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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M0721999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Pass Dates ML20217D8361999-10-11011 October 1999 Provides NRC with Summary of Activities at TMI-2 During 3rd Quarter of 1999 ML20217F8271999-10-0707 October 1999 Forwards Pmpr 99-13, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990828- 0924.Diskette Containing Pmpr in Wordperfect 8 Is Encl. All Variances Are Expressed with Regard to Current Plans ML20212L1831999-10-0101 October 1999 Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health ML20212L2081999-10-0101 October 1999 Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance ML20212K1241999-10-0101 October 1999 Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected ML20212L1971999-10-0101 October 1999 Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety ML20212J9991999-10-0101 October 1999 Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected ML20212L0061999-10-0101 October 1999 Discusses GL 97-06 Issued by NRC on 971231 & Gpu Response for Three Mile Island .Staff Reviewed Response & Found No New Concerns with Condition of SG Internals or with Insp Practices Used to Detect Degradation of SG Internals ML20212L2171999-10-0101 October 1999 Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island ML20212K8771999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Three Mile Island on 990913.No Areas Identified in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Provides Historical Listing of Plant Issues & Insp Schedule ML20212K8551999-09-30030 September 1999 Informs That During 990921 Telcon Between P Bissett & F Kacinko,Arrangements Were Made for Administration of Licensing Exams at Facility During Wk of 000214.Outlines Should Be Provided to NRC by 991122 ML20216J6581999-09-28028 September 1999 Provides Info as Requested of Licensees by NRC in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20212J0011999-09-27027 September 1999 Forwards Insp Rept 50-289/99-07 on 990828.No Violations Noted ML20212E1971999-09-16016 September 1999 Forwards Rev 11 of Gpu Nuclear Operational QAP, Reflecting Organizational Change in Which Functions & Responsibilities of Nuclear Safety & Technical Support Div Were Assigned to Other Divisions ML20212A2101999-09-13013 September 1999 Forwards Rev 3 of Gpu Nuclear Post-Defueling Monitored Storage QAP for Three Mile Island Unit 2, Including Changes Made During 1998.Description of Changes Provided on Page 2 ML20216G4151999-09-0909 September 1999 Forwards Pmpr 99-12, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990731- 0827.All Variances Expressed with Regard to Current Operations Plans ML20211M5861999-09-0202 September 1999 Forwards non-proprietary & Proprietary Response to NRC 990708 RAI Re TS Change Request 272,reactor Coolant Sys Coolant Activity.Proprietary Encl Withheld ML20211M6591999-09-0101 September 1999 Forwards Errata Page to 990729 Suppl to TS Change Request 274,to Reflect Proposed Changes Requested by . Page Transmitted by Submitted in Error ML20211L2401999-09-0101 September 1999 Submits Response to NRC AL 99-02, Operator Reactor Licensing Action Estimates ML20211H3731999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI LAR 285 & TMI-2 LAR 77 Re Changes Reflecting Storage of TMI-1 Radioactive Matls in TMI-2 Facility.Revised License Page mark-up,incorporating Response,Encl ML20211H4001999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI-1 LAR 285 & TMI-2 LAR 77 Re Changes to Clarify Authority to Possess Radioactive Matls Without Unit Distinction.Revised License Page mark-up, Incorporating Response Encl ML20211K2391999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Repts for TMI, Oyster Creek & Corporate Headquarters Located in Parsippany, Nj ML20211H5041999-08-20020 August 1999 Forwards Proprietary & non-proprietary Rept MPR-1820,rev 1, TMI Nuclear Generating Station OTSG Kinetic Expansion Insp Criteria Analysis. Affidavit Encl.Proprietary Rept Wihheld 05000289/LER-1999-007, Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface1999-08-20020 August 1999 Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface ML20211A4261999-08-19019 August 1999 Forwards Insp Rept 50-289/99-04 on 990606-0717.Two Severity Level 4 Violations Occurred & Being Treated as Noncited Violations ML20211H3571999-08-19019 August 1999 Forwards Itemized Response to NRC 990712 RAI Re TS Change Request 248 Re Remote Shutdown Sys,Submitted on 981019 ML20211A3931999-08-12012 August 1999 Requests NRC Concurrence with Ongoing Analytical Approach as Described in Attachment,Which Is Being Utilized by Gpu Nuclear to Support Detailed License Amend Request to Revise Design Basis for TMI-1 Pressurizer Supports ML20210R4691999-08-11011 August 1999 Forwards Update 3 to Post-Defueling Monitored Storage SAR, for TMI-2.Update 3 Revises SAR to Reflect Current Plant Configuration & Includes Minor Editorial Changes & Corrections.Revised Pages on List of Effective Pages ML20210N7601999-08-10010 August 1999 Informs That NRC Staff Reviewed Applications Dtd 990629, Which Requested Review & Approval to Allow Authority to Possess Radioactive Matl Without Unit Distinction Between Units 1 & 2.Forwards RAI Re License Amend Request 285 ML20210N7191999-08-0606 August 1999 Forwards Notice of Partial Denial of Amend to FOL & Opportunity for Hearing Re Proposed Change to TS 3.1.12.3 to Add LCO That Would Allow Continued HPI Operation ML20210L3831999-07-30030 July 1999 Responds to NRC 990617 RAI Re OTSG Kinetic Expansion Region Insp Acceptance Criteria That Was Used for Dispositioning Indications During Cycle 12 Refueling (12R) Outage ML20210K7371999-07-30030 July 1999 Forwards Rev 2 to 86-5002073-02, Summary Rept for Bwog 20% Tp LOCA, Which Corrects Evaluation Model for Mk-B9 non- Mixing Vane Grid Previously Reported in Util to Nrc,Per 10CFR50.46 ML20210L1151999-07-28028 July 1999 Confirms Two Senior Management Changes Made within Amergen Energy Co,Per Proposed License Transfer & Conforming Administrative License Amends for TMI-1 05000289/LER-1999-009, Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section1999-07-22022 July 1999 Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section ML20216D4001999-07-22022 July 1999 Provides Summary of Activities at TMI-2 During 2nd Quarter of 1999 ML20210B8231999-07-21021 July 1999 Forwards Exemption from Certain Requirements of 10CFR50.54(w) for Three Mile Island Nuclear Station,Unit 2 in Response to Licensee Application Dtd 990309,requesting Reduction in Amount of Insurance for Unit to Amount Listed ML20210G9471999-07-15015 July 1999 Forwards Pmpr 99-10, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990605- 0702.Diskette Containing Pmpr in Wordperfect 8 Format Is Also Encl ML20209H9401999-07-15015 July 1999 Forwards Copy of Environ Assessment & Findings of No Significant Impact Re Application for Exemption Dtd 990309. Proposed Exemption Would Reduce Amount of Insurance for Onsite Property Damage Coverage as Listed ML20209G2451999-07-15015 July 1999 Advises That Suppl Info in Support of Proposed License Transfer & Conforming Adminstrative License Amends,Submitted in & Affidavit,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20212K1701999-07-13013 July 1999 Submits Concerns Re Millstone & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Should Provide Adequate Emergency Planning in Case of Radiological Accident ML20216D9861999-07-12012 July 1999 Forwards RAI Re 981019 Application Request for Review & Approval of Operability & SRs for Remote Shutdown Sys. Response Requested within 30 Days of Receipt of Ltr ML20209G5861999-07-0909 July 1999 Forwards Insp Rept 50-289/99-05 on 990510-28.No Violations Noted ML20209F2571999-07-0909 July 1999 Forwards Staff Evaluation Rept of Individual Plant Exam of External Events Submittal on Three Mile Nuclear Station, Unit 1 ML20209D8451999-07-0808 July 1999 Forwards Insp Rept 50-289/99-06 on 990608-11.No Violations Noted.Overall Performance of ERO Very Good & Demonstrated, with Reasonable Assurance,That Onsite Emergency Plans Adequate & That Util Capable of Implementing Plan ML20209D6291999-07-0808 July 1999 Forwards Notice of Withdrawal & Corrected TS Pages 3-21 & 4-9 for Amend 211 & 4-5a,4-38 & 6-3 for Amend 212,which Was Issued in Error.Amends Failed to Reflect Previously Changes Granted by Amends 203 & 204 ML20209D5141999-07-0808 July 1999 Forwards RAI Re 981019 Application & Suppl ,which Requested Review & Approval of Revised Rc Allowable Dose Equivalent I-131 Activity Limit with Max Dose Equivalent Limit of 1.0 Uci/Gram.Response Requested within 30 Days 05000289/LER-1999-008, Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public1999-07-0202 July 1999 Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public ML20196J3981999-07-0101 July 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure for TMI-1 Encl ML20209C1131999-07-0101 July 1999 Forwards Signed Agreement as Proposed in NRC Requesting Gpu Nuclear Consent in Incorporate TMI-1 Thermo Lag Fire Barrier Final Corrective Action Completion Schedule Commitment of 000630 Into Co Modifying License 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217D8361999-10-11011 October 1999 Provides NRC with Summary of Activities at TMI-2 During 3rd Quarter of 1999 ML20217F8271999-10-0707 October 1999 Forwards Pmpr 99-13, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990828- 0924.Diskette Containing Pmpr in Wordperfect 8 Is Encl. All Variances Are Expressed with Regard to Current Plans ML20216J6581999-09-28028 September 1999 Provides Info as Requested of Licensees by NRC in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20212E1971999-09-16016 September 1999 Forwards Rev 11 of Gpu Nuclear Operational QAP, Reflecting Organizational Change in Which Functions & Responsibilities of Nuclear Safety & Technical Support Div Were Assigned to Other Divisions ML20212A2101999-09-13013 September 1999 Forwards Rev 3 of Gpu Nuclear Post-Defueling Monitored Storage QAP for Three Mile Island Unit 2, Including Changes Made During 1998.Description of Changes Provided on Page 2 ML20216G4151999-09-0909 September 1999 Forwards Pmpr 99-12, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990731- 0827.All Variances Expressed with Regard to Current Operations Plans ML20211M5861999-09-0202 September 1999 Forwards non-proprietary & Proprietary Response to NRC 990708 RAI Re TS Change Request 272,reactor Coolant Sys Coolant Activity.Proprietary Encl Withheld ML20211M6591999-09-0101 September 1999 Forwards Errata Page to 990729 Suppl to TS Change Request 274,to Reflect Proposed Changes Requested by . Page Transmitted by Submitted in Error ML20211L2401999-09-0101 September 1999 Submits Response to NRC AL 99-02, Operator Reactor Licensing Action Estimates ML20211H3731999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI LAR 285 & TMI-2 LAR 77 Re Changes Reflecting Storage of TMI-1 Radioactive Matls in TMI-2 Facility.Revised License Page mark-up,incorporating Response,Encl ML20211H4001999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI-1 LAR 285 & TMI-2 LAR 77 Re Changes to Clarify Authority to Possess Radioactive Matls Without Unit Distinction.Revised License Page mark-up, Incorporating Response Encl ML20211K2391999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Repts for TMI, Oyster Creek & Corporate Headquarters Located in Parsippany, Nj 05000289/LER-1999-007, Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface1999-08-20020 August 1999 Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface ML20211H5041999-08-20020 August 1999 Forwards Proprietary & non-proprietary Rept MPR-1820,rev 1, TMI Nuclear Generating Station OTSG Kinetic Expansion Insp Criteria Analysis. Affidavit Encl.Proprietary Rept Wihheld ML20211H3571999-08-19019 August 1999 Forwards Itemized Response to NRC 990712 RAI Re TS Change Request 248 Re Remote Shutdown Sys,Submitted on 981019 ML20211A3931999-08-12012 August 1999 Requests NRC Concurrence with Ongoing Analytical Approach as Described in Attachment,Which Is Being Utilized by Gpu Nuclear to Support Detailed License Amend Request to Revise Design Basis for TMI-1 Pressurizer Supports ML20210R4691999-08-11011 August 1999 Forwards Update 3 to Post-Defueling Monitored Storage SAR, for TMI-2.Update 3 Revises SAR to Reflect Current Plant Configuration & Includes Minor Editorial Changes & Corrections.Revised Pages on List of Effective Pages ML20210L3831999-07-30030 July 1999 Responds to NRC 990617 RAI Re OTSG Kinetic Expansion Region Insp Acceptance Criteria That Was Used for Dispositioning Indications During Cycle 12 Refueling (12R) Outage ML20210K7371999-07-30030 July 1999 Forwards Rev 2 to 86-5002073-02, Summary Rept for Bwog 20% Tp LOCA, Which Corrects Evaluation Model for Mk-B9 non- Mixing Vane Grid Previously Reported in Util to Nrc,Per 10CFR50.46 ML20210L1151999-07-28028 July 1999 Confirms Two Senior Management Changes Made within Amergen Energy Co,Per Proposed License Transfer & Conforming Administrative License Amends for TMI-1 05000289/LER-1999-009, Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section1999-07-22022 July 1999 Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section ML20216D4001999-07-22022 July 1999 Provides Summary of Activities at TMI-2 During 2nd Quarter of 1999 ML20210G9471999-07-15015 July 1999 Forwards Pmpr 99-10, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990605- 0702.Diskette Containing Pmpr in Wordperfect 8 Format Is Also Encl ML20212K1701999-07-13013 July 1999 Submits Concerns Re Millstone & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Should Provide Adequate Emergency Planning in Case of Radiological Accident 05000289/LER-1999-008, Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public1999-07-0202 July 1999 Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public ML20196J3981999-07-0101 July 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure for TMI-1 Encl ML20209C1131999-07-0101 July 1999 Forwards Signed Agreement as Proposed in NRC Requesting Gpu Nuclear Consent in Incorporate TMI-1 Thermo Lag Fire Barrier Final Corrective Action Completion Schedule Commitment of 000630 Into Co Modifying License ML20196J7651999-06-29029 June 1999 Provides Updated Info Re Loss of Feedwater & Loss of Electric Power Accident Analyses to Support TS Change Request 279 Re Core Protection Safety Limit,As Discussed at 990616 Meeting ML20196J7701999-06-29029 June 1999 Forwards LAR 285 for License DPR-50,clarifying Authority to Possess Radioactive Matls Without Unit Distinction,So That After Transfer of TMI-1 License to Amergen,Radioactive Matls May Continue to Be Moved Between TMI-1 & TMI-2 Units ML20209C0391999-06-29029 June 1999 Forwards LAR 77 to License DPR-73,clarifying Authority to Possess Radioactive Matls Without Unit Distinction,So That After Transfer of TMI-2 License to Amergen,Radioactive Matl May Continue to Be Moved Between TMI-1 & TMI-2 Units ML20196G2061999-06-23023 June 1999 Requests That NRC Update Current Service Lists to Reflect Listed Personnel Changes That Occurred at TMI 05000289/LER-1999-006, Forwards LER 99-006-00,providing Complete Description,Extent of Condition & Actions Taken in Association with Determination of Inability of Pressurizer Support Bolts to Meet FSAR Requirements1999-06-23023 June 1999 Forwards LER 99-006-00,providing Complete Description,Extent of Condition & Actions Taken in Association with Determination of Inability of Pressurizer Support Bolts to Meet FSAR Requirements ML20196D2171999-06-17017 June 1999 Forwards Pmpr 99-9, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990508- 0604.New Summary Personnel Table Was Added to Rept Period.Matl Scientist Joined Staff Period ML20196A0431999-06-15015 June 1999 Providess Notification That Design Verification Activities Related to Calculations Supporting Analytical Values Identified in Gpu Nuclear Ltr to NRC Has Been Completed 05000289/LER-1999-004, Forwards LER 99-004-00,re Discovery of Emergency FW Pump Bearing Failure During Performance of Oil Change on 990510. Event Was Determined Reportable IAW 10CFR50.73,since Pump Was Determined to Be Inoperable Longer than TS AOT1999-06-0909 June 1999 Forwards LER 99-004-00,re Discovery of Emergency FW Pump Bearing Failure During Performance of Oil Change on 990510. Event Was Determined Reportable IAW 10CFR50.73,since Pump Was Determined to Be Inoperable Longer than TS AOT ML20212K2541999-06-0808 June 1999 Submits Concerns Re Millstone NPP & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Requests That NRC Provide Adequate Emergency Planning in Case of Radiological Accident ML20212K2671999-06-0808 June 1999 Submits Concerns Re Millstone NPP & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Requests That NRC Provide Adequate Emergency Planning in Case of Radiological Accident ML20195E2751999-06-0404 June 1999 Informs That PCTs & LOCA Lhr Limits Submitted in Util Ltr for LOCA Reanalysis Performed in Support of TMI-1 20% Tube Plugging Amend Request Have Been Revised.Revised PCT & LOCA Lhr Limit Values Are Provided on Encl Table 1 ML20195E3281999-06-0404 June 1999 Forwards Application for Amend to License DPR-50,modifying Conditions Which Allow Reduction in Number of Means for Maintaining Decay Heat Removal Capability During Shutdown Conditions ML20195C5721999-06-0202 June 1999 Forwards Description of Gpu Nuclear Plans for Corrective Actions for 1 H Fire Barriers in Fire Zones AB-FZ-3,AB-FZ-5, AB-FZ-7,FH-FZ-2 & Previous Commitments for Fire Zones CB-FA-1 & FH-FZ-6 ML20207E2561999-05-25025 May 1999 Submits 30-day Written Rept on Significant PCT Change in ECCS Analyses at TMI-1 ML20195B2461999-05-21021 May 1999 Forwards Itemized Response to NRC 990506 RAI for TS Change Request 279 Re Core Protection Safety Limit ML20206R6461999-05-13013 May 1999 Forwards Rev 39 of Modified Amended Physical Security Plan for TMI 05000289/LER-1999-003, Forwards LER 99-003-00, Discovery of Condition Outside UFSAR Design Basis for CR Habitability, Which Was Determined Reportable on 990310.Rept Is Being Submitted Four Weeks Later than Required,Per Discussion with NRC1999-05-0707 May 1999 Forwards LER 99-003-00, Discovery of Condition Outside UFSAR Design Basis for CR Habitability, Which Was Determined Reportable on 990310.Rept Is Being Submitted Four Weeks Later than Required,Per Discussion with NRC ML20206K6301999-05-0707 May 1999 Provides Addl Info Re TMI-1 LOFW Accident re-analysis Assumptions for 20% Average SG Tube Plugging as Discussed on 990421 ML20206H0781999-04-30030 April 1999 Forwards Rev 0 to 1092, TMI Emergency Plan. Summary of Changes Encl ML20206J4811999-04-30030 April 1999 Provides Summary of Activities at TMI-2 During First Quarter of 1999.TMI-2 RB Was Not Inspected During Quarter.Routine Radiological Surveys of Auxiliary & Fuel Handling Bldgs Did Not Identify Any Significant Adverse Trends ML20206E4121999-04-27027 April 1999 Requests That TS Change Request 257 Be Withdrawn ML20206C5211999-04-23023 April 1999 Requests Mod to Encl Indemnity Agreement Number B-64,on Behalf of Gpu & Affiliates,Meed,Jcpl,Penelec & Amergen Energy Co,Llc.Ltr Supersedes & Withdraws 990405 Request Submitted to NRC ML20206C8261999-04-22022 April 1999 Submits Financial Info IAW Requirements of 10CFR50.71(b) & 10CFR140.21 1999-09-09
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Dr. Nunzio J. Palladino Chairman of the Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555
Dear Chairman Palladino:
Enclosed is a copy of a letter dated January 26, 1982, from the Union of Concerned Scientists to Governor Richard Thornburgh of Pennsylvania.
Perhaps you have responded to this letter via one of the other recipients of a copy of the letter.
In any event, I would welcome'your comments.
Thank you for your assistance.
incerely, Arlen ecter J
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Mr. Robert D. Pollard
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7 UNION OF' 1346 Connecticut Avenue, N.W.
Dupont Circle Building, Suite 1101 CONCERNED washington, o.C. 2coas gCIENTISTS (202) 29e.5e00 January 26, 1982 Honorable Richard Thornburgh "
Governor Commonwealth of Pennsylvania Harrisburg, Pennsylvania 17120
Dear Governor Thornburgh:
We are writing in response to the NRC staff's letter to you of January 5, 1982, regarding the restart of Three Mile Island Unit 1. The most charitable interpretation of that letter is that it is grossly misleading.
A more frank appraisal is that it is deliberately deceptive.
As you recall, your letter of November 20, 1981 to the Chairman of the Nuclear Regulatory Cornission forwarded for review letters you had received from U.S. Rep. Morris K. Udall, dated July 23, 1981, and from UCS, dated October 19, 1981. You urged Chairman Palladino "to conduct a careful and objective review" of the questions surrounding the safety of restarting TMI-1 that were raised by R e,p . Udall and UCS. You suggested that if there were "any Unit 1 safety questions that have yet to be satisfactorily addressed, now is the time for the NRC to address them." Finally, you requested "a written response from [ Chairman Palladino] or [his] staff reflecting NRC's view of the,various points raised by UCS and Rep. Udall."
The NRC staff characterized its reply to ,your expression of a " paramount concern for the health and safety of. the people who live within the shadow of Three Mile Island" as an " interim response." However, it is clear that the NRC staff did not address the questions you posed. There is no evidence that the staff carefully and objectively reviewed the substantive issues raised by l UCS and Rep. Udall. The staff avoids saying whether any Unit 1 safety
) questions heve yet to be satisfactorily addressed or, if so, whether the NRC has any plans to address them now. Instead, the staff's letter purports to
" summarize Staff positions on the several technical and procedural issues l raised."
If the NRC had simply failed to respond to your questions, we would not need to bring that self-evident fact to your attention. Our reason for writing now is that the NRC staff has not only declined to address the safety i
concerns that you articulated, but in addition has presented you with information that does not reflect the whole truth. In our view, the staff has attempted to create an impression more favorable to restart of TMI-1 than it knows is warranted.
Massachusetts O// ice: -
1384 Massachusatts Avenue
(617)547 5552
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Rep. Udall's Letter Consider, for example, the staff's response to the issues raised by Rep. Udall. Mr. Udall pointed to the " continuing resistance by GPU to requirements instituted for purposes of correcting deficiencies revealed by inquiries into the accident." He cited as an example GPU's resistance to the requirement to install water level instrumentation for the reactor vessel.
Rep. Udall concluded with the following observation: .
The reluctance of GPU *a meet the NRC requirement, ' to say nothing of its failure to go the extra mile, suggests that the current TMI management, as did its predecessor, holds that the plant systems as they exist are adequate to cope with anticipated events; they appear to believe that ,
unanticipated events simply will not occur. This is of course the same line of thinking that led to GPU's present predicament.
Thus, Rep. Udall's letter can fairly be characterized as expressing concern primarily about GPU's attitude and only secondarily about water level instrumentation. The staff's response is to acknowledge only the example and not to address the fundamental issue of GPU's attitude.
In -addition, even this limited response does not accurately represent the staff's views. In its letter to you, the staff said:
. . . GPU has revised its position' on this matter and has now committed to installation of a system in the Reactor (Coolant] System (RCS) hot leg piping which will provide an indication of RCS inventory loss. This system is currently being reviewed by the Staff and some design modifications are expected to be'-required before the system is installed at the next THI-1 refueling outage.
This statement'does not convey the same message as the report the staff gave the NRC Commissioners on the THI-1 water level instrumentation only a week before its letter to you. In a memorandum for the Commissioners dated December 29, 1931, the staff said:
A single dp (differential pressure] measurement over the top
. 10 feet of the hot leg (as proposed for THI-1) would detect voiding at the top of the candy cane. It will probably track hot leg level for a. sufficient distance to distinguish between over cooling transients and a loss of coolant inventory indicative of an approach to core 'uncovery. -It would also provide valuable information to support reactor coolant. system venting operations and to confirm that natural circulation operation is not interrupted by voiding in the -
candy cane. 'However, it would not trend voiding with the pumps running and would not indicate void formation in the reactor vessel head until vessel water level reaches the hot leg nozzle. It would also fail to provide a continuous e
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indication of coolant inventory loss proceeding to core uncovery, and would not track the replenishing of coolant inventory. e a e As presently proposed, the single dp measurement over the top .10 feet of the hot leg is unacceptable to the staff. (emphasis added)
The inability of the proposed instrumentation to detect the formation of a steam bubble void in the reactor vessel and the inability to measure .the extent of core uncovery are major deficiencies. In , view of these deficiencies and the staff's conclusion that the proposed IMI-1 instrumentation design is unacceptable, we believe that the staff's statement to you that "some design modifications are expected to be required" was misleading. The staff's phrasing is akin to saying that a proposed automobile design that does not include wheels and an engine is acceptable although some design modifications may be required.
In sum, the NRC staff's response to the matters raised by Rep. Udall consists of ignoring the principal issue of GPU's attitude and failing to accurately inform you that the staff found GPU's belatedly proposed design changes to be unacceptable.
UCS's Letter Regarding the staff's handling of the safety. issues raised by UCS, it is clear that the staff did not address the substance of those issues:
- 1) The NRC's focus on quick, cheap fixes that ignore the more serious problems revealed by the TMI-2 accident;
- 2) The restrictions in the scope of the hearings which prevented consideration of important questions about the safety . of restarting
- 'INI-1;
- 3) Reducing NRC's standard of safety to the lowest common denominator l by ignoring safety problems that are not unique to THI-1; l
I
- 4) NRC's . repeated extension of deadlines for implementing the .TMI " lessons learned" requirements. after pressure from ~ the . nuclear industry; and r
! 5) The retraction or substantial weakening of commitments made by the' NRC staff and GPU Nuclear to make improvements directly related to the causes of the TMI-2 accident.
Like the response to the matters raised by Rep. Udall, the staff's answer to the safety questions raised by UCS consists of ignoring the-principal issues and providing . misleading information on the examples. A brief discussion of ~just one subject, environmental qualification of safety equipment, will illustrate the deceptive nature of the staff's response to you.
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Environmental qualification of safety equipment involves demonstrating that the equipment which is needed to safely shut down, the plant in an accident can survive the environment that it will be exposed to during the
, accident. In our earlier letter to you, we pointed out that the staff's testimony had not addressed accidents such as steam line breaks and, even for small break loss-of-coolant accidents, had been limited to an accident of
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much smaller dimension than the TMI-2 accident. We also noted that limitations on the scope of the hearings had prevented UCS from presenting evidence that many safety-related components in THI-1 have not been qualified to survive serious accidents. Finally, we expressed our doubts that the NRC staff and GPU Nuclear would honor their promises to correct the environmental qualification deficiencies at TMI-1 by July 1982.
In its response the staff acknowledges the accuracy of one of our j statements, but misleads you on the remainder of the issues we raised. The staff states that its testimony was " directed [rather than UCS's term
" limited"] to the ability of equipment to function following a small break i
loss of coolant accident (SBLOCA) not involving core damage . . ." Since the THI-2 accident was a ~ small break loss-of-coolant accident .that involved i
substantial core damage, this confirms that the staff analyzed only . an accident of the same type as, but less serious than, the.TMI-2 accident.
l Next the staff states its position favoring " interim operation" of THI-1 until GPU can " complete the actions required for all operating plants under the ' Commission's Memorandum and Order CLI-8" Sted May 27, 1980 to demonstrate that all safety-related electr.ical _ _.nt will be qualified to withstand accident environments." CLI-buw21 specifies that all safety-related electrical equipment in all operating plants must be environmentally qualified by June 30, 1982. (11 NRC 707, 714, 715) However, the staff n' eglected to tell you that since July 1981, it has supported a I request to extend that deadline. In October and November 1981, the staff I
prepared proposals for Commission. consideration to accomplish that objective.
Just two days after the staff's letter to you, a majority of the Commissioners voted for a proposed rule which, if adopted, will extend the June 30, 1982 " deadline" to the end of the second refueling af ter March 31,
'1982. (See Inside- N.R.C. , January 11, 1982, p. 1) Thus, the situation is now even worse than when we last wrote you. GPU apparently will not be required to correct the environmental qualification deficiencies at TMI-1 until 1984 at the earliest. Furthermore, the proposed rule does not apply to all safety equipment. " Additional electrical equipment important to safety will be covered in a later rule, NRC said." (Id.) It would be pure speculation to attempt to estimate when or even if all the safety equipment in THI-1 will be required to,be environmentally qualified.
The next point in the staff's response which we believe is misleading is the statement that "[a]lthough qualification of all of the equipment has not been fully demonstrated, many of the inabilities to fully demonstrate compliance involve a lack of documentation' of confirmatory test results to
! support a finding that the equipment is qualified." This statement creates the false impression that most of the remaining problems involve only a few missing pieces of paper or the performance of some ' perfunctory tests that will not provide any new information. In reality, the situation is far worse and the staff knows it. In urging the Commissioners to extend the June 30,
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1982 deadline, the staff informed the Commissioners that " licensee submittals to date do not satisfactorily identify all deficiencies or provide complete justification for interim operation . . . " (Staff Recommendations Concerning Extension of June 30, 1982 Deadline for Environmental Qualification of Safety-Related Electrical Equipment, July 31, 1981, p. 2) The staff also informed the Commissioners that its " review to date has determined that full qualification has not yet been demonstrated for .approximately 80% of the equipment in a harsh environment" and that it estimated "that 15-40% of the ecuipment in a harsh environment will need to be replaced." (Id.)
The staff's own " Safety Evaluation Report for the Environmental c coalification of Safety-Related Electrical Equipment at Three Mile Island Unit 1," dated March 24, 1981, discloses that environmental qualification deficiencies exist in the . following safety systems: Emergency Core Cooling; Core Flood; Containment Spray; Auxiliary Feedwater; Nuclear Service Water; Containment Isolation; Decay Heat Removal; and Containment Cooling. The equipment involved includes pump motors, valve' motor operators, pressure switches, electrical distribution centers, solenoid valves, limit switches, instruments to measure various temperatures, pressures and levels, cables for instrumentation, control and power circuits, electrical connectors, terminal blocks, containment electrical penetrations, and heat shrink tubing used as an insulator. The deficiencies range from some equipment that may be inadequate "only" because of aging effects ta other equipment. that may be inadequate due to the effects of temperature, pressure, humidity, chemical spray, radiatioh, and aging. Thus, relying solely on the staff's own documents, it is clear that the staff's letter to you is decidedly incomplete. Numerous important safety systems at TMI-1 have not been shown
- to be capable of functioning during an accident and, under the extension proposed by -NRC, the deadline for demonstrating adequate assurance of safety will be postponed for years.
. The staff successfully prevented UCS from introducing this. same safety evalu? tion report into evidence during the restart hearings, a ruling that the Licensing Board now regrets. (Partial Initial Decision, December 14, 1981, paragraph 1162) The staff's objection to the introduction into evidence of its own safety evaluation report on environmental qualification of TMI-1 safety equipment should be contrasted with its statement to you that
"[t]his issue was litigated in the THI-1 restart proceeding." The fact is that this issue was not fully litigated.
Despite the barriers which the staff and GPU erected to preclude a complete review of the environmental qualification issue, the Licensing Board nonetheless concluded that .UCS " prevailed to. the. extent .that UCS has demonstrated that all of the safety equipment at TMI-1 will, not meet all of the [ environmental qualification] criteria in Regulatory.. Guide 1.89 at the time of restart." (Partial Initial Decision, paragraph 1181) Unfortunately, the Board declined to face the issue of whether " interim operation" of TMI-1 should be , denied, in part because.it also was misled into believing that the issues would be addressed by June 30, 1982. (Id.)
In sun, the staff's response regarding the safety significance of the environmental qualification issue is grossly misleading. It creates a false impression that the issues were fully litigated, that the remaining
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,. ,. . t environmental qualification deficiencies are minor, and that they all will be corrected by June 30, 1982. On all these points, nothing cou~ ld be further from the truth.
Conclusion We have discussed only two of the safety issues in the staff's letter and concluded that ou both the staff attempted to mislead you. The bases for this conclusion are, we belie'e, v amply explained in the discussion above. If you would like copies of any of the referenced documents, we would be pleased to provide them. We repeat our offer to brief you or your staff on these and other safety issues relevant to restart of TMI-1 if you so desire.
We believe it is important to address one other point you made in your letter to Chairman Palladino. You commented that it would be foolish for you, as a layman, to substitute your judgment for the NRC's on whether there is adequate assurance that Unit 1 can be operated safely. We do not. agree entirely.with that view. It etrtainly would be unreasonable to expect you to become involved in analyzing the details of water level instrumentation design or the adequacy of an environmental qualification test for a particular piece of safety equipment. On the other hand, we believe that the judgments involved in assessing whether the Nuclear Regulatory Commission has conducted a careful and objective review of the relevant safety issues are well within your capability and, more importantly, your responsibilities to the residents of central Pennsylvania. In these latter areas, you need not be concerned about substituting your judgment for the Commission's. We believe that your independent review of.the record will clearly show that the NRC failed in its responsibilities and that THI-1 should not be restarted in these circumstances.
Sincerely, kaf
- r n Henry W. Kendall Chairman Board of Directors
, Robert D. Pollard Nuclear Safety Engineer Cc:
Rep. Morris K. Udall Sen. John Heinz Sen. Arlen Specter Rep. Allen Ertel Rep. Robert.S. Walker William J. Dircks -
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