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Category:EXHIBITS (DOCKETING AND SERVICES BRANCH INFORMATION
MONTHYEARML20214F1991987-04-22022 April 1987 Applicant Exhibit A-188,consisting of Admitting Exhibit.Util Re General Ofc Records Audit,Lk Comstock Engineering Co,Inc 830110 Memo Re Audit Responses & 821101 General Insp Rept Re Torque Wrench Test Record Encl ML20214F1611986-12-0505 December 1986 Applicant Exhibit A-187,consisting of Forwarding marked-up 860312 Deposition of ML Goedecke in Chicago,Il Re Welding at Plant,Per Board 861204 Ruling.Supporting Documentation Including Related Insp Repts Encl ML20214D8431986-12-0404 December 1986 Intervenor Exhibit I-ROREM-248,consisting of 840123 Memo Listing Methods for Alleviation of Present Number of Open Insp Correction Repts.Qa Surveillance Rept 3244 Encl ML20214E1371986-12-0404 December 1986 Intervenor Exhibit I-ROREM-261,consisting of 840508 Memo Discussing Insp of Outstanding QC-US Rept Items for safety- Related Items,Per Author Procedures.Areas Deficient for QC Dept Listed ML20214E0771986-12-0404 December 1986 Intervenor Exhibit I-ROREM-254,consisting of 840418 Memo Discussing Considerations to Be Taken Into Account Prior to Cross Training,Per 840416 Meeting ML20214E1081986-12-0404 December 1986 Intervenor Exhibit I-ROREM-258,consisting of 840502 Memo Requesting Assurance in Writing That All Necessary Insps Complete Re Closed safety-related Reworks 014,015 & 018,per Plant Procedure 4.3.24 ML20214C3901986-12-0404 December 1986 Intervenor Exhibit I-ROREM-233,consisting of 830406 Memo Requesting That saftey-related Cable Pull Cards Be Forwarded to QC Dept for Compliance W/Plant Procedures 4.3.8 & 4.8.8. Basis for Request Discussed ML20214C4441986-12-0404 December 1986 Intervenor Exhibit I-ROREM-236,consisting of 830719 Memo Advising That Qualified joint-disciplined,certified Inspector Should Inspect Welding When Inspecting Configurations.Reason Stated ML20214F6111986-12-0404 December 1986 Intervenor Exhibit I-ROREM-274,consisting of 840709 Memo Summarizing Major Concerns Expressed by QC Dept at 840630 Meeting.Overall Mgt Meeting Scheduled for 840718.Response in Memo Form Required by 840712 ML20214F6001986-12-0404 December 1986 Intervenor Exhibit I-ROREM-273,consisting of 840630 Memo Re QC Inspectors Directing Craft Personnel During in-processing Type Insps.Inspectors Should Not Direct Craft at Any Time ML20214F5861986-12-0404 December 1986 Intervenor Exhibit I-ROREM-272,consisting of Summary of 840627 Staff Meeting Re Insp of Conduit Straps,Raceway Status,Insp Quantity Vs Quality,Level III Welding Inspectors Assignments & Remodeling Plans ML20214E0941986-12-0404 December 1986 Intervenor Exhibit I-ROREM-256,consisting of 840501 Memo Discussing Actions Required in Response to T Paserba Memo. Schedule Should Be Established for cross-training of Welding Inspectors,Indicating Progress on Daily Basis ML20214E1071986-12-0404 December 1986 Intervenor Exhibit I-ROREM-257,consisting of 840502 Memo Advising That Coupons/Samples Being Fabricated W/Acceptable & Rejectable Items on Each for Enhancement of Weld Insp Training Program ML20214F5521986-12-0404 December 1986 Intervenor Exhibit I-ROREM-271,consisting of 840627 Memo Requesting Attendance of Listed Individuals at 840628 Meeting of Facility Const Assessment Program,Per 840627 Telcon W/C Mennecke.Handwritten Notes Encl ML20214D8241986-12-0404 December 1986 Intervenor Exhibit I-ROREM-247,consisting of 840112 Memo Providing Plan of Action for Completion of Phase II & Backlog Insps,By 840501 for Welding & Configurations. Personnel Assignments Discussed.Schedules Encl ML20214F5371986-12-0404 December 1986 Intervenor Exhibit I-ROREM-270,consisting of 840623 Memo Re Falling Behind on Reworks & Daily Insps.Turn Around Time for Rework Review Is 1 Day.Rework Status Update Encl ML20214D9711986-12-0404 December 1986 Intervenor Exhibit I-ROREM-251,consisting of Undated Reinsp Program Status Rept ML20214E1511986-12-0404 December 1986 Intervenor Exhibit I-ROREM-263,consisting of 840512 Memo Submitting Guidelines for Completion of New Daily Insp Status Repts.Sample Rept Encl ML20214D6561986-12-0404 December 1986 Intervenor Exhibit I-ROREM-243,consisting of 831019 Memo Discussing Vendor Welded Hangers Not Conforming to Present Welding Procedures.Concurrence Re Whether or Not Hangers Need Repairing or Acceptable Requested ML20214D6731986-12-0404 December 1986 Intervenor Exhibit I-ROREM-244,consisting of 831024 Handwritten Speed Ltr Instructing Continued Installation of Pan Hangers in Unit 2 Wing Walls & Insp of Lk Comstock Welds Only.Another Insp Company Analyzing All Mfg Welds ML20214C5211986-12-0404 December 1986 Intervenor Exhibit I-ROREM-240,consisting of 831003 Memo Forwarding Trend Analysis Rept,Per Util Request.Rept Consists of Review of Lk Comstock Insp Correction Repts from Spet 1982 - Aug 1983 ML20214F4661986-12-0404 December 1986 Intervenor Exhibit I-ROREM-269,consisting of 840616 Memo Re Improving Inspectors Productivity,Per Conversations of Last Supervisor Meeting.Plan for Improving Insp Output Should Be Submitted by 840618 ML20214D6341986-12-0404 December 1986 Intervenor Exhibit I-ROREM-242,consisting of 831011 Memo Authorizing RM Saklak Signature Authority for Items Including Review of Insp Correction Repts/Notification of Change Repts & Welder Qualification Forms for 831013-19 ML20214D7611986-12-0404 December 1986 Intervenor Exhibit I-ROREM-246,consisting of 831108 Memo to All QC Inspectors Reiterating Previous Instructions That QC Checklists & Insp Correction Repts/Nonconformance Repts Used in Field During Insp ML20214C4821986-12-0404 December 1986 Intervenor Exhibit I-ROREM-238,consisting of 830923 Memo Re 830922 Welding & Configuration Meeting.Instructions Resulting from Meeting Discussed ML20214D6231986-12-0404 December 1986 Intervenor Exhibit I-ROREM-241,consisting of 831005 Memo to Training File Summarizing Requirements for Proper Documentation & Use of Checklists Re Insps,Established During 830929 Training Class ML20214C4321986-12-0404 December 1986 Intervenor Exhibit I-ROREM-235,consisting of 830707 Memo Questioning Why Engineering Requesting That Lk Comstock Engineering QC Prepare Ncrs for nonsafety-related Items When Author Not Chartered to Inspect nonsafety-related Items ML20214C5081986-12-0404 December 1986 Intervenor Exhibit I-ROREM-239,consisting of 830827 Daily Insp Status Rept W/Handwritten Instructions for Completing Repts ML20214C4611986-12-0404 December 1986 Intervenor Exhibit I-ROREM-237,consisting of 830805 Memo Requesting Inspectors to Conduct Weld Rod Insp Prior to Leaving Areas Under Insp,Due to Util Surveillance on Weld Rod Control ML20214F8361986-12-0404 December 1986 Intervenor Exhibit I-ROREM-277,consisting of 840806 Memo Requesting Nonconformance Rept for DCRs Mentioned in Encl J Poe Memo (C84-07-06) & RM Saklak Reply.Request Received One Day After Due Date & Involves Reinspection ML20214E1261986-12-0404 December 1986 Intervenor Exhibit I-ROREM-260,consisting of 840505 Memo Proposing Estimated Completion Date of Jan 1985 for Review of Avos.Proposal Based on Use of Two QC Inspectors Devoting Efforts Solely to Avo ML20214D8751986-12-0404 December 1986 Intervenor Exhibit I-ROREM-249,consisting of 840124 Memo Forwarding Electrical Bulk Quantity Curves for Period Ending Dec 1984.Curves Include New Fuel Load,Eccs,Ihf & Unit II Cold Hydro Dates & Reflect New Estimates for Unit 1 ML20214D9211986-12-0404 December 1986 Intervenor Exhibit I-ROREM-250,consisting of 840125 Memo Discussing Activities Which Should Be Undertaken in Response to Util Surveillance 3244 Re Timeliness of Closeout of Insp Correction Repts ML20214E0831986-12-0404 December 1986 Intervenor Exhibit I-ROREM-255,consisting of Minutes of 840426 Meeting Conducted as Result of 840424 Meeting W/Util Re QC Insp.Personnel Instruction Logs Encl ML20214E0721986-12-0404 December 1986 Intervenor Exhibit I-ROREM-253,consisting of 840227 Memo Listing Individuals & Respective Insp Disciplines for Which Qualification by Stated Dates Required ML20214C4151986-12-0404 December 1986 Intervenor Exhibit I-ROREM-234,consisting of 830516 Memo Re Weld Insp non-reported Backlog Chart Condition.Backlog of Weld Insps Discussed ML20214E0411986-12-0404 December 1986 Intervenor Exhibit I-ROREM-252,consisting of 840209 Memo Requesting That Present Insp Correction Repts (ICR) & Nonconformance Repts Be Closed by 870220.Response to Listed Requirements Requested by 840218 ML20214F8921986-12-0404 December 1986 Intervenor Exhibit I-ROREM-280,consisting of 840801 Memo Listing Revised Counts for Backlog Insp for Welding & Configuration,Junction Box & Equipment & Riser Project ML20214F8821986-12-0404 December 1986 Intervenor Exhibit I-ROREM-279,consisting of 840730 Memo Suggesting 100% Reinspection on All Cable Pan Riser Hangers ML20214F8751986-12-0404 December 1986 Intervenor Exhibit I-ROREM-285,consisting of Forwarding QA Investigation AR007388-7396 Re Pace of Facility Const Assessment Program.Related Documentation Encl ML20214F8581986-12-0404 December 1986 Intervenor Exhibit I-ROREM-278,consisting of 840723 Memo Forwarding Status Rept for Wk of 840713-19.RM Saklak 840726 Memo Responding to 840721 Memo Re Welding/Configuration & K Worthington 840723 Memo on Root Causes of Backlog Encl ML20214F8391986-12-0404 December 1986 Intervenor Exhibit I-ROREM-284,consisting of 841023 Memo Re Concerns Addressed in Through Paint Weld Insps.Requests Response by 841026.Related Info Encl ML20214E1131986-12-0404 December 1986 Intervenor Exhibit I-ROREM-259,consisting of 840505 Memo Requesting Matrix Indicating All Special Projects Involving QC Dept & Manpower (by Name) for Each by 12:00 Pm 840507,per 840503 Meeting W/D Cosaro ML20214F8331986-12-0404 December 1986 Intervenor Exhibit I-ROREM-283,consisting of Re Steady Increase in Number of Insps Not Completed in Current Group.Table of Facility Qc,Number of Insps Incomplete, Organization Chart & Other Related Info Encl ML20214F8221986-12-0404 December 1986 Intervenor Exhibit I-ROREM-282,consisting of 840822 Staff Meeting Summary & Minutes,Weekly Mgt Rept for Week of 840813 & Update of Current Insp Group.Related Viewgraphs Also Encl ML20214F8021986-12-0404 December 1986 Intervenor Exhibit I-ROREM-281,consisting of 840801 Memo Recommending Inclusion of New Welding & Configuration Count Compiled by K Worthington Into Backlog Status Rept to Be Issued 840803.Addl Insps Will Not Be Complete Until 840905 ML20214F8011986-12-0404 December 1986 Intervenor Exhibit I-ROREM-276,consisting of 840730 Memo Requesting Completion Date for Qualification/Training in Remaining Areas,Per Lk Comstock Procedure 4.1.2 ML20214F7911986-12-0404 December 1986 Intervenor Exhibit I-ROREM-275,consisting of 840721 Memo Forwarding Status Summary Rept for Wk of 840113 - 840719, Weekly Insp Status for 840712-18 & Backlog Completion Schedule for Wk of 840713-19 ML20214E1871986-12-0404 December 1986 Intervenor Exhibit I-ROREM-268,consisting of 840613 Memo Requesting Written Clarification Indicating Individual Responsible for Beam Stiffner Installation,Per Encl 840529 Speed Ltr ML20214E1741986-12-0404 December 1986 Intervenor Exhibit I-ROREM-266,consisting of 830419 Memo Advising That Requirements for Reporting Clearance Problems Re Installation of Piping,Conduit,Cable Tray & Other Components Described in Encl Eliminated.W/O Stated Encl 1987-04-22
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20149H0301997-06-19019 June 1997 Comment Opposing Proposed Generic Communications Re Control Rod Insertion Problems ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20204G3081988-10-19019 October 1988 Order Imposing Civil Monetary Penalty in Amount of $50,000, Per 880506 Notice of Violation from Insp on 880301-17 ML20154K0301988-05-20020 May 1988 Transcript of 880520 Dicussion/Possible Vote in Rockville,Md Re Full Power OL for Facility.Pp 1-70.Related Info Encl ML20148G2161988-03-25025 March 1988 Decision.* Affirms Concluding Partial Initial Decision, LBP-87-14,25 NRC 461.Served on 880325 ML20149D8231988-02-0101 February 1988 Notice of Withdrawal.* Withdraws Appearance as Atty for Util in Proceeding,Effective 880201.Certificate of Svc Encl ML20236A8341987-10-21021 October 1987 Transcript of 871021 Proceedings in Bethesda,Md.Pp 1-100 ML20235K8741987-09-30030 September 1987 Notice of Oral Argument.* Oral Argument on Pending Appeal of Intervenors Bridget Little Rorem from Board 870519 Concluding Partial Initial Decision in Proceeding Will Be Heard on 871021.Served on 871002 ML20235H7121987-09-25025 September 1987 Memorandum & Order.* Intervenor Appeal from ASLB Rejection of late-filed Contention Dismissed & LBP-87-19 & LBP-87-22 Vacated on Grounds of Mootness Due to Util Withdrawing Amend Application.Served on 870928 ML20237L7461987-09-0303 September 1987 Order.* Oral Argument on Pending Appeal of Intervenors Bl Rorem Et Al from Licensing Board 870519 Concluding Partial Initial Decision in OL Proceeding Will Be Heard on 871021 in NRC Public Hearing Room.Served on 870903 ML20237L7721987-09-0101 September 1987 Reconstitution of Aslab.* Notice That Aslab Has Been Reconstituted for OL Proceeding.Board Will Consist of as Rosenthal,Wr Johnson & Ha Wilber.Served on 870902 ML20237L6931987-08-28028 August 1987 Decision.* Review of Licensing Board 870513 & 0706 Partial Initial Decisions Revealed No Error Necessitating Corrective Action.Result Reached by Licensing Board Re Decision LBP-87-13 Affirmed.Served on 870831 ML20237K0361987-08-11011 August 1987 NRC Staff Brief in Support of LBP-87-14.* Certificate of Svc Encl ML20236P1101987-07-31031 July 1987 Brief of Comm Ed.* Brief Filed Re Appeal by Bridget Little Rorem,Et Al from ASLB 870519 Concluding Partial Initial Decision.Appeal Shoud Be Denied & Decision Affirmed. Certificate of Svc Encl ML20236N9791987-07-31031 July 1987 NRC Staff Response to Aslab Order of 870721.* NRC Supports Deferral of Briefing of Intervenors Appeal Until Applicant Affirmation Re Withdrawal of License Amend Application Received.Bc Hunsader Encl.W/Certificate of Svc ML20236N8851987-07-31031 July 1987 Response to Intervenors Request for Deferral of Further Appellate Proceedings.* Forwards Util to NRC Withdrawing License Amend Applications Re Ownership.Pending Appeal Should Be Dismissed.Certificate of Svc Encl ML20235Y8711987-07-23023 July 1987 Appeal from Licensing Board Denial of Motion to Reopen Record.* Intervenors Rorem Appeal from Decision of Licensing Board of 870706 Denying Rorem Motion to Reopen Record for Purpose of Admitting Late Contention.W/Certificate of Svc ML20235Y9081987-07-21021 July 1987 Order.* Date for Filing Briefs Re Intervenor Appeal of Board 870706 Memorandum & Order Denying Motion for Reconsideration & Motion to Admit late-filed Contention Postponed Until Further Order by Board.Served on 870722 ML20234D0521987-07-0202 July 1987 Motion to Reopen Record to Admit late-filed Contention on Financial Qualifications.* Record Should Be Reopened Since Rule Barring case-by-case Financial Qualification Adjudication Not Applicable ML20235D6761987-07-0202 July 1987 Order.* Intervenors 870623 Motion That ASLB Reconsider 870610 Memorandum & Order Denying 870506 Motion to Reopen Record & 870701 Motion to Admit late-filed Contention Denied.Motion in Alternative Dismissed.Served on 870707 ML20234D0961987-07-0101 July 1987 Affidavit of DW Cassel.* Affidavit Re Intervenors Rorem,Et Al Motion to Reopen Record to Admit Late Filed Contention on Financial Qualification.Related Info Encl.W/Certificate of Svc & Svc List ML20216J8821987-07-0101 July 1987 Motion in Alternative Before Appeal Board.* Intervenors Hold That Jurisdiction Over 870701 Motion to Reopen Record to Admit Late Filed Contention on Financial Qualifications Remains W/Aslb.W/Svc List & Certificate of Svc ML20234D0361987-07-0101 July 1987 Opening Brief of intervenors-appellants Bridget Little Rorem,Et Al.* Board Majority Committed Errors of Fact & Law That Compel Reversal of 870519 Concluding Partial Initial Decision.Certificate of Svc Encl CLI-87-07, Order CLI-87-07.* ASLB Concluding Partial Initial Decision, Resolving All Contested Issues & Authorizing NRR to Issue Ol,Reviewed by Commission & Effective Immediately.Separate Views of Commissioner Asselstine Encl.Served on 8707011987-06-30030 June 1987 Order CLI-87-07.* ASLB Concluding Partial Initial Decision, Resolving All Contested Issues & Authorizing NRR to Issue Ol,Reviewed by Commission & Effective Immediately.Separate Views of Commissioner Asselstine Encl.Served on 870701 ML20235A7271987-06-30030 June 1987 Transcript of 870630 Discussion/Possible Vote in Washington, DC Re Full Power OL for Facility.Pp 1-70.Supporting Documentation Encl ML20216D1941987-06-22022 June 1987 Order.* Amend to 861107 Protective Order Which Resolved Dispute Between ASLB & Commission Ofc of Investigation Over Disclosure of Certain Investigatory Matls.Certificate of Svc Encl.Served on 870623 ML20215J8891987-06-19019 June 1987 Applicant Texas Utils Electric Co Petition for Directed Certification of Licensing Board Order of 870312.* Brief Supports Granting Petition to Vacate ASLB 870312 Order. Supporting Documentation & Certificate of Svc Encl ML20215D9241987-06-15015 June 1987 Memorandum on Licensing Board Jurisdiction.* Jurisdiction Over Intervenors 870506 Motion Retained Until Further Action of Licensing Board Due to Util 870528 Filing of Application for Amend to Ol.Served on 870616 ML20214W9601987-06-12012 June 1987 Transcript of 870612 Telcon in Washington,Dc.Pp 18,585- 18,596 ML20214W5031987-06-10010 June 1987 Memorandum & Order (Denying Intervenors Motion to Admit late-filed Contentions on Financial Qualifications).* Rorem, Et Al 870506 Motion Re Financial Qualifications of New co- Licensees Denied for Want of Jurisdiction.Served on 870611 ML20214W5491987-06-0909 June 1987 Notice of Reconstitution of Board.* Iw Smith,Chairman & Rf Cole & AD Callihan,Members.Served on 870610 ML20214W4911987-06-0909 June 1987 Order.* ASLB 870513 Partial Initial Decision Addressing Emergency Planning Issues Will Be Reviewed Sua Sponte & Will Not Be Deemed Final Until Further Order.No Appeal from Decision Received ML20214P0811987-06-0101 June 1987 Notice of Appeal.* Intervenor Bl Rorem,By Attys & in Accordance w/10CFR2.762,appeal ASLB 870519 Concluding Partial Initial Decision Re Plant Which Served on Parties on 870521.Notice of Appearance & Certificate of Svc Encl ML20214N0521987-05-28028 May 1987 Affidavit of Mj Wallace.* Affidavit of Mj Wallace Re Startup & Initial Criticality of Unit 1.W/Certificate of Svc ML20214N0471987-05-28028 May 1987 Affidavit of Jc Bukovski.* Affidavit of Jc Bukovski Re Delay in Startup,Testing & Commercial Operation of Unit 1 ML20214N0421987-05-28028 May 1987 Commonwealth Edison Co Comments to Commission on Immediate Effectiveness Issues.* Forwards Affidavits of Mj Wallace & Jc Bukovski.Requests Opportunity to Be Heard If Commission Contemplates Such Stay ML20214N4321987-05-26026 May 1987 NRC Staff Response to Motion to Admit late-filed Contention on Financial Qualifications.* Board Must Deny Motion to Admit late-filed Contention & Deny Request to Certify Question of Waiver to Commission.W/Certificate of Svc ML20214N3901987-05-22022 May 1987 Amend to Concluding Partial Initial Decision.* Amends 870519 Concluding Initial Decision to Delete Limited Authorization Granted NRR to Issue License for Low Power Testing,Due to Issuance of LBP-87-13 on 870513.Served on 870526 ML20214N0631987-05-19019 May 1987 Errata Correction.* Requests Pen & Ink Corrections to Minority Decision Pages Forwarded as Corrected Pages to Errata .Pages 73,74 & 75 Should Be Numbered as Pages 72,73 & 74,respectively.Served on 870529 ML20214N0851987-05-19019 May 1987 Errata.* Forwards Corrected Pages to Minority Opinion, Matters of Dissent.Served on 870528 ML20214G5141987-05-19019 May 1987 Response to Intervenor Motion Seeking to Reopen Record for Admission of New Contention.* Intervenor Filed Motion, Motion to Admit Late Filed Contention on Financial Qualifications. Affidavit & Certificate of Svc Encl ML20214N3431987-05-19019 May 1987 Errata to Concluding Partial Initial Decision (Ol).* Minor Editoral Corrections Listed.Served on 870528 ML20214G5921987-05-19019 May 1987 Concluding Partial Initial Decision (Ol).* Due to Violation Re Discouragement to Document Any Major Deficiency That Could Result in Lengthy Delay in Production,Civil Penalty Should Be Imposed on Comstock & Util.Served on 870521 ML20214G8701987-05-18018 May 1987 Notice of Reconstitution of Aslab.Gj Edles Chairman & WR Johnson & CN Kohl Members.Served on 870520 ML20213F9971987-05-13013 May 1987 Partial Initial Decision on Emergency Planning Issues.* ASLB Resolves All Outstanding Issues Re Offsite Emergency Favorably to Applicant Subj to Certain Info Being Included in Next Emergency Info Booklet.Served on 870514 ML20215K9991987-05-0606 May 1987 Motion to Admit late-filed Contention on Financial Qualifications.* Contention Based on Util 870406 Filing Re New Ownership & Financing for Facility.Affidavit & Certificate of Svc Encl ML20214F1991987-04-22022 April 1987 Applicant Exhibit A-188,consisting of Admitting Exhibit.Util Re General Ofc Records Audit,Lk Comstock Engineering Co,Inc 830110 Memo Re Audit Responses & 821101 General Insp Rept Re Torque Wrench Test Record Encl 1999-03-02
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f .N UNITED STATES
% /d[7/Ji4 S1:! Ns
'/..?"S[% NUCLEAR REGULATORY COMMISSION -
wx}.2 WASHINGTON, D. C. 20555 ~by6 UA/ ~' / b T.;:1 '-
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February' I, 1982
.y:'y;;~T210??fUgg 12 FE .-2 ggf P.10D.& UT.: .-Av.g.Q.s, _
- - ( _- -yyr)[Jjj The Honorable Wohn D. Dingell, Chairman Committee on Inergy and Commerce 0
-Q n ,. o.; . b United States House of Representatives p, D /S g
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Dear Mr. Chairman:
//
We share the concerns expressed in your Novembe ,.J98 4 tter regarding the implication of the recent seismic design errors detected at the Diablo Canyon nuclear power plant. The implication of these errors has been and will be thoughtfully considered by the Commission.
(WQ '
- u. The timing of the detection of these errors, so soon after authorization '
for icw-power operation, was indeed unfortunate and it is quite understandable that the Congress' and the public's perception of our licensing pro. cess has been adversely affected. Had this information been known to us on or prior to September 22, 1981, I am sure that the facility license would not have been issued until the question's raised by these disclosures had been resolved.
Because of these design errors, on November 19, 1981 we suspended Pacific Gas and Electric Company's (.PG&E) license pending satisfactory completion of the following:
- 1. The conduct of an independent design review program of all
' sa.fety-related activities performed prior to June 1,1978 under all seismic-related s.ervice contracts used in the design of safety-related structures, systems and components.
- 2. A technical report that fully assesses the basic cause of all design errors identified by this program, the significance of the errors found and their impact on facility design.
- 3. PG&E's conclusions of the effectiveness of the design verification program in assuring the adequacy of facility design.
- 4. A schedule for completing any modificat. ions to the facility that are required as a result of the design verification program.
In addition, the Commission ordered PG&E to provide for NRC review and approval:
- 1. A description and discussion of the corporate qualifications of the lAltfiMENDE[ B6P98980N] company or,w companies
,3iC35 N that d ' 3N:PG4E:wculd
. prepose to carry out the s.msW*l5% 2/ hA m , . _ aw
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\ f B705190619 861007
//
PDR ADOCK 05000275 j/ \ t, _.;. J .::.C. .
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RESPONSES TO QUESTIONS IN NOVEMBER 13, 1931 LETTER TO .
.. CHAIRMAN PALLADINO FROM CONGRESSMEN DIfGELL AND OTTINGER U' Ouestion 1: Please provide, prior to the i'ssuance of the 50.54(f) letter, the definition of the terms (i) " independent,"
'. / (ii) " competent," (iii) " integrity," and (iv) " complete.
/ Response:
Although one of the options under. consideration by the Commission was a 50.54(f) letter, the Commission decided to suspend PG&E's license to load fuel and conduct tests up to 5 percent power by Memorandum and Order dated November 19, 1981, pending satisfactory completion of certain actions, including the conduct of a design verification program.
Also, a staff letter of the same .date required PG&E to carry on other design verificatica programs prior to issuance of any license authorizing operation above 5 4 . percent power.
O The most important factor in NRC's evaluation of the indi-viduals or companies proposed by Paci~fic. Gas and Electric '
to complete the required design verification program is their competence. This competence must be based on knowledge and experience in the matters under resiew. These individuals.
or companies should also be independent. Independence means that the individuals or companies selected must be able to provide an objective, dis;:assionate technical judgment, provided solely on the basis of technical merit. Independence e also means that the design verification program must be conducted by companies or individuals not previou' sly involved with the activities at Diablo Canyon that they will now be reviewing. Their integrity must be such that they are regarded as reputable companies or individuals. The word
" complete" applies to the NRC requirement for review of all O - au its ssuraace Procedures ad c=atro's used by e ch pre-June 1978 seismic and non-seismic service related contractor and try PG&E with regard to that centract. A comparison of these procedures and controls with the related criteria of
. Appendix B to 10 CFR 50 is also re uired. Any deficiencies or weaknesses- in the quality assurance . procedures and controls
- c.f the contractor and PG&E will be investigated in more detail. In addi. tion, calculations will be checked in an audit program. Numerical calcula: ions for which the original basis cahnot be de: ermined will be recalculated to verify the initial design in::ut.
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independent design verification program, including info'rmation\ -
demonstrates the independence of these companies.
- 2. A detailed program plan for conducting the design verification program.
In recognition of the need to assure the credibility of,the design
- verification program, NRC will decide on the acceptability of the '
companies' proposed by PG&E to conduct this program after providing the Governor of California and Joint Intervenors in the pending operating licensing proceeding 15 days for comment. Also, the NRC will decide on the acceptability of the plan proposed by PG&E to conduct the program, after providing the Governor of California and the Joint Intervenors in the pending operating ifcense proceeding 15 days for comment. ,
Prior to authorization to proceed with fuel loading, the NRC must be l satisfied with the results of the seismic design verification program and with any plant modification resulting from that program that may be
. ' necessary prior to fuel loading. The NRC may impose additional requirements prior to fuel loading necessary to protect health and safety based upon its review of the program or any of the information provided by PG&E. This may include some or all of the requirements i
specified in the letter to PG&E dated November 19, 1981.
~
Responses to each of the four questions in your letter are enclosed.
A decision to pemit PG&E to proceed with fuel loading will not be made until all the actions contained in the Comission's November 19, 1981
.. Order are fully satisfied. .
- Sincerely, l
Nunzio J. Pallacino l cc: Rep. Carlos Moorhead ,
Enclosures:
- 1. Comission Order, dated 11/19/81 .
- 2. Ltr from Office of Nuclear Reactor Regulation, NRC to PG&E dated 11/19/81
- 3. Responses to Questions e o e
he------ , . - - . . . . . . . eme**e----=*=**e**==.e..-. -
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Ouestion 2: Please provide the criteria to be used in \
assuring that the proposed audit will 'be independent."
Response: The competence of the individuals or companies is the most important factor in the selection of an auditor. Also, the companies or individuals may not-have had any direct previous involvement with the activities at Diablo Canyon that they will be reviewing.
In addition, the following. factors will be considered in evaluating the question of independence:
i
- 1) Whether the individuals or companies involved had been previously hired by PG&E to do similar seismic design work.
- 2) Whether any individual involved had been
~
previously employed by PG&E (and the nature of the employment).
- 3) Whether the individual owns or controls
. significant amounts of PG&E stock.
- 4) Whether members of the present household of individuals involved _are employed by PG&E.
- 5) Whether any relatives-are employed by PG&E in a management capacity.
In addition to the above considerations, the following procedural guidelines will be used to assure independence:
, (h.
- 1) An auditable record will be provided of all comments on draft or final reports, any changes made as a. result of such comments, and the reasons for such-changes; or the consultant will i ssue only a final report (without prior licensee comment).
- 2) NRC will assume and exercise the respon-sibility for serving the report on all 4
parties.
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.' Ouestion 3: In view of the licensee's past performance,-
. ,, and that of its subcontractors, what
'_'- procedures will be utilized to ensure that
/' there are not conflicts of interests in the performance of any required audits?
i f
./ .
Resoonse: We are requiring that PG&E provide the NRC l with a description and a discussion of the corporate qualifications of the companies proposed to carry out the various design verification programs, including information that demonstrates the independence of these
, companies. This information will be provided to the Governor of California and the Joint Intervenors for comments. Based upon review of the information provided by PG&E and the ,
comments of the Governor and Join: Inter-C/) venor, the NRC.will decide on the accept-ability of the companies with respect to their " independence" and " competence." In addition, approval will not be,given by NRC if.we determine that a potential conflict of interest exists in the performance of any
. required audits that cannot be adequately addressed by procedural safeguards.
Question 4: What plans does $he NRC have to ensure that a similar situation will not arise at other plants now under construction? What, if any,
' additional quality control. procedures does the NRC propose to institute in its inspec-tion program?
r"N Resoonse: The Commission is developing an action plan
(-) that will result in improved NRC review of quality assurance programs at operating nuclear power plants and nuclear power plants under construction. The details of the action plan will be available in the near future.
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February 23, 1982 rui. ,
n c= =. c= - -
The Honorable Nunzio Palladino .
Chairman q Nuclear Regulatory Commission Washington, D.C. 20555 .
Dear Mr. Chairman:
I Your response of February 1, 1982 to our letter of -
November 13, 1981 concerning the independence of the Diablo Canyon.
Audit is, quite frankly, unsatisfactory. Despite the amount of
. time requi red to provide your response, for which no explanation was given, your reply failed to adequately address the issues. ,
This establishes an unacceptable level'of performance for.the -
Commission. .
While recogni=ing that the ultimate responsibility of the Commission is the protection of public health and safety, the
- Committee'.s concern, expressed in our.Nove=ber 15, 1981. letter, is the establishment and maintenance of competent and credible
. procedures by which technical issues are addressed throughout'the Cjs licensing process.
In the case of the Diablo' Canyon nuclear power plant, the NRC's f ailure to discover the utility's numerous technical errors before issuing an operating license points to a p:oblem which may be far more serious than the errors the=selves. As a result of the sequence of events in this case, we are no longe: confronted with simply technical erro:s a= enable to technical solutions.
Rathe:, we are f aced with the erosion of the public confidence in not only the NRC's ability, but also its willingness, to fulfill its responsibility as the protector of public health and safety.
Subsequent to the discovery of the errors at Diablo Canyon, the NRC suspended the license of the utility and required an independent audit of the plant's seismic design. The purpose of the audit is to determine what, if any, additional protections are needed at the plant to ensure the public's t.ealth and safety and to :es:cre public confidence in the saf ety .cf 7he plant. In order
- accc plish these goals, che integri y Of t'.D audit must be .
guaranteed by the unimpeachable p prie:y of its p:: cess. ,
e
Honorablo Nunzio Palladino February 23, 1982 Page 2 -
The c.riteria contained in your letter appear to do little to ensure the integrity of the audit. Your letter seems to confuse
" independence" with " competence" and " avoidance of conflict of -
I interest"; all'of which are required in the Commission. order for l the audit. Indeed, your letter ultimately fails to provide any meaningful standard by which the independence of the audit can be
For example, even if R. L. Cloud and Associates met the independence through lack of conflict of interest requirements described in your response to our letter, the independence of the ;
3 firm has been brought into question by evidence in the Inspection u,) Report (NUREG-0862) that Cloud and PG&E together tailored the scope of the audit to meet the needs of the utility. This degree of cooperation between the auditor and the audited is inconsistent with the concept of independence. The independent auditor must clearly nnderstand its client to be, in cases like this, the public as represented by the Commission and the intervenors, not the utility. If .thir is not a view shared by the Commission, we should be so informed. .
The NRC staff has understood the importance of avoiding real or apparent improprieties in an audit if its findings are to merit public confidence. The staff has taken steps to guarantee the independence of audits for nuclear units seeking licenses in the near term. These precautions are being taken for plants that are not now contested by intervenors and have no record of .
construction irregularities! It is ironic that the Diablo Canyon
(~)T L.
plant, so heavily construction contested record, is not and with to subject such at a deplorable least equivalent
. standards.
In extemporaneous remarks before the Interior and Insular Affairs subcommittee on Energy and the Environment on November 19, 1981, you stated that freedom from editorial comment would be an essential. element in determining the independence of an audit. We a:e dismayed that after three months you have discarded even this minimal standard of independence and replaced it with an entirely different concept: no conflict of interest.
We, too, wish the audit.to avoid a conflict of inte:est. But we also believe it must be independent. Absent special definitions, it must be assumed that the Cctsission intends ,
cem=cnly accepted definitions of words used in its orders. The 1 dictienary defines " independent" to nean:
Pelitical autoncmy, f:ee f:0m influence, guidance, c: cent:ci of ancthe: c: cthers. -
. Eenorablo Nunrio Palladino
- February 23, 1982 Page 3 l
Failure to use precise language in Commission orders, or later substitution of words that are by no means synonymous, -
' confuses staff and applicants alike, and makes the task of
. conforming action.s to Co= mission orders.more difficult.
As the NRC considers the applications for operating licenses 4 '
~
I of plants with histories .of poor quality assurance during -
construction, the importance of a credible audit increases. The I value of such an audit will increase proportionally to the I perception of its independence from the utility. In this manner, public confidence which was lost through the disclosures at Diablo
([') Canyon and other , constructions sites can be regained by the Commission. In view of the foregoing, we request the Commissioners to review the response contained in the February 1, 1982 letter and reformulate the criteria by which they will evaluate the " independence" of the audit ordered on Nove=ber 19, .,
1981 of the Diablo Canyon nuclear power plant. !
Sincere'ly, l 1
l ,
. John D. Dingell, C airma. Richard L. Ottinger, Chairman Committee on Energy Subcom=ittee on Energy and Commerce. Conservation and Pcwer Committee on Energy O and Commerce i
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