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Category:Legal-Pre-Filed Testimony
MONTHYEARML1025100062010-09-0707 September 2010
Revised Direct Testimony of Christopher I. Grimes on Behalf of the Prairie Island Community
ML1025100132010-09-0707 September 2010
Revised Redlined Direct Testimony of Christopher I. Grimes on Behalf of the Prairie Island Community
ML1025005872010-09-0707 September 2010
Revised NRC Staff Testimony of Dr. Valerie E. Barnes, June Cai, Molly Jean Keefe, and Audrey L. Klett Concerning Safety Culture and NRC Safety Culture Policy Development and Implementation
ML1025005882010-09-0707 September 2010
Revised NRC Staff Testimony of Dr. Dan J. Naus and Abdul H. Sheikh Concerning the Safety Culture Contention and the Reactor Refueling Cavity Leakage
ML1025005892010-09-0707 September 2010
NRC Staff Revised Exhibit List for Evidentiary Hearing on Safety Culture Contention
ML1025005902010-09-0707 September 2010
Revised NRC Staff Testimony of John Giessner Concerning the Safety Culture Contention and the Reactor Oversight Process
ML1025005922010-09-0707 September 2010
Revised NRC Staff Testimony of Richard A. Plasse Concerning Safety Culture Contention
ML1025005942010-09-0707 September 2010
Revised NRC Staff Rebuttal Testimony of Abdul H. Sheikh and Dr. Dan J. Naus Concerning the Safety Culture Contention and Reactor Refueling Cavity Leakage
ML1025005952010-09-0707 September 2010
Revised NRC Staff Rebuttal Testimony of Richard A. Plasse Concerning Aging Management Programs
ML1025005972010-09-0707 September 2010
Revised NRC Staff Rebuttal Testimony of John Giessner Concerning the Safety Culture Contention and the Reactor Oversight Process
ML1025005982010-09-0707 September 2010
Revised NRC Staff Rebuttal Testimony of Dr. Valerie E. Barnes, June Cai, Molly Jean Keefe, and Audrey L. Klett Concerning Safety Culture and NRC Safety Culture Policy Development and Implementation
ML1025006002010-09-0707 September 2010
Revised Redlined NRC Staff Testimony of Richard A. Plasse Concerning Safety Culture Contention
ML1025006012010-09-0707 September 2010
Revised Redlined NRC Staff Testimony of Dr. Dan J. Naus and Abdul H. Sheikh Concerning the Safety Culture Contention and the Reactor Refueling Cavity Leakage
ML1025006032010-09-0707 September 2010
Revised Redlined NRC Staff Rebuttal Testimony of Richard A. Plasse Concerning Aging Management Programs
ML1025006052010-09-0707 September 2010
Revised Redlined NRC Staff Testimony of Dr. Valerie E. Barnes, June Cai, Molly Jean Keefe, and Audrey L. Klett Concerning Safety Culture and NRC Safety Culture Policy Development and Implementation
ML1025006062010-09-0707 September 2010
Revised Redlined NRC Staff Testimony of John Giessner Concerning the Safety Culture Contention and the Reactor Oversight Process
ML1025006072010-09-0707 September 2010
Revised Redlined NRC Staff Rebuttal Testimony of Abdul H. Sheikh and Dr. Dan J. Naus Concerning the Safety Culture Contention and Reactor Refueling Cavity Leakage
ML1025006082010-09-0707 September 2010
Revised Redlined NRC Staff Rebuttal Testimony of Dr. Valerie E. Barnes, June Cai, Molly Jean Keefe, and Audrey L. Klett Concerning Safety Culture and NRC Safety Culture Policy Development and Implementation
ML1025006092010-09-0707 September 2010
Revised Redlined NRC Staff Rebuttal Testimony of John Giessner Concerning the Safety Culture Contention and the Reactor Oversight Process
ML1024605112010-09-0303 September 2010
Revised Testimony of Scott D. Northard, Kurt W. Petersen, and Ed M. Peterson II on Safety Culture Contention
ML1024605182010-09-0303 September 2010
Revised Testimony of Scott D. Northard, Kurt W. Petersen, and Ed M. Peterson II on Safety Culture Contention.(Redlined)
ML1024605122010-09-0303 September 2010
Revised Testimony of Steven C. Skoyen on Safety Culture Contention. (Redlined)
ML1024605132010-09-0303 September 2010
Revised Testimony of Steven C. Skoyen on Safety Culture Contention
ML1024605162010-09-0303 September 2010
Revised Rebuttal Testimony of Steven C. Skoyen on Safety Culture Contention.(Redlined)
ML1024605172010-09-0303 September 2010
Revised Rebuttal Testimony of Scott D. Northard, Kurt W. Petersen, and Ed M. Peterson II on Safety Culture Contention. (Redlined)
ML1024605202010-09-0303 September 2010
Revised Rebuttal Testimony of Scott D. Northard, Kurt W. Petersen, and Ed. M. Peterson II on Safety Culture Contention
ML1024605142010-09-0303 September 2010
Revised Rebuttal Testimony of Steven C. Skoyen on Safety Culture Contention
ML1022504692010-08-13013 August 2010
NRC Staff Rebuttal Testimony of Richard A. Plasse Concerning Aging Management Programs
ML1022504652010-08-13013 August 2010
NRC Staff Rebuttal Testimony of Abdul H. Sheika and Dr. Dan J. Naus Concerning the Safety Culture Contention and Reactor Refueling Cavity Leakage
ML1022504682010-08-13013 August 2010
NRC Staff Rebuttal Testimony of Dr. Valerie E. Barnes, June Cai, Molly Jean Keefe, and Audrey L. Klett Concerning Safety Culture and NRC Safety Culture Policy Development and Implementation
ML1022504722010-08-13013 August 2010
NRC Staff Rebuttal Testimony of John Giessner Concerning the Safety Culture Contention and the Reactor Oversight Process
ML1022504972010-08-12012 August 2010
Rebuttal Declaration of Steven C. Skoyen on Safety Culture Contention
ML1022505022010-08-12012 August 2010
Rebuttal Testimony of Scott D. Northard, Kurt W. Petersen & Ed M. Peterson II on Safety Culture Contention
ML1022505072010-08-12012 August 2010
Joint Rebuttal Declaration of Scott D. Northard, Kurt W. Petersen & Ed M. Petersen II on Safety Culture Contention
ML1022505182010-08-12012 August 2010
Rebuttal Testimony of Steven C. Skoyen on Safety Culture Contention
ML1021503762010-07-30030 July 2010
NRC Staff Testimony of Richard A. Plasse Concerning Safety Culture Contention
ML1021200682010-07-30030 July 2010
Intervenor-Direct Testimony of Christopher I. Grimes on Behalf of the Prairie Island Indian Community
ML1021503912010-07-29029 July 2010
Applicant-Joint Declaration of Scott D. Northard, Kurt W. Petersen and Ed M. Peterson II on Safety Culture Contention
ML1021503862010-07-29029 July 2010
Applicant-Testimony of Scott D. Northard, Kurt W. Petersen and Ed M. Peterson II on Safety Culture Contention
ML1021503822010-07-29029 July 2010
Applicant-Testimony of Steven C. Skoyen on Safety Culture Contention
ML1021503802010-07-29029 July 2010
Applicant-Declaration of Steven C. Skoyen on Safety Culture Contention (Partial Resubmittal)
2010-09-07
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REVISED: 9/7/2010 August 13, 2010 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
NORTHERN STATES POWER COMPANY ) Docket Nos. 50-282-LR/ 50-306-LR
)
(Prairie Island Nuclear Generating Plant, )
Units 1 and 2) )
NRC STAFF REBUTTAL TESTIMONY OF RICHARD A. PLASSE CONCERNING AGING MANAGEMENT PROGRAMS Q1. Please state your name, occupation, and by whom you are employed.
A1. My name is Richard A. Plasse (Plasse). I am employed as a project manager in the Nuclear Regulatory Commissions Office of Nuclear Reactor Regulation, Division of License Renewal. A statement of my professional qualifications is attached to my July 30, 2010 pre-filed testimony.
Q2. What is the purpose of your testimony?
A2. The purpose of my testimony is to respond to testimony and exhibits submitted by the Prairie Island Indian Community (PIIC) and Northern States Power Company (NSP or Applicant) on July 30, 2010.
Q3. In A18 and A31, Mr. Grimes testifies that the Applicants performance with respect to the leakage of borated water and the Applicants performance issues with respect to the White finding related to the design of the component cooling water system call into question the Applicants ability to implement aging management programs during the period of extended
operation. Why is Mr. Grimes reliance on these performance issues misplaced?
A3. Mr. Grimes reliance on these performance issues in the license renewal is misplaced. These issues are not addressed as part of the license renewal process. They are addressed by the Reactor Oversight Program. As I stated in my July 30, 2010 testimony at A17-18, the Staffs determination of the adequacy of AMPs presumes that if a license is issued, the licensee will implement the AMPs in accordance with its renewed licensing basis.
The Staff can presume this because Regional Staff will conduct a post-approval inspection in which it will sample aging management programs to check for implementation and Resident Inspectors and Regional Staff will routinely conduct inspections and assessments of compliance during the period of extended operation. Therefore, when it issues its Safety Evaluation Report, there is no need for the Staff to try to judge the Applicants ability to implement aging management programs.
Q4. In A22-23, Mr. Grimes testified that performance issues associated with NSPs mispositioning of a valve violate certain elements of an effective aging management program.
Do you agree?
A4. No. According to Mr. Grimes testimony and the document he referred to (Information Notice 2009-11, Configuration Control Errors,), the performance issues regarding the mispositioned valve included 1) the valve not being labeled, 2) the valve not being locked, and 3) procedures did not identify that the mispositioned valve should be locked. These performance issues are not relevant to whether or not NSPs AMPs effectively manage the effects of aging. Pursuant to NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Rev.1, dated September 2005 (NRC Staff Exhibit No. 4ANRC000006), the Staffs aging management review does not include a review of configuration control errors and these issues were not considered by the Staff in its evaluation
of NSPs aging management programs.
