ML20094R012

Responds to from Jr Gray Containing Copy of Demand for Info Transmitted to NPPD 941110 Re Actions Taken During 930309 Refueling Outage

ML20094R012
Person / Time
Site:	Cooper
Issue date:	12/09/1994
From:	Galen Smith NEBRASKA PUBLIC POWER DISTRICT
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20094Q932	List: ML20094Q958 ML20094Q971 ML20094Q976 ML20094Q986 ML20094R001 ML20094R012 ML20094R028 ML20094R038 ML20094R059 ML20094R067 ML20094R076 ML20094R086 ML20094R115
References
FOIA-95-262 NUDOCS 9512040233
Download: ML20094R012 (3)

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'c h [h Nebraska Public Power District 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. 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.

Exclanation of SORC's Action A uality Assurance Manage I participated in the March 9, 1993 SORC meeting as non-voting me r (as I had been for the prevjous 7 years). The A Manager]is th nly non-voting member of SORQCper the Technic ' Specifications. I would review propo d changes rocedures from a technical perspective for th Departmen y and I concurred with the changes to the RPV disass ly procedures on March 9, 1993, as well as with the 1991 changes to those procedures. I recollect that I was present for the entire SORC meeting on March 9th. I believe it is fair to say that I am known as a very active participant at SORC meetings. I have no reluctance to ask questions or express any disagreement with proposed actions.

My recollection of the March 9, 1993 SORC meeting is sketchy, but I do recall discussion on the issue of what is meant by heavy loads. SORC reviewed the Technical Specifications requirements concerning movement of loads in the secondary containment and maintenance of secondary containment integrity. An issue of interpretation arose, which is not that unusual for SORC because Cooper Nuclear Station has custom technical specifications.

To my recollection, this was the first time the issue of prior d

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'Mr. James Lieberman December 9, 1994- .

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.c verification of secondary containment integrity (i.e. , prior to RPV disassembly) had arisen. I recall that SORC members- were' consulting a bound volume of the Technical Specifications during

.the meeting, . and that the guidance of NUREG-0612 concerning movement of heavy loads was discussed.

From my experience, SORC -would not have approved the  !

proposed revisions to the procedures if there was . actually a conflict with the Technical Specifications. I don't- recall  ;

disagreement at the meeting, but it is unlikely that SORC would '

approve a proposed change unless any disagreement was resolved.

4 I

am not . reluctant to ' speak up at SORC meetings to ensure that proposed changes are adequately justified.

• Emlanation Why NRC Sanctions Are Inacoropriate .

I believe that no sanctions against me personally are l warranted in connection with the November 10, 1994 Demand ' for -

Information issued to Nebraska Public. Power District. Any sanctions against me would impair my ability to pursue a career in I the nuclear power industry, in which I have made a s' ificant t investment professionally, beginning essentially with th . S . Navy

, ~in 1970. I attended Machinist Mate A School, Nuclear P er School ,

and was trained at the West Milton Nuclear Power Prototype Training Unit where I served as an instructo {

ollowing -an honorable discharge from the U.S. Navy in l 1976, I olned Nebraska Public Power District at the Cooper Nuclear i Station. Since then, I have held positions of increasing responsibility, including: Engineering Technician (1976-1980);

Quality Assurance Specialist (1980-1983); Senior Quality Assurance Specialist (1983-1987); and, most recently, Quality Assurance Manager (1987-Present). As a Quality Assurance' Manager, I am currently responsible for directing a staff of 14 personnel to i implement and maintaio $he Audit and Quality Control Programs at CooperNuclearStatio%

o,.I am a Certified Lead Auditor in accordance with .

ANSI N45.2.23 (January 1982). I received a Associate's Degree in

. Social Sciences from Dean Jr. College (1969 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 ,

withheld from placement in the NRC Public Document Room.and from  :

disclosure pursuant to 10 C.F.R. S 2.790.

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",\ b I Mr. James Lieberman December 9, 1994

.Page 3 incergl Garrett E. Smitll,7 Sworn to and subscribed pefore me this/f day of hLvow/.cN , 1994.

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