ML18046A136
| ML18046A136 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/07/1980 |
| From: | Stephen Burns NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML18046A137 | List: |
| References | |
| ISSUANCES-CIV, NUDOCS 8011100629 | |
| Download: ML18046A136 (3) | |
Text
- ~*
~--
J "i"'.. '*,./.*
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION "BEFORE THE. ADMINISTRATIVE LAH. JUDGE In the Matter of CONSUMERS POWER COMPANY (Palisades Nuclear Power Facility)
)
)
)
~
11/7 /80 Docket No.
50~255 (Civil Penalty)
NRC STAFF'S REQUESTS FOR ADMISSIONS BY CONSUMERS. POWER. COMPANY.....
Pursuant to 10 CFR 2.742 of the Commission's regulations, the NRE Staff requests Consumers Power Company (CPC) to make the following admissions.
CPC should answer these requests no later than ten days after service. For each document which is the subject of a request for admission, a copy of the docu-ment is attached.
- 1.
Does CPC admit that the two manual containment isolation valves in Containment Building Penetration 4a were found locked open on September 11, 1979?
- 2.
Does CPC admit that Ted B. Jones found the valves locked open on September 11, 1979?
- 3.
Does CPC admit that, when the valves were discovered locked open on September 11, 1979, the valves were locked open by virtue of a steel chain threaded through the spokes of the valve operating wheels, through the valve yoke, and joined by a padlock?
- 4.
Does CPC admit that, prior to September 11, 1980, the last local leak test of penetration 4.a occurred on March 20, 1978?
- 5.
Does CPC admit that Document 11A 11 is a true copy of a letter sent by R.B. DeWitt, CPC, to Victor Stello, Jr., NRC, on November 29, 1979, which letter concerns CPC's "Response to Notice of Violation?
- Sll1 111 CO fo 1!..0\\
-__,- I: 6.
Does CPC admit that Document 118 11 is a true copy of a letter sent by R.C. Youngdahl, CPC, to Victor Stello, Jr., NRC, on November 29, 1979, including revisions to page 7 of the letter, which letter concerns CPC's response to "Notice of Proposed Imposition of Civil Penalties"?
- 7.
Document 118 11 (letter to V. Stello from R. C. Youngdahl, dated November 29, 1979) includes as "Exhibit l" a table of days on which the Palisades facility was operated in other than a cold shutdown condition.
Does CPC admit that the Palisades facility was operated in other than a cold shut-down condition on all days during 1978 and 1979 which are marked.by an 11X 11 or 11*
11 in the exhibi-t?
- 8.
Does CPC admit that Document "C" is a true copy of a letter sent by David P. Hoffman, CPC, to James G. Keppler, NRC, on September 28, 1979, and its enclosure, Licensee Event Report No.79-037?
- 9.
Does.CPC admit that Document 11D 11 is a true copy of a letter sent by David P. Hoffman, CPC, to James G. Keppler, NRC, on October 31, 1979 and its enclosure, Revision l to Licensee Event Report No.79-037?
- 10.
Does CPC admit that Document 11E 11 is a true copy of CPC internal memorandum RAE 75-79, dated October 18, 1979, with its attachments?
- 11.
Does CPC admit that the two manual isolation valves in Penetration 4.a were not listed on the containment integrity checklist (C.L.3.3) used between March 30, 1978, and September 11, 1979?
- 12.
Does CPC admit that neither the shift supervisor nor the plant health physicist signed off on Procedure H.P. 6.27 after HEPA filter replacement and testing were completed in Penetration 4.a on or about April 6, 1978?
,"'\\--
- .. /
1'1-:
- 13.
Does CPC admit that neither the shift supervisor nor the plant health physicist were notified upon completion of HEPA filter replacement and testing in Penetration 4.a on or about April 6, 1978?
- 14.
Does CPC admit that Thomas P. Neal, an employee of CPC, did not ob-serve the replacement and testing of the HEPA filter in Penetration 4.a between April 4 and 7, 1978?
- 15.
Does CPC admit that the containment integrity checklist (C.L.3.3) was completed for Penetration 4.a on April l or 2, 1978?
- 16.
Does CPC admit that the two manual containment isolation valves in penetration 4.a are located in a vital area as defined in 10 CFR 73.2(h)?
- 17.
Does CPC admit that it controls access to the vital area within which the two manual containment isolation valves are located?
Dated at Bethesda, Maryland this 7th day of November, 1980.
Enclosures:
Documents A, B, C, D, E
- Respectfully submitted_,
~lv--6~
Stephen G. Burns Counsel to NRC Staff