ML20094R115
| ML20094R115 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| 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) | |
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1 Decemkey 12, 199 0
0 Mr.~ James Lieberman Director, Office of Enforcement U.S. Nuolear Regulatory Commission Washington, D.C.
20555
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 greater detail the events during the March 1993 refueling outage, a
particu3arly the approval by the Station Operations Review Colatittee (SORC) on March 9,
1993 of changes to procedures governing reactor pressure vessel (RPV) disassembly.
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===Immation of sonc's lation On March 9, 1993, I wa cting Senior Manager of Operati 4
I was in this position temporarily, filling in for San Petersen, j
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.
- =9 During the meeting, I recall that there was a fairly lengthy discussion of the propos d change o the reactor pressure vessel aber of documents and discussed previou$
im Flahert theCCES Engineering Managea i
head removal procedure,j s
i presented a_ considerable s p oceduqs and Technical Specification changes.
When asked, Mr.
1 PJlahert out some of the documents for SORC members to l
- review.y passedhe discussion dealt in part with the fact that there was 2
i some confusion over which loads were controlled under NUREG-0612 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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9512040278 951122 r /
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Mr. James Lieberman December 12, 1994 l
Page 2 l
l My understanding was that, under the NUREG, a licensee has two options -- (1) analyse each load to assess the conseqvsnces of a load drop, or (2) implement a program to ensure that lifting j
devices are single-failure proof, along with surveillance testing and load lift testing on the lifting devices.
CNS had taken the latter course by implementing the required program.
Therefore, 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 l
members brought out a set of the Technical Specifications and discussed Tech, spec. 3.7.C.1.d.
The focus of the dicevasion was i
on the intent.of the previous Tech. Spec. changes that restricted movement of loads that had the entia damage irradiated fuel.
It is my recollootion that Mr.
lahert 1ked about the intent of l
the Tech. Spec. requirements expla that the proposed change to the procedure did not violate the intant of the Tech. speos.
As i
best I recall, Tech. spec. Amendment 147 was discuemed. one reason l
it was discussed was that a box had been checked on the Procedure i
Change Notice indicating that a change to Tech.
Speos.
was j
involved, and there was confusion initially over what this item on the form meant.
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I At the time of the SORC meeting, I recall being aware that the l-secondary containment leak test had come close to passing.
As a l
good practice, the CNS Outage Guidelines (OMP-2-2) call for 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.
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I recall that a memorandum from Dr. Long, the NRC Project
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Manager for CNS, was provided to SORC.
I remember looking at dr.
Long's memorandum during the 50RC meeting or right afterward.
The memorandum indicated that secondary containment._ testing did not l
need to be completed until immediately prior to moving _ irradiated fuel.
This reassured me that 80RC's approval of'the procedura change was correct.
As I recall, Dr. Long stated in the memorandum j
that he was documenting this position so that the issue would not i.
be raised again.
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I also r====har thinking that the Standard BWR Technical
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Specifications do not contain a specific requirement to maintain secondary containment integrity during vessel disassembly.
My i
sense was that if this was such an important technical issue, one j
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
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received verbal confirmation from General Electric as to the intent 1
of PRC 88-11.
I believe there was discussion of this during the meeting.
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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 l
technical standpoint.
I also do not recall whether John Meacham]
l the Rate Manag attended the 50RC meeting.
Even he had, my
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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.
l As I recall, the SORC meeting broke so that the final 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 session of the meeting on March 9, 1993.
i 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
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I believe that no sanctions against me personally are l
warranted in connection with the November 10, 1994 Deman,I fpr Information issued to Nebraska Public Power District.
I continue to believe that SORC's actions were taken appropriately and with e
ad justification.
1 ing my tenure with NPPD (1989 to 1994), I wae'cTassified as l
a Management Trainee.
I am no longer employed by NPPD.
Any sanctions against be would impair my ability to pursue a career 1
1 elsewhere in the nuclear power industry.
I have over 20 years of 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.
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I affirm that this letter is true and correct to the best of ny knowledge and belief.
I hereby request that this letter be i
-ie
,w u
Mr. James Lieberman j
December 12, 1994 i
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J withheld from plaoament in the NRC Public Document Room and from l
disclosure pursuant to 10 C.F.R. 5 2.790.
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Sincerely, Y
1
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I Sworn to and su ibed bef a me this y of og,2:*
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