ML20094R115

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Responds to from Jr Gray Containing Demand for Info Transmitted to NPPD 951110 Re 930309 Refueling Outage. Info Deleted
ML20094R115
Person / Time
Site: Cooper Entergy icon.png
Issue date: 12/12/1994
From: Estes C
AFFILIATION NOT ASSIGNED
To: Lieberman J
NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20094Q932 List:
References
FOIA-95-262 NUDOCS 9512040278
Download: ML20094R115 (4)
v • d • e


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1 Decemkey 12, 199 0

0 Mr.~ James Lieberman

  • Director, Office of Enforcement U.S. Nuolear Regulatory Commission 20555
' Washington, D.C.

Dear Mr. Lieberman:

The purpose of this letter is to respond to the letter I j received from Mr. Joseph R. Gray of your office dated November 10, I

1994, which contained a copy of the Demand for Information (DFI) transmitted to the Nebraska Public Power District (NPPD) by letter i dated November 10, 1994. I have had the opportunity to review in a

greater detail the events during the March 1993 refueling outage, Review particu3arly the approval by the Station Operations Colatittee (SORC) on March 9, 1993 of changes to procedures governing reactor pressure vessel (RPV) disassembly.

f ===Immation of sonc's lation On March 9, 1993, I wa cting Senior Manager of Operati 4 j I was in this position temporarily, filling in for San Petersen, who was serving as an Outage Director at that time. In this

' capacity, I attended the first portion of the SORC meeting on March 9, 1993. .

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! During the meeting, I recall that there was a fairly lengthy discussion of the propos d change o the reactor pressure vessel head removal procedure,j im Flahert theCCES Engineering Managea i

presented a_ considerable aber of documents and discussed previou$s i s p oceduqs and Technical Specification changes. When asked, Mr. 1 out some of the documents for SORC members to l

  1. PJlahert review.y passedhe discussion dealt in part with the fact that there was 2

l i some confusion over which loads were controlled under NUREG-0612 l and which ones were subject to PRC 88-11. I remember that the i i

discussion focused on the fact that the NUREG addresses heavy loads '

while the PRC addresses loads of generally less than 1,000 pounds.

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Mr. James Lieberman .

! December 12, 1994 l Page 2 l

' My understanding was that, under the NUREG, a licensee has two options -- (1) analyse each load to assess the conseqvsnces of a j load drop, or (2) implement a program to ensure that lifting devices are single-failure proof, along with surveillance testing and load lift testing on the lifting devices. CNS had taken the Therefore,

- latter course by implementing the required program. t

' because CNS met the NUREG requirements, the lifting of the vessel l j head did not present the " potential" to damage irradiated fuel l

! under the ToAnical Specification requirements. I recall that SORC members brought out a set of the Technical Specifications and l

discussed Tech, spec. 3.7.C.1.d. The focus of the dicevasion was i

on the intent.of the previous Tech. Spec. changes damage irradiated fuel.

that restricted movement of loads that had the lahert entia It is my recollootion that Mr. 1ked about the intent of l the Tech. Spec. requirements expla that the proposed change i to the procedure did not violate the intant of the Tech. speos. As l

best I recall, Tech. spec. Amendment 147 was discuemed. one reason i it was discussed was that a box had been checked on theSpeos. Procedure was

! Change Notice indicating that a change to Tech.

j involved, and there was confusion initially over what this item on l 2

the form meant.

s I At the time of the SORC meeting, I recall being aware thatAsthe a l-secondary containment leak test had come close to passing. call for l good practice, the CNS Outage Guidelines (OMP-2-2)

maintaining secondary containment available throughout an outage, i

even when not required by Tech. Specs. I also believe I was aware at the time of the meeting that the head had already been detensioned. There may have been some sention of this fact during the SORC meeting.

1 I recall that a memorandum from Dr. Long, the NRC Project l

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Manager for CNS, was provided to SORC. I remember looking at The dr.

Long's memorandum during the 50RC meeting or right afterward.

memorandum indicated that secondary containment._ testing did not need to be completed until immediately prior to moving _ irradiated l fuel. This reassured me that 80RC's approval of'the procedura change was correct. As I recall, Dr. Long stated in the memorandum j

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that he was documenting this position so that the issue would not f be raised again.

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I also r====har thinking that the Standard BWR Technical Specifications do not contain a specific requirement to maintain

{' secondary containment integrity during vessel disassembly. My i

j sense was that if this was such an important technical issue, one would have expected that the Standard Tech. Specs. would address it. I believe this point was discussed during the SORC meeting, j but I am not sure.

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! I Mr. James I.ieberman  ;

j December 12, 1994 i i,

Page 3 ,

I seem to recall that at the time of the SORC meeting, CNS had i I

i received verbal Iconfirmation from General Electric as to the intent believe there was discussion of this during the  :

1 of PRC 88-11.

meeting. l j ,

i Although sORC did noc take formal votes, I do not believe i

there was any disagreement among soRc ma=hmes with the proposed  !

procedure change. I would not have been reluctant to voice any l 1 disagreement if I had had any concerns from a compliance or  !

technical standpoint. I also do not recall whether John Meacham]

l attended the 50RC meeting. Even he had, my l the Rate Manag

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judgment regard the proposed change would not have been l influenced. I also did not experience any undue schedule pressures to approve the proposed change.

As I recall, the SORC meeting broke so that the final l

j paperwork and procedures could be completed. The paperwork was not

final at the time of SORC's meeting. I did not attend the second i

session of the meeting on March 9, 1993. ,

General Electric later performed an analysis of the i consequences of dropping the RPV head and upper internals at CNS.  ;

Althoutph this analysis was after the fact, it now means that CNS  :

l satist:.as both options of NUREG-0612 for RPV disassembly loads.

l I do not recall being involved in the earlier changes to procedures that were made in 1991.  !

l munimaation Why unc ganations Are Inamarenriate J

I believe that no sanctions against me personally are

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l warranted in connection with the November 10, 1994 Deman,I fpr Information issued to Nebraska Public Power District. I continue e

to believe that SORC's actions were taken appropriately and with

! ad justification. -

1

! ing my tenure with NPPD (1989 to 1994), I wae'cTassified as a Management Trainee. I am no longer employed by NPPD. Any l

1 sanctions against be would impair my ability to pursue a career I have over 20 years of 1 elsewhere in the nuclear power industry.

experience in nuclear power. I received a B.S. in Nuclear l Engineering from Kansas State University in 1970 and a Masters in

Nuclear Engineering from Kansas State in 1971. I as certified on
both PWRs and BWRs in th ited States, and have held an NRC operators license on a PWR. 1 4

I affirm that this letterI is true and correct to the best of hereby request that this letter be i ny knowledge and belief.

- -- ,w

Mr. James Lieberman j

' December 12, 1994 i

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Page 4 l J

l withheld from plaoament in the NRC Public Document Room and from  !

disclosure pursuant to 10 C.F.R. 5 2.790. , l l l Sincerely, Y

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Sworn to and su ibed bef a me this y of

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