ML20080R993

Answers to City of Philadelphia Interrogatories (Discovery 27).Certificate of Svc Encl

ML20080R993
Person / Time
Site:	Limerick
Issue date:	02/21/1984
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	PHILADELPHIA, PA
Shared Package
ML20080R985	List: ML20080R983 ML20080R993
References
NUDOCS 8402280479
Download: ML20080R993 (22)

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- h-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Philadelphia Electric Company ) -Docket Nos. 50-352

) 50-353 (Limerick Generating Station .)

-Units 1 and 2) )

APPLICANT'S ANSWERS TO INTERVENOR CITY OF PHILADELPHIA'S INTERROGATORIES IN THE LIMERICK OPERATING LICENSE HEARINGS DISCOVERY 27 FEBRUARY 21, 1984 I

8402280479 840222 POR ADOCK 05000352 0 PDR t .- - - - - - - -

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e INTERROGATORY NO. 14 Provide PECO's list of all equipment important to safety.

Identify separat,ely that equipment which is " safety-related" and that equipment which is "important-to-safety" as defined "in the November 20, 1981 Denton Memorandum. Equipment in this case includes electrical, mechanical and hydraulic / fluid systems and components.

ANSWER The list of Limerick Generating Station electrical equipment important to safety which is located in a potentially harsh

-environment is provided by Appendix B of the Environmental Qualification Report (October, 1983) as revised by transmittal from J. S. Kemper to A. Schwencer dated 2/16/84 (revised Appendix B). See also answer to Interrogatory No. 18, infra.

PARTICIPANTS IN PREPARATION OF ANSWER

~ John S.~Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 William J. Eoyer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101~

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s INTERROGATORY NO. 15 Regarding the " List of Systems Important to Safety" in Appendix A of the Environme,ntal Qualification program submittal (October,1983):

a. Which of the systems are important-to-safety but not safety related?

b. -Are there components in other systems which are important to safety but not safety-related? If the answer is affirmative, please provide a list of these components and their qualification status,

c. Please provide a list of the systems and components in Appendix A of .the EQ submittal which were reviewed for compliance with 10CFR50.49(i) (5) regarding the need to show that failure of important-to-safety equipment which is not fully qualified will result in "[n]o... misleading information to the operator as a result of failure of equipment under the accident environment resulting from a design basis event."

d. For Section IX E of Appendix A provide the documentation of the analysis described in (15) (c) above to demonstrate compliance with 10CFR50.49(i) (5) .

ANSWER

a. None-

b. No I

c. All equipment identified by the revised Appendix B list is expected to be qualified by fuel load; therefore, 10CFR50.49 (i) (5) is not applicable. The folloaing systems were reviewed in establishing the Appendix A list:

High Pressure Coolant Injection Nuclear Boiler Instrumentation Residual Heat Eemoval Core Spray ADS

15c. (Continued)

Nuclear Boiler System (Reactor Vessels and Auxiliaries, and Main Steam Piping and Valves)

Nuclear Steam Supply Shutoff MSIV Leakage Control Reac# tor Water Cleanup Reactor Protection S/R Valve Position Indication Reactor Recirculation Leak Detection Reactor Core Isolation Cooling Standby Liquid Control Control Rod Drive Hydraulic Fuel Pool Cooling, Cleanup System and Refueling Pool Process Radiation Monitoring Neutron Monitoring System (APRM, IRM, SRM)

Containment Atmosphere Control included Containment Purge, Containment Vacuum Relief, Combustible Gas Control, Containment Isolation Gas Reactor Manual Control including Rod Sequence Control, Refueling Interlock and Rod Position Information Feedwater Control Area Radiation Monitoring Fuel Handling Main Steam System Solid Radwaste Liquid Radwaste Gaseous Radwaste Recombiners and Filters including Offgas Standby Gas Treatment Control Enclosure Unit Coolers including Chilled Water System Spray Pond Pump Structure HVAC Pressure Regulator and Turbine Generator Cable Spreading / Auxiliary Switchgear Room HVAC Emergency Switchgear, Battery and Inverter HVAC Safety Parameter Display System Primary Containment including Penetrations Drywell HVAC (Cooling)

Safeguard Piping Fill Radwaste Enclosure HVAC EHC Turbine Stop Valve Reactor Enclosure Main Crane Refueling Interlocks Control Enclosure HVAC Refueling Floor HVAC Non-Safeguard DC Power (125 & 250 VDC) 208V/120V Vital AC and Instrument AC Safeguard DC Power (125V/250V) 13.2 kV Auxiliary Power

15c. (Centinued)

4 kV Power i 2.3 kV,. Power (Non-Safeguard) 440V Load Centers and MCCS Service Water Emergency Service Water

.RHR Service Water-Fire Protection Reactor Enclosure Cooling Water Service Air Instrument Air Primary Containment Instrument Gas Low Pressure Air Diesel Generator and Auxiliaries (including Fuel Oil and Lube Oil)

' Diesel Generator Enclosure HVAC Fuel Oil Transf. Enclosure-HVAC Emergency Fresh Air Supply Control Room HVAC Reactor Enclosure HVAC Circulating Water Condensate Storage and Transfer Main Condenser Evacuation System Condensate Cleanup Feedwater including Pump Turbines Extraction Steam Feedwater Heater Vents and Drains Equipment and Floor Drains Demineralized Water Makeup including Demineralizer Drywell Chilled Water

. Post Accident Sampling

' Auxiliary Equipment Room HVAC SGTS Equipment Compartment HVAC RHR, HPCI, RCIC, and CS Rooms HVAC Reactor Enclosure Isolation Suppression Pool Cleanup Remote Shutdown Process Sampling ANSWER

d. Appendix A contains no section IX E. The equipment on the revised Appendix B list is associated with the systems

xs 15c. (Continued).

identified on Appendix - A. Since all equipment on the

. Appendix B' list is expected to be qualified by fuel load, 10CFR50.49 (1) (5) is not applicable.

PARTICIPANTS IN PREPARATION OF ANSWER John S. Kemper Vice President,' Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 William J. Boyer Philadelphia Electric' Company 2301 Market Street Philadelphia, PA 19101 D. J. Thompson Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 l

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INTERROGATORY NO. 16

a. Provide a list of all important-to-safety equipment which is subjec,t to a harsh environment during an accident but for which exception is taken. with respect to that harsh environment.

b. 'For each item on the list in (16) (a) , above, identify the specific basis for exclusion or exception from qualification.

ANSWER The specific basis for each equipment item for which exception is taken is. listed below. The specific basis (es) is identified by a number 1 through' 4 corresponding directly to the bases on pages 2.2 and 2.3 of the Environmental Qualification Report (October, 1983).

Plant ID Description Exemption Basis FT-55-1N051 Flow Transmitter 2 HV-55-1F054 Motor Operator 2 LSH-55-1N014 Level Switch 2 PT-55-1N013 Pressure Transmitter 2 PT-55-1N050 Pressure Transmitter 2 PT-56-1N052 Pressure Transmitter 2 PT-56-lN053 Pressure Transmitter 2 PT-56-1N055B Pressure Transmitter 2 PT-56-1N055D Pressure Transmitter 2 PT-56-1N055F Pressure Transmitter 2 PT-56-1N055H Pressure Transmitter 2

'PT-56-1N056B Pressure Transmitter 2 PT-56-1N056F Pressure Transmitter 2 ZS-56-111 Position Switch 2 ZS-56-112 Position Switch 2 56-10P213 Pump Motor 2 56-10P215 Condensate Pump Motor 2 56-10P216 Motor 2 56-10S211 Turbine Controls 2 XV-59-140A Shear valve 3 XV-59-140B Shear Valve 3 XV-59-140C Shear valve 3 XV-59-140D Shear Valve 3 XV-59-140E Shear Valve 3 XV-59-141A Solenoid Valve 3 XV-59-141B Solenoid Valve 3 XV-59-141C Solenoid valve 3 XV-59-141D Solenoid Valve 3 XV-59-141E Solenoid Valve 3 i

Plant ID Description Exemption Basis l 48-1AP208 Pump Motor 1 48-1BP208 Pump Motor 1 48-1CP208 Pump Motor- 1 48-1AS213 Pump Motor 1,3 48-1BS213 Pump Motor 1,3 TSHL-48-1N003 Temperatare Switch 1 TE-48-1N006 Temperature Element 1 10D201 Motor Control Center 2 10D202 Motor Control Center 2 10D203 Motor Control Center 2 LSH-50-110 Level Switch 2 LSH-50-120 Level Switch 2 50-105212 Turbine Controls 2 HS-46-12'/ Hand Switch 3 HS-45-128 Hand Switch 3 TE-44-1N007 Temperature Element 1 TIS-44-1N008 Temperature Switch 1 FT-43-1N024A Flow Transmitter 1 FT-43-1N024B Flow Transmitter 1 FT-43-1N024C Flow Transmitter 1 FT-43-1N024D Flow Transmitter 1 Neutron Monitoring System 1,3 PARTICIPANTS IN PREPARATION OF ANSWER John S. Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia,7PA 19101 William J. Boyer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Daniel J. Thompson Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 1

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INTERROGATORY NO. 17 Is Limerick Unit 1 in complete compliance with the requirements of 10CFR50.49 and the Final Rule on Environmental Qualifications? If

.not, describe the variance and the justification for each variance. <

ANSWER Limerick Unit 1 is expected to be in compliance with 10CFR50.49 without variance by fuel load..

PARTICIPANTS IN PREPARATION OF ANSWER John S. Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 William J. Boyer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 I

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INTERROGATORY NO. 18

a. Has PECO accepted the Denton definitions of safety-related and important-to-safety as defined in the November 20, 1981 Memorandum? If not, describe which definitions are not accepted.

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} b. Has the LGS EQ program been planned, perfonned, and j

reviewed, using the Denton definitions as in (18) (a) ,

L above? If not, state the differences. If yes, document and explain.

f ANSWER

a. A review of the Denton definitions has not been performed with respect to the Limerick equipment qualification program.

The Limerick Environmental Qualification Progra:n utilizes the

-definition of important-to-safety equipment (to be qualified) which is provided in 10CFR50.49.

b No; see response to part a. above. While the Limerick Environmental. Qualification Program was planned and partially performed prior to the issuance of 10CFR50.49, it has been determined to be in compliance with 10CFR50.49.

PARTICIPANTS IN PREPARATION OF ANSWER John-S. Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 William J. Boyer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

' INTERROGATORY NO. 19

a. Has PECO installed all the BWR post-accident monitoring equipm,ent identified in Regulatory Guide 1.97, Rev. 27 If not, identify each piece of equipment not installed and the reason why not.

b. Identify the status of qualification of each piece of Regulatory Guide 1.97, Rev. 2 equipment which is installed.

ANSWER

a. See FSAR Section 7.5.2.5.1.1.2 and FSAR Table 7.5-5 for a discussion of Limerick's compliance with Regulatory Guide 1.97 Rev. 2.

b All Regulatory Guide 1.97, Rev. 2 equipment requiring environmental qualification is included in the Limerick Environmental Qualification Program. This equipment is identified by a Note 0 in revised Appendix B, except the Neutron Monitoring System (see answer to Interrogatory No.

16). All equipment including Regulatory Guide 1.97 instrumentation listed in the revised Appendix B is expected to be installed and qualified by fuel load.

PARTICIPANTS IN PREPARATION OF ANSWER John S. Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 William J. Boyer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

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I INTERROGATORY NO. 20

a. For each piece of Regulatory Guide 1.97, Rev. 2 equipment not installed, identify equipment (systems and components) which are relied on to perform the same function after an accident,

b. Identify the safety classification and qualification status of the equipment used to serve the RG 1.97 Rev. 2 function.

ANSWER

a. All Regulatory Guide 1.97, Rev. 2 equipment included in 1, . revised Appendix B is expected to be installed and qualified by fuel load; therefore, it will not be necessary to rely on' alternative equipment or systems. See also the answer to Interrogatory 19.a.

b. The specific qualification status is reflected on the EQRR sheets and revised Appendix B.

PARTICIPANTS IN PREPARATION OF ANSWER John S. Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 William J. Boyer Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

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I. INTERROGATORY NO. 21 I

f Kindly provide any actions PECO has taken to insure that LGS

. equipment operability is not impaired due to:

a. qualification methodology shortcomings;

b. design bases shortcomings;

c. inadequate equipment.

Reference:

Environmental Qualification Briefing of Chairman By Sandia (Board Notification 004) , January 5,1984.

Dated: February 3, 1984 ANEWER

-Philadelphia Electric Company has a long record attesting to its recognition of its responsibility to ensure that electrical equipment, which is important to safety,'is environmentally qualified. PECO has had continuous representation on the IEEE subcommittee or its associated working groups which authored the basic qualification standard IEEE-323-1971 since 1974. In addition, PECO is a member of the EPRI Advisory Group On Equipment Qualification-which serves as a forum for environmental qualification information exchange. between

, utilities. Information exchange meetings between this group and Sandia Laboratories Research personne1'have been held on several occasions, thus giving PECO representatives access to information concerning Sandia test programs through technical presentations by the Sandia representatives. As a member of the EPRI Advisory Group On Equipment

. Qualification, the PECO representative may suggest the initiation of test programs where needed to advance the state-of-the-art concerning qualification-and is responsible for reviewing and commenting on EPRI

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e sponsored research programs. The results of the EPRI research projects are periodically reviewed by Advisory Group members via technical presentations by'those organizations performing research under contract to EPRI, giving PECO representatives direct access to EPRI research.

PECO is represented on the AIF Subcommittee On Equipment Qualification which has an established dialogue with the NRC Staff on equipment qualification. The AIF Subcommittee has met with NRC Staff representatives on a number of occasions allowing PECO representatives direct access to NRC interpretations and philosophies concerning environmental qualification requirements and guidelines. PECO representatives have authored technical position papers on equipment qualification and have participated in several workshops from which technical position papers have been developed.

PECO sponsored a meeting between the utilities which operate BWR nuclear plants in response to the NRC request to the utilities to re-review the environmental qualification of their safety-related electrical equipment. This meeting led to the organization of the Utility Equipment Qualification - BWR Owners Group which PECO chaired throughout its active period of approximately 2 years. PECO representatives have also participated in co-authoring the NSAC Guide On Equipment Qualification which has been made the subject of an educational seminar to the nuclear industry throughout the United States.

PECO's participation in industry groups and stan6ards committees has resulted in its personnel gaining extensive experience in all aspects of equipment qualification. This experience is concentrated

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within the PECO Electrical Engineering Division Environmental Qualification Group (EQG) which has prime responsibility to assure that Limerick's safety related electrical equipment is environmentally qualified. The PECO EQG is supported by the Limerick Architect Engineer, Bechtel Power Corporation which has significant environmental qualification expertise in its own right.

Sandia research is regularly reviewed and evaluated by the PECO EQG to determine its relevance to the Limerick Equipment Qualification Program. PECO's experience has been that upon completion of its evaluation the research testing is usually not directly relevant to Limerick either because the equipment tested is different than that installed at Limerick or the - test conditions are significantly different from those to which the Limerick equipment would be exposed by the postulated design basis event. An industry comment that has been repeatedly offered to Sandia at technical exenange meetings is that if industry were offered the opportunity to review Sandia test plans, they could be restructured to have greater relevance to the nuclear plants. In the reference cited by this interrogatory, the Sandia representatives' presentation makes this same point. Without the pre-established relevance, as discussed above, the concerns expressed by Sandia personnel via the cited reference are of academic interest. When there is relevance, PECO takes action to address the research findings within the EQ Program. For example the synergistic effects of radiation and temperature on cable have been addressed within the Limerick EQ Program.

't The . environmental ' qualification program has a great deal of margin factored into it in several different ways. First the environmental co'nditions to which the equipment is tested are based on conservative calculations which reflect co-incidental occurrences, as improbably-as they may be, such as a design basis accident (DBA) Loss of Coolant Accident (LOCA) with a loss of all off-site power and the single active failure of redundant plant safety equipment. In concert ,

with these assumptions, the reactor core is assumed to non-mechanistically degrade resulting in elevated radiation dose assumptions for equipment exposure in addition to the elevated temperatures resulting from the line break effluent. In addition to the post accident service condition conservativisms, the qualified operating time has varying degrees of margin over the specified operating time for the safety equipment.

For the majority of plant equipment the actual test itself introduces a conservativism because the test laboratories cannot replicate the postulated plant profile for temperature and

-corresponding ambient pressure. The test pressure is generally at least several times greater than the postulated pressure. This ,

conservativism results in forcing the adverse test environment into equipment enclosures at a much faster rate than that which would occur in response to the postulated pressure. Many equipment items have been

- generically tested to environmental conditions significantly greater than the postulated Limerick environment.

The Limerick post accident service environment for the reactor i

enclosure is assumed to be at the maximum design temperature prior to the postulated accident. Even with this conservativism,

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the .: maximum . temperature to which the reactor enclosure rises is 120*F. . This temperature is well within recognized capabilities of standard. industrial plant equipment and well below published temperature . limits for materials commonly used in electrical equipment. Although the reactor enclosure is postulated to reach a

maximum, temperature of 120'F, it shoulsi also be recognized that this

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' maximum temperature wills~,not. be raached until approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />

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after the postulated accidenc. By this time, the majority of plant equipment will have perfonned its, safety func' tion and only a limited number of equipment itert will be required to support the plant in the

%w shut-down condition. 3 ,m q-When revisions to pla'nt design have r'equired the procurement of new equipmerit, the most recent qualification -equirements have been ref'lected in the plant specifica t.' ions.' In some instances the

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equipment qualification review .iden;Nified qualification deficiencies s

which were resolved by procpring replacement equipment qualified to N . ,

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the' most recenti guidance. s -

'! D k% N a In summary, the Limerick Egyprogram is administered and performed by PECO personnel who are nationally recognized industry leaders in equipment " qualification. Sandia research is routinely reviewed and evaluated by PECC In those cases wI1ere sufficient relevance to Limerick can-.be established, steps are taken to ensure that the results

.N .of ths.research are addressed within the EQ Program. The combinations

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of. design basis occurrences, initial condition assumptions, and method

,. ' of calculation result in conservative postulated accident service y

_ conditions.for equipment qualification. The standard industry EQ test t

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practices add additional margin to the environmental qualification of equipment.

In some - c'a'ses environmental qualification documentation deficiencies has led to the procurement of new equipment qualified to the latest guidance. It is the environmental qualification review program'which formalizes the results of these reviews and ensures that there is no inadequately qualified equipment installed at Limerick.

PARTICIPANTS IN PREPARATION OF ANSWER Jonti S. Kemper Vice President, Engineering and Research Philadelphia Electric Company 2301 Market Street Philadelphia, PA. 19101 William J. Boyer .

Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101

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COMMONWEALTH OF PENNSYLVANIA  :

j ss.

COUNTY OF PHILADELPHIA  :

P J. S. Kemper, being first swren, deposes and states:

j That he is Vice President of Philadelphia Electric Company, the Applicant herein; that hb has read the foregoing Applicant's Answers to Intervenor City of Philadelphia's Interrogatories in the Limerick Operatipg License Hearings and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, l and belief.

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- 'Vice Presitent Subscribed and sworn to before me this M/ day of Febr,uary, 1984.

/e6 e Notary Public PATRICIA D. SCHOLE Netsry butic, PS.hje!r't:a. PMaddrhia Cr.

My Commissen Ingres hbru:ry 10,1%6

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UNITED STATES OF AMERICA

, NUCLEAR REGULATORY COMMISSION In the Matter of )

)

Philadelphia Electric Company ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereoy certify that copies of " Applicant's Answers to Intervenor City of Philadelphia's Interrogatories in the Limerick Operating License Hearings" dated February 22, 1984, in the captioned matter have been served upon the following by deposit in the United States mail this 22nd day of February, 1984:

• Lawrence Brenner, Esq. (2) Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Sect. ton Dr. Richard F. Cole Office of the Secretary Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555

• Ann P. Hodgdon, Esq.

Counsel for NRC Staff Office

• Dr. Peter A. Morris of the Executive Atomic Safety and Legal Director.

Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Hand Delivery

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Atomic Safety and Licensing Steven P. Hershey, Esq.

Board Panel Community Legal U.S.' Nuclear Regulatory Services, Inc.

Commission. Law Center West North Washington, D.C. 20555 5219 Chestnut Street Philadelphia, PA 19139 Philadelphia Electric Company ATTN: Edward.G. Bauer, Jr. Angus Love, Esq.

Vice President & 107 East Main Street General Counsel Norristown, PA 19401 2301 Market Street Philadelphia, PA 19101_

Mr. Joseph H. White, III 15 Ardmore Avenue Mr. Frank R.' Romano Ardmore, PA 19003 61 Forest Avenue Ambler, Pennsylvania 19002 Robert J. Sugarman, Esq.

Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street I the Delaware Valley Philadelphia, PA 19107 L 106 Vernon Lane, Box 186 i

Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I. Lewis Basement,. Transportation 6504 Bradford Terrace- .and Safety Building Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer, Esq. Martha W. Bush, Esq.

. Limerick Ecology Action Kathryn S. Lewis, Esq.

P.O. Box 761 City of Philadelphia 762 Queen Street Municipal Services Bldg.

.Pottstown, PA 19464 15th and JFK Blvd.

Philadelphia, PA 19107 Charles W. Elliott, Esq.

Brose and Postwistilo Spence W. Perry, Esq.

1101 Building lith & Associate General Counsel Northampton Streets Federal Emergency Easton, PA 18042 Management Agency 500 C Street, S.W., Rm. 840 Zori G. Ferkin, Esq. Washington, DC 20472 Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director

.' Governor's Energy Council ' Bureau of Radiation 1625'N. Front Street Protection Harrisburg, PA 17102 Department of Environmental Resources 5th Floor, Fulton Bank Bldg.

Third and Locust Streets Harrisburg, PA 17120

• • Federal Express L -__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _

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Jay M. Gutierrez, Esq.

U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 -

James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Mark Jy Wetterhahn

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