ML20214B570

Forwards Trip Rept of 851210-12 Onsite Visit Re Fire Protection Review.Automatic Fire Suppression Should Be Provided or Justifications Submitted

ML20214B570
Person / Time
Site:	South Texas
Issue date:	02/10/1986
From:	Kadambi N Office of Nuclear Reactor Regulation
To:	Goldberg J HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8602200597
Download: ML20214B570 (17)

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$EB 10 R6 Docket Nos.: 50-498 and 50-499 Mr. J. H. Goldberg Group Vice President-Nuclear ,

Houston Lighting and Power Company P.O. Box 1700 Houston, TX 77001

SUBJECT:

TRIP REPORT OF STAFF AUDIT ON FIRE PROTECTION - DECEMBER 10,11

.AND 12, 1985 AT SOUTH TEXAS PROJECT The staff visited the South Texas Project at the houston, TX offices and at the site on the above dates in support of the Fire Protection review.

We observed the scale model of the Project in preparation for the site visit. We were provided plant drawings and indicating cable concentrations and automatic fire suppression locations. The results of our audit are described in Enclosure 1.

As shown in the trip report, the staff's guidelines indicate that automatic fire suppression should be provided in certain area which currently do not have it as part of the design, unless acceptable justification is provided. We look forward to working with your staff to resolve this issue.

Sincerely yours, N. Prasad Kadambi, Project Manager PWR Project Directorate #5 Division of PWR Licensing-A

Enclosure:

As stated cc: V. Noonan J. Milhoan

• See next page for previour concurrences PD#5 PSB:DPLA PKadambi* JMilhoan*

2/6/86 2/6/86 9602200597 860210' PDR ADOCK 05000498 F PDR

Docket Nos.: 50-493 and 50-493 Mr. J.H. Goldberg _

Group Vice President-Nuclear Houston Lighting and Power Company P.O. Box 1700 Houston, TX 77001

SUBJECT:

TRIP REPORT OF STAFF INSPECTION ON FIRE PROTECTION - DECEMBER 10, 11

-ANC 12, 1985 AT SOUTH TEXAS PROJECT The staff visited the South Texas Project at the Houston, TX offices and at the site on the above dates in support of the Fire Protection review. We ,

observed the scale model of the Project in preparation for the site visit. We were provided plant drawings indicating cable concentrations and automatic fire suppression locations. The results of our inspection are described in Enclosure 1.

As shown in the trip report, the staff's guidelines would require that.

automatic fire suppression be provided in certain areas which currently do not have it as part of the design, unless acceptable justification 'is made -

otherwise. We look forward to working with your staff to resolve this issue.

Sincerely yours, N. Prasad Kadambi, Project Manager PWR Project Directorate No. 5 Division of PWR Licensing-A

Enclosure:

As stated cc: V. Noonan Distribution:

J. Milhoan Docket or Central file NRC PDR Local PDR PD#5 Reading File M. Rushbrook P. Kadambi f\ <1 0FC :PM:PD#5  : SB BILA  :  :  :  :  : 4

_____:____________:. ..... ___:____ ...____:____________:____________:____________:_ ________ l NAME-:PKadambi:js :JM lhoan=  :  :  :  :  : I DATE:>/(g/86: :t/h/86  :  :  :  :  :

'0FFICIAL RECORD COPY

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",, UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION

. O E WASHINGTON, D. C. 20555 e

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RP 101946 Docket Nos.: 50-498 and 50-499 ,

Mr. J. H. Goldberg Group Vice President-Nuclear Houston Lighting and Power Compcny P.O. Box 1700 Houston, TX 77001

SUBJECT:

TRIP REPORT OF STAFF AUDIT 0N FIRE PROTECTION - DECEMBER 10,11 AND 12, 1985 AT SOUTH TEXAS PROJECT The staff visited the South Texas Proiect at the Houston, TX offices and at the site on the above. dates in support of the Fire Protection review.

We observed the scale model of the Pro.iect in preparation for the site visit. We were provided plant drawings and indicating cable concentrations and automatic fire suppression locations. The results of our audit are described in Enclosure-1.

As shown in the trip report, the staff's guidelines indicate that automatic fire suppression should be provided in certain area which currently do not have it as part of the design, unless acceptable justification is provided. We look forward to working with your staff to resolve this issue.

Sincerely yours, as a ca kW N. Prasad Kadambi, Project' Manager PWR Project Directorate #5 Division of PWR Licensing-A

Enclosure:

As stated cc: V. Noonan J. Milhoan )

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Mr. J. H. Goldberg' Houston Lighting and Power Company South Texas Project I

cc:

Brian Berwick, Esq. Pesident Inspector / South Texas -

Assistant Attorney General Project.

Environmental Protection Division c/o U.S. Nuclear Regulatory Comission P. O. Box 12548 P. O. Box'910 Capitol Station Bay City, Texas 77414 Austin, Texas 78711-Mr. Jonathan Davis Mr. J. T. Westermeir Assistant City Attorney Manager South Texas Project City of Austin Houston Lighting and Power Company P. O. Box 1088 P. O. Box 1700 Austin, Texas 78767 Houston, Texas 77001 Mr. H. L. Peterson Citizens Concerned About Nuclear Mr. G. Pokorny Power City of Austin 5106 Casa Oro P. O. Box 1088 San Antonio, Texas 78233 Austin, Texas 78767 Mr. Mark R. Wisenberg Mr. J. B. Poston Manager, Nuclear Licensing  ;

Mr. A. Von Rosenberg Houston Lighting and Fower Company l City Public Service Boad P. O. Box 1700 P. O. Box 1771 Houston, Texas 77001 San Antonio, Texas 78296 Mr. Charles Halligan Jack R. Newman, Esq. Mr. Burton L. Lex Newman & Holtzinger, P.C. Bechtel Corporation 1615 L Street, NW P. O. Box 2166 Washington, D.C. 20036 Houston, Texas 77001 Melbert Schwartz, Jr., Esq. Mr. E. R. Brooks Baker & Botts Mr. R. L. Range One Shell Plaza Central Power and Light Company  ;

Houston, Texas 77002 P. O. Box 2122 l Corpus Christi, Texas 78403  :

Mrs. Peggy Buchorn Executive Director Citizens for Equitable Utilities, Inc.  !

Route 1, Box 1684 1 Brazoria, Texas 77422 l

i Houston Lighting 1 Power Company- - South Texas Project l 1

. cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. Lanny Sinkin Christic Institute

. 1324 North Capitol Street Washington, D.C. 20002

. Mr. S. Head, Representative Houston Lighting and Power Company Suite 1309 7910 Woodmont Avenue Bethesda, Maryland 20814 .

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Enclosure 1 PWR-A Plant Systems Branch Trip Report South Texas Project, Units 1 and 2 Docket Nos.: 50-498/499

1.0 INTRODUCTION

General Design Criterion 3 (GDC 3), " Fire Protection," of Appendix A to -

10 CFR 50 requires, in part, that fire fighting systems of appropriate capacity and capability be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Appendix A to BTP APCSB 9.5-1 and Appendix R to 10 CFR 50 present criteria acceptable to the NRC staff for satisfying GDC 3. The guidelines of Section D.3.c of Appendix A to  ;

BTP APCSB 9.5-1 state that automatic water sprinkler systems should be provided for cable trays outside the cable spreading room.

In Section 4.2 of its Fire Hazards Analysis Report (FHAR), the applicant stated that sprinkler systems would not be installed in accordance with Section D.3.c of Appendix A to BTP APCSB 9.5.1. The applicant did not present technical jus-tification for this deviation from Appendix A to.BTP APCSB 9.5-1. Therefore, the staff's Fire Protection section of the Draft Safety Evaluation Report stated that the applicant should meet Section D.3.c of Appendix A to BTP APCSB 9.5-1 or provide justification for the deviation. The applicant pro-vided additional information by letters dated August 14, 1985, October.12, 1985, October 18, 1985, and October 31, 1985, as well as in meetings and discussions.

In July 1981, BTP CMEB 9.5-1 was issued and through this document the staff guidance for fire protection of cable trays outside the cable spreading room

was revited. Unlike Section D.3.c of Appendix A to BTP APCSB 9.5-1, which im-plies that automatic sprinklers should be provided for all cable trays-located outside the cable spreading room, Section C.5.e of BTP CMEB 9.5-1 states that automatic water suppression systems 'should be provided when more than six stan-dard 24 inch wide cable trays, or their equivalent, are located in a given fire area. The guidelines of BTP CMEB 9.5-1 are less stringent than those of Appendix A to BTP APCSB 9.5-1. The staff evaluation of cable concentrations has been done against Section C.S.e of BTP CMEB 9.5-1 instead of Section D.3.c of Appendix A to BTP APCSB 9.5-1. The applicant did not object to this.

The applicant has taken the position that (1) where cable trays are accessible for manual fire fighting, manual fire fighting capability alone (i.e., without automatic water suppression systems) is an adequate means of fire protection and (2) under their current design, safe shutdown capability is provided by three redundant safe shutdown trains. Following a cable fire in any given plant location that damages one of the three safe shutdown trains, the applicant contends that safe shutdown can be achieved using one of the two remaining redundant safe shutdown trains. (See Section 3.0 of this report for a discussion of safe and alternate shutdown capability.)

The staff has informed the applicant that justification is required fJr deviating from the guidelines of Section C.5.e of BTP CMEB 9.5-1.

Having three redundant trains of safe shutdown systems does not eliminate the attendant fire hazards associated with each train and, therefore, does not mini-mize the adverse effects of fires as required for conformance with GDC 3.

In addition to stating that automatic suppression systems should be provided for some cable concentrations, the guidelines also state that cables should be accessible for manual fire fighting. Therefore, as a general provision, accessibility for manual fire fighting is not suitable justification for not I providing automatic suppression systems. However, in certain fire zones, l based on the characteristics of the fire zone and responsiveness _of the fire brigade, it may be possible to technically justify not providing automatic suppression systems. The staff has reviewed such justification on a case-by-case basis.

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A site audit was conducted at South Texas Project, Unit 1 between December 10 and 12, 1985. The purpose of the audit was to review the electrical. cable configurations and concentrations throughout Unit I and determine which -

fire areas and/or zones should be protected by automatic fire suppression systems to meet the guidelines of Section C.S.e of BTP CMEB 9.5-1. In conjunction with the site visit, the staff also visited the Houston offices of the applicant where a scale model of the plant is located. Observations at the model aided the inspection 2.0 DISCUSSION Prior to the plant site audit, the applicant provided copies of drawings ,

from the FHAR color coded to identify the fire zones where cable concentrations exist in the plant. The drawings identified the fire zones where the applicant proposes to rely on manual fire fighting capabilities, and zones where automatic fire suppression systems will -be provided. During the site i

visit, each of these fire zones was toured.

The fire zones identified as having cable concentrations are listed in Table 2.1 below. With the exception of Fire Zone Z121, which was identified during the walk down, all of the fire zones listed in Table 2.1 were. identified by the ap -

plicant before the walkdown. 0f the fire zones listed in Table 2.1, the appli-cant proposes to install automatic fire suppression systems in the zones iden-

- tified in Table 2.2. These fire zones require no further discussion in this report and will be addressed, as appropriate, in the SER._

j The fire zones from Table 2.1 that do not need automatic fire suppression sys- _

tems to meet Section C.S.e of BTP CMEB-9.5-1 are listed in Table 2.3. The fire zones from Table 2.1 that should be provided with automatic fire suppression capability to meet Section C.5.e of BTP CMEB 9.5-1 are listed in Table 2.4.

Following the plant site. audit, the staff met with the applicant at

[ the offices in Houston (list of attendees enclosed as Enclosure 2)

to discuss the course of action to be taken to reach-a final-resolution j on fire protection for these locations. The staff stated that.'the fire .

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protection review would identify the: locations where staff fire protection guidelines would call for automatic fire suppression capability. To facilitate this effort, the fire zones identified as having cable concentrations are categorized as follows:

A- Fire zones to be provided with automatic fire suppression capability.

These fire zones are identified in Table 2.2.

B- Fire zones where application of staff fire protection guidelines would necessitate automatic fire suppression capability. These fire zones are identified in Table 2.4.

C- Fire zones where extenuating circumstances may allow for acceptable alter-natives to staff guidelines. Several of the fire zones listed in Table 2.4 fall into this category. For example, Fire Zones Z102, Z138, and Z139 are borderline cases. Based solely on the number of cable trays in these zones, automatic sprinkler systems should be installed to meet Section C.5.e of BTP CMEB 9.5-1. However, in view of the low percentage cable fill of the trays, it may be possible to justify a lack of sprinkler protection for these zones.

D- Fire zones where technical justification and past precedent may allow for acceptable alternatives to staff guidelines. Several of the fire zones listed in Table 2.4 also fall in this category. For example, an automatic suppression syst,em should be installed in Fire Zone 2058 to meet Sec-tion C.5.e of BTP CMEB 9.5-1. However, in view of the even distribution of cable trays in the zone and the lack of stacked cable trays, it may be possible to develop technical justification for not installing automatic sprinklers in the zone. Conversely, it may not be possible to develop a technical argument to justify the lack of a fire suppression system for

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some of the zones. A case in point is Fire Zone 2112; this zone is similar l

to zones 2010, Z026, Z018, 2047,'Z057, and Z060, which the applicant pro-l poses to equip with automatic fire st.ppression capability.

E- Fire zones that do not require automatic fire suppression capability to

, meet staff guidelines. These fire zones are listed ir. Table 2.3.

The applicant has taken the position that nuclear safety considerations should take precedence over fire protection, per se, and, therefore, the 3-train safe shutdown capability at STP justifies the use of manual fire fighting capability as a primary means for fire protection. They feel that widespread automatic fire suppression capability is not needed at STP.

In fact, automatic fire suppression capability has been provided only in the three cable spreading rooms and in those zones, regardless of cable concentration, that are judged to be inaccessible for manual fire fighting. These fire zones are listed in Table 2.2.

A two-pronged approach to resolving this matter was suggested. The staff will continue with the fire protection review to ascertain the extent of non-compliance with the fire protection guidelines in the present position of the applicant. The applicant will continue efforts to seek relief from the staff guidelines.

3.0 SAFE AND ALTERNATE SHUTDOWN CAPABILITY The staff's review of safe and alternate shutdown capability is not conplete.

However, the applicant stated in the FHAR that safe shutdown capability is pro-vided by three redundant safe shutdown trains (A, B and C) powered form indepen-dent Class IE power supplies. Where the system design contains less than three redundant trains, alternate or diverse pathways have been identified to ensure that the necessary functions to achieve safe shutdown are available during ar.d after any postulated fire. The applicant's stated design objective is to pro-vide two functionally redundant safe shutdown pathways'to allow the plant to be safely shutdown following a fire in any given location.

On the basis of this design objective, the applicant deviates from staff guide-lines requiring certain fire barriers and fire suppression systems. In addition, the applicant has identified (FHAR Table 2-1) 15 locations uhere the design objective has not been met.

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The three redundant trains will-be separated from one another by one of the alternatives set forth in Section III.G of Appendix R.f An alternate shutdown capability is provided for the Control Room by remote shutdown panels.

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The staff's review of safe and alternate shutdown capability and the associated deviations from staff guidelines will be addressed in a supplement to the SER.

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Table 2.1 Fire Zones Having Cable Concentations Fire Building

• Elevation Area Fire Zone DGB 25'-0" 36 2500 Diesel Generator No. 13 DGB 25'-0" 37 2501 Diesel Generator No. 12 OGB 25'-0" 38 2502 Diesel Generator No. 11 IVC 21'-2" 50 Z401 Platform IVC 21'-2" 49 Z402 Platform IVC 21'-2" 48 2403 Platform EAB 10'-0" 2 Z010 Power Cable Vault A EAB 10'-0" 68 Z011 Electrical Chase B EAB 10'-0" 74 Z012 Electrical Chase C

, EAB 10'-0" 2 2006 Electrical Penetration Area A EAB 10'-0" 71 Z007 Electrical Chase B EAB 10'-0" 69' 2008 Electrical Chase C EAB 10'-0" 2 2004 Siwtchgear Room A EAB 23'-0" 66 2025 HVAC and Electrical Area EAB 21'-0" 64 Z026 Cable Spreading Room A EAB 21'-0" 2 2027 Electrical Chase A EAB 41'-0" 70 Z023 B0P Electrical Chase EA3 60'-0" 70 Z068 Electrical Chase C EAB 41'-0" 73 2070 Electrical Chase B EAB 41'-0" 18 Z020 Electrical Chase A EAB 45'-0" 1 2034 Area Above Control. Room EAB 35'-0" 1 2032 Relay Room EAB 35'-0" 3 2031 Electrical Penetration B EAB 35'-0" 3 ZO42 Switchgear Room B EAB 48'-0" 33 2018 Cabling Area B-EAB 60'-0" 31 ZO47 Cable Spreading Room B EAB 74'-0" 65 Z057 Cable Spreading Room C EAB 60'-0" 4 Z046 Electrical Penetration C IAB 60'-0" 4 Z050 Corridor EAB 76'-0" 34 2060 Cabling Area C EAB 60'-0" 4 Z052 Switchgear Room C EAB 72'-0" 67 ZO58 Work Area MAB 60'-0" 21 Z122 HVAC Intake MAB 60'-0" 75 Z112 Cabling Area MAB 60'-0" 32 Z145 Personnel Access to Containment MAB 41'-0" 30 Z144 Foyer MAB 41'-0" 75 Z112 Electrical Chase C MAB 41'-0" 3 Z116 Nonradioactive Piping Penetration MAB 41'-0" 3 Z130 Office Services Area MAB 41'-0" 3 Z147 Health Physics Above Ceiling MAB 10'-0" 22 Z133 Pipe Penetration Area MAB 10'-0" 22 Z132 480V MCC-MAB 10'-0" 24 Z102 Corridor MAB 10'-0" 27 Z138 Corridor and HVAC Chase

Table 2.1 (Continued)

Fire Building

• Elevation Area Fire Zone MAB 10'-0" 27 Z139 CCW Pump and Chiller C-MAB 29'-0" 75 Z112 Electrical Chase C MAB 29'-0" 23 Z134 Electrical Chase MAB 29'-0" 20 Z129 Nonradioactive Pipe Chase MAB 29'-0" 2 Z111 Electrical Chase A MAB 29'-0" 3 Z143 Electrical Chase B MAB 29'-0" 27' 2109 Electrical Chase C MAB 60'-0" 32 Z121 Decontamination Area FHB 21'-11" 35 Z303 HVAC Equipment Area FHB 21'-11" 35 Z311 Cable Area FHB 21'-11" 35 2306 Electrical Chase FHB 21'-11" 35 Z307 Electrical Chase FHB 42'-6" 35 Z303 HVAC Equipment Area

• DGB = Diesel Generator Building IVC = Isolation Valve Cubicle EAB = Electrical Auxiliary Building MAB = Mechanical Auxiliary Building FHB = Fuel Handling Building a____-________-___-___--____--____:___-_--_-_-____-

Table 2.2 Fire Zones to be Provided With Automatic Fire Suppression Systems I

s Fire Building

• Elevation Area Fire Zone DGB 25'-0" 36 Z500 Diesel Generator No. 13 DGB 25'-0" s 37 2501 Diesel ' Generator No.12 DGB 25'-0" 38 Z502 Diesel Generator No. 11 EAB 10'-0" 2 Z010 Power Cable Vault A EAB 21'-0" 64 Z026 Cable Spreading Room A EAB 35'-0" 1 2032 Relay Room EAB 48'-0" 33 2018 Cabling Area B EAB 60'-0" 31 Z047 Cable Spreading Room B EAB 74'-0" 65 2057 Cable Spreading Room C EAB 76*-0" 34 2060 Cable Area C MAB 60'-0" 32 'Z145** Personnel Access to Containment MAB 41'-0" 3 Z130** Office Services Area MAB 41'-0" 3 Z147 Health Physics Above Ceiling MAB 10'-0" 22 Z133 Pipe Penetration Area

• DGB = Diesel Generator Building EAB = Electrical Auxiliary Building MAB = Mechanical Auxiliary Building

• • Partial coverage automatic fire suppression system to be provided .

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Table 2.3 Fire Zones That Do Not Require Automatic Fire Suppression Systems Fire Building

• Elevation Area Fire Zone IVC 21'-2" 50 Z401 Platform IVC 21'-2" 49 Z402 Platform IVC 21'-2" 48 I403 Platform EAB 10'-0" 68 Z011 Electrical Chase B EAB 10'-0" 74 2012 Electrical Chase C EAB 10'-0" 71 2007 Electrical Chase B EAB 10'-0" 69 Z008 Electrical Chase C EAB 23'-0" 66 Z025 HVAC and Electrical Area EAB 41'-0" 70 Z023 B0P Electrical Chase EAB 60'-0" 70 Z068 Electrical Chase C EAB 41'-0" 73 Z070 Electrical Chase B EAB 41'-0" 18 Z020 Electrical Chase A EAB 45'-0" 1 Z034** Area Above Control Room EAB 35'-0" 3 Z031 Electrical Penetration B EAB 60'-0" 4 Z050 Corridor MAB 10'-0" 22 Z132 480V MCC MAB 29'-0" 20 Z129 Nonradioactive Pipe Chase MAB 29'-0" 2 Z111 Electrical Chase A MAB 29'-0" 3 Z143 Electrical Chase B MAB 29'-0" 27 Z109 Electrical Chase C FHB 21'-11" 35 Z303 HVAC Equipment Area FHB 21'-11" 35 Z311 Cable Area FHB 21'-11" 35 Z306 Electrical Chase FHB 21'-11" 35 Z307 Electrical Chase FHB 42'-6" 35 Z303 HVAC Equipment Area

• IVC = Isolation Valve Cubicle EAB = Electrical Auxiliary Building MAB = Mechanical Auxiliary Building FHB = Fuel Handling Building l

• • The applicant has identified a deviation from Section F.2 of Appendix A to BTP APLSB in this fire zone. This deviation will be addressed in the SER.

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Table 2.4 Additional Fire Zones That Should Have Automatic Fire Suppression Systems to Meet The Guidelines of BTP CMEB 9.5-1 Fire Building

• Elevat, ion Area Fire Zone EAB 10'-0" 2 Z006 Electrical Penetration Area A EAB 10'-0" 71 Z007 Electrical Chase B EAB 10'-0" 69 2008 Electrical Chase C EAB 10'-0" 2 Z004 Switchgear Room A EAB 23'-0" 66 Z025 HVAC and Electrical Area EAB 21'-0" 2 Z027 Electrical Chase A EAB 35'-0" 3 ZO31 Electrical Penetration B EAB 35'-0" 3 Z042 Switchgear Room B .

EAB 60'-0" 4 Z046 Electrical Penetration C EAB 60'-0" 4 Z050 Corridor EAB 60'-0" 4 2052 Switchgear. Room C EAB 72'-0" 67 Z058 Work Area MAB 60'-0" 21 Z122 HVAC Intake MAB 60'-0" 75 Z112 Cabling Area MAB 60'-0" 32 Z145 Personnel Access to Containment MAB 41'-0" 30 Z144 Foyer MAB 41'-0" 75 Z112 Electrical Chase C MAB 41'-0" 3 Z116 Nonradioactive Piping Penetration MAB 10'-0" 24 Z102 Corridor MAB 10'-0" . 27 Z138 Corridor and HVAC Chase MAB 10'-0" 27 Z139 CCW Pump and Chiller C MAB 29'-0" 75 Z112 Electrical Chase C MTB 29'-0" 23 Z134 -Electrical. Chase MAB 29'-0" 20 Z129 Nonradioactive Pipe Chase MAB 29'-0" 2 Z111 Electrical Chase A MAB 29'-0" 3 Z143 Electrical Chase B MAB 60'-0" 32 Z121 Decontamination Area

• EAB = Electrical Auxiliary Building MAB = Mechanical Auxiliary Building O

Enclosure 2 NRC Exit Attendees December 12, 1985 NAME ORGANIZATION Charles Ayala HL&P Licensing Michael E. Powell HL&P Licensing Wayne Harrison HL&P Engineering Carl M. Turner liL&P Engineering Joseph C. LaVallee HL&P Engineering Glenn D. Ma.nasco HL&P Engineering Bruce D. Moreton BEC Engineering Carl D. Wren HL&P NP0D Erroll W. Dotson HL&P Engineering Wayne Varnell BEC Engineering Jack Bailey .HL&P Engineering Ken Scown Impell Corp.

NRC Participants '

Steven West USNRC/PWRA/PSB Jim Shapaker USNRC/PWRA/PSB N. P. Kadambi USNRC/PD#5 w g -y , .w% c 9