ML19340F166
| ML19340F166 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/09/1981 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Donlon W NIAGARA MOHAWK POWER CORP. |
| References | |
| EA-81-008, EA-81-8, NUDOCS 8101210159 | |
| Download: ML19340F166 (3) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION h /[..
WASHINGTON, D. C. 20555 g,, y ;j s, ~.
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Docket No. 50-220 EA 81-08 Niagara Mohawk Power Corporation 0
ATTN:
Mr. William J. Donlon President 300 Erie Boulevard West D
D fl M A I Syracuse, New York 13202
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Dear Mr. Donlon:
Ycur De: ember 19, 1980 response to our Nevereer 26, 1980 Notice of Violation and Notice of Proposed Imposition of Civil :enalties; the December 29, 1980 M: tion to Dismiss Proceeding with Respect te Allegation 3 of hetice of Vicia.icn, filec by ycur attorney on behalf of ieiagara Mohawk Power Cer::ra. tion; and your January 3,1981 Respo se to Show Cause Order are being evaluated.
To ccmplete our evaluations we recuire the following information:
1.
What specific actions were taken on er befere December 31, 1979 to implement NUREG 0578 as clarified on pages 31-34 and 37 of tne enclosure t: the October 30, 1979 NRC letter? We are particularly interested in tne description of the systems /methoc anc procecures for :encucting all aspects of the measurement / analysis referred to at pages 33 and 34 of the en:lesure to the October 30, 1979 letter.
2.
Wnat was meant by the use of the phrases "c::ument our comsliance with NUREG 0578" and " attached are the cesi;. details and the status of the cutstanding commitments" as those phrr,tes were used in the December 31, 1979 letter?
In addition, was it your intention nat the NRC rely on that letter?
If not, what was the purpose of tne commitments in that letter?
3.
Provide copies of procedures in effect on Cecember 31, 1979 and indicate dates first adopted, to assure that empicyees would, if existing in-line instrumentation went off scale:
(a) place the portable monitor in the preselected location; and (b) provide radiation readings to the control room every 15 minutes during an accident.
4.
Provide copies of procedures in effect on December 31, 1979, and indicate dates first adopted, to assure that at least one high range survey monitor capable of providing continuous readout for seven consecutive days would be in the emergency in plant survey kit and available to be used in the case of an accident for the purpose of measuring radiation from the exhaust air.
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8101DkD
Niagara Mohawk Power Corporation JAN 3
- gg; 5.
What measurements are required to be performed with the high range survey monitors in the emergency in plant survey kit? (i.e., what are the "other required high range surveys"? under what conditions are they performed?
at which locations would they be performed? and at what frequency would they be performed?)
6.
Provide the analysis you performed showing that there is no significant difference in amount or efficiency of shielding between the cave as proposed on December 31, 1979 and the lead brick which was in place prior to October 10, 1980.
How would this analysis change if it accounted for background radiation, other than from " adjoining sample lines," that might be present at various times under postulated accident conditions.
In addition, provide your analysis of dose rates at various times in the vicinity of the monitor under postulated accident conditions.
7.
Investigation Reper' 50-220/80-17 contains the foliowing sworn statements:
(a) James Bartlett stated:
"With regard to the' response to the order, I am familiar with the general process of preparing such documents, however I did not participate in preparation of the specific cata, nor was I personally aware of the basis for formulating the imple-mentation schedule...
"In a ger.eral sense I was kept aware of the general status of these items through verbal contact with our engineering branch and site management."
(b) Donald P. Cfse stated (regarding the December 31, 1979 letter):
"At the time I signed this document, I was of the understanding that all the items were completed as stated.
I was not personally aware of the specific details as to how the items were actually com::le ad but relied on the management chain below me who con-firmed t!Mt all the items, inclucing 2.1.8.B were complete."
(c) Tnoma: E. Lempges stated:
"With regard to the basis of the response for the answer to show cause I would state that the answer to show cause was based primarily on the Decemoer 31, 1979 submittal...I do not personally know on wnat easis Francisco crafted this letter." (emphasis added)
(d) Thomas J. Perkins stated:
"The majority of the resconse letter was based on the submittal of Decemoer 31, 1979.
This letter of Decemoer 31, 1979 was prepared in the same manner as tne response to snow cause letter only in more detail." (empnasis acced)
Mr. Perkins further stated:
"In my first statement I stated that I was aware that the lead cave was not completed at the time of the Decembe-31, 1979 letter and the Janeary 22, 1980 letter.
However, since I placed no significance to the cave I did not feel it necessary to relay the fact that the cave was not completed to anyone else up the management chain."
P00R ORIGINAL
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. ' Niagara Moha'k Power Corporation (e) Peter E. Francisco stated:
"Folicwing receipt of the show cause order, I was instructed to prepare the response to the show cause order. The affidavit was preparec with the assistance of an attorney.
Exhibit A to the affidavit was prepared by myself.
The mechanics of the chart were based orimarily on the NRC recommendation in tne October 30 ietter.
The oasis I used was based on a review of tne Decetoer 31, 1979 status and vercal contact witn various site supervisors and particularly Mel Silliman and Ed teach." (empnasis added)
(f) Edward W. Leach stated:
"When the December 31, 1979 letter was prepared by Peter Francisco at Corporate Headquarters he relied on verbal contact and discussions with me to formulate the 2.1.8.B portion of the letter and what we had done.
In the process of preparing the letter, I receivec a craft copy througn the company mail for comment.
I made some changes to the draft and telecopied it to Francisco on 12-27-79.
Tr.e e was no further substantial change to this area of the status report and it went out in its final form.
To the best of my <new' edge this was the only formal reference material use: 'o-input into the show cause order resoonse." (emphasis ad e:)
In light of these statements was :nvestigation Report 50-220/80-17 reviewed by you or your staff p-icr to preparation of your December 19, 1980 response? If it was re.iewed, identify the basis on which you reconcile the apparent in:c7sistency between the sworn state-ments and the statement in your December 19, 1980 response that the January 22, 1980 response did n:t "... refer to or rely upon, implicitly or explicitly, the state ents in NM's December 31, 1979 status letter."
In view of the significance of th#s action and the desirability of a prompt resolution, it is impo tant that you provide your supple-mental response, under oath cc af'i mation, ny not later than January 23, 1981.
Your previous responses and your reoly to this letter will be considered in determining wnether further enforcement action is warranted.
In tnis regard, we ara carticularly concerned about the apparent inconsistencies addresses in item 7. above.
Sincerely, cf.fc:1 OWd ::7 V. S :ll3 Victor Stello, Jr., Director Cffice of Inspection and Enforcement P00R BRIGlnR
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