ML20094R067
| ML20094R067 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 12/09/1994 |
| From: | Mace E NEBRASKA PUBLIC POWER DISTRICT |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| Shared Package | |
| ML20094Q932 | List: |
| References | |
| FOIA-95-262 NUDOCS 9512040254 | |
| Download: ML20094R067 (5) | |
Text
3 d-33 rr-rm e 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:
i 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 under oath 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 is 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
,t I served as tage Direct for the March 1993 refueling outage.
I reported t ck Gardne My responsibilities included managing the outage hedule.
I was a voting member of SORC and attended a_ portion of the March 9, 1993 SORC meeting when changes to the procedure (7.4.4) governing RPV head removal were discussed and approved.
I had become aware on the previous day that detensioning of the head bolts was prohibited by the procedure pending completion of a successful test to verify secondary containment integrity.
.A M 4,
i 9512040254 951122 fV PDR FOIA PATTERS95-262 P, dry
Mr. James Lieberman December 9, 1994 Page 2 I knew then that previously the RPV was disassembled prior to verifying secondary containment integrity.
Accordingly, I did not feel that the delay to verify containment integrity was consistent with this prior practice.
Because I thought the delay was not appropriate, I
expressed my displeasure (using an intemperate word or two).
At the time, I was not familiar with revisions to the procedure in 1990-1991, which added a prohibition against lifting the head prior to verifying secondary containment integri Others besides myself (including, as I recall,%ick Gardne also questioned the rationale for the prohibition fn the proced re.
I recall that a temporary procedure change was processed to move the requirement to verify containment integrity to a later step in the procedure.
To the est of my rec
- lection, the temporary change was initiated by eff Bracrsovsk but I do not recall who directed that the chan e'be made.
I bel'ieve that I waa not in the approval chain for the temporary change to tne procedure.
I recall that detensioning t he studs took pbout one i hift to com ete.
I believe that perhapsEgick Gardne@ qontacted
\\ Jim Flahert ubsequently about the need f'or permanent' changes to the RPV dis ssembly procedures.
I was not involved much in discussions leading up to the SORC meeting on March 9, 1993.
I remember that SORC considered the change to procedure 7.4.4 (removal of the RPV head) during the first session on March 9,
1993 and that the meeting was subsequently reconvened that afternoon.
I did not attend the subsequent session of the meeting.
I recall im Flahert thehgineering Manage spresented the proposed proc dure changes to SORC.
He consulte a stack of reference materials which he had brought to the meeting.
I remember looking at the PCN form for the change.
I do not recall specifically what other materials were distributed at the meeting for SORC members' information (in addition to the PCN form).
I do not recall looking at the NUREG-0612 document, although at the time I believe I was generally familiar with its coverage of the heavy loads issue.
I do not recall askipq, many que
'ons during the meeting or challenging the basis for W m Flahert s presentation.
/'
My recollection in general is that SORC considered the purpose of that procedurs.1 restriction in relation to safe movement of loads over the RPV and the need to maintain secondary containment integrity as required by the technical specifications.
I recall that the meeting lasted a couple of hours and involved a
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.Mr. James /Lieberman
' December 9,E1994' l
Pagef3-l i
considerable amount of discussion.
As I remember, the. concurrence l
portion of the PCN form was blank'when the SORC meeting. began, and
~
was. filled in during the meeting after the procedure was approved.
l r
kutage Directo did not ' attend SORC l
~
Typically, as
. meetings..~ I attended t!fie March 9,
1993 meeting -.in particular -
because I felt the need to be aware of the procedures governing ~ RPV
{
disassembly which.were to be discussed.
During the. meeting, SORC" members: discussed so-called aheavy"-loads,~ as addressed by.NUREG-
.0612, and distinguished them from lighter loads. addressed by GE PRC i
88-11 (loads other than the RPV head, dryer and assembly).
SORC
-also d cussed Tecpnical Specification Amendments 147 and 150,
-whic im Flahert@pad identified in his research.
I do not recall l
whether SORC revihwed copies of the amendments.
As SORC viewed it,'
-the proposed procedure changes allowing RPV disassembly prior to
'f verifying secondary containment integrity were consistent with the guidelines of NUREG-0612 and GE PRC 88-11.
'l My recollection is that SORC was satisfied that the District's' actions in response to NUREG-0612 left no credible 1
potentisl for damage to irradiated fuel ao a result of movement'of j
loads during RPV disassembly (i.e., moving the head, separator and j
dryer).
I recall discussion at the meeting on the telecon with GE concerning the scope of PRC 88-11.
We,were in a somewhat unique position at the time, with the RPV head bolts detensioned under the j
temporary PCN and the pending procedure changes being considered by i
SORC.
My-view at the time was that the 1991 procedure changes probably exceeded the guidelines contained in GE PRC 88-11 because'
]
the changes unnecessarily restricted the timing of RPV disassembly.
I recall SORC members discussing the NUREG-0612 aspects of the lifting systems in place at the plant (i.e.,
the systems are designed to withstand single failures).
i To the best of my recollection, SORC also discussed an earlier interpretation by the NRC Staff indicating that the 4
technical specifications did not prohibit RPV ' disassembly pending verification of secondary containment integrity.
I do not recall' any. dissenting votes by SORC members,' and to my knowledge the proposed procedure change was una usly app v d at the meeting.
-I do not -- recall = whether or not ohn Meacha attended the SORC meeting.
i h l=== tion Why NRC S=ntatian= Are Tnannronriate From 'my experience as tage Direct for the 1993
' refueling,- it is important to try to maintai schedule for
h.
Mr. James Lieberman December 9, 1994 Page 4 refueling activities and schedule demands are primarily self-imposed.
Although maintaining a schedule is important, it is of secondary importance to plant safety.
In my view, SORC members I
considered several relevant factors in approving the procedure change, including the requirements for moving loads in secondary containment, GE PRC 88-11, NUREG-0612 and requirements for secondary containment integrity.
I do not recall any undue pressure from SORC members or others to reach a hasty conclusion in connection with the procedure changes.
Although I do not recall having personally reviewed all of the background documents discussed at the SORC meeting, it was my understanding at the time that the changes to procedures approved by SORC on March 9, 1993 were considered to be consistent with technical specification requirements for secondary containment integrity.
In hindsight, I still believe that SORC's decision was appropriate under the circumstances.
In this regard, I respectfully suggest that sanctions against me personally as suggested in the November 10, 1994 Demand for Information would be inappropriate.
As explained above, I believe that my understanding of the matters discussed at the SORC meeting on March 9, 1993, provided an adequate basis for my vote to approve the procedure change.
Any sanctions against me personally would result in personal hardship because of my significant investment as a nuclear power professional.
earned a B.S.
in mechanical engineering from the University of ebraska in 1982. My experience includes approximately 12 years of employment by NPPD at the Cooper Nuclear Station (1982 to Present).
Prior to that time, I served in the U.S. Navy nuclear submarine program for about nine years (1968 to 1977).
I am certified as a Senior Reactor Operator (1990) and am a qualified Shift Technical Advisor (1983) at Cooper Nuclear Station.
I have held various positions including Senior Manager of Site Support (1992), Senior Manager of Staff Support (1990), Engineering Manager (1986), Plapt Engineering Supervisor (1983) and Mechanical Engineer (1982)g
/
In my current position as Senior Manager of Site Support, I have cv all responsibility for supporting site activities in matters related to training, site services, security, outage and modifications, emergency preparedness and personnel coordination.
This position reports directly to the Site Manager.
This position also has interface responsibility with the Construction Management Department and serves as public relations spokesperson for the site.
My additional collatera uties include memberships in the Safety Review and Audit Boar pnd the Station Operations Review
.' s so Mr. James Lieberman December 9, 1994 Page 5 i
Committee (SORC).
I am also echnical Support Center Directo under the NPPD Emergency Plan f r Cooper Nuclear Station.
I affirm 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.
$ 2.790.
Sincerely, 5
~
hugeneM. Mace Sworn to and subscribed fore me this [ day of 1 n dW, 1994.
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