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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M3801999-10-21021 October 1999 Forwards Insp Rept 50-263/99-06 on 990813-0923.Four Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217G0711999-10-13013 October 1999 Forwards Insp Rept 50-263/99-12 on 990913-17.No Violations Noted ML20216J2491999-09-30030 September 1999 Ack Receipt of 980804,990626 & 0720 Ltrs in Response to GL 98-01,suppl 1, Year 2000 Readiness of Computer Sys at Npps. Staff Review Has Concluded That All Requested Info Has Been Provided ML20217B1421999-09-30030 September 1999 Informs That on 990902,NRC Staff Completed mid-cicle Plant Performance Review of Monticello Nuclear Generating Station. Staff Conducted Reviews for All Operating NPPs to Integrate Performance Information & to Plan for Insp Activities ML20212K9131999-09-30030 September 1999 Refers to 990920 Meeting Conducted at Monticello Nuclear Generating Station to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA ML20216J8091999-09-24024 September 1999 Informs That New Diaphragm Matl Has Corrected Sticking Problem Associated with Increased Control Rod Drive Scram Times.Augmented Testing of Valves at Monticello Has Been Discontinued ML20216G4341999-09-24024 September 1999 Forwards Exam Rept 50-263/99-301 on 990823-26.Violation Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy.Test Was Administered to Two Applicants. Both Applicants Passed All Sections of Exam ML20212G7171999-09-24024 September 1999 Submits Semiannual Status Update on Project Plans for USAR Review Project & Conversion to Its.Conversion Package Submittal Continues to Be Targeted for Aug of 2000 ML20212G9801999-09-23023 September 1999 Refers to Resolution of Unresolved Items Identified Re Security Alarm Station Operations at Both Monitcello & Prairie Island ML20212F0901999-09-21021 September 1999 Confirms Discussion Between M Hammer & Rd Lanksbury to Have Routine Mgt Meeting on 991005 in Lisle,Il.Purpose of Meeting to Discuss Improvement Initiatives in Areas of Operations & Equipment Reliability ML20212A9761999-09-0909 September 1999 Submits 1999 Annual Rept of Any Changes or Errors Identified in ECCS Analytical Models or Applications ML20217A5751999-09-0909 September 1999 Forwards Individual Exam Results for Licensee Applicants Who Took Aug 1999 Initial License Exam.Without Encls ML20211Q6981999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Monticello Operator License Applicants During Wks of 010604 & 11.Validation of Exam Will Occur at Station During Wk of 010514 ML20211L1981999-09-0101 September 1999 Forwards Insp Rept 50-263/99-05 on 990702-0812.No Violations Noted ML20211K7971999-09-0101 September 1999 Informs That Util Reviewed Rvid as Requested in NRC .Recommended Corrections Are Listed ML20211K2591999-08-27027 August 1999 Forwards NSP Co Fitness for Duty Program Performance Data for Six Month Period Ending 990630 ML20211F9961999-08-26026 August 1999 Forwards Effluent & Waste Disposal Semi-Annual Rept for 990101-990630, Revised Effluent & Waste Disposal Semi-Annual Rept for 980701-981231 & Revs to ODCM for Monitcello Nuclear Generating Plant ML20211C9501999-08-23023 August 1999 Forwards Rev 17 to Monticello Nuclear Generating Plant USAR, Updating Info in USAR to Reflect Implementation of Increase in Licensed Core Thermal Power from 1,670 Mwt to 1,775 Mwt.Rept of Changes,Tests & Experiments Not Included ML20210U1831999-08-12012 August 1999 Revises 980202 Commitment Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions ML20210T9601999-08-12012 August 1999 Provides Rept on Status of Util RPV Feedwater Nozzle Insps Performed in Response to USI A-10 Re BWR Nozzle Cracking ML20210Q0341999-08-0404 August 1999 Forwards SE Granting Licensee 980724 Relief Request 10 Re Third 10-year Interval ISI Program Plan,Entitled, Limited Exam ML20210H0861999-07-28028 July 1999 Forwards Insp Rept 50-263/99-04 on 990521-0701.No Violations Noted.Licensee Conduct at Monticello Facility Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Appropriate Radiological Controls ML18107A7051999-07-20020 July 1999 Provides Suppl Info Which Supersedes Info in 990625 Ltr in Response to NRC RAI Re GL 98-01, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML20212H3191999-07-16016 July 1999 Forwards Aug 1999 Monticello RO Exam Package,Including Revised Outlines.All Changes Are in Blue Font ML20209G5621999-07-14014 July 1999 Forwards Insp Rept 50-263/99-11 on 990621-24.No Violations Noted.Objective of Insp,To Determine Whether Monticello Nuclear Generating Station Emergency Plan Adequate & If Station Personnel Properly Implemented Emergency Plan ML20196J5351999-07-0202 July 1999 Discusses GL 92-01,Rev 1,Supp 1, Rv Integrity, Issued by NRC on 950515 & NSP Responses & 980917 for Monticello Npp.Informs That Staff Revised Info in Rvid & Released Info as Rvid Version 2 ML20196J9681999-07-0101 July 1999 Informs That in Sept 1998,Region III Received Rev 20 to Portions of Util Emergency Plan Under 10CFR50.54(q).Based on Determination That Changes Do Not Decrease Effectiveness of Licensee Emergency Plan,No NRC Approval Required ML20209B6151999-06-25025 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Y2K Readiness Disclosure Attached ML20196H2291999-06-24024 June 1999 Responds to Administrative Ltr 99-02,dtd 990603,requesting Licensee to Provide Estimate of Licensing Action Submittals Anticipated.Four New Submittals Per Year Are Anticipated ML20207D5851999-05-25025 May 1999 Submits Info Re Partial Fulfillment of License Conditions Placed on Amend 101,which Approved Use of Ten Exceptions for 24 Months Subject to Listed App C Conditions.Util Will Submit Second Rept to Obtain Approval for Continued Use ML20206S0911999-05-17017 May 1999 Forwards Response to NRC 990324 RAI Re Proposed Amend to pressure-temp Limits & Surveillance Capsule Withdrawal Schedule, .Supporting Calculations Also Encl ML20206N5601999-05-13013 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Cm Craig Will Be Section Chief for Monticello Npp.Organization Chart Encl ML20206G2181999-05-0505 May 1999 Discusses Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, Dtd 960110,for Plant ML20206G4901999-05-0404 May 1999 Forwards Staff Review of Licensee 960508 Response to NRC Bulletin 96-002, Movement of Heavy Loads Over Sf,Over Fuel in Rc or Over Safety-Related Equipment, .Overall, Responses Acceptable.Tac M95610 Closed ML20206G7741999-05-0303 May 1999 Forwards Insp Rept 50-263/99-02 on 990223-0408.One Violation Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20206D1651999-04-27027 April 1999 Forwards Radiation Environ Monitoring Program for MNGP for Jan-Dec 1998, Per Plant TS 6.7.C.1.Ltr Contains No New NRC Commitments or Modifies Any Prior Commitments ML20205N0821999-04-12012 April 1999 Forwards SE of NSP Response to NRC GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Licensee Adequately Addressed Actions Requested in GL ML20205N4811999-04-0909 April 1999 Forwards Licensing Requalification Insp Rept 50-263/99-10 on 990308-12.No Violations Noted.However,Inspectors Through Observation of Simulator Scenario Exams Noted Difficulties in Ability of SM to Simultaneously Implement Duties of SM ML20205N5301999-04-0909 April 1999 Discusses Arrangements Made on 990406 for Administration of Licensing Exams at Monticello Nuclear Generating Station During Wk of 990823.Requests That Exam Outlines Be Submitted by 990128 & Supporting Ref Matls by 990719 ML20196K7831999-03-31031 March 1999 Forwards Decommissioning Funding Status Rept for Monticello & Prairie Island Nuclear Generating Plants,Per Requirements of 10CFR50.75(f)(1) ML20205H5731999-03-29029 March 1999 Submits Required 1998 Actual & 1999 Projected Cash Flow Statements for Monticello Nuclear Generating Plant & PINGP, Units 1 & 2.Encl Contains Proprietary Info.Proprietary Info Withheld,Per 10CFR2.790(b)(1) ML20205C4851999-03-26026 March 1999 Informs That on 990203,NRC Staff Completed PPR of Nuclear Plant.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205C6561999-03-26026 March 1999 Submits Semiannual Update on Project Plans for USAR Review Project & Conversion to ITS ML20205A5881999-03-24024 March 1999 Forwards Request for Addl Info Re Submittal Requesting Rev of pressure-temperature Limits & Surveillance Capsule Withdrawal Schedule ML20204H4711999-03-18018 March 1999 Forwards SER Concluding That Util Established Acceptable Program to Verify Periodically design-basis Capability of safety-related MOVs at Monticello & Adequately Addressed Actions Requested in GL 96-05 ML20207H5161999-03-11011 March 1999 Forwards Insp Rept 50-263/99-01 on 990112-0222.No Violations Noted ML20207F4091999-02-28028 February 1999 Forwards Fitness for Duty Program Performance Data for Six Month Period from 980701-981231,IAW 10CFR26.71 ML20207F6741999-02-24024 February 1999 Forwards Summary of Nuclear Property Insurance Maintained at Monticello & Prairie Island Nuclear Generating Plants ML20207F6901999-02-23023 February 1999 Forwards Effluent & Waste Disposal Semi-Annual Rept for 980701-981231, Off-Site Radiation Dose Assessment for 980101-981231 & Revised Effluent & Waste Disposal Semi- Annual Rept for 980101-980630, for Monticello ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-09
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217M3801999-10-21021 October 1999 Forwards Insp Rept 50-263/99-06 on 990813-0923.Four Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20217G0711999-10-13013 October 1999 Forwards Insp Rept 50-263/99-12 on 990913-17.No Violations Noted ML20216J2491999-09-30030 September 1999 Ack Receipt of 980804,990626 & 0720 Ltrs in Response to GL 98-01,suppl 1, Year 2000 Readiness of Computer Sys at Npps. Staff Review Has Concluded That All Requested Info Has Been Provided ML20217B1421999-09-30030 September 1999 Informs That on 990902,NRC Staff Completed mid-cicle Plant Performance Review of Monticello Nuclear Generating Station. Staff Conducted Reviews for All Operating NPPs to Integrate Performance Information & to Plan for Insp Activities ML20212K9131999-09-30030 September 1999 Refers to 990920 Meeting Conducted at Monticello Nuclear Generating Station to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA ML20216G4341999-09-24024 September 1999 Forwards Exam Rept 50-263/99-301 on 990823-26.Violation Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy.Test Was Administered to Two Applicants. Both Applicants Passed All Sections of Exam ML20212G9801999-09-23023 September 1999 Refers to Resolution of Unresolved Items Identified Re Security Alarm Station Operations at Both Monitcello & Prairie Island ML20212F0901999-09-21021 September 1999 Confirms Discussion Between M Hammer & Rd Lanksbury to Have Routine Mgt Meeting on 991005 in Lisle,Il.Purpose of Meeting to Discuss Improvement Initiatives in Areas of Operations & Equipment Reliability ML20217A5751999-09-0909 September 1999 Forwards Individual Exam Results for Licensee Applicants Who Took Aug 1999 Initial License Exam.Without Encls ML20211Q6981999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Monticello Operator License Applicants During Wks of 010604 & 11.Validation of Exam Will Occur at Station During Wk of 010514 ML20211L1981999-09-0101 September 1999 Forwards Insp Rept 50-263/99-05 on 990702-0812.No Violations Noted ML20210Q0341999-08-0404 August 1999 Forwards SE Granting Licensee 980724 Relief Request 10 Re Third 10-year Interval ISI Program Plan,Entitled, Limited Exam ML20210H0861999-07-28028 July 1999 Forwards Insp Rept 50-263/99-04 on 990521-0701.No Violations Noted.Licensee Conduct at Monticello Facility Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Appropriate Radiological Controls ML20209G5621999-07-14014 July 1999 Forwards Insp Rept 50-263/99-11 on 990621-24.No Violations Noted.Objective of Insp,To Determine Whether Monticello Nuclear Generating Station Emergency Plan Adequate & If Station Personnel Properly Implemented Emergency Plan ML20196J5351999-07-0202 July 1999 Discusses GL 92-01,Rev 1,Supp 1, Rv Integrity, Issued by NRC on 950515 & NSP Responses & 980917 for Monticello Npp.Informs That Staff Revised Info in Rvid & Released Info as Rvid Version 2 ML20196J9681999-07-0101 July 1999 Informs That in Sept 1998,Region III Received Rev 20 to Portions of Util Emergency Plan Under 10CFR50.54(q).Based on Determination That Changes Do Not Decrease Effectiveness of Licensee Emergency Plan,No NRC Approval Required ML20206N5601999-05-13013 May 1999 Informs That NRC Office of Nuclear Reactor Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Cm Craig Will Be Section Chief for Monticello Npp.Organization Chart Encl ML20206G2181999-05-0505 May 1999 Discusses Completion of Licensing Action for GL 96-01, Testing of Safety-Related Logic Circuits, Dtd 960110,for Plant ML20206G4901999-05-0404 May 1999 Forwards Staff Review of Licensee 960508 Response to NRC Bulletin 96-002, Movement of Heavy Loads Over Sf,Over Fuel in Rc or Over Safety-Related Equipment, .Overall, Responses Acceptable.Tac M95610 Closed ML20206G7741999-05-0303 May 1999 Forwards Insp Rept 50-263/99-02 on 990223-0408.One Violation Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20205N0821999-04-12012 April 1999 Forwards SE of NSP Response to NRC GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Licensee Adequately Addressed Actions Requested in GL ML20205N4811999-04-0909 April 1999 Forwards Licensing Requalification Insp Rept 50-263/99-10 on 990308-12.No Violations Noted.However,Inspectors Through Observation of Simulator Scenario Exams Noted Difficulties in Ability of SM to Simultaneously Implement Duties of SM ML20205N5301999-04-0909 April 1999 Discusses Arrangements Made on 990406 for Administration of Licensing Exams at Monticello Nuclear Generating Station During Wk of 990823.Requests That Exam Outlines Be Submitted by 990128 & Supporting Ref Matls by 990719 ML20205C4851999-03-26026 March 1999 Informs That on 990203,NRC Staff Completed PPR of Nuclear Plant.Staff Conducts Reviews for All Operating NPPs to Develop an Integrated Understanding of Safety Performance ML20205A5881999-03-24024 March 1999 Forwards Request for Addl Info Re Submittal Requesting Rev of pressure-temperature Limits & Surveillance Capsule Withdrawal Schedule ML20204H4711999-03-18018 March 1999 Forwards SER Concluding That Util Established Acceptable Program to Verify Periodically design-basis Capability of safety-related MOVs at Monticello & Adequately Addressed Actions Requested in GL 96-05 ML20207H5161999-03-11011 March 1999 Forwards Insp Rept 50-263/99-01 on 990112-0222.No Violations Noted ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function ML20202B7191999-01-26026 January 1999 Discusses 990125 Telcon with T Witschen & D Mcneil Re Arrangements for NRC to Inspect Licensed Operator Requalification Program at Monticello Nuclear Generating Station.Insp Planned for Week of 990308 ML20199H8321999-01-20020 January 1999 Forwards Insp Rept 50-263/98-18 on 981201-990111.No Violations Were Identified.Conduct of Activities at Monticello Facility Was Generally Characterized by safety- Conscious Operations & Sound Maint Practices ML20199G7721999-01-14014 January 1999 Forwards Request for Addl Info Re GL 88-20, Individual Plant Exam of External Events (IPEEE) for Severe Accident Vulnerabilities, Issued in June 1991 ML20206R8631999-01-12012 January 1999 Informs That Staff Has Prepared TS Interpretation of Requirements for Extending Surveillance Intervals at Plant,Per NRC Request ML20199E4791999-01-0606 January 1999 Forwards SER Accepting Licensee 951116,960214 & 0524 Responses to NRC Bulletin 95-002, Unexpected Clogging of Residual Heat Removal Pump Strainer While Operating in Suppression Pool Cooling Mode, for Monticello ML20206R8741999-01-0404 January 1999 Discusses Clarification of Understanding of Safety Evaluation Related to Deviation from Emergency Procedure Guidelines for Monticello.Staff Agrees with NSP Characterization & Resolution of Issues ML20198R2001998-12-30030 December 1998 Forwards Insp Rept 50-263/98-19 on 981214-18.No Violations Noted.Purpose of Insp Was to Review Plant Chemistry Program, PASS & REMP ML20198P0501998-12-28028 December 1998 Informs of Completion of Review of Relief Request 9 Re Third 10-year Interval ISI Program Plan,Entitled Use of High Alloy/High Nickel Calibr Block for Dissimilar Metal Welds. Supporting SE Encl ML20198G0761998-12-21021 December 1998 Acks Receipt of Notifying NRC That Commitment Noted in Is Complete Re Tornado Effects on Reactor Bldg Superstructure ML20198D0181998-12-15015 December 1998 Informs That as Part of PRA Implementation Plan,Commission Assigned Two SRAs to Each Regional Ofc.Sras Will Routinely Assess Licensee Event Repts,Plant Events,Insp Findings & EAs from Risk Perspective ML20198B7721998-12-14014 December 1998 Forwards Insp Rept 50-263/98-16 on 981014-1130 & Notice of Violation Re Fire Brigade Drill Participation ML20198D0641998-12-10010 December 1998 Forwards SE Accepting Licensee 971118 Request for Review & Approval of Deviation from BWROG Epg,Rev 4,NEDO-31331, March,1997.Deviation Will Permit Rev of Plant EOPs to Recognize 2/3 Core Height as Adequate for Core Cooling ML20196C2411998-11-24024 November 1998 Forwards Insp Rept 50-263/98-17 on 981026-30.No Violations Noted.Security Dept self-assessment Efforts Continue to Be Very Strong ML20196D5641998-11-20020 November 1998 Discusses 981104 Insp Resource Planning Meeting for Monticello & Advises of Planned Insp Effort for Next 6 Months at Plant.Info Provided to Min Resource Impacts on Staff & to Allow for Rescheduling Conflicts to Be Resolved ML20195J8811998-11-19019 November 1998 Informs That EOP Flow Charts C.5-1100 RPV Control, Rev 5 & C.5-1100... Rev 6 Marked Proprietary & Submitted as Attachments 3 & 4 to Util Will Be Withheld from Public Disclosure Per 10CFR2.790(b)(5) ML20196G6081998-11-19019 November 1998 Submits Correction to Which Advises Licensee That EOP Flow Charts, C.5-1100 RPV Control, Rev 5 & C.5-1100 RPV Control, Rev 6,marked Proprietary,Will Be Withheld from Public Disclosure.Ltr Reissued to Correct Date of Issuance ML20195E3321998-11-12012 November 1998 Forwards SE Concluding That Licensee Implementation Program to Resolve USI A-46 at Facility Has Adequately Addressed Purpose of 10CFR50.54(f) Request.Usi A-46 Program Was Established in Response to GL 87-02 ML20196D7291998-11-10010 November 1998 Forwards Insp Rept 50-263/98-15 on 980831-1014.No Violations Noted.Investigation Team Assembled by Station Mgt to Determine Root Cause of Offgas Sys Problem Was Thorough & Aggressive ML20154L2951998-10-0909 October 1998 Informs That Effective 981011,project Mgt Responsibility for Plant Will Be Transferred from Tj Kim to CF Lyon.Cf Lyon May Be Contacted at Listed Number ML20154F4971998-10-0606 October 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-263/98-09 Issued on 980730 ML20154J2501998-10-0202 October 1998 Forwards Audit of Year 2000 Program at Monticello Nuclear Generating Plant on 980915-17 as Followup to NRC GL 98-01, Year 2000 Readiness of Computer Systems at Nuclear Power Plants, Issued on 980511 ML20153C4611998-09-21021 September 1998 Submits Comments on Draft Environ Impact Statement for Minnesota Lake Superior Coastal Program 1999-09-09
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SEP 17 M l- Bonorable Albert E. Quio l Mouse of Representatives l
Dear Mr. Quie s l
The enclosed letter from Mrs. Eugene A. -Imhoff that you referred to us
' coussats to the effect that the ABC makes no tests of-its own while inspecting nuclear power plants to make sure they asse requirementa, but '
instead relies hsavily on reports of tests actually conducted by the builders of the plants.
The AgC inspection program, cartied 'out by its Division c2 Compliance was described in detail during the AEC hearing. in the patter of the Northern States power Company, Monticello Nuclest Centrating plant, Unit 1, . Docket No. 50-263. The yrincipal informatica is in Supplement 1 to the AEC Regulatory Steff Safety Evaluation and Wortions of the _testi--
many on August 5, _1970. Copios of this materia 1 are enclosed. This material is also available for-inspection at the Office of- the Clerk, l
Wright Comty Court House, Buffalo, Minnesota, l
Swanarising briefly the Atomic Energy Cawdssion in its regulatory pre-- '
gram holds its licensees responsible far iafety in the design, construction and operation of their nuelaar reactot 'acilities - The ARC inspection program is directed toward assuring that the -licensees are fulfilling these safety responsibilities. Among the requirements imposed upon licensees to accomplish this is one that requires them to establish quality assurance programs that include suitable provisions for independent reviews :of quality of construction. Specifically, part 50.34 'of AEC regulations (copy enclosed) states in part that "A program for inspection _ of activities ' affacting quality shall be established. and executed by or for the organization per-forming the activity- to _ verify conformance with the. documented instructions, i
procedures, _and drawings for accomplishing the activity. Such inspection shall be performed by individuals _other_ than- those who_ performed the ac-tivity being inspected." - Af ter work is -performed by craf tsase under 'respea-sible supervision, it is reviewed by appropriate quality assurance personnel.-
In many cases this imelados quality control personnel fron the workman's organisation, the . construction contractor. - the architect-engineer. and- the licensee. Independent testing laboratories are often employed by these 1-organisations. The licensee' is responsible for auditing the entire program and for assuring that it is functioning properly. , g ')
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a Comerable Albert M. Quis The Division of coup 11anse them inspects the performance of all these groups through a system of opet cheeks, rooerd reviews, interviews, and aboarvation of work in progrees. We believe that this system of independ-est shocks and audito provides adequate aneuranee of the quality of construction.
As to Mrs. Imhoff's questime with raepeat to the authority of the state of Minnesota to establish more restrictive standards regarding releases of radioactivity from anclear power plaats licensed by the AEC, this matter is now is litigation before the U. S. District Court for the District of Minnesota.
Sincerely, I signe3 J Harold L. Price Harold L. Price Director of Regulation Enclosures :
- 1. Cy ler Mrs. Imhoff to Rep. Quie, dated August 7, 1970
- 2. Cy Supplement 1
- 3. Cy Monticalle Testimony
- 4. Cy Federal Register Distribution:
OCR (2)
H. L. Price, DR H . K. Shapar , GC E . G . Case , DRS P. A. Morris, DRL A . G iamb us s o , CO R. H. Engelken, C0 B. H. Grier, C0:111 G. Ertter, DR-2755 (Note : Retyped on 9/14 per Dr. Beck's consnents)
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!;04TM:,'R : ST/,TC", POWEF. ) Docket No. 50-203 j COMANY r
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'ihe Division of Complianec's inspection progratt has been generally described l in the introductory part of Supplement flo.1, the AEC Regulatory Staff safety -
l cval uat ion. Questiens were raised during the deposition and since the sub -
nittal of Supplcrent 1. An a result of these, I will' provide some further
- discussion of the inst ection program.
The inspection role assigned to the Division of Compliance in the AEC tbgulatoryprogramisbanedencertalu-fundamentaldecisionsradobythe 4 Congress and on impicracntlng policios adopted by . the Conraission. The
! Congress bas entablished a systen of licensing privately owned and operated
! nucicar rnet13 tien.
Inherent in the concept of- private activitics, _ subject to licensing and result. tion by a covernment agency is the fact that the liacnsee is held
.esponsible for meeting the objectives of the -licensing.and regulatory
! system, In this case, protection of the health and safety of ;;he public.
This is in contrast to ' the cituation in which operational activitics are 1
carried on by the agency, ,it cif, and in which the agency carries out operational cafety activitics. Let.me reiterate that the Atomic Energy ,
Con:r.ission in its licensing and Regulatory program holds its licensec9 responsible for safety in the design, construction,_ and operation of nucicar
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reactor facilitics.-
-ENCLOSURE 3
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The Division of Compliar.ce's inspection program is designed to assure that a licensee is carrying out his safety responsibilities. The Commission's I '- regulations in Appendix B to Part 50 require a 1kensec to have a quality i
- assurance program which includes provisions for independent safety and i
quality revicus of design, construction, end operation. By independent, l
t it is meant that revicen are conducted by persons who do not have responsibility for perforning the work in question or for related costa in scheduling.
4 I In the case of a construction project, the Division of Compliancc's inspec-tion activitics are directed touard verifying that a 1kensee han inplomcuted J
the required assurance prograr!. Typical ~ Lispection activitics which are carried out in this regard are identified on'Page 3 of Supplenent Mo. 1.
< Specifinn11y, thene include such things chich I tuuld like to ncntion of
! witnessing the perfornance of major construction tents such as hydrostatic 4
tests of piping and pressure tests of containment vessels and review of prograt.i for a functional or preoperational testing of system and equipment including the test program, the test procedures and the test results.
t lie have concluded that these inspection activitico provide an adequate basir-1
- for verifying independent reviews of- construction activitics and provide i !
i reasonabic assurance that the completed facility vill conform to AEC regulatory requirencnts. - Let tac emphasize one area of our. inspection program I
j which I've just mentioned,' that related to preoperational testing'of the I > facility. The licensee is required to develop and irry out a comprehensive.
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1 preoperational testing program. The procedurco developed under this t
program are reviewed by Compliance inspectors. The comments are directed to the licenccc. The performance of selected preoperational tests are witnessed by Compliance inspectors.
The recults cf the teste and the 11cencce's evaluation thereof are reviewed by the inspectors. Thia testinp, of the plant to the extent possibic prior to the loading of fuel denonstrates whether the plant systens and components .l are capable of performing their intended functions under both normal and abnormal conditions. These testo also serve to demonstrete the adequacy of plant operating procedurcs.
,W Satisfactory completion-of the preoperational testing program is an important part of the basis for our finding of plant conpletion. Division of Compliance a inspection personnel are experienced and knowledgeable in the practical aspects l of construction and operation of nucicar reactors. This is demonstrated by the qualifications of the inspectors which have been entered in the record of this proceeding.
In addition to the inspectors, specialints in appropriate fields of engineering I
- and technology who are assigned to the Division of Compliance headquarters staff and to other divisions within the regulatory staf f are utilized to
.nssiat in special inspections.
Further, consultants to the AEC also provide assistance. The experience s
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l and technical competence of the innpcetion personnel arc important factors -
in the success of the innpection program. We scch uniformity and objectivity I
in the conduct of the Division of Compliance inspcetion progran by a system j
of internal checkn and balances. This system. includes prope. ration of inopcc-tien plans prior to an inspection, rev$cu of the results of thnse inspect. ions J
4 by the cupervisor, the preparation and _ distribution of the written inspection i report to headqunrters groups, oncite vinits by suucrvisors with innpactors, accompaniment of inspectors by headqucrters or other Complinnce staff including specialicts nnd consultants, rotation of inspection assignments, and in the case of operating facilitics, assi;nm:nt of back-up inspectors who participate in onsite inspections.
The matter of our reliance on the licensee to maintain accurate and conplete records has been raised. For example, records pertaining to the installation
! i and testing of a particular systen. It has been implied that these records k
could be falsified. It is true that through incent, negligence or oversight,-
incorrect records may be generated. In my opinion, our inspection program cannot be readily frustrated by falsified or incorrect records. As a-basis 4~
for this opinion let me - point out, first, 't order to achieve a coherent i
j coverup of some adverso information, a large nunber Lof licensing and contractor
, personnel would have to be a party to the concealment. . This is almost 4
inconceivable.
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i i Secc..d the licensee does not know ubere our spot checks will take pince.
1 Thene checks nay, indeed, be random and with so nuch interreic.ted data, I
it would be very dif ficult to conceal inconsistencies.
i l ; Thirdly, the nyntens in question arc t.angible nr.d our inspectors do verify
! information in records or request verifict.t ion uador their observation.
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- t. gain, bear in mind as pointed out previously, our inspection personnci are Because of this experience, experienced in reactor construction and operation.
they are fanillar with chat records ought to look like and uhat typical relationships enist amng data through revices of records, observation of vork in progreca, discussion with licensee and contractor per=onnel at all levels they are able to formulate judgaento as to the validity of the records.
Ity com: tents so far have reinted principally to the construction and inspection T
l program. The frequency of inspection after the operation begins depends upon
- the status of the facility. During the period af ter initial fuel loading when low power and power sensing tecting is' in progress, inspections are performed on at least a monthly basis. Inspections may be more frequent
' if tests which we want to vitness are in process or if any operational I difficulties have developed. Inspection frequency will be reduced only af ter f
the plant coupletes full power testing and coterances routine operation. It is at this time, af ter satisfactory performance of. the plant has been
' demonstrated, that the minimum frequency. becomes four times per year. . sTo 1
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I repeat, this is minimun frequency. If the plant maintenance or refueling operations are scheduled, or if operational difficultics develop, our
! inspection frequency will be increased.
The Divisinn of Compliance was initially cetablished in 1960. I have been i
o member of the Division since shortly after its fornation. !!r. Thornburg, the supervioory inspector for Monticello, han nico been a menbcr of the Division since approximately that time. During this ten-year period the fundamental philosophy of inspection has remained the sanc: that is, a system for relectively c.xanininr, the canner in dich the licensee is meeting his responsibilities. The progran has, of course, undergenc period review rnd upanting. The preexam as it hac been deceribed for !;onticello is no different than that which has born and is being followed elsewhere. Based on our exparience during tha perlod since the establinhnent of the Division, t'e conclude the Division of Compliance inspection program as' it applies to the -
facilitica under cont:truction provides na adequate basis for the findings chich must be rxtdo, namely. that a facility has been cornpleted in. accordance with AEC regulctory requirencnts.
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