ML20094Q976

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Responds to from Jr Gray Containing Copy of Demand for Info Transmitted to NPPD Re Action Taken During Mar 1993 Refueling Outage
ML20094Q976
Person / Time
Site: Cooper Entergy icon.png
Issue date: 12/09/1994
From: Matt Young
NEBRASKA PUBLIC POWER DISTRICT
To: Lieberman J
NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20094Q932 List:
References
FOIA-95-262 NUDOCS 9512040217
Download: ML20094Q976 (4)
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Nebraska Public Power District i Cooper Nuclear Station P.O. Box 98 Brownville, NE 68321 December 9, 1994 Mr. James Lieberman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Lieberman:

The purpose of this letter is to respond to the letter I received from Mr. Joseph R. Gray of your office dated November 10, 1994, which contained a copy of the Demand for Information (DFI) transmitted to the Nebraska Public Power District (NPPD) by letter dated November 10, 1994.

In connection with this matter, I was interviewed by a representative of the NRC's Office of Investigations. Since that time I have had the opportunity to review in greater detail the events during the March 1993 refueling outage, particularly the approval by the Station Operations Review Committee (SORC) on March 9, 1993 of changes to procedures governing reactor pressure vessel (RPV) disassembly. This letter provides the NRC with information that may be in addition to the information I provided during my previous interview. To the best of my recollection and belief, the information provided herein is in all material respects consistent with my previous interview.

Exclanation of SORC's Action

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I attend he March 9, 1993 SORC meeting asbeting Maintenance Manage Mike Unruh, who normally attended as the Maintenance Department's representative, was on the night shift at i the time). The meeting was split into two sessions. I believe we started about 3:15 p.m., met for some length of time, and re-convened after a brief break about 5:00 p.m.

- I recall that, leading up to the meeting, we were at a point of RPV disassembly following cold shutdown and venting. We could not obtain verification of secondary containment integrity necessary to proceed with disassembly. I recall that the wind was a factor preventing a successful test, which would have been I believe -0.25 in gage pressure. My recollection is that we were zaag 5 9512040217 951122 PDR FOIA /

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.i Mr. James Lieberman December 9, 1994 Page 2 measuring about .20 or .21 in. gage pressure at the time. This is a relatively small difference compared to the criterion; a significant difference would be if we were measuring zero or a positive value of gage pressure. However, we were stopped in the vessel disassembly process as a result.

I believe that someone in the Engineering Department questioned the procedural restriction preventing removal of the RPV head until secondary containment integrity was verified. This was an engineering issue primarily. I recall that the Engineering LDepartment nitiated the procedure change process via the PCN form.

g im Flahert fas well prepared at the SORC meeting to support the changes. I reviewed the PCN form. Because I had no technical concerns, I initialed the form as the responsible supervisor for maintenance.

I recall askingMim Flahert ome questions at the meeting, because I had to be comfortable in my understanding of the changes. ,I was comfortable with Engineering's assessment. As I recall, ohn Meachm7was at the meeting and he asked some questions. At the meeting SORC discussed whether the procedure changes were justified and what were the requirements that must be met. I believe we looked into the meaning of technical specification requirements and, in my mind, the RPV disassembly loads were not ones that could potentially damage fuel because of ,

their geome ry SORC was aware that the District (it may have been

' im Flahert I'm not certain) had contacted GE concerning PRC ' 11 and the $991 procedure changes and that GE representatives distinguished PRC-88-11 loads (about 750 lbs.) from heavy loads associated with RPV disassembly. As I recall, GE used the example of control blade drop as a typical PRC-88-11 concern.

I recollect @im

? Flahertyhaving a lot of papers with him at the meeting. I do not remember whether SORC members received a package of information.) 91tqThad the answers to questions and I thought he adequately covered the issues. I remember SORC discussing NUREG-0612, which addresses heavy loads, though it doesn't really address the issue of secondary containment. I recall not having a concern with the RPV disassembly lifts or rigging, because the issue was whether secondary containment integrity was necessary and whether the loads were ones that could potentially damage irradiated fuel. I felt the geometry of the loads would prevent any damaging of the fuel if dropped, and with the design of the lifting devices and use of safe load paths I wasn't concerned about dropping the loads.

.1 b9 Mr. James Lieberman December 9, 1994 l Page 3 I recall tha imFlaherthI[adreferencedtworelatedTS amendments on the PCN form, but I don't recall reviewing these amendments. I do recall, however, reading the technical specifications requirements for secondary containment integrity at the meeting (TS 3.7.C). SORC discussed the surveillance requirement (4.7.C) in relation to the proposed procedure change.

We concluded that the 1991 procedure change seemed to exceed the concerns in GE PRC-88-11 and that the proposed change was not in conflict with the technical specifications. I recall specifically that SORC discussed the issue of loads that could potentially damage irradiated fuel, because the term " load" was not precisely defined in the procedure. SORC was comfortable with its interpretation of the technical specification on secondary containment integrity and moving loads. I don' t recall looking at the NRC memorandum by Mr. Long at the meeting.

I remember a lot of discussion at the meeting, without strong oppoEi tion to th3 proposed changes. I reca 1 questions coming from[$ohn MeachamJ,that resulted in$im Flahert; doing some more researt .h. I do not recall being influenced in my judgment by Mohn Meacha@f involvement. I am not reluctant to speak up at SORC meetings. -

On the PCN form at the bottom, the "yes" box was checked indicating that a TS chan e was inv 1 d, and SORC felt this was a mistake. I believe tha im Flahert may have pointed this out and I do not recall it w s' an issue. There was some additional handwritten information on the second page of the form, which was probably written before the meeting (I am uncertain).

Exclanation Why NRC Sanctions Are Inaccrocriate My recollection is strong that the two main issues discussed by SORC at the meeting were (1) safe movement of heavy loads and (2) the timing requirements for verification of secondary containment. I am convinced that SORC acted with sufficient information for a sound decision. In this regard, I do not believe that NRC sanctions against me personally would be appropriate. Any sanctions would have an unwarranted negative impact on my career as a nuclear power professional. % ince 1986, I have worked in the Maintenance Department at the C6oper Nuclear Station, most recently as Maintenance Superviso I af firm that this letter is true and correct to the best of my knowledge and belief. I hereby request that this letter be

.,6 59 Mr. James Lieberman December 9, 1994 Page 4 withheld from placement in the NRC Public Document Room and from disclosure pursuant to 10 C.F.R. S 2.790.

Sincerely, F%, N 9 L.- _-

ichael F. ung) ,

t Sworn to and su cribed lyefore me this ay of ,

Is om L A/ , 1994.

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