ML20035B569
| ML20035B569 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/18/1993 |
| From: | Mcgranery J ENVIRONMENTAL & RESOURCES CONSERVATION ORGANIZATION, MCGRANERY, J.P., JR. |
| To: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE |
| References | |
| CON-#293-13769 CLI-93-03, CLI-93-3, DCOM, NUDOCS 9304020163 | |
| Download: ML20035B569 (3) | |
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SENT BY;D0'S LCHNES & ALBERTSON: 3-19-93 t 4:21PM t 2026590059-301 504 1672
- 2 James P. McGranery, Jr.
93 6" 22 All:04 ATTDENEY ATtAw SUrm ?$0 1255 TWENTY-TmRD s"rREET. N.W.
WAsmNoTON. D.C. 20037 P.aumine: (2:2) ts7.Z Telephone; (202) s512F29 March 18,1993 vrA TETICOPY Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, D.C. 20037 Re: USNRC Docket No. 50-312-DCOM
Dear Tom:
I appreciate your firm's prompt partial compliance by letter of March 9 wid the Commission's Order in CI.I-93-3 requiring the Sacramento Municipal Utility Distrtet ("SMUD")
to provide Environmental and Resources Conservation Organization ("ECO") wit'. all correspondence related to decommissioning and decommissioning funding submitted to the NRC staff by or on behalf of SMUD after July 14,1992. I can understand how some metters may '
have been overlooked in trying to provide me with relevant information as quickly as possible.
I expect that the speed with which the package was assembled also accounts for the 2
mistake in representing to the Commission that none of the information relates to decommissioning funding. As you and I discussed, any development or change in the Decommissioning Plan would aimost inevitably affect decommissioning cost and, hence, have a bearing on the adequacy of the decommissioning funding plan. But even more directly, the information furnished in response to the Commission's Order addresses decommissioning funding emlicitiv: for example, the verv Erst staff question of the verv Erst package which you furnished me (namely, DAGM/NUC-92198 (dated August 6,1992)) asked SMUD to "Td]escribe any possible changes in sgst due to [ delays in transfer of spent fuel to the onsite ISFSI) and how they could be accommodated by periodic reviews required by the funding nian." (Emphasis added).
F 9304020163 930318 PDR ADOCK 05000312 p50 C
SENT BY:DOW LOHNES & ALBERTSON; 3-19-93 ; 4:21PM
- 202559005E-301 50e 1572
- 3 Thomas A. Baxter, Esq.
March 19,1993 Page 2 Tbc following is my effort to assist you in complying with the Commission's Order:
(1)
It appears that you wrote a letter to the Commission dated July 15,1992 forwarding a SMUD response to an NRC request for additional information in support of the Decommksioning Plan and the anociated Environmental Report.
However, neither that letter nor the package which it forwarded are among the materials fumished me so far (and I couldn't even identify it in the PDR computer listing).
(2)
It appears that SMUD and others met with the NRC staff with respect to Decommissioning Plan inues (including the status of the ISFSI application) on (a)
July 15, (b) October 27, and (c) November 18-19, 1992. However, the March 9 package lacks copies of the chans, graphs and other information used in or provided at such meetings. (Of course, to the extent there may have been yet other meetings which I am unaware of, such information is also lacking with respect to those meetings). In referring to other information,"I do not seek to have oral communications reduced to writing but only allude to this variety of forms of documentation including, for example, computer disks.
t (3)
A SMUD letter dated September 23,1992 relating to various insurance / indemnity issues relevant to the current status of the plant.
(4)
DAGM/NUC-92-242 dated October 15,1992 addressing financial protection issues -
relevant to the current decommissioning effort at Rancho Seco.
(5)
DAGM/NUC-92-280 dated December 17,1992 related to modifications to the Rancho Seco Quality Manual and transmitting Revision 7 to that Manual.
(6)
A SMUD letter dated January 26,1993 transmitting various information on NELIA and MAELU matters related to the current condition of the plant.
i (7)
DAGM/NUC-93-36 dated February 22,1993 apparently related to physical security training exercises at Rancho Seco.
(8)
DAGM/NUC-93-25 dated December 31,1992 transmitting the semi annual radioactive efDuent release repon for July-December 1992.
(9)
DAGM/NUC 93-45 dated March 2,1993 transmitting the Rancho Seco 1992 Annunl Exposure Report.
(10)
DAGM/NUC 93 46 also dated March 2,1993 appears to transmit the 1992 Annual Occupational Radiation Exposure Report.
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- 55NT.' BY:DOW LDhNES &'hlBERT50N' 3-19-93 i t.:22PM t 2026590059-T30150lb672
- s I Thomas A. Baxter, Esq.
l March 19,1993 l
Page 3 (11)
NOA-93-14 dated March 1,1993 appears to transmit Revision 3 to ODCM inadvertently admitted from July December 1992 Semi-Annual Radioactive Effluent j
Release Report.
I hope the foregoing will be of help to your client in complying fully with the Commission's Order. Of course, I cannot guarantee that the list that I have provided ab'ove is complete, but it is at least my good faith effort to assist you in assuring that the relevant j
information is identiBed and furnished to ECO.
j i
.i It may be that the documentation identified above will, after we have a chance to review j
it, provide ECO with assurances that there is no cause for concern in at least some areas, rather than forming the basis for contentions expressing ECO's concerns. While I hope that is the case, you can appreciate that such ajudgment cannot be made until we have had the opportunity to review the information submitted by or on behalf of SMUD to the NRC Staff.
In order to keep the Commhdon advised of the status of our ongoing cooperative effort to comply with its Order, I am furnishing a copy of this letter to the Comminion and the NRC Staff by telecopy and mail and to the balance of the service list by mail.
As I was finalizing this letter this morning, I received the Coimnission's Order (CLI 93-5).
which was issued March 15. I hope that, when the Commission sees that there was'a faulty premise underlying the denial of the relief which I requested (namely, the assumption that I had l
received all relevant documentation on March 9), the Commission will reconsider CLI-93-5 sua i
(
sponte.
I. coking forward to hearing from you, I am, With Best Wishes,-
?:)r i
James P. McGranery, Jr..
~~'
Counsel for the Environmental and-Resources Consen'ation Organization cc:
Chairman Ivan Selin Commissioner Kenneth C. Rogers Commissioner James R. Curtiss Commissioner Forrest J. Remick
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Commissioner E. Gail de Planque The Secretary of The Commission Senice List 1
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