ML20235A425
ML20235A425 | |
Person / Time | |
---|---|
Site: | Byron, Braidwood, Comanche Peak |
Issue date: | 11/23/1982 |
From: | Fitzgerald J, Fortuna R, Herr R NRC OFFICE OF INVESTIGATIONS (OI) |
To: | |
Shared Package | |
ML20235A207 | List:
|
References | |
FOIA-86-133 4-82-012, 4-82-12, NUDOCS 8707080433 | |
Download: ML20235A425 (16) | |
Text
}, e' c , m . UNITED ST ATES ,7 ,
y .* ,
- ', NUC. . AR REGULATORY COMMISSION v '
b REGION IV k,
- ef 611 RYAN PLAZA DRIVE, SUITE 1000 ARLINGTON, TEX AS 76011
'y- .
OFFICE OF INVESTIGATIONS DATE: November 23, 1982 REPORT OF INVESTIGATION TITLE: Comanche Peak Steam Electric Station Alleged Electrical Deficiencies SUPPLEMENTAL: DN 50-445/50-446 CASE NUMBER: 4-82-012 CONTROL OFFICE: ' REGION IV STATUS: CLOSED PERIOD OF INVESTIGATION: August 4 - September 17, 1982 REPORTING INVESTIGATOR: / [&
Richa~rd'K. HeYr,' Acting Director 01 Field Office, Region IV PARTICIPATING PERSONNEL: Lawrence E. Martin, Reactor Inspector Reactor Project, Section B, Region.IV i
William D. Kelley, Senior Resident Reactor Inspector Reactor Project, Section A, Region IV
( r REVIEWED BY: Nf- '
tub- --
Rober/A. Fortuna, Acting Deputy Director j Office of Investigations APPROVED BY: //w Mf, -
_hesis A. FitzgeraldY Acti.ng Di. rector jfficeofInvestigations ,
l 87070B0433 870701 hDEB 33 PDR , ,j
]
SUMMARY
Investigation of alleged electrical deficiencies that occured from August,1979 to January,1980 in the constructior, phase of the Comanche Peak Nuclear Power Plant at Glen Rose, Texas, included an interview of the contractor's ,
electrical Superinterdent, the review of numerous electrical records, and the !
inspection by NRC personnel of identified alleged electrical " deficiencies."
Investigation disclosed that three of the four basic alleged " deficiencies" were in the areas of non-safety wiring. During August and September,1982 all alleged ...
i deficiencies were examined and no irregularities were found. Review of noncon-formance report records did identify similar deficiencies discovered in the December 1979 through January / February 1980 time frame; however, these deficien-cies were properly addressed in 1980.
t i
i
& /
a yp ,j"///,o
'% Q .g, eky- ,q$h
(,'y 4 IMAGE EVALUATION /jp/
i . {% V,
/ f(8 s /o[// TEST TARGET (MT-3)
/ 8 f 4 ff >
g>
~
xy,
+ '*p 1 l
l 1.0 l E" Rd
\;lQ\\\\l?1 i.i l "' lilllE I l.8 l.25 l4 1.6
==
150mm ,
4- 6" >
A 4
>y
.g?O 4
%sfL $afxx-A
- ' o>p,ffffy <%.y .
Q?*
O O JN )}@$f IMAGE EVALUATION ////p I$g,
//o///s[<% %N#
k/' TEST TARGET (MT-3) g[)#fe 4(gf N%?/$59 /& /
1 l.0 2W M g: su
, L" Igpu l,l
- bb
?
l.25 1.4 1.6 4 150mm >
4 6" >
[%,, f4 4;;34[4%
- >f7#ffff
% //// ; .
9v
f.
il gP
/,
f
'4, g 4Q% IMAGE EVALUATION ,e%
yyy 'c $$* TEST TARGET (MT-3) [//k/ /# </[ eg p,4A Q l.0 l0 F " U!
- t '>
,7 g m
gme i,i tr ni l[ll.=2R =
ll 1.8
\ \--
I.25 1.4 1.6 i-- . i==
- 150mm >
- 6" >
h b Wp 4%
,Ay ,x/// ,$4f;;4y o\xNN p ge
. , . 1
.N l
I, T
I l
r I
1
.ee 1 l
}
I i
l i
l i
i 1
DETAILS k
l
- s 1
Purpose of Investigatio_n_
The purpose of this investigation was to investigate allegations of electrical
" deficiencies" during the 1979/1980 construction phase of the Coman.he Peak Steam Electric Station, Glen Rose, Texas.
+
i l
l 1
l l
i i
I my s
p l
2 i Background On August 4, 1982, Mrs. Juanita Ellis, President, Citizens Association for Sound Energy (CASE), met with NRC Investigator R. K. Herr at the NRC offices in Arlington, Texas. Mrs. Ellis provided reporting investigator a copy of a sta xecuted on June 14, 1982 b Chandler. Attachment j l
Mrs. Ellis explained that Chandler worked at the Comanc e Pea !
cons 1uc on site in the Electrical Departmen l Mrs. Ellis remarked that Chandler alle d " electrical fau ts of '"
construction" at the Comanche Peak site located in Glen Rose, Texas.
I rf /
1 B}
l l
I I
, a 4
1 i
l I
I I
1 '
l I
m -
3 Interview of CHARLES BRETT On August 31, 1982, Charles Brett, Superintendent of the Electrical Department, Brown and Root, contractors for Comanche Peak construction, was interviewed by NRC Investigator R. K. Herr et the construction site located in Glen Rose, Texas. Brett explained that he was present during the 1979 time frame, and in December 1979, the electrical department c-eated a " termination crew." Brett stated that this crew would check out all glectrical (safety and non-safety) wiring to ensure that work had been accomplished and that the work was done satisfactorily. Brett remarked that the men assigned to the work crews would submit handwritten reports to show what work was done, where the work was done, and the status of the work. Brett emphasized that this crew checked the .-. ;
electrical wiring before the Quality Control Inspectors were advised that the electrical wiring was ready for inspection. Brett explained that the termin- !
ation crew conducted a preinspection review of all electrical work. Brett l also pointed out that, if a deficiency was noticed and reported, the deficiency would be addressed before the Quality Control Inspector would conduct his inspection. Brett explained that this extra " check out" by the electrical ;
personnel was used as a management tool to show the electrician where problems )
arose and to point out various potential deficiencies. Brett stated that the l Quality Control Inspector could still find various deficiencies, and that >
the practice of utilizing " termination crews" to check the electrical wiring is no longer being used. Brett remarked that " termination crews" were not a l requirement in the Brown and Root procedure or instructions, but were merely ;
an extra check for the electrical department itself, and therefore, none of the handwritten reports or status sheets were kept. I l
~
r.
4 The Review of Michael Chandler's Daily Time _ Sheet On August 31, 1982, a review of Michael Chandler's Daily Time Sheet, under his assumed working name of Michael G. Maxfield, by NRC Investigator R. K. Herr at the Comanche Peak construction site, Glen Rose, Texas was accomplished. This review disclosed that Chandler worked for Brown and Root (contractors) from August 21, 1979 to January 11, 1980. The records further disclosed that from August 21, 1979 to January 1, 1980, Chandler worked on non-safety related wiring.
According to the records, Chandler worked for the " termination crew" from January 3 to January 11, 1980.
I a
e = esw - e
o e " 1 k 5 i
Interview of MICHAEL CHANDLER I
On September 2,1982, Michael Chandler, a former electrician employed at the l j Comanche Peak construction project, Glen Rose, Texas, s interviewed by NRC Investicator R. K. Herr n RC nspector L. E. Martin im Chandler executed a igned sworn statement, 1
Attachment (2), wherein e loentified four areas of alleged " deficiencies" and drew a map depicting the exact location of these deficiencies. Chandler further described these deficiencies as follows:
(1) Motor control center located in the circulation water system:
use of 1000 MCM cable, using 750 MCM lug that was drilled to "
accept larger cable.
(2) Auxiliary Building, Reactor No.1: lug designed for an approximate screw size of 3/8 inch was used on a terminal block designed for #10 screws. ,
i (3) Switch Gear Room, Reactor No. 1, black cable: lug designed for inch screws were used on terminal blocks designed for #10 screws.
(4) Annunciator logic panels, Control Room, Reactor No.1, black cable: improper cable splicing and wiring to the wrong l side of lugs.
Chandler's other general allegations of deficiencies identified in his previous j
statement of June 14, 1982, were addressed in the following manner. Chandler expressed concern with the improper installation and check-out of Cannon type plugs. Chandler was provided NRC Inspection Report 50-445/80-13, dated !
May 21, 1980. Chandler stated that after reading the NRC Inspection Report, the report answered all his concerns in this area. Mr. Chandler had also expressed concern regarding the patching / repairing of damaged cable, faulty grounding, and wiring not protected from abrasions. Chandler was provided eight nonconformance reports covering the above general allegations that were issued from December 20, 1979 to March 18, 1980 and subsequently corrected.
Chandler, after reviewing the nonconformance reports, stated that the deficiencies identified in the nonconformance reports and subsequent corrections appeatd to address the concerns that he identified in his previous statement of June 14, 1982.
Chandler explained that he was not in a position to determine 1 n. concerns were addressed proper y, pointing out that he did not have access to the nonconformance reports or NRC inspection reports. Further, Chandler remarked that most of his work was with non-safety ca ble. However, he stated that between January 2 and January 11, 1980 he was l
assigned to the Electrical Department " termination check-out crew" that went around to ensure that all work was done properly, and that some of the items he checked could have been safety related.
0 l
(,,1 I
Chandler stated that he was unaware of QA/QC activities or procedures that took place subsequent to the check-out crew activities on all safey-related activities. Chandler also expressed concern that when cad-welding was done. -
welders only protected an area of about 3 feet; however, Chandler had not -
inspected any of these to determine if any cables had been damaged and could not identify any specific areas for follow-up by NRC.
i 1
1 I
I i
7 P s:ection of Alleged Deficiencies Cn August 31, 1982, Dennis L. Kelley, NRC Senior Resident Reactor Inspector (5R:), assigned to Comanche peak, Glen Rose, Texas, met with NRC Investigator R. K. Herr to review the allegations set forth by Michael Chandler.
Allegation Number 1: Kelley was able to physically locate the motor control center (MCC) located in the circulating water system, as described in the allegation concerning the use of 1000 MCM cable with a 750 MCM lug. Kelley stated that he inspected the area in question and found no 1000 MCM cable in the motor control center. Kelley reported that he did find one 750 MCM cable '"
in MCC XB3-2 that is matched up to the proper lugs. He also found that the MCC 183-2 contained paired 350 MCM cables properly terminated. Kelley remarked 1 that as of August 31, 1982, no improper wiring was evident in the MCC's of the circulating water system.
On September 17, 1982, Kelley advised that the areas of the alleged deficiencies that were identified by Michael Chandler in his statement of September 2,1982 (see below), were located with the assistance of the maps drawn by Chandler.
Allegation Number 2, Auxiliary Building, Reactor No.1, improper screw size for lugs: Kelley stated that he physically located this area utilizing Map No.1, and found that there were no washer / screws in panel 5 or 6. However, he did discover a number of screws with attached washers. Kelley explained that upon close examination he found that the washer attached to-the screws is an intricate part of the screw (manufactured together) and i,tiot an add-on as it may appear at first glance. Kelley stated that some sdrews contained brass plate and some contained chrome plate. Kelley remarked that the chrome plate gives the appearance of a steel washer and could easily be mistaken for steel. Kelley concluded that as of September 1982, there was no improper I wiring in this area. ,
Allegation Number 3, Swith Gear Room, Reactor No. 1, improper screw size for lugs: Kelley stated he physically located this area utilizing Map No. 2 and found that the same conditions existed as per Allegation No. 2, above. Kelley added that as of September 1982, when he inspected Switch Gear Room, Reactor No.1, no improper wiring was observed.
Allegation Number 4, Control Room, Reactor No.1, splicing and cable termina-tion to wrong side of fuse block with some shaving of the lugs: Kelley stated he physically located this area, using Map No. 3, and found no evidence of shaving or erroneous termination of cable. Kelley further stated that he checked the section in question as well two other sections in the control panel and found that there was no evidence of lugs being shaved and added that blocks were of such a nature that it makes no difference which side accepts power leads.
Kelley remarked that there were three blocks located in this area at the time of his examination. He did not find any improper wiring. Kelley confirmed Chandler's statement that the wiring in this area is black cable wiring, and is non-safety.
I i
l
8 Kelley stated that during his inspection effort, he also examined safety and non-safety cable in the location of Chandler's concern, utilizing Map No. 4, 1 to determine if any cables were pulled too tight. Kelley explained that the cables are tied off with tie wraps and anchored with adhesive clips to hold wires down and stated he found adequate slack in these cables. Kelley pointed out that these conditions are in existence at the present time. However, he i could not comment on the conditions as they existed in January 1980.
i I
i
\
l l
. 1 S
9 Status of Investigation The status of this investigation is CLOSED.
I re *--
10 Attachments -
Attachment 1 - Chandler's signed statement 6-14-82 COPY ALL Attachment 2 - Chandler's signed sworn statement 9 06-82 ORIG 01:RIV/CY ALL f
l 1
i l
1 1
l l
l S'iiTMr'NT OF MICHAEL CHAFiLD' g My narse in Michael Chandler, b;ister So, 03030-06L Prior to I was working at the Comanche Peak cac ser r plant construction ite the name of Michaal Gale Maxfield identification number T-797 ould obtain employment at the s to caase questions to us as aoout air security measures, sapecially when it was learned that my job gave me access to all areas of the construction job, even the most confidential.
I can personally attest to and will be supported by docu:nented reoards ~
of sovsral faalts in the electrical phase of construction at Comanche Peak as of January 11, 1980. Having been amployed as a journey::an electrician by
! Brova & Root, Inc. during the latter part of 1979 until January 11, 1980 at ,
Comanche Peak, I worked in the electrical " termination creva doing the actaal phyrical termination of the wiring anc later on the "checkoat crew *. l This latter crew checks the wiring done by the ternination crew as to ascaracy and peeper termination technique. I uas requireC to turn in a written and signed report on each cable checked by me. So'ne, if not all or these faults can be vertried and located through these reports. S hese faults incluce improper lug sizing and actual physical alteration of lugs, splicing of cable, patching of damageo cables, i;nproper pin setting on " canon
- type plugs, f aulty grounding, vi. ring not properly protected-from abrasion, wire tensian tce high, and imprcper protection of cables ciuring ther:nal welding.
Lude are a wiring device that attach to the enas of wires or cables as an aid to termination and cone in a variety or styles and sizes. The
- ring j typeaused at Ccuanche Peak has a hole in its tongue to accept screws from terminal blocks. These holes can be of vary-ing eize dependent upon what diameter or stud site ecrew the ter:ninal block is engineered for. A stad .
size six is p=mMer in dia:neter in both the threaded portioc and the head of I the screw than a stud size 8 or 10. The lu;s for these, in order to fit the siifferent terminal blockr. and screw size ano at ti.e .-ame time maintain the i amperage caoacity they are rated for, are manufactured with a different shaped tongua. For example, #12 copper wire has an ampera;e rating of 20 supo, and i a lug designed to accept the vire must have the same or larger ampacity. The ,
rating of the wire is deterrined by the diameter of the copper conductor. The j rating of a lug is determined by the size and shape of the tongua. It must I have a specific area of its s'u rface in cont.act with the terminal block or its ampacity vill be leesened. A lug ..-ith its tongue designed for a kl0 acrerv has a hole in its tongue that is larger than tne hole in one designed for a #6 or 78 screw. The tongue is also wider and thinner. If a lug designed for a #10 s screw is used on a terminal block designed for use with #8 acrews, its ampacity is lessened because a $6 screw having a smaller head size only applies pressure to the inner ring of the lug tongue causin; a " belling" effect. It sanses Se outer edges of the tongue to curl outward, also less area under the serow head is in contact with the ternhal bwck because of its larger hole. There are ,
many instames where this us happened at Comanche Peak. Scae of these ares
- 1. Awnbry Building Reactor #1---Lag desi@ed for an appearimate screv sise .
l of J/8" was used on a terninal block assigned for 410 acrews. Thiar was dase with the aid of a steel washer with at the use of contact aid to provost trolysis between the two dissimilar metals.
g NI U
gren. O) i .
U .
- t. Switchcoar Ro<m.. Several lu4:s designed for 1/4" scrows were used co f terminal blooks daaigned for fit screws.
r
\ Thsse two instances stsnd out in my mino but there are many more is particalar cancerning the circulating water system and fire control; however wi%out re.forance maiorials I cannot be more epocific. However, there is at least cae lastamoe I can reen11--in f act for which I an at least partially responsible. This is the termination of a 1000 NCM embla with h use of a 75c MCM lug that was orilleo to accept the larger omble rise. It was done after protest by both siyself and Lennis Neaves, another Drilling W lag '
journeyman working as sty partaar on the terimination crew.one, it reduced the amountI affected its anpacity la two manners:
t.o candset electricity and it was a bolt type mechanical lag, - ning that ---
the lug was secured to the cabis by means of a bolt or est screw in its bo47 Drilling the lug body had the effect of lessening the number of threads to in This was not more than Erse or four for the set screw to be screwed into. -
a Noter 00atrol Center'in the Circulating Water system. Any fa % in the ;
ciresimu ng v ter system which provides coolant water for the reactor could
- posaihly casse very serious problems.At least cae cable in the Annunciator Logie room for Roaster (1 was spliced in the annunciator panel itself and covered over with other wires te hide it from sight. The cable was too large (it was assumed) to terminate on W fuse block to wich it was danignated.
Upos exassiastion of the fuse block 1 found the cable terminated to the wrong side er it. Had it been terminated on the correct a e the or1 '
sable would have fit. The splice was made on the orders a or pane 2A W General Forsmam over termination. also in the Annunc were several ' Canon
- type pisgs in which the pins were not seated proper.!y. ,
i his can eause the connector pins to be puehoc backThe intoAnnunciator the booy ofLogie the plug causing W pin or pins to have poor contact.
Panels give the alarm if any part of the system n.alfunctions. Any malfumeties in the annunctatar systes can cause no alarm.to be given in any amargency to which the plant may be subject.
Portions of the grounding eyeten for the cable trays im the Spreader Roes were damaged either by an suployee collecting copper or deliberate ,
vamti=14 = . Strands were cut from the cables in several places. h conductors -
were never cut entirely in two but the removal of a strand of no matter what length reduceu the capacity of the condactor.
In the Control Center f or Reactor al literally hundreds and possibly thwsande of wires were brought out of their metal racway ano pulled sharply over their sharp, unprotected eagee, naking them particularly vulnerable to abrasise and vibration. Every portion of every system in W plant could be . adversely affected by this faulty procedure. '
At laast one cable in the Switebgear Room was damaged while being pulled. Its insulation was nicked in several places and patched with heat shrink tubing instead of being replaced.
' In at least two instasoes wires or caules were too short by only a ,,
j matter of inchas for proper termination. These were pulled very tightly l sad terminated. They were palled tight enough that there is the possibility of W ir being pulled from their lu,,s. Due of these is in the Spreader Roca; amether is in a Motor Control Cenkt in ti.e Circulating Water System.
I
/
$/y-
U .
O l
} "Cac welding" or ther.aal el.in of t.:.e ,;rcundin, c ar uc tore on t.he cable trays was done after many cables hac alreacy Dev . ;miled scrougn them. I coula not inspect for cam;;e, out the only protection -
ned on tha cables was en asbestoc blanket that ,arotected only t!.e c2cles in tne irriediate vicinity or the .. eld.
I am necessarily vagae on whien carticalor caLinet or panel or even system to which I refer due to tifoo alt.p.:sd anu the large tinber of systans on which I worken. dith reforeace materials the location of these faulte could oe raaen .nore closely identified as could others not mentionoa specifically herein. --
Signed this /4 O day of Jano 1902 at
,- i t .
f' . .- ')f
- WbWh/ ~
- !; g/d-rfr.' :
a$chas1 Chandler I
= = .
0 0O l
\
)
l i
I t I
)
I 1
1 l!
i
. l j
1 I l
o_ ,; m - ,
[
I.~ Mi[naelChandler _ , mereoy ma(e ne f;il: wing vol ar. ary I:a ement u herr, wnc nas 1cen:1flec nimself to te as an .nves:1cator a1:n :ne U. 5.
to Mr. R.
! luclear Eecula:Ory C: mission. : maKe :nis ita amen: " eely 4 :n no :nrea:s Or :r:mises Of j -ewart naving been mace to Te. - i I worked at the Comanche Peak Construction site for Brown & Root as an elec-trician from August 21, 1979 to January 11, 1980. I worked about 3 months on the termination crews and f rom January 2, 1980 to January 11, 1980 I l worked on the termination check out crew.
On June 14, 1982,I prepared a statement covering areas of concern that I had with various practices that the electrical department was doing. I prepared my statement upon the reauest of a friend of mine who ask me if I had any problems or concerns with the elec rical epartm t, and told me that these concerns would be made known through the upcoming #yi l
hearings on the Glen Rose Comanche Peak Nuclear Power site at Ft. Worthj7Eggf f Mr. Herr and Mr. L. Martin of the NRC have gone over with me the concerns that I mentioned in my statement.
I would like to point out that most of my concerns deal with Black Cable that is non-safety.
$GC In my June 14, 1983, statement I mentioned signed reports that could identi-fy faults. These reports that I refer to are cable termination cards and cable pull cards. These cards have sign off blocks for the craft, their i supervisor and O. C., also k there is an area for comments. Any comment that l I may have made on these cards would have to be addressed by O. C. and/or corrected before Q. C. sign off, however, I was not present to observe all of the corrective action. To the best of my knowledge I documented all of my concerns on the above cards. However, most of my work was in non-safety related areas.
I have drawn a map of the Auxiliary Building Reactor #1 and located the area of my concern. This area or control panel has both safety and non-safety wiring. Mr. Herr stated he would contact me later and report the results of the NRC inspection in this area.
I have also drawn a map of the Switchroom area and have located my concern in Reactor Building #1, Grould Level, just left to the door entrance. I worked with black cable and I recall that Black Cable is non-safety related.
I have also drawn a map of the Annunciator Logic Panels, in the control room, Reactor #1 and have located my area of concern. I worked with Black cable and I understand that this area is also non-safety related.
' /nc c Mr. Herr and Mr. Martin discussed my area of concern in the MantxMotor Con-trol Center in the Circulating Water System. In my statement I said that 1000MCM cable was present in the Motor Control Center, however, upon re-thinkin this could have been 750 mcm. I am not sure. Mr. Kerr told me as of August 30, 1982, this area was inspected by the NRC and the lugs and wire were found to be correct. Apparently my concerns were identified and
,arres corrected after I left in January 1980.
My concerns with improper installation and checkout of cannon type plugs a Pagei of A Pages h 1
/Wdif. (
- l. subsecuentl. identified by e 3
. ~: docur.ented in SRC .spection report 5f-445/80-13 that I have read : .ay ( S e r. t e m b e r 2, 1987; and addressed to my satisfactions.
As to the rest of my concerns regarding damace, cable by sharp edges, and/or other means, Mr. Herr has shown me a number of Non-Conformance Reports (NCR) that address these concerns. Most of these NCR were discovered and corrected after I left the site.
My concern about the repair / patch of cable damage have been addressed by a procedure that was published in October 1980, that outlines the repair pro-cedure requirement. I did not know about this procedure because it was pubilished after I left, however I have raead the procedure (eel-13 Rev. 2) and have no further concerns.
I cann/%c e(3 locate the exact area where cables were too short and were pulled ...
tight for termination' however 'I realize that on safety-related cable, Quality Control checks and pre-requicite testing would have identified and corrected my concerns. In the MCC Rm,BLK Cable, CCW(1 cable too tight) . In the Spreader Rm, either BLK or orange as per the map I gave to Mr. Herr.
I woul'd like to clarify as statement I made on cadwelds. I said that I could not check for damage but what I meant to say is that I did not check for damage. My concern is th + g asbestos covering was only for an area of three feet and believed it have h covered an area of,six feet.
rna /?xc I now realize that subsequent megger tests and O. C. Survelliance would j hxave identified damaged cable. l Mr. Herr has asked me if I have any other concern or area of concern that I wish to convey and I have no other concerns except as identified on my e 14, 1980, statement and in this statement.
l i
l i
/A'C C 1 have read the foregoing statement consisting of f2 typewritten /h=M wjt'en pages.
have made any necessary corrections and have initialed them. I have signed my name in I the margin of each page. .This statement is the truth to the best of my knowledge and oelief. I declare under penalty of perjury that the foregoing is true and correct.
Executed on SEf7: :2,14 0 at l'.05 .OW. 1 (Date) (Time) c M Amw[ NP
. d'
~
j 11GNATURE j
A~ h ~ ,
Subscribed and sworn to before me at / 306, this ;2'J 0ay(f 5cor , 199A at I /lTNESS /,w+~
1- _
[ M.
Ri~ chard K. Herr, NRC Investigator AUTH: Sec. 161c AEA 1954 as amended
[;f' 1 j PAGE ( f, OF (4 ) PAGES
\ .
i Wj(/
_