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Category:Legal-Pre-Filed Exhibits
MONTHYEARML16081A3252016-03-21021 March 2016 NRCR12001 - NRC Staff Prefiled Hearing Exhibit List (Revised) ML16078A4172016-03-18018 March 2016 ENTR20726 - Entergy Track 2 Exhibit List ML16078A4122016-03-18018 March 2016 NRC000236 - Crack Growth Rate Comparison - Eason Pathania Model to MRP Model- Excel Spreadsheet ML16078A4132016-03-18018 March 2016 NRCR11001 - Exhibt List NRC Staff Prefiled Hearing Exhibit List (Revised) ML15321A0352015-11-17017 November 2015 NYS000582 - Diagram of Strength Vs Amplitude by Dr. Richard T. Lahey ML15315A0132015-11-11011 November 2015 ENTR00726 - Track 2 Hearing Exhibit List ML15309A1292015-11-0505 November 2015 ENT000726 - Entergy Track 2 Hearing Exhibit List ML15309A1712015-11-0505 November 2015 RIVR14001 - Riverkeeper Tailored Track 2 Exhibit List ML15309A2212015-11-0505 November 2015 NRCR10001 - NRC Staff Track 2 Exhibit List ML15309A1552015-11-0404 November 2015 NYSR25001 - NYS Revised Tailored Exhibits List Relevant to Track 2 Contentions ML15313A4602015-11-0404 November 2015 NYSR25001 - Corrected Page 24 to Exhibits List Relevant to Track 2 Contentions ML15307A1152015-11-0303 November 2015 NYSR24001 - State of Ny Revised Hearing Exhibits List ML15307A8112015-11-0303 November 2015 NRC000230 - Corrections to Prefiled Testimony NRC000168 and NRC000197 ML15302A4672015-10-29029 October 2015 ENTR16001 - Entergy Revised Exhibit List ML15252A4442015-09-0909 September 2015 NYS000563 - Pressurized Water Reactor (PWR) Systems, USNRC Technical Training Center, Reactor Concepts Manual, Pages 4-1 to 4-28 ML15252A4432015-09-0909 September 2015 NYS000566 - Figure 1 for Supplemental Reply Testimony of Dr. Richard T. Lahey ML15252A5042015-09-0909 September 2015 NYS000568 - Supplemental Reply Statement of Position of the State of New York in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015) ML15252A5062015-09-0909 September 2015 NYS000570 - Supplemental Reply Statement of Position of the State of New York and Riverkeeper, Inc. in Support of Contention NYS-26B/RK-TC-1B (Public, Redacted) (September 9, 2015) ML15252A5092015-09-0909 September 2015 RIV000164 - NUREG-1740, ACRS, Voltage-Based Alternative Repair Criteria: a Report to the Advisory Committee on Reactor Safeguards by the Ad Hoc Subcommittee on a Differing Professional Opinion (2001) ML15252A5112015-09-0909 September 2015 RIVR13001 - Riverkeeper Updated Exhibit List ML15252A5752015-09-0909 September 2015 NYS000573 - Supplemental Reply Statement of Position of the State of New York and Riverkeeper, Inc. in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015) ML15252A5792015-09-0909 September 2015 NYS Updated Exhibit List ML15261A8302015-09-0404 September 2015 ENTR00615 - Entergy'S Statement of Position Re Contention NYS-25 (Embrittlement) - Redacted ML15222A9152015-08-10010 August 2015 ENT000648 - M. Mitchell, Chief, Vessels and Internals Integrity Branch, Response to Non-Concurrence Regarding Safety Evaluation for Topical Report MRP-227, Pressurized Water Reactor Internals Inspection and Evaluation Guidelines (Undated) ML15223A4512015-08-10010 August 2015 NRC000206 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 14 - Safety Analysis (2014) ML15223A4542015-08-10010 August 2015 NRC000207 - Regulatory Information Conference Presentation Slides, Recent Materials Inspections of PWR Reactor Internals (Mar. 2015) ML15223A4502015-08-10010 August 2015 NRC000205 - Indian Point, Unit 2, Updated Final Safety Analysis Report (Ufsar), Rev. 25, Chapter 3 - Reactor (2014) ML15223A3932015-08-10010 August 2015 NRCR00104 - on Yee Statement of Professional Qualifications (Revised) ML15223A3912015-08-10010 August 2015 NRCR00105 - Ching Ng Statement of Professional Qualifications (Revised) ML15222A8212015-08-10010 August 2015 ENT000617 - Curriculum Vitae of Timothy J. Griesbach ML15223A6712015-08-10010 August 2015 NRCR00147- NRC Staff'S Revised Statement of Position on State of New York and Riverkeeper'S Joint Contention NYS-38/RK-TC5 (Revised) ML15223A6752015-08-10010 August 2015 NRC000227 - Gary Stevens Statement of Professional Qualifications ML15222A8222015-08-10010 August 2015 ENT000618 - Curriculum Vitae of Randy G. Lott ML15223A7022015-08-10010 August 2015 NRCR900001 - NRC Staff Pre-filed Hearing Exhibit List (Revised) ML15222A8252015-08-10010 August 2015 ENT000629 - Letter from C. Grimes, NRC, to D. Walters, NEI, License Renewal Issue No. 98-0030 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Components (May 19, 2000) ML15222A8302015-08-10010 August 2015 ENT000634 - Entergy, IP2, FSAR Update, Revision 25 (2014) (Excerpts) ML15223A7792015-08-10010 August 2015 NRC000224 - IP3 FSAR Rev. 04 Chapter 16 ML15223A7812015-08-10010 August 2015 NRC000226 - Jeffrey C. Poehler Statement of Professional Qualifications ML15223A7832015-08-10010 August 2015 NRC000228 - Indian Point Unit 2 Technical Specifications 3.1.4 ML15223A7852015-08-10010 August 2015 NRC000229 - Indian Point, Unit 3 Technical Specifications 3.1.4 ML15223A7872015-08-10010 August 2015 NRC000196 - NRC Staff'S Initial Statement of Position on Contention NYS-25 (Reactor Vessel Internals) ML15223A3872015-08-10010 August 2015 NRCR00118 - Indian Point Unit 3 Technical Specifications (Excerpt) (Revised) ML15222A8352015-08-10010 August 2015 ENT000621 - Westinghouse, WCAP-17894-NP, Rev. 0, Component Inspection Details Supporting Aging Management of Reactor Internals at Indian Point Unit 2 (Sept. 2014) ML15223A8052015-08-10010 August 2015 NRC000169 - Indian Point, Unit 2 Technical Specifications (Excerpt) ML15223A9452015-08-10010 August 2015 NRC000223 - IP3 FSAR Rev. 04 Chapter 14 (2011) ML15223A3862015-08-10010 August 2015 NRC000222 - IP3 FSAR Rev. 04 Chapter 3 (2011) (Excerpt) ML15222B1242015-08-10010 August 2015 ENT000680 - Curriculum Vitae of Barry M. Gordon ML15222B1262015-08-10010 August 2015 ENT000687 - NRC, Safety Evaluation Report, Topical Report on ASME Section III Piping and Component Fatigue Analysis Utilizing the Westems Computer Code (WCAP-17577, Revision 2) (Undated) ML15222B1612015-08-10010 August 2015 ENTR00186 - Curriculum Vitae of Mark A. Gray ML15222A8482015-08-10010 August 2015 ENT000637 - NUREG-1874, Recommended Screening Limits for Pressurized Thermal Shock (PTS) (March 2010) 2016-03-21
[Table view] Category:Congressional Correspondence
MONTHYEARML23097A0822023-04-0606 April 2023 LTR-23-0084 Senator Charles Schumer Et Al., Letter Regarding Holtec Decommissioning International'S Decision to Expedite Its Planned Release of Over One Million Gallons of Radioactive Wastewater from the Indian Point Energy Center Into the ML21235A1002021-09-13013 September 2021 LTR-21-0219-1 Letter Response to Senator Chuck Schumer Et Al Letter Re Comments for the July 29, 2021 Government to Government Meeting Regarding Indian Point ML21235A1012021-09-13013 September 2021 LTR-21-0219-1 Enclosure Response to Senator Chuck Schumer, Et Al., Letter Comments for the July 29, 2021 Government-to-Government Meeting Regarding Indian Point ML21077A2732021-03-25025 March 2021 03-25-21 Letter to the Honorable Charles E. Schumer, Et Al., from Chairman Hanson Responds to Letter Regarding Concerns Related to the Commission'S Recent Decision to Deny Hearing Requests in the Indian Point Energy Center License Transfer ML21054A1992021-02-22022 February 2021 LTR-21-0062 Senator Charles Schumer, Et Al., Concerns Denial of the Hearing Requests Submitted Regarding the License Transfer from Entergy to Holtec for the Decommissioning of Indian Point and Urges the NRC to Reverse This Decision Under It ML21022A2212021-02-0505 February 2021 Letter to Senator Charles Schumer from Margaret Doane Response for NRC to Reconsider Its Decision to Not Allow for a Public Hearing in the Transfer of Indian Point'S License ML20336A2932020-11-20020 November 2020 Letter to the Honorable Charles E. Schumer Et Al., from Margaret M. Doane, Executive Director for Operations Re a Public Hearing in the Transfer of Indian Point'S License ML20328A2632020-11-16016 November 2020 LTR-20-0421 Senators Schumer and Gillibrand, and Representatives Lowey, Maloney, and Engel Letter Calling on the NRC to Reconsider Its Decision to Not Allow for a Public Hearing in the Transfer of Indian Point'S License ML20262H1382020-09-18018 September 2020 Letter from David C. Lew to Congresswoman Nita Lowey Regarding Indian Point Virtual Plant Safety Assessment, the Proposed License Transfer, and the Nrc'S Reviews Regarding the 42-inch Alonquin Incremental Market Natural Gas Pipeline ML20262H1842020-09-18018 September 2020 Letter from David C. Lew to Senator Kirsten Gillibrand Regarding Indian Point Virtual Plant Safety Assessment, the Proposed License Transfer, and the Nrc'S Reviews Regarding the 42-inch Alonquin Incremental Market Natural Gas Pipeline ML20087M2782020-03-11011 March 2020 LTR-20-0116 Sandra Galef, Assemblywoman, New York State Legislature, Et Al., Letter Inspector General'S Report on Concerns Pertaining to Gas Transmission Lines at the Indian Point Nuclear Power Plant Case No. 16-024 ML20023B3292020-01-21021 January 2020 LTR-20-0019 Senator Charles Schumer, Et Al., Letter Request for NRC to Extend the Public Comment Period for the License Transfer for Indian Point ML19329C9922019-11-21021 November 2019 LTR-19-0459 Senator Charles Schumer, Et Al., Letter to Holtec Regarding Oversight of the Decommissioning Process and the Potential Transfer of Indian Point'S Nuclear Regulatory Commission License from Entergy Corporation to Holtec Internati ML16208A4302016-08-15015 August 2016 08/15/16, Letter to Congressman Maloney from Chairman Burns responds to this letter with concerns regarding the restart of Indian Point Energy Center Unit 2 and the need for a safety review of Unit 3 ML16196A3832016-07-14014 July 2016 Acknowledgement Receipt of Letter to Congressman S.P. Maloney Letter Submitted to NRC on 06/17/2016 ML16196A3662016-06-17017 June 2016 LTR-16-0374: Representative Sean Patrick Maloney, Letter Concern with Restarting Operations at Indian Point Unit 2 Without Having Completed a Comprehensive Root Cause Analysis That Includes Metallurgical Testing of the Failed Baffle Bolts ML16146A2332016-06-0303 June 2016 06/03/2016 - Letter to Senator Kirsten Gillibrand from Chairman Burns re: Degraded Baffle Former Bolts at Indian Point, Unit 2 ML16146A2022016-06-0303 June 2016 06/03/2016 - Letter to Senator Barbara Boxer, Kirsten Gillibrand and Cory Booker from Chairman Burns re: Degraded Baffle Former Bolts at Indian Point Nuclear Power Plant, Salem Nuclear Plants and Diablo Canyon Power Plant ML16145A0722016-05-20020 May 2016 LTR-16-0285 Senator Barbara Boxer Et Al., Letter Degraded Baffle Former Bolts at Indian Point Nuclear Power Plant, Salem Nuclear Plants and Diablo Canyon Power Plant ML16132A3672016-05-10010 May 2016 LTR-16-0268 - Senator Kirsten Gillibrand, Congress, Ltr Degraded Baffle Former Bolts at Indian Point, Unit 2 ML16068A2322016-03-29029 March 2016 Letter to Senator Kirsten Gillibrand from Chairman Burns Accidental Release of Radioactive Material Into the Groundwater at the Indian Point Energy Center ML16055A4742016-03-10010 March 2016 03/10/16, Letter to the Honorable Nita Lowey from Chairman Burns Responds to her Letter Regarding the Recent Tritium Leak at the Indian Point Energy Center ML16050A4322016-02-18018 February 2016 LTR-16-0086 - Senator Kirsten Gillibrand, Letter re: Accidental Release of Radioactive Material into the Groundwater at the Indian Point Energy Center ML16074A0922016-02-11011 February 2016 02-11-16 Ack Ltr to Congresswoman Lowey Regarding a Tritium-Contaminated Water Leak Into Groundwater at Indian Point Energy Center ML16040A2712016-02-0808 February 2016 LTR-16-0061 - Representative Nita Lowey Letter Recent Tritium Leak Into the Groundwater at the Indian Point Energy Center ML15159A8652015-06-24024 June 2015 Ltr to Congresswoman Nita M. Lowey from Chairman Burns Responds to Her Letter to Build a New Gas Pipeline About one-quarter Mile from the Indian Point Energy Center Units 2 and 3 Reactors ML15153A2082015-06-16016 June 2015 Letter to Congresswoman Nita Lowey, from Chairman Burns Regarding Nuclear Safety at the Indian Point Energy Center Following a Transformer Fire on Ma 9, 2015 (Response) ML13234A0642013-08-20020 August 2013 08-20-13 Acknowledgment Letter to the Honorable Nita Lowey Signed Petition by Residents of New York and New Jersey on the Relicensing Renewal Requests for Reactors 2 and 3 at Indian Point (G20130601) ML13231A2412013-08-19019 August 2013 Limited Appearance Statement of Nita M. Lowey, U.S. Congress, Opposing Indian Point License Renewal ML13231A2242013-08-19019 August 2013 G20130601/LTR-13-0682-Ticket - Representative Nita Lowey Ltr. Signed Petition by Residents of New York and New Jersey, Urging the NRC to Deny the Relicensing Renewal Requests for Reactors 2 and 3 at Indian Point Entergy Center in Buchanan, ML13231A2222013-08-19019 August 2013 G20130601/LTR-13-0682 - Representative Nita Lowey Letter Signed Petition by Residents of New York and New Jersey, Urging the NRC to Deny the Relicensing Renewal Requests for Reactors 2 and 3 at Indian Point Entergy Center in Buchanan, Ny ML13141A3582013-05-0606 May 2013 G20130396/LTR-13-0439 - Senator Kirsten Gillibrand Ltr. Findings from a Recent Gao Report (March 2013) and the Lack of Information as to How Residents Outside of the 10-Mile Emergency Planning Zone Would React in an Emergency ML12340A7112012-07-12012 July 2012 Official Exhibit - ENT000544-00-BD01 - Letter from A. Macfarlane, Chairman, NRC, to E. Markey, U.S. Congressman, Regulatory Commitments (July 12, 2012) ML12233A7072012-07-12012 July 2012 Entergy Pre-Filed Hearing Exhibit ENT000544 - Letter from A. Macfarlane, Chairman, NRC, to E. Markey, U.S. Congressman, Regulatory Commitments (July 12, 2012) ML12318A0302012-03-16016 March 2012 State of New York Pre-Filed Evidentiary Hearing Exhibit NYS000461, Regulations and Policies to Undertake Safety and Other Improvements by NRC Licensees as Part of License Extension Proceedings (EDATS: SECY-2012-0131) ML15331A1592012-03-16016 March 2012 Official Exhibit - NYS000461-00-BD01 - Regulations and Policies to Undertake Safety and Other Improvements by NRC Licensees as Part of License Extension Proceedings (EDATS: SECY-2012-0131) ML12080A1512012-03-13013 March 2012 G20120186/LTR-12-0100/EDATS: SECY-2012-0127 - Ltr. Fm Rep. Nita M. Lowey Concerns About Evacuation Plans for Impacts of a Fukushima-Level Accident at Indian Point ML11270A0772011-09-26026 September 2011 Response of EDO to Representative Lowey Letter Regarding Replacement Power for IP2 and IP3 ML11265A1392011-09-26026 September 2011 G20110686/LTR-11-0482/EDATS: SECY-2011-0514 - Ltr to Rep. Nita M. Lowey Fm R. W. Borchardt Regulation Identification Number (Rule) Flexibility on Relicensing Terms - Indian Point ML11263A2632011-09-16016 September 2011 Letter from the Secretary in Response to Congresswoman Nita Lowey'S Letter of August 15, 2011 ML11263A0102011-08-15015 August 2011 G20110686/LTR-11-0482/EDATS: SECY-2011-0514 - Ltr. Rep. Nita M. Lowey Regulation Identification Number (Rule) Flexibility on Relicensing Terms - Indian Point ML11210B4222011-07-21021 July 2011 G20110552/LTR-11-0432/EDATS: SECY-2011-0430 - Ltr. Nita Lowey Indian Point Safety Concerns CY-92-223, G20110523/LTR-11-0411/EDATS: SECY-2011-0411 - Ltr. from Rep. E.J. Markey to Chairman Jaczko NRC Safety Requirements for Reactors Granted Construction Permits Prior to 19712011-07-14014 July 2011 G20110523/LTR-11-0411/EDATS: SECY-2011-0411 - Ltr. from Rep. E.J. Markey to Chairman Jaczko NRC Safety Requirements for Reactors Granted Construction Permits Prior to 1971 ML11171A5182011-06-22022 June 2011 G20110418/LTR-11-0322/EDATS: SECY-2011-0328 - Ltr to Rep. Nita M. Lowey from R. W. Borchardt Nrc'S Annual Assessment Meeting for Indian Point Energy Center ML11329A0452011-05-31031 May 2011 Acknowledgement Letter to Honorable Kirsten E. Gillibrand, U.S. Senate, Requesting a Review of All Past Agreements and Exemptions Granted to the Licensee of the Indian Point Nuclear Generating Stations ML11159A1382011-05-26026 May 2011 G20110418/LTR-11-0322/EDATS: SECY-2011-0328 - Ltr. Nita M. Lowey Nrc'S Annual Assessment Meeting for Indian Point Energy Center ML11147A1002011-05-24024 May 2011 G20110384/LTR-11-0315/EDATS: SECY-2011-0312 - Ltr. from Sen. Kirsten E. Gillibrand Recent Inspection of Indian Point Nuclear Generating Units 2 & 3 ML11172A1582011-04-29029 April 2011 G20110462/LTR-11-0259/EDATS: SECY-2011-0367 - Ltr. Sen. Kirsten E. Gillibrand, Indian Point - Safety Concerns ML1109400682011-03-24024 March 2011 LTR-11-0171 - Ltr. Rep. Nita Lowey Urges the White House to Coordinate with the NRC and FEMA to Ensure the Soundness of the Emergency Evacuation Process and Give Full Consideration of the Risks and Consequences Associated with Indian Point ML1015905462010-06-0303 June 2010 LTR-10-0195 - Response to Request from REP Nita Lowey Regarding Shortfall of Decommissioning Funds for Indian Point Unit 2 2023-04-06
[Table view] |
Text
NYS000461 Submitted: November 9, 2012 EDO Principal Correspondence Control FROM: DUE: 04/17/12 EDO CONTROL: G20120192 DOC DT: 03/16/12 FINAL REPLY:
Representative Edward J. Markey TO:
Chairman Jaczko FOR SIGNATURE OF : ** PRI ** CRC NO: 12-0108 Chairman DESC: ROUTING:
Regulations and Policies to Undertake Safety and Borchardt Other Improvements by NRC Licensees as Part of Weber License Extension Proceedings (EDATS: SECY-2012- Virgilio 0131) Ash Mamish OGC/GC DATE: 03/22/12 Leeds, NRR Dean, RI ASSIGNED TO: CONTACT: Pedersen, RIII Zimmerman, OE EDO Rihm McCrary, 01 Bell, OIG SPECIAL INSTRUCTIONS OR REMARKS: Burns, OGC Schmidt, OCA Please prepare response in accordance with OEDO Notice 2009-0441-02 (ML093290179). Offices to provide input to Roger Rihm, OEDO, if required.
Roger Rihm will coordinate response with OGC and OCA.
EDATS Number: SECY-2012-0131 Source: SECY 6enerlInfomaio Assigned To: OEDO OEDO Due Date: 4/17/2012 11:00 PM Other Assignees: SECY Due Date: 4/19/2012 11:00 PM
Subject:
Regulations and Policies to Undertake Safety and Other Improvements by NRC Licensees as Part of License Extension Proceedings
Description:
CC Routing: EDO ADAMS Accession Numbers - Incoming: Response/Package: ML12108A307 ML12083A128 16hrIfomto.
Cross Reference Number: G20120192, LTR- 12-01 08 Staff Initiated: NO Related Task: Recurring Item: NO File Routing: EDATS Agency Lesson Learned: NO OEDO Monthly Report Item: NO IAction rcs Inomtn Type: Letter Priority: Medium Sensitivity: None Signature Level: Chairman Jaczko Urgency: N'0 Approval Level: No Approval Required OEDO Concurrence: YES OCM Concurrence: NO OCA Concurrence: NO Special Instructions: Please prepare response in accordance with OEDO Notice 2009-0441-02 (ML093290179). NRR to provide input to Roger Rihm, OEDO, if required. Roger Rihm will coordinate response with OGC and OCA.
.Ie Originator Name: Representative Edward J. Markey Date of Incoming: 3/16/2012 Originating Organization: Congress Document Received by SECY Date: 3/22/2012 Addressee: Chairman Jaczko Date Response Requested by Originator: NONE Incoming Task Received: Letter Page 1 of I
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Mar 22, 2012 11:06 PAPER NUMBER: LTR-12-0108 LOGGING DATE: 03/16/2012 ACTION OFFICE: EDO AUTHOR: REP Edward Markey AFFILIATION: CONG ADDRESSEE: Gregory Jaczko
SUBJECT:
Request information about NRC regulations and policies surrounding commitments to undertake safety and other improvements made by NRC licensees as part of their license extenstion proceedings ACTION: Signature of Chairman DISTRIBUTION: RF, OCA to Ack LETTER DATE: 03/16/2012 ACKNOWLEDGED No SPECIAL HANDLING: Commission Correspondence NOTES: Response requested by Friday, April 6, 2012 FILE LOCATION: ADAMS DATE DUE: 03/30/2012 DATE SIGNED:
EDO -- G20120192
COMMITTEES EDWARD J. MARKEY 2108 RAYBURN HOUSE OFFICE RUILDING WASHINGTON, DC 20515-2107 NATURAL RESOURCES .* 7TH DISTRICT, MASSACHUS S (202) 225-2836 RANKING DEMOCRAT ....................... DISTRICT OFFICES:
ENERGY AND COMMERCE ~~DS~C FCS b HIGHSTREET. SUITE 101 Ciu At M ' q MEDFORD, MA 02155 If. wouge oft(781) 5 ................
396.-2900 1 188 CONCORD STREET, SUITE 102 140,5rdington, DC 20515-2107 FRAM!NGHAM, MA 01702 (508) 875--2500 M arch 16, 2012 ................
httpý/lmarkey~house~gov The Honorable Greg Jaczko, Chairman Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852
Dear Chairman Jaczko:
I am writing to request information about Nuclear Regulatory Commission (NRC) regulations and policies surrounding commitments to undertake safety and other improvements made by NRC licensees as part of their license extension proceedings. I am concerned that recent inspections at Entergy's Vermont Yankee Nuclear Power Station in Vernon, Vermont and Xcel's
.Monticello Nuclear Generating Station in Monticello, Minnesota have underscored broader weaknesses in the NRC'S general commitments policy - weaknesses that have also been identified by a recent report by the NRC Office of the Inspector General (OIG).
As you know, commitments are docketed, written statements describing a specific action that a licensee has agreed or volunteered to take.' The NRC considers commitments as appropriate for matters that are of significant interest to NRC staff but do not warrant a more formal regulatory control mechanism. Commitments are neither legally binding nor obligations of a license, but failing to meet a commitment can result in the issuance of a Notice of Deviation, which is less severe than a Notice of Violation but allows NRC staff to request information if the implementation of an action was not consistent with the agreed-upon commitment.
On December 22, 2011, the NRC released a report on its October 20, 2011 inspection at Vermont Yankee during a re-fueling outage.2 The inspection was an examination of commitments made during the renewal license application process. When the NRC approved Vermont Yankee's relicensing application March 21, 2011 , Entergy agreed to comply with more than 50 license renewal commitments in preparing for the extended period of operation, which begins March 22, 2012. Although there were no findings identified during this inspection, the NRC inspectors did challenge the completion of several commitments:
Commitment 6: The aging of some nuclear plant components is tracked by monitoring the heatup and cooldown cycles they experience. The resulting metal expansion and contraction causes -thermal stresses that can 'reduce safety margins.
Workers at Vermont Yankee had been tracking the thermal cycle information by 1Nuclear Energy Institute Guidelines For Managing NRC Commitment Changes (NEI 99-04) 2 Vermont Yankee Nuclear Power Station - NRC Integrated Inspection Report 0500027 11201 1011 3 Vermont Yankee Nuclear Power Station License Renewal Application (http://www~nrc gov/reactors/operating/licensing/renewal/applications/vermont-yankee~htmi)
manually recording the number of times the reactor started up and shut down.
When the NRC questioned this practice during its review of the Vermont Yankee license renewal application, the company pledged to use a computerized monitoring system called FatiguePro. This is a more sophisticated tool that is commonly used in the nuclear industry to monitor thermal stresses caused by heatups and cooldowns. The NRC inspectors found that Entergy is not using a computerized monitoring but is still using manual monitoring. The NRC inspection report notes that Entergy has therefore effectively "rescinded the commitment".
o Commitment 12: Many safety systems at nuclear plants feature, heat exchangers.
For example, heat exchangers provide cooling for the engines of the emergency diesel generators, provide cooling for the oil used to cool and lubricate the motors in the high pressure coolant injection and reactor recirculation systems, and heat exchangers also cool the water in spent fuel pools. The performance of heat exchangers degrades with time, and the agreed-upon monitoring program will inspect heat exchangers for degradation, evaluate any degradation for its effects on the heat exchanger's design functions including its ability to withstand a seismic event. The inspectors determined that additional .NRC review was appropriate prior to the period of extended operations to determine that Entergy meets this commitment.
- Commitment 25: Entergy agreed to implement the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program, which is a program to detect the effects of loss of fracture toughness due to thermal aging in the CASS steel reactor coolant-system piping. The aging mechanism of concern is degradation caused by neutron bombardment, which tends to make metals more brittle and failure-prone. The industry-developed detection program uses three criteria for determining when CASS components must be monitored for aging degradation: (1) cumulative neutron bombardment, (2) material toughness, and (3) stress applied to the component. The NRC inspectors found that Entergy had adopted the industry methods, but had used a value. 1,000 times higher for the cumulative neutron bombardment criterion and thus there was "a contradiction between the current program and what Entergy had submitted in the [license renewal] application". By using the different criterion, workers might exclude components from aging degradation monitoring that the industry standard would deem to warrant monitoring.
On December 29, 2011 the NRC released a report4 on its December 15, 2011 Special Inspection at Monticello to evaluate the September 2, 2011 identification of substantial blockage in the intake building fire protection piping. As part of Monticello's License Renewal Application (LRA) 5, which was approved on November 8, 2006, the licensee committed to manage the effects of aging on the structure, systems and components of the plant by implementing aging management programs (AMPs), including a program for its fire protection 4 Monticello Nuclear Generating Plant NRC Special Inspection Team (SIT) Report 05000263/201 1010 5 http://www.nrc.gov/reactors/operating/licensing/renewal/applications/monticello.html
water distribution system. The licensee made a commitment to incorporate into the AMP any operating experience reports - either externally from other nuclear power plants or internally from Monticello itself- that might affect the Fire Water System. The NRC inspectors found seven such operating experience reports that were not reviewed at Monticello, all of which involve blockage of fire sprinkler piping,7 demonstrating that they did not satisfy their license renewal commitment. Had the licensee fulfilled that commitment, it may have avoided the cause of the Special Inspection: fire sprinkler piping at the plant becoming clogged with rust particles.
The NRC has publiclystated that "...public confidence and trust in the license renewal process hinges on the NRC's confirmation that the licensee's commitments have been completed.
The fulfillment of these commitments is important because it forms the basis for the agency's determination of reasonable assurance that the effects of aging will be managed throughout'the period of extended operation...,,6 However, in a September 19, 2011 report, the Office of the Inspector General (OIG) identified significant problems in the NRC's management of licensee commitments. 7 Specifically, the NRC OIG found:
" The NRC inconsistently implements the audits of licensee commitment management programs because agency guidance is incomplete and imprecise, which can result in ineffective audits.
- NRC training does not effectively address the definition and use of commitments and is not provided to all agency staff involved in reviewing licensee commitments, potentially resulting in the misapplication of commitments by NRC staff.
" The NRC does not systematically track commitments and thus cannot ensure oversight of commitments.
The OIG report authors also made five specific recommendations for actions the NRC should take to address these problems:
0 Revise NRC policy8 on conducting commitment management audits to include detailed direction on how to sample commitment for audit. For example, a checklist of sources to be used in identifying the complete collection of commitments from which to sample.
- Revise NRC policy8 on conducting commitment management audits to include well-defined expectations and guidelines regarding the conduct of those audits. The guidelines should include an expectation that audited commitments are reviewed to ensure that they have been appropriately implemented in the plant facility, procedures, program, or other plant documentations.
- Develop training that addresses the definition and use of commitments and provide the training to all agency staff involved in reviewing reactor licensee commitments.
- Identify ways to determine how many commitments exist that are considered safety significant and/or necessary for approval of proposed licensing actions. This could be accomplished by either: (1) Project managers identifying such commitments as part of the triennial commitment management audits, or (2) conducting a review of all existing commitments and identifying any inappropriately applied commitments.
6 http://www.nrc.gov/reactors/operating/licensing/renewal/introduction/inspections/faq-ip71003.htmi#2 7 Audit of NRC's Management of Licensee Commitments (O[G-1 I-A-17)
LIC-105, Managing Regulatory Commitments Made by Licensees to NRC
- Depending on the outcome of the efforts to meet recommendation 4, develop and utilize a tool for systematically tracking the status of commitments that are deemed safety significant and/or necessary for approval of proposed licensing actions.
The cases at Vermont Yankee and Monticello and the OIG report clearly indicate that reforms in the renewal license commitment system are necessary. In order to evaluate what steps the Commission and its staff are taking to respond to these safety issues, I hereby request that you provide me with the following information:
- 1. How and when will the NRC re-evaluate Entergy's actions toward meeting commitments 6, 12, and 25 for the Vermont Yankee power plant?
- 2. How and when will the NRC re-evaluate Xcel's actions toward meeting its commitment regarding the Aging Management Plan for the Fire Water System at the Monticello Nuclear Generating Station?
- 3. Please provide a list of all commitments for relicensing that each licensee that has received a license extension from the NRC has made since January 1, 2001. Please also provide details of how and when the NRC has validated each of these commitments. For any commitments that the NRC has not verified, how and when does the NRC plan to do so? If no such plans are contemplated, why not?
- 4. Please~provide copies of all Notices of Deviation that have been issued to licensees for failing to meet or inadequately meeting commitments. For each of these Notices of Deviation, what further action was taken by the licensee and by the NRC, and how were licensee actions validated?
- 5. What actions is the NRC taking to implement the recommendations identified in the OIG's audit report? How were these actions decided upon? What is the timeline for implementing those actions? The OIG report laid out five specific recommendations.
Does the NRC plan to implement each of those recommendations? If so, how and when?
If not, why not?
Thank you very much for your consideration of this serious matter. Please provide your response no later than close of business Friday; April 6, 2012. If you have any questions or concerns, please have your staff contact Dr. Makenzie Lystrup or Dr. Michal Freedhoff of my staff at 202-225-2836.
Sincerely, Edward J. Markey4