ML052630411

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G20050379 - Paul Gunter Ltr 2.206 Inoperable Hemyc/Mt Fire Protection Systems, Proposed Directors Decision
ML052630411
Person / Time
Site: Mcguire, Indian Point, Catawba, Harris, Arkansas Nuclear, Vermont Yankee, Ginna, Waterford, Robinson, FitzPatrick, McGuire  Constellation icon.png
Issue date: 10/20/2005
From: Marsh L
NRC/NRR/DLPM
To: Gunter P
Nuclear Information & Resource Service (NIRS)
Patel C P, NRR/DLPM, 415-3025
Shared Package
ML052640061 List:
References
G20050379, TAC MC7023, TAC MC7024, TAC MC7025, TAC MC7026, TAC MC7027, TAC MC7028, TAC MC7029, TAC MC7030, TAC MC7031, TAC MC7032, TAC MC7033, TAC MC7034, TAC MC7035, TAC MC7036
Download: ML052630411 (21)


Text

October 20, 2005 Mr. Paul Gunter Nuclear Information and Resource Service 1421 16th Street NW., Suite 404 Washington, DC 20036

Dear Mr. Gunter:

Your petition dated May 12, 2005, submitted on behalf of Nuclear information and Resource Service, Citizens Awareness Network, Indian Point Safe Energy Coalition, North Carolina Waste Awareness and Reduction Network, Alliance for Affordable Energy, and Blue Ridge Environmental Defense League, and addressed to Mr. Luis A. Reyes, Executive Director for Operations of the Nuclear Regulatory Commission (NRC), has been reviewed by the NRC staff pursuant to Section 2.206 of Title 10 of the Code of Federal Regulations. The staffs proposed Directors Decision on the petition is enclosed. I request that you provide comments to me on any portions of the petition that you believe to be erroneous or any issues in the petition that you believe have not been fully addressed. The staff will then review your comments and consider them in the final version of the Directors Decision. You will have no further opportunity to comment.

Please provide your comments within 30 days of this letter. Comments should be submitted by letter or e-mail to the petition manager, Chandu Patel (Mailstop 0-8G9 or E-mail CPP@NRC.gov).

Sincerely,

/RA/

Ledyard B. Marsh, Director Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-244, 50-247, 50-271, 50-286, 50-313, 50-333, 50-368, 50-369, 50-370, 50-382, 50-400, 50-413, 50-414, and 50-261

Enclosures:

Proposed Directors Decision cc w/o encl: See next page

ML052630411 NRR-002 OFFICE PDII-2/PM PDII-2/LA SPLB/SC PDII-2/SC PDII-PD DLPM/D NRR/OD NAME CPatel BClayton SWeerakkody MMarshall EHackett TMarsh BSheron for JDyer DATE 9/27/05 9/27/05 9/23/05 09/29/05 10/04/05 10/20/05 10/19/05

Proposed Directors Decision - Paul Gunter, the Nuclear Information and Resource Service, Letter dated May 12, 2005, Re: 2.206 - Request for Emergency Enforcement Action under 2.206 to address inoperable Hemyc/MT fire protection systems at multiple plants DATE: October 20, 2005 Distribution: G20050379 PUBLIC PDII-2 r/f RidNrrPMCPatel RidsNrrPMDWilliams RidsNrrLARSola RidsNRRLABClayton RidsNrrDlpmLpdi RidsNrrDlpmLpdi2 RidsNrrDlpmLpdii RidsNrrDlpmLpdiv RidsNrrDlpm RidsNrrDssa RidsNrrWpcMail RidsNrrAdpt RidsNrrOd SWeerakkody DFrumkin RidsOgcRp RidsOpaMail RidsOcaMail RidsOigMailCenter RidsEdoMailCenter RidsRgn1MailCenter RidsRgn2MailCenter

PROPOSED DD-YY-XX UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION James E. Dyer, Director In the Matter of

) Docket Nos. 50-244, 50-247, 50-271, Carolina Power and Light Company

) 50-286, 50-313, 50-333, 50-368, 50-369, Duke Power and Light Company

) 50-370, 50-382, 50-400, 50-413, 50-414, Entergy Nuclear Operations, Inc.

) And 50-261

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)

Plant Names: As Shown Below

) License Nos: As Shown Below

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DIRECTORS DECISION UNDER 10 CFR 2.206 I. Introduction By letter dated May 12, 2005, Mr. Paul Gunter, on behalf of Nuclear Information and Resource Service, Citizens Awareness Network, Indian Point Safe Energy Coalition, North Carolina Waste Awareness and Reduction Network, Alliance for Affordable Energy, and Blue Ridge Environmental Defense League (the petitioners) filed a petition pursuant to Title 10 of the Code of Federal Regulations, Section 2.206. The petitioners requested that the U.S. Nuclear Regulatory Commission (NRC) engage emergency enforcement actions to modify and/or suspend operating licenses for Shearon Harris Nuclear Power Station Unit 1, Docket No. 50-400, License No. NPF-63; H. B. Robinson Unit 2, Docket No. 50-261, License No.

DPR-23; McGuire Units 1 and 2, Docket No. 50-369, License No. NPF-9; Catawba Units 1 and 2, Docket Nos. 50-413 and 50-414, License Nos. NPF-35 and NPF-52; Ginna, Docket No. 50-244, License No. DPR-18; James A. FitzPatrick, Docket No. 50-333, License No. DPR-59; Indian Point Units 2 and 3, Docket Nos. 50-247 and 50-286, License Nos. DPR-26 PROPOSED and DPR-64; Vermont Yankee, Docket No. 50-271, License No. DPR-28; Waterford Unit 3, Docket No. 50-382, License No. NPF-38; and Arkansas Nuclear One Units 1 and 2, Docket No. 50-313 and 50-368, License No. DPR-51 and NPF-6, with regard to potential violations of NRC regulations for fire protection under Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Specifically, the petition requested emergency enforcement under 10 CFR 2.206 to include the following actions by the Commission:

1)

Collect information through generic communication with nuclear industry and specifically with the named reactor sites to determine the extent of condition of the inoperable fire barriers; including the requirement that the licensees conduct a full inventory of the type Hemyc/MT to include the amount in linear and square footage, its specific applications, and the identification of safe shutdown systems, which are currently unprotected by the noncompliance and an assessment of the safety significance of each application; 2) the communication should require, at minimum that the above-named sites provide justification for operation in noncompliance with all applicable fire protection regulations; and 3) with the determination that any and/or all of the above-mentioned sites are operating in unanalyzed condition and/or that assurance of public health and safety is degraded, promptly order a suspension of the license or a power reduction of the affected reactors until such time as it can be demonstrated that the licensees are operating in conformance with all other applicable fire protection regulations.

As the basis for the requests, the petitioners cited a meeting on April 29, 2005, held by NRC with all stakeholders to discuss the performance of 1-hour (Hemyc) and 3-hour (MT) fire barriers for Electrical Raceways during full scale fire testing. In that meeting the NRC staff informed all stakeholders that the Hemyc/MT electrical raceway fire barrier system (ERFBS) failed to protect electrical cables for 1 hour/3 hours in fire tests that were performed to the PROPOSED American Society of Testing and Materials (ASTM) Standard E119. The petitioners request was also based on the following conclusions made by the petitioners: (1) The same Hemyc/MT fire barrier wrap systems as installed in the above nuclear plants fail to assure the protection of the control room operations for achieving safe shutdown of the reactor in the event of a significant fire, (2) NRC has not quantified the full extent of the amount of Hemyc/MT fire barrier material in terms of linear and/or square footage deployed per fire protection regulation, and NRC has not determined the safety significance of this deployment for safe shutdown systems that are not currently protected by these fire barriers, and (3) the petitioners believe that the above listed nuclear power stations are operating in violation of NRC fire protection requirements and in an unanalyzed condition resulting in a degradation of defense-in-depth fire protection and safe shut down in the event of a significant fire.

By teleconference on June 1, 2005, the petitioners provided information to the NRCs Petition Review Board as further explanation and support for their petition. The transcript of this teleconference was treated as a supplement to the petition and is available in the Agencywide Documents Access and Management System (ADAMS) for inspection (Accession No. ML051640452) at the Commission's Public Document Room (PDR), located at One White Flint North, Public File Area O1 F21, 11555 Rockville Pike (first floor), Rockville, Maryland.

Publicly available records will be accessible from the ADAMS Public Electronic Reading Room on the NRC Web site http://www.nrc.gov/reading-rm/adams.html. Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS, should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, 301-415-4737, or by e-mail to pdr@nrc.gov.

During the teleconference, petitioners also requested that this petition be modified to consider this fire barrier material in context of an overall picture of the extent of condition for fire barrier protection under Section III.G.2 of Appendix R to 10 CFR Part 50 (i.e., not just the PROPOSED Hemyc/MT ERFBS). As a basis for this request, the petitioners stated that they dont believe it is justifiable for NRC or industry to wait on a potential ruling with regard to operator manual action.

In a letter dated June 27, 2005, the NRC informed the petitioners that their request was received and that the issues in the petition were being referred to the Office of Nuclear Reactor Regulation for appropriate action. However, the petitioners request for immediate action and the request to expand the scope to cover other fire barriers issues were denied by the NRC.

When the Hemyc test results became available, the staff examined whether there was an immediate and significant risk to safety. Because fire detection, prevention, and suppression measures are already in place to minimize both the probability of occurrence and consequences of a fire that could prevent the performance of safe shutdown functions, the staff concluded that continued plant operation while corrective actions are implemented will not pose an undue risk to public health and safety.

II. Discussion NRCs concern with the performance of fire barriers at nuclear power plants began with the failure of Thermo-Lag to pass performance tests in October 1989 at Southwest Research Institute. The tests were done for the Gulf States Utilities Company after visually observing degradation of Thermo-Lag at River Bend Station.

Because of questions about the ability of 1-hour-and 3-hour-rated Thermo-Lag fire barrier material to perform its specified function, and because of the widespread use of Thermo-Lag in the nuclear industry, the NRC issued Generic Letter (GL) 92-08, Thermo-Lag 330-1 Fire Barriers, December 17, 1992, to inform licensees of the Thermo-Lag test results and to request that licensees implement appropriate compensatory measures and develop plans to resolve any noncompliances with 10 CFR 50.48.

PROPOSED In response, the licensees reviewed their fire protection safe shutdown plans to determine if corrective actions were needed. Some licensees had made conservative commitments and installed Thermo-Lag in locations where it was not needed to satisfy NRC requirements, therefore, no corrective actions were required. Where fire barrier materials were required, licensees took one or a combination of the following corrective actions:

Rerouted cables through other fire areas so that redundant safe shutdown trains were not located in the same fire area; Replaced Thermo-Lag, or the affected material, with an alternative rated fire barrier material; Upgraded the installed fire barriers to a rated configuration; or Concluded that certain Thermo-Lag barriers were no longer required.

Subsequently, deficiencies were also identified in other fire barrier materials. In 1993, for example, Kaowool installed as a 1-hour-rated fire barrier was found to be unable to pass fire endurance tests as a rated fire barrier. In response, the NRC reassessed previous staff reviews of Kaowool fire barriers and informed the industry and the Commission of the potential failure of Kaowool to perform as intended and suggested additional testing of Kaowool (SECY-99-204; ADAMS Accession No. ML992810028). To resolve the issue, the industry took voluntary corrective actions.

In August 1993, the Nuclear Energy Institute (NEI) formed a Fire Barrier Review Ad Hoc Advisory Committee to address the adequacy of fire barrier materials other than Thermo-Lag.

The Committee reviewed the original testing of the fire barrier, Hemyc (performed in the early 1980s in Spain), and concluded that Hemyc was differently constructed than Thermo-Lag 330-1, and therefore was not subject to the same failure modes as Thermo-Lag 330-1. In May 1994, this review was documented in the NEI report, Documentation of the Adequacy of Fire PROPOSED Barrier Materials in Raceway Applications Vis-á-vis Failure Characteristics Inherent to the Thermo-Lag 330-1.

However, beginning in late 1999, three plant-specific findings by the NRC staff raised concerns about the performance of Hemyc and MT fire barriers. Hemyc and MT, manufactured by Promatec, Inc., were installed at Nuclear Power Plants (NPPs) to protect circuits and instrumentation cables in order to meet regulatory requirements and in accordance with plant-specific commitments. In June 2001, the NRC initiated confirmatory fire tests in response to Task Interface Agreement 99-028 (ADAMS Accession No. ML003736721), after concluding that existing testing was likely insufficient to qualify Hemyc or MT as rated fire barriers. In March/April 2005, the NRC conducted confirmatory testing of both materials at the Omega Point Laboratories in San Antonio, Texas. The NRC tests were based on ASTM E119 Standard time-temperature conditions and the current NRC guidance in GL 86-10, Supplement 1, for typical Hemyc and MT arrangements used in NPPs. The test results indicated that when tested to GL 86-10, Supplement 1, criteria, neither Hemyc nor the MT fire barrier systems would provide their rated fire barrier protection for the configurations tested.

On April 1, 2005, the NRC issued Information Notice (IN) 2005-07, Results of Hemyc Electrical Raceway Fire Barrier System Full Scale Fire Testing. This IN describes the results of the NRC-sponsored confirmatory testing of Hemyc. However, the staff recognized that additional evaluations would be needed to determine whether regulatory compliance exists in light of the concerns identified in IN 05-07. On April 29, 2005, the NRC staff held a public meeting with licensees and interested members of the public to discuss the Hemyc and MT test results and the staffs intentions to take prompt additional regulatory action to ensure that appropriate measures are under way for compliance with 10 CFR 50.48 requirements at affected plants.

PROPOSED The NRC staff recognizes the concern expressed by the petitioners. The NRC staff is concerned that the Hemyc and MT fire barriers may not provide the level of fire endurance intended by licensees and that licensees that use Hemyc or MT may not be complying with NRC regulations or plant specific licensing bases. Section 50.48 of 10 CFR Part 50 requires that each operating NPP have a fire protection plan that satisfies General Design Criterion (GDC) 3, Fire Protection, of 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants. GDC 3 requires that structures, systems, and components important to safety be designed and located to minimize, in a manner consistent with other requirements, the probability and effect of fires and explosions. Fire protection features required to satisfy 10 CFR 50.48 include features to limit fire damage to structures, systems or components important to safety so that the capability to shut down the plant safely is ensured.

The NRC has issued guidance on acceptable methods of satisfying the regulatory requirements of GDC 3 in the Branch Technical Position (BTP), Auxiliary and Power Conversion Systems Branch BTP 9.5-1, Standard Review Plan, Section 9.5-1, and GLs.

GL 92-08 specifically included the staffs expectation that licensees would review existing fire barrier configurations credited for 10 CFR Part 50, Appendix R, compliance, based on earlier concerns with Thermo-Lag.

Licensees of plants licensed to operate before January 1, 1979, must comply with their fire protection requirements as specified in 10 CFR 50, Appendix R, and licensees of plants licensed to operate after January 1, 1979, must comply with the approved fire protection program incorporated into their operating license. The staff expects licensees to reevaluate their fire protection programs in light of information provided in IN 05-07 and other guidance, and to implement appropriate compensatory measures and develop plans to resolve any noncompliances within a reasonable timeframe. All licensees should consider the impact of fire PROPOSED barrier degradation on the operability of affected equipment and assess the impact on plant safety.

If a nonconforming condition is identified, licensees can use at least two methods, individually or in combination, to restore compliance. One way is to make plant modifications such as replacing the Hemyc or MT fire barriers with an appropriately rated fire barrier material, upgrading the Hemyc or MT to a rated barrier, or rerouting cables or instrumentation lines through another fire area. Another way to address the issue is to perform a technical evaluation that considers defense-in-depth and safety margins as follows:

Plants licensed to operate before January 1, 1979, may request an exemption from 10 CFR Part 50, Appendix R, in accordance with the requirements of 10 CFR 50.12, Specific Exemptions.

Plants licensed to operate after January 1, 1979, must meet the fire protection requirements in the operating license condition. The standard license condition allows a licensee to make changes to the approved fire protection program without prior staff approval if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. GL 86-10, Implementation of Fire Protection Requirements, provides guidance on performing and documenting these changes. The plants that adopt a risk-informed approach should submit a license amendment in accordance with 10 CFR 50.90.

On July 25, 2005, the NRC staff issued a GL for comments in the Federal Register. The comment period expired on September 23, 2005. The NRC staff intends to issue the final GL by March 31, 2006. The GL will request all licensees who credit Hemyc or MT for compliance to provide information regarding the extent of the installation; whether the material is degraded or nonconforming; and any compensatory actions in place to provide equivalent protection and maintain the safe shutdown function of affected areas of the plant in light of the recent findings PROPOSED of potential degradation of Hemyc and MT. Licensees will be requested to provide evaluations to support conclusions that they are in compliance with regulatory requirements for the Hemyc and MT applications. Licensees that cannot justify their continued reliance on Hemyc or MT are requested to provide a description of corrective actions taken or planned and a schedule for milestones including when full compliance will be achieved. In addition, licensees will be requested to identify and discuss all applications that are considered degraded but operable, including a basis for this conclusion.

It is expected that the compensatory and corrective actions shall be implemented in accordance with existing regulations commensurate with the safety significance of the degraded or nonconforming condition. The NRC expects that all licensees will fully restore compliance with 10 CFR 50.48, and submit the required documentation to the NRC, by December 1, 2007.

III. Conclusion The NRC staff shares the concerns identified by the petitioners. The NRC staff is addressing the Hemyc/MT material performance issues in an expeditious manner. In response to Request Nos. 1 and 2, the NRC staff has granted the petitioners request through the generic communication process. Specifically, as discussed before, the staff is issuing a GL to all licensees asking them to provide detailed information about the use of Hemyc/MT in their NPPs. In response to Request No. 3, the NRC staff is planning to review all affected plants in detail and will take appropriate actions to resolve the issues with the use of Hemyc/MT material commensurate with the safety significance of the protected systems. The GL will be issued after the public comment period expires and after the NRCs internal review process is completed.

PROPOSED A copy of this directors decision will be filed with the Secretary of the Commission for the Commissions review in accordance with 10 CFR 2.206(c). As provided for by this regulation, the decision will constitute the final action of the Commission 25 days after the date of the decision unless the Commission, on its own motion, institutes a review of the decision within that time.

FOR THE NUCLEAR REGULATORY COMMISSION J. E. Dyer, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, this day of 2005.

David T. Conley, Associate General Counsel II Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551 Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 U. S. Nuclear Regulatory Commission Resident Inspector's Office H. B. Robinson Steam Electric Plant Route 5, Box 413 Hartsville, South Carolina 29550 Mr. William G. Noll, Director Site Operations H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Beverly Hall, Section Chief N.C. Department of Environment and Natural Resources Division of Radiation Protection 3825 Barrett Dr.

Raleigh, North Carolina 27609-7721 Mr. Robert P. Gruber, Executive Director Public Staff N. C. Utilities Commission 4326 Mail Service Center Raleigh, North Carolina 27699-4326 Mr. John H. ONeill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

Washington, DC 20037-1128 Mr. J. W. Moyer, Vice President H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Henry H. Porter, Assistant Director Division of Radioactive Waste Management South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Mr. Chris L. Burton, Manager Performance Evaluation and Regulatory Affairs, PEB 7 Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551 U. S. Nuclear Regulatory Commission Resident Inspectors Office Shearon Harris Nuclear Power Plant 5421 Shearon Harris Road New Hill, North Carolina 27562-9998 Mr. James Scarola, Vice President Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165 New Hill, North Carolina 27562-0165 Mr. Robert J. Duncan II, Director Site Operations Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Mr. Warren Lee Emergency Management Director New Hanover County Department of Emergency Management Post Office Box 1525 Wilmington, North Carolina 28402-1525 Chairman of the North Carolina Utilities Commission Post Office Box 29510 Raleigh, North Carolina 27626-0510

Mr. C. T. Baucom Supervisor, Licensing/Regulatory Programs H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Herb Council, Chair Board of County Commissioners of Wake County P.O. Box 550 Raleigh, North Carolina 27602 J. F. Lucas, Manager Support Services - Nuclear H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Terry C. Morton, Manager Support Services Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 Mr. David H. Corlett, Supervisor Licensing/Regulatory Programs Shearon Harris Nuclear Power Plant Carolina Power & Light Company Post Office Box 165, Mail Zone 1 New Hill, North Carolina 27562-0165 Mr. Dan Stoddard, Plant General Manager H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Tommy Emerson, Chair Board of County Commissioners of Chatham County Post Office Box 87 Pittsboro, North Carolina 27312 Mr. C. S. Hinnant, Senior Vice President Nuclear Generation & Chief Nuclear Officer Progress Energy CPB 12 Post Office Box 1551 Raleigh, North Carolina 27602-1551 Ms. Lisa F. Vaughn Duke Energy Corporation 526 South Church Street P. O. Box 1006 Mail Code = EC07H Charlotte, North Carolina 28201-1006 County Manager of Mecklenburg County 720 E. Fourth St.

Charlotte, NC 28202 Mr. C. Jeffrey Thomas Manager Regulatory Compliance Duke Energy Corporation McGuire Nuclear Site 12700 Hagers Ferry Road Huntersville, NC 28078 Senior Resident Inspector c/o U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntersville, NC 28078 Mr. Peter R. Harden, IV VP-Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road 12th Floor Charlotte, NC 28210 Dr. John M. Barry Mecklenburg County Department of Environmental Protection 700 N. Tryon Street Charlotte, NC 28202 Division of Radiation Protection NC Dept of Environment, Health, & Natural Resources 3825 Barrett Dr.

Raleigh, NC 27609-7721

Ms. Karen E. Long Asst Attorney General NC Dept of Justice P.O. Box 629 Raleigh, NC 27602 Mr. R.L. Gill, Jr., Manager Nuclear Regulatory Issues & Industry Affairs Duke Energy Corporation 526 S. Church St.

Mail Stop EC05P Charlotte, NC 28202 NCEM REP Program Manager 4713 Mail Service Center Raleigh, NC 27699-4713 Mr. T. Richard Puryear Owners Group (NCEMC)

Duke Energy Corporation 4800 Concord Road York, SC 29745 Lee Keller Regulatory Compliance Manager Duke Energy Corporation 4800 Concord Road York, South Carolina 29745 NC Municipal Power Agency No. 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, NC 27626-0513 County Manager of York County York County Courthouse York, SC 29745 Piedmont Municipal Power Agency 121 Village Dr.

Greer, SC 29651 Saluda River Electric P.O. Box 929 Laurens, SC 29360 Henry Porter, Assistant Director Division of Waste Management Bureau of Solid and Hazardous Waste Dept of Health & Environmental Control 2600 Bull St.

Columbia, SC 29201-1708 NC Electric Membership Corp.

P.O. Box 27306 Raleigh, NC 27611 Senior Resident Inspector 4830 Concord Road York, SC 29745 Mr. Dhiaa Jamil Vice President Catawba Nuclear Station Duke Energy Corporation 4800 Concord Road York, SC 29745 Mr. G.R. Peterson Vice President McGuire Nuclear Station Duke Energy Corporation 12700 Hagers Ferry Road Huntersville, NC 28078 Henry Barron Group Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006 Vermont Yankee Nuclear Power Station Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.

Washington, DC 20037-1128 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601

Mr. Michael H. Dworkin, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.

Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Mr. James M. DeVincentis Manager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.

Framingham, MA 01702-5399 Jonathan M. Block, Esq.

Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Theodore A. Sullivan Site Vice President Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Kevin J. Mulligan General Manager, Plant Operations Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Oscar Limpias Vice President Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Christopher Schwarz Vice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Resident Inspector's Office James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. David Wallace

Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Richard Plasse Manager, Regulatory Compliance Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Oswego County Administrator Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. Travis C. McCullough Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael D. Lyster BWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306 Ms. Deb Katz, Executive Director Nuclear Security Coalition c/o Citizens Awareness Network P.O. Box 83 Shelburne Falls, MA 01370 Mr. Michael J. Wallace President R.E. Ginna Nuclear Power Plant, LLC c/o Constellation Energy 750 East Pratt Street Baltimore, MD 21202 Mr. John M. Heffley Senior Vice President and Chief Nuclear Officer Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 500 Annapolis, MD 21401 Kenneth Kolaczyk, Sr. Resident Inspector R.E. Ginna Nuclear Power Plant U.S. Nuclear Regulatory Commission 1503 Lake Road Ontario, NY 14519 Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Carey W. Fleming, Esquire Senior Counsel - Nuclear Generation Constellation Generation Group, LLC 750 East Pratt Street, 17th Floor Baltimore, MD 21202 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Ms. Thelma Wideman, Director Wayne County Emergency Management Office Wayne County Emergency Operations Center 7336 Route 31 Lyons, NY 14489

Ms. Mary Louise Meisenzahl Administrator, Monroe County Office of Emergency Preparedness 1190 Scottsville Road, Suite 200 Rochester, NY 14624 Mrs. Mary G. Korsnick Vice President R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519 Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Paul Rubin General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 2 P.O. Box 249 Buchanan, NY 10511-0249 Mr. James Comiotes Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric Conroy Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Mr. Travis C. McCullough Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Senior Resident Inspectors Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511-0038 Senior Resident Inspectors Office Indian Point 3 U. S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Daniel C. Poole PWR SRC Consultant P.O. Box 579 Inglis, FL 34449 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001

Mr. Michael E. Henry, State Liaison Officer Department of Environmental Quality Permits Division P.O. Box 4313 Baton Rouge, Louisiana 70821-4313 Vice President Operations Support Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Director Nuclear Safety Assurance Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.

17265 River Road Kilona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Winston & Strawn 1700 K Street N.W.

Washington, DC 20006-3817 Resident Inspector/Waterford NPS P.O. Box 822 Kilona, LA 70060-0751 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Executive Vice President

& Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 Jackson, MS 39286-1995 Chairman Louisiana Public Services Commission P.O. Box 91154 Baton Rouge, LA 70825-1697 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Senior Vice President

& Chief Operating Officer Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 Mr. Jeffrey S. Forbes Site Vice President Arkansas Nuclear One Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801