay heat present a unique challenge
to reactivity
control and require the operator and management
to give careful attention
to avoid recriticality.
The events at Monticello
and Big Rock Point also highlight the importance
of the operator giving continuous
attention
to plant parameters
during a shutdown.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices*SEE PREVIOUS CONCURRENCE
OFC :RIII :S Oq;:EfAB:ADM:RPB
- C:D B :C:DOEA:OEAB
- C:DOEA:OGCB
- D:DOEA-____ _ _________----
_ --____________
_ -:---------------
NAME :GWright*
- Rbennig :JMain* j Jones :AChaffee
- CBerlinger
- CRossi DATE :03/11/92
- 3 /11/92 :03/11/92
- /13/92 : / /92 : / /92 : / /92 OFFICIAL RECORD COPY Document Name: IN DENNIG
Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
Once a reactor has been placed in a subcritical
condition, as part of a plant shutdown, it is of primary importance
that the reactor be maintained
in that subcritical
condition.
Given that recriticality
has not been avoided, prompt insertion
of control rods and termination
of the cooldown are more conservative
actions than upranging
IRMs to prevent scram while waiting on temperature
coefficients
to turn power.Upranging
IRMs in the event of recriticality
can be inappropriate
if management
oversight, prior training, and specific procedures
are absent.The experience
at Grand Gulf and Monticello
indicate that slow shutdowns
in situations
with low decay heat present a particular
challenge
to reactivity
control, and require heightened
operator and management
awareness
to avoid recriticality.
In addition, the events at Monticello
and Big Rock Point highlight
the importance
of continuous
operator attention
to plant parameters
in the course of a shutdown.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices OFC :RIII :SC:DOEA:OEAB:ADM:RPB
- C:DST:SRXB
- C:DOEA:OEAB
- C:DOEA:OGCB
- D:DOEA NAME :GWright :RDennig :JMain_ w :RJones :AChaffee
- CBerlinger
- CRossi DATE ://92 :1/92 :3/11 /92 :1/92 ://92 :1 /92 :/ /92 OFFICIAL RECORD COPY Document Name: IN DENNIG/DUP
IN 92-XX March xx, 1992 Further details of the event may be found in NRC Inspection
Report 50-416/92-04 and Licensee Event Report 50-416/91-16.
Discussion
The underlying
principle
of reactivity
management
is to maintain the reactor in the desired condition
by properly anticipating, controlling, and responding
to the plant's changing parameters.
Once a reactor has been placed in a subcritical
condition, as part of a plant shutdown, it is of primary importance
that the reactor be maintained
in that subcritical
condition.
Given that recriticality
has not been avoided, prompt insertion
of control rods and termination
of the cooldown are more conservative
actions than upranging IRMs to prevent scram while waiting on temperature
coefficients
to turn power.Upranging
IRMs in the event of recriticality
can be inappropriate
if management
oversight, prior training, and specific procedures
are absent.The experience
at Grand Gulf and Monticello
indicate that slow shutdowns
in situations
with low decay heat present a particular
challenge
to reactivity
control, and require heightened
operator and management
awareness
to avoid recriticality.
In addition, the events at Monticello
and Big Rock Point highlight
the importance
of continuous
operator attention
to plant parameters
in the course of a shutdown.This information
notice requires no specific action or written response.
If you have any questions
about the information
in this notice, please contact one of the technical
contacts listed below or the appropriate
Office of Nuclear Reactor Regulation (NRR) project manager.Charles E. Rossi, Director Division of Operational
Events Assessment
Office of Nuclear Reactor Regulation
Technical
contacts:
Melvyn Leach, RIII (708) 790-5559 Geoffrey Wright, RIII (708) 790-5695 Paul O'Connor, NRR (301) 504-1307 Attachment:
List of Recently Issued NRC Information
Notices OFC :R111 bC:DOEA:OEAB:ADM:RPB
- C:DST:SRXB
- C:DOEA:OEAB
- C:DOEA:OGCB
- D:DOEA NAME :GWrightV'
- RDennig :JMain :RJones :AChaffee
- CBerlinger
- CRossi DATE :3 /II/92 ://92 :/ /92 :/ /92 :/ /92 :/ /92 :/ /92 OFFICIAL RECORD COPY Document Name: IN DENNIG