ML20138H655
| ML20138H655 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/26/1996 |
| From: | Miraglia F NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20138H601 | List: |
| References | |
| 2.206, NUDOCS 9701060154 | |
| Download: ML20138H655 (3) | |
Text
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v' 7590-01-P UNITED STATES NUCLEAR REGULATORY COMISSION NORTHEAST NUCLEAR ENERGY COMPANY 3 MILLSTONE NUCLEAR POWER STATION. UNIT 1 DOCKET NO. 50-245 ISSUANCE OF PARTIAL DIRECTOR'S DECISION UNDER 10 CFR 2.206 i Notice is hereby given that the Acting Director, Office of Nuclear Reactor Regulation, has issued a Partial Director's Decision with regard to a Petition dated August 21, 1995, and supplemented on August 28, 1995, submitted by Mr. George Galatis and We the People, Inc. (the Petitioners), requesting action under 10 CFR 2.206. The Petition pertains to Millstone Nuclear Power Station Unit 1, operated by Northeast Nuclear Energy Company (Licensee).
The Petitioners requested that the NRC (1) suspend the license for the Millstone Unit I facility for a period of 60 days after the unit is brought 16to compliance with the license and the design basis; (2) revoke the operating license until the facility is in full compliance with the terms and conditions of its license; (3) perform a detailed independent analysis of the offsite dose consequences of the total loss of spent fuel pool water; and (4) I take enforcement action pursuant to 10 CFR 50.5 and 50.9. As bases for their requests, the Petitioners raised the following three issues: (1) the Licensee has knowingly, willingly, and flagrantly operated Millstone Unit 1 in '
violation of License Amendments Nos. 39 and 40; (2) License Amendments Nos. 39 and 40 for Millstone Unit I are based on material false statements made by the Licensee in documents submitted to the NRC; and (3) the license amendment proposed in a letter dated July 28, 1995, should be denied and the Licensee should be required to operate in full conformance with License Amendment No.
- 40. Issue 3 was determined to be a request for a licensing action and so was beyond the scope of 10 CFR 2.206.
9701060154 961226 DR ADOCK 050002 5
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The Acting Director of the Office of Nuclear Reactor Regulation has ;
partially granted Requests 1, 2, and 3 of the Petition. The reasons for this decision are explained in the " Partial Director's Decision Pursuant to 10 CFR i
2.206" (DD-96-23), the complete text of which follows this notice. With '
I regard to Petitioner's Request 4, the NRC staff activities are not yet ;
t complete. A Final Director's Decision will be issued upon completion of NRC j l
activities in this area.
A copy of this Partial Director's Decision will be available for public inspection at the Comission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, D.C., and at the local public document room located at the Learning Resources Center, Three Rivers Community-Technical College, 574 New London Turnpike, Norwich, Conxcticut, and at the temporary local public document room located at the Waterford Library, ATTN: Vince Juliano, 49 Rope Ferry Road, Waterford, Connecticut.
A copy of this Partial Director's Decision has been filed with the Secretary of the Comission for review in accordance with 10 CFR 2.206(c) of the Commission's regulations. This Decision will become the final action of the Comission (for Petitioners' requests dispositioned in this Partial Director's Decision) 25 days after the date of issuance unless the Comission, on its own motion, institutes review of the Decision within that time.
Dated at Rockville, Maryland, this 26thday of December 1996.
FOR THE NUCLEAR REGULATORY COMMISSION O
79tb N~ N(
Frank J. M O glia, J ,ActingObector Office of Nuclear Reactor Regulation
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.'Ernact C. Hadley FINAL REPLY:
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ROUTING:
2.206 PETITION ON BEHALF OF GEORGE GALATIS, & Taylor WE THE PEOPLE,.INC. TO SUSPEND LICENSE ISSUED TO 'l Milhoan i
' *1THEAST UTILITIES TO OPERATE MILLSTONE UNIT 1 Thompson l Blaha. -i
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,DATE: 08/22/95 TTMartin,.RI l ASSIGNED'TO: CONTACT: ',
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r NRR RECEIVED: AUGUST 31, 1995 NRR ACTION: DRPE:VARGA j i
ACTION >
l NRR-ROUTING: RUSSELL l y"^ld^ DUET 0fp/R DIRECTOR'S OFFICE ZIMMERMAN -
N M, '070,'f6 CRUTCHFIELD B0HRER BY j -
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\ '" h " W tverd$ Y y, hf 1040 B MAIN STRE'ET PO.BOXS49 WEST WAREHAM. MA 02576 ERNEST C. HADLEY (508)2911354 OFCOUNSEL JOLEEN PAYEUR OLSEN FAX (508) 295 7002 WAITE P. STUHL August 21, 19 fi5 James Taylor Executive Director of Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 re Request for Licensing Actions 10 C.F.R. S 2.206 Northeast Utilities Millstone Unit 1 C\
Dear Mr. Taylor:
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Pursuant to 10 C.F.R. S 2.206, this letter constitutes a petition filed on behalf of George Galatis, a Senior Engineer at Northeast Utilities ("NU"), and We the People, Inc., of the United States
("We the People") to institute a proceeding under 10 C.F.R. S 2.202, to suspend the license issued to NU to operate the Millstone Nuclear Reactor, Unit 1, for a period of 60 calendar days.
Moreover, Mr. Galatis and We the People request that a proceeding also be instituted, under 10 C.F.R. S 2.202,2 to deny a proposed amendment to the operating license of Millstone Unit 1, which currently is pending before the Commission under Docket No. 50-245, B15248. As grounds for this petition, Mr. Galatis and We the People maintain that NU has knowingly, willingly and flagrantly operated Millstone Unit 1 in violation of its operating license for approximately 20 years; that it obtained previous licensing amendments through the use of material false statements; and, that it presently proposes to continue operating under unsafe conditions rather than comply with the mandates of its license. The basis for the petition is set forth in further detail below.
2/ Petitioners note that they are not opposed to one l consolidated proceeding on both requested actions. l I
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Background
On July 15, 1976, the Nuclear Regulatory Commission ("NRC")
approved License Amendment No. 39 for Millstone Unit 1. That amendment permitted NU to make certain changes in the design of Unit I spent fuel storage racks in order to increase the capacity of the spent fuel cooling pool from 1,100 to 2,184 fuel assemblies. ,
In addition to increasing the storage capacity of the spent fuel l cooling pool, License Amendment No. 39 also permitted NU, as part of its normal refueling practice, to off-load one-quarter of the ,
Millstone Unit i reactor core-i.e., 145 of 580 fuel assemblies. l l
The NRC based approval of License Amendment No. 39 on a Safety l Assessment Report ("SAR") compiled by NU and a subsequent Safety i l Evaluation Report ("SER") conducted by the NRC.2 Both the original )
j SAR and the resulting SER were premised on the assumption that NU J would operate in compliance with License Amendment No. 39. 1 i specifically, the Spent Fuel Pool ("SFP") system at Millstone Unit J 1, in compliance with NRC safety criteria, is capable of safely '
handling a heat load of 8 million BTU / hour. The heat load of one-quarter of the reactor core, as approved for off-load in License .
4 Amendment No. 39, also is 8 million BTU / hour.
From 1980 to 1981, the NRC initiated its Systematic Evaluation i a Program ("SEP"). The purpose of the program was to assist the NRC
- in evaluating the safety of older nuclear plants,' as compared to n newer plants. Each plant subject to the SEP was required to I perform specific assessments of various plant systems to assess its degree of compliance with the regulatory and safety criteria as they existed in 1980.
All of these evaluations were completed by 1982. Specifically, NU l conducted an evaluation of SEP Topic IX-1, " Fuel Storage for MP-1. " )
In the SAR accompanying that SEP Topic, NU a1serted that Millstone l Unit I had: (1) " seismic makeup capability to the spent fuel pool,"
and (2) "the SFP cooling system return pipes are equipped with check valves and have one-half inch holes drilled in them one foot below the normal pool water level."
The purpose of having seismic makeup capability to the spent fuel pool is to ensure that during a seismic event there always will be a way to add water to the pool if the SFP cooling system pipelines 2/ lt should be noted that SER's conducted by the NRC are not independent evaluations of safety conditions at nuclear power plants. Rather, they merely are evaluations of the SAR's submitted
- by the licensee.
8/ Millstone Unit 1 was one of 11 plants that were subject to the SEP.
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_ l O break, or the pool boils. The purpose of having the one-half inch (U/ holes drilled in the SFP cooling return lines is to prevent syphoning of water out of the pool in the event of an SFP cooling I
pipe break. Obviously, such assurances are necessary to prevent stored nuclear fuel from being exposed and creating fuel heat-up and subsequent fuel meltdown. Further, loss of water above the spent fuel would result in the spent fuel pool area becoming inaccessible due to loss of shielding, and airborne, surface and direct radiation from the lost radioactive spent fuel pool water, such that emergency manual actions to recover would not be possible.
Based on the SAR, the NRC conc)uded that Millstone Unit 1 spent fuel storage met the then-current acceptance criteria for SEP Topic IX-1 and its associated NRC regulatory requirements, i.e. , Standard Review Plan Sections 9.1.2- " Spent Fuel Storage" and 9.1.3- " Spent Fuel Pool Cooling and Cleanup System;" Regulatory Guides 1.29,
" Seismic Design Classifications;" General Design Criteria 63,
" Monitoring Fuel and Waste Storage;" and Regulatory Guide 1.13, Position C.6 and C.7.
Also as part of the SEP, NU submitted an SAR on SEP Topic IX-5,
" Ventilation Systems." The purpose of this SEP Topic was to ascertain whether ventilation systems at Millstone Unit 1 could I provide a safe environment for plant personnel under all modes of I operation and whether all safety-related equipment was capable of s properly functioning in order to ensure a safe shutdown. In
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w September 1982, the NRC accepted NU's evaluation stating the design temperature of the Stand-By Gas Treatment ("SBGT") System was 125 degrees Fahrenheit maximum, which also is the maximum temperature of the spent fuel cooling pool. At that time, License Amendment No. 39, which had been in effect since 1976, showed the maximum temperature of the spent fuel cooling pool was 140 degrees Fahrenheit.
In December of 1981, NU submitted an SAR on SEP Topic III-7B,
" Design Codes, Design Criteria and Load Combinations." The SAR stated that spent fuel pool cooling piping met American Nuclear Standards Institute (" ANSI") stress criterion B 31.1. The SAR also contended that the maximum temperature to which the piping was subjected was 125 degrees Fahrenheit. NU thus determined the pipe was safe and would not breaP.
In 1988, NU submitted License Amendment No. 40 for Millstone Unit
- 1. Under this amendment, NU sought to incraase spent fuel storage from 2,184 to 3,229 fuel assemblies. NU also sought to increase its normal reactor core off-load from one quarter to one-third of the core, or 193 fuel assemblies. Based on the SAR's and SEP Topic submissions of NU, the NRC approved the amendment.
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( Contentions l Contention No. 1: NU has knowingly, willingly and flagrantly l operated Millstone Unit 1 in violation of License Amendments Nos. ;
39 and 40.
Petitioners George Galatis and We the People contend that at all times while License Amendments Nos. 39 and 40 were in effect, NU )
has off-loaded all 580 fuel assemblies into the spent fuel cooling pool during refueling outages. Mr. Galatis and We the People base !
this contention on sworn testimony provided to the NRC's Office of l
Investigations ("OI") by George Galatis, a senior engineer with NU.
Mr. Galatis made his disclosures to OI only after unsuccessfully pursuing the matter internally at NU.
The nature of the violation is such that it could not be anything other than a willing and knowing violation. It simply would not be l possible to repeatedly off-load all 580 fuel assemblies through oversight or omission.' This is particularly true where, during the relevant period of time, NU specifically requested a license amendment to increase the number of fuel assemblies for off-loading.
Moreover, the nature of the violation is particularly flagrant I since NU knowingly and willingly subjected the public to an n unacceptable risk. For example, the heatload approved by License f } Amendment No. 39 was 8 million BTU / hour, but the actual practice of
(./ offloading the entire core resulted in a heatload of 23 million BTU / hour. The Millstone Unit 1 spent fuel cooling pool has never been analyzed, or approved, for such a heat load. Failure of any equipment important to safety, loss of electrical power, or an earthquake easily could have resulted in exposure of stored fuel by ;
loss of pool water inventory, through pipe breaks, syphon effects, or the boiling of the pool during any of these off-loads.
The risk was made even more flagrant and unacceptable by virtue of the fact that NU misled the NRC about several of the SEP Topics related to the spent fuel cooling pool. For example, with regard to SEP Topic IX-1, in May 1995, NU conceded that Millstone Unit 1 cooling pool does not have a seismic make-up capability and, in
- / Petitioner notes that the situation also raises significant questions with regard to NRC on-site inspectors. Specifically, were the resident inspectors not aware that the 580 fuel assemblies represented the entire core? Were the resident inspectors not aware of the provisions of the Millstone Unit 1 operating license, including License Amer.dments Nos. 39 and 40? Did the resident inspectora knowingly allow Millstone Unit 1 to act in violation of its license? Or, did the resident inspectors report their observations to relevant components of the NRC?
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A August 1995, NU conceded that since 1988 the Millstone Unit 1 (v cooling pool did not have the one-half inch syphon-breaker holes installed. Thus, the pool's ability to withstand the consequences of seismic events is well below what was represented to the NRC.
The NRC specifically relied upon NU's misrepresentations in conducting its own Environmental Assessment Report for License Amendment 40. In that assessment, the NRC concluded:
The staff believes that the probability of such an accident (i.e., NUREG/CR-9982, entitled, " Severe Accidents in Spent Fuel Pools in Support of Generic Issue 82") occurring at Millstone is extremely low. This belief is based upon the Commission's requirements for design and construction of spent fuel pools and their contents (e.g., racks), and adherence to approved industry codes and standards. . . .The cooling water system is extremely reliable; in the highly unlikely event of a ,
total cooling system failure, makeup water sources are '
available. These are but a few of the considerations f used by the staff in assessing the adequacy of the rerack. The staff acknowledges that if the severe accidents occurred as described above, the environmental i impacts [ human environment] could be significant; !
however, these events are highly unlikely and are not reasonably foreseeable in light of the design of the !
spent fuel pool system and racks.
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) Also, with respect to SEP Topic IX-5, as previously noted, the SBGT system has a maximum temperature of 125 degrees Fahrenheit.
also as previously noted, even at the time of the 1982 SAR, License But, I l
Amendment No. 39 showed the maximum SPF temperature was 140 degrees Fahrenheit. This was reconfirmed in License Amendment No. 40. In May 1995, NU conceded that the SBGT system design basis operating condition is exceeded and portions of SEP Topic IX-5 were invalid.
With respect to SEP Topic III-7B, as early as 1990, NU knew that the SPF cooling return piping line, which is encased in concrete, is only good to 85 degrees Fahrenheit per ANSI B-31.1. No attempt was made to rectify the problem. Moreover, in May 1995, NU conceded that the return line exceeds the stress code criteria for thermal expansion and deadweight stress. Thus, the SEP Topic is invalid and the pipe could break.
Based on the foregoing reasons, Mr. Galatis and We the People request that the operating license for Millstone Unit 1 be suspended for a period of 60 days after the unit is brought into compliance with the license and the design basis.5 Mr. Galatis and 5/ In the event that. the NRC does not take action on this petition before the next scheduled shutdown of Millstone Unit 1 on .
October 20, 1995, NU should, at a minimum, be required to operate I 5
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.. 1 O We the People believe that under the circumstances such action is necessary due to the severity of NU's license violations.
In addition, 10 C.F.R. S 50.100 states that a license may be revoked, suspended or modified for any material false statement in the application for the license, or license amendment, or for failure to operate the facility in accordance with the terms of the license. It is clear that Millstone Unit I has been in violation of the conditions of the license and, therefore, the license should 1 be revoked until the facility is in full compliance with terms and I conditions of its license. l i
l In the absence of such action, there is no incentive for NU, or any l' other licensee, to operate in compliance with NRC requirements or licensing conditions.
Mr. Galatis and We the People further request, prior to the reinstatement of the Millstone Unit 1 license, that a detailed independent analysis of the off-site dose consequences be conducted. Such analysis should assume an accident that results in the total loss of water from the spent fuel cooling pool in accordance with the NRC's Environmental Assessment Report supporting the increase in fuel storage approved by License Amendment 40. Mr. Galatis and We the People are concerned with both the probability of this event and how the off-site dose requirements of 10 C.F.R. Part 100 would be maintained in such a scenario.'
Contention No. 2: License Amendments Nos. 39 and 40 for Millstone Unit 1 are based upon material falso statements made by NU in documents submitted to the NRC.
From the facts recited above, it is readily apparent that NU has made material false statements in connection with the supporting documentation submitted to the NRC in connection with License Amendments Nos. 39 and 40. Pursuant to 10 C.F.R. S 50.100:
A license or construction permit may be revoked, suspended, or modified, in whole or in part, for any material false statement in the application for license or in the supplemental or other statement of fact required of the applicant; or because of conditions revealed by the application for license or statement of in compliance with License Amendment No. 40 during the shutdown.
8/ A standard NRC response to the effect that such an " event is outside design basis" would be patently inadequate. Millstone Unit I has been operating outside of design basis since at least 1976 and will continue to so operate unless this petition is granted.
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l fact or any report, record, inspection, or other means,
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i which would warrant the Commission to refuse to grant a 1 license on an original application (other than those relating to SS 50.51, 50.42(a), and 50.43(b) of this part); or for failure to construct or operate a facility in accordance with the terms of the construction permit or license, provided that failure to make timely completion of the proposed construction or alteration of a facility under a construction permit shall be governed by the provisions of S 50.55(b); or for violation of, or failure to observe, any of the terms and provisions of the act, regulations, license, permit, or order of the Commission.
False statements abound in the SAR's and SEP Topics associated with License Amendments Nos. 39 and 40, as well as License Evaluation Report ("LER") 93-011-00, and the Final Safety Analysis Report
( "FSAR" ) updates . Those statements are discussed in Contention No.
1.
The only question is whether the false statements are " material;"
l that is, did the NRC rely upon them in approving License Amendments ;
Nos. 39 and 40.7 As discussed in Contention No. 1, the answer l clearly is yes. The NRC specifically relied upon the I representations of NU in granting License Amendments Nos. 39 and
- 40. ,
- 1 It is the position of Mr. Galatis and We the People, that the actions of NU represents two separate and discrete violations of j Commission regulations. In the first instance, NU obtained License j Amendments Nos. 39 and 40 based, at least in part, on material false statements, and, in the second instance, it deliberately operated in violation of its licensing conditions. Both are serious violations of the first magnitude. Each would independently provide a sufficient basis for a swift and decisive licensing action on the part of the NRC. Taken together, they more than justify a 60 day suspension of the operating license for i Millstone Unit 1.
'/ Black's Law Dictionary, (5th ed. 1981) defines a " material ;
fact" as it relates to contracts as: j one which constitutes substantially the consideration of the contract, or without which it would not have been made. See also Reliance.
Id. at p. 881 (emphasis in original). Application of that definition is particularly appropriate in this case since a license amendment essentially is a form of contract-i.e., the NRC permits the licensee to engage in certain activities in exchange for certain promises made by the licensee.
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/ Moreover, Mr. Galatis and We the People request that enforcement i l action be taken against NU, in accordance with 10 C.F.R. SS 50.5 V
and 50.9, for knowingly and willingly providing false and !
inaccurate information to the NRC.'
Contention No. 3: The license amendment proposed in Docket No. 50-245, D15248 for Millstone Unit 1 should be denied and NU should, at the very least, be required to operate in full conformance with License Amendment No. 40.
Mr. Galatis and We the People understand that NU has, at the urging of NRC staff, now filed a proposed amendment to the operating license for Millstone Unit 1 under Docket No. 50-245, B15248.'
Under the proposed amendment, NU is asking for permission to amend its operating license to come into conformity with its actual practice of off-loading the entire core. Mr. Galatis and We the People respectfully request that the amendment be denied 2 and that Millstone Unit 1 be required to operate in conformance and compliance with License Amendment No. 40, the SEP Topics and associated regulatory criteria."
- / Requests for enforcement-type action, not specifically I referenced in Section 2.206 are entirely appropriate. See, "OGC Analysis of the Inspector's General Regulatory Commentary on 10 C.F.R. S 2.206, at p. 2 (language "such other action as may be ;
proper" in section "was intended to permit petitioners to request (oJ V
enforcement-type action other than modification, suspension or revocation of a license").
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'/ Petitioners also understand that, in 1996-97, Millstone Unit 1 plans to initiate another license amendment to further increase the capacity of the spent fuel pool from 3,229 to 4338 fuel assemblies.
20/ Given the discussion in Contention Nos. 1 and 2, above, it would be a travesty for the Commission to fail to take any licensing action to punish NU and, at the same time, give its :
blessing to a licensing amendment that achieves conformity by bringing the requirements into line with the conduct of the wrongdoer, instead of vice versa. Moreover, the submittal itself, dated July 28, 1995, is disingenuous. Nowhere in the proposal, which is a public document, does NU disclose that it is seeking the amendment in order to bring its operating license into to compliance with its actual practice over the past 20 years.
"/ Petitioners believe that a request to deny a proposed license amendment falls squarely within the "such other action as may be proper" language of Section 2.206. Essentially, Petitioners are requesting that the Commission take a licensing action-in this case denying a license a.nendment-as a means of enforcing existing regulatory and licensing requirements. See, OGC Analysis, supra at e 8
,s C Mr. Galatis and We the People incorporate, by reference, entirety of Contentions Nos. 1 and 2.
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( Based upon the errors and omissions cited with respect to the SAR's submitted as part of the SEP Topic process and License Amendments 39 and 40, it is readily apparent that NU connot demonstrate the public health and safety is adequately protected in the event of failure of safety equipment, loss of electrical power, earthquakes, hurricanes, or other calamities during a full core off-load. Simply stated, the Millstone Unit 1 spent fuel cooling pool was never designed for a full core off-load, nor has it ever been properly evaluated as being able to handle a full core off-load. Moreover, it now is conceded by NU, that the actual construction of the spent fuel cooling pool does not meet even the minimum design criteria.
In addition, it is apparent, through the errors and omissions of the NU SAR's cited above, that any of its submissions to the NRC must be heavily scrutinized for acceptance. Given the enormous significance of the proposed amendments and the dubious reliability of past information provided by NU, the Commission should do more than simply a paperwork review of the licensee's submissions. Mr.
Galatis and We the People request that the Commission retain an independent expert to prepare an SAR on the proposed amendment. ,
Such an expert should be retained at NU's expense, but must remain !
directly responsible to the NRC in order to maintain complete j independence.22 Anything short of an independent, comprehensive l expert evaluation would be irresponsible on the part of the Commission and, if the NRC approves the proposed amendment based
\ solely on NU's submissions, would needlessly place public health j and safety in jeopardy.
l In further support of the need for an independent expert evaluation, Mr. Galatis and We the People note that both License Amendments Nos. 39 and 40, and the SEP Topics, went through extensive reviews by both NU and the NRC. The results of those reviews are reflected above. Moreover, this problem was specifically brought to the attention of NU officers via its internal safety concern procedures in 1992. See, REF 92-73.
- p. 4, quoting, " Review Process for 10 CFR S 2.206 Petitions,"
Handbook 8.11, Part II Section A.(1)(a): l A petition will be reviewed under the requirements of 10 CFR S 2.206...if the request meets...the following criteria: The request ... asks that a license be modified, suspended, or revoked, or asks that some action be taken against a licensee.
(emphasis added by OGC).
l 22 / Petitioners suggest that LRS Consultants be used. LRS has a previous reliable history with both NU and the NRC.
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/~T Despite NU's intentional violations of its licensing criteria, and I iV)
I a formal internal complaint over those violations, the licensee planned, as of July 1995, to continue to off-load the entire core i during its next scheduled outage October 1995 without seeking a i further amendment of its license. !
Because of major deficiencies in the design of the Millstone Unit 1 1 spent fuel cooling pool and supporting systems, it is clear that '
the plant has operated outside the original design basis and in a condition that has not been analyzed. See, 10 C.F.R. S 50.72(b)(ii)(A)-(C). Neither the probability or the consequences of these events has been analyzed even though the NRC has been formally requested to provide such an analysis." An analysis l including both the probability and consequences of appropriate events should be conducted prior to any license amendment that would grant NU greater latitude in its handling of spent fuel.
Mr. Galatis and We the People request prompt action on this portion of the petition, since NU has sought an accelerated review of the ,
proposal by NRC staff. Such accelerated review precludes any !
meaningful public participation. At a minimum, the Commission should hold in abeyance any final decision on this petition and !
NU's proposed license amendment until after the scheduled October outage in order to allow adequate time for complete review of the proposal and opposition to the proposal.
,m All of the documentation relied upon in this petition is in the 1 possession of the NRC. Therefore, additional copies of those (V ) I documents have not been provided. However, copies of such documents will be provided, upon request, if the Commission cannot i locate them. !
I thank you for your prompt attention to this matter.
S' [ dely,
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l cc: S. Comley, Ex. Dir., WTP I G. Galatis R. Busch, Pres., NU Sen. J. Lieberman
"/ See, Letters to John Zwolinski from Paul M. Blanch, dated February 28 and March 6, 1995.
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