ML20094R028

Responds to from Jr Gray Containg Copy of Demand for Info Transmitted to NPPD 941110 Re Actions Taken During 930309 Refueling Outage

ML20094R028
Person / Time
Site:	Cooper
Issue date:	12/09/1994
From:	Ballinger P NEBRASKA PUBLIC POWER DISTRICT
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20094Q932	List: ML20094Q958 ML20094Q971 ML20094Q976 ML20094Q986 ML20094R001 ML20094R012 ML20094R028 ML20094R038 ML20094R059 ML20094R067 ML20094R076 ML20094R086 ML20094R115
References
FOIA-95-262 NUDOCS 9512040238
Download: ML20094R028 (4)

Text

j

, '3D

---

mm , r , -

Nebraska Public Power District Cooper Nuclear Station P.O. Box 98 Brownville, NE 68321 December 9, 1994 Mr James Lieberman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Lieberman:

The purpose of this letter is to respond to the letter I received from Mr. Joseph R. Gray of your office dated November 10, 1994, which contained a copy of the Demand for Information (DFI) transmitted to the Nebraska Public Power District (NPPD) by letter dated November 10, 1994.

In connection with this matter, I was interviewed by a representative of the NRC's Office of Investigations. Since that time I have had the opportunity to review in greater detail the events during the March 1993 refueling outage, particularly the approval by the Station Operations Review Committee (SORC) on March 9, 1993 cf changes to procedures governing reactor pressure vessel (RPV) disassembly. This letter provides the NRC with information that is in addition to the information I provided during my previous interview. To the best of my recollection and belief, the information provided herein is in all material respects consistent with my previous interview.

Exclanation of SORC's Action I recall that during the March 9, 1993 SORC meeting the' proposed RPV disassembly procedure revisions we discussed connection with the Technical Specifications. At m Flahert request, I had done some research in preparation f r the meet g.

I reviewed NUREG-0612's guidance concerning movement of heavy loads and for certain design controls on cranes, hoists, etc. for transport of loads. The basic rationale of NUREG-0612 was that heavy objects could be safely moved if design assurance against single failures was established.

I recall that the GE PRC-88-11 guidance addressed loads weighing not over 750 lbs. The PRC-88-11 isn't very explicit with respect to weights of typical loads, but GE had acknowledged that

.AN 9512040238 9'51122 PDR FOIA i PATTERS95-262 PDR ,,

t g' [

r io ..

Mr. James Lieberman  !

December 9, 1994  ;

Page.2 PRC-88-11 applied to smaller loads compared- to NUREG-0612. I- I remember that we obtained the clarification from GE. I also  ;

remember information in the District's resp e to NUREG-0612 bein  !

dis ussed by SOR . I recall having met wit y Horn, Jim Flahert an 1ck Gardne o discuss the results of research on NUREG-  ;

061 and related ssues. NUREG-0612 focussed on the credibility of dropping certain loads and the resulting possibility of damage to fuel.

The purpose of the procedure changes considered by SORC during the March 9th meeting was to delete the steps that.

prohibited movement of the RPV head, separator and dryer absent

{

prior verification of secondary containment integrity. Wind  !

conditions at the plant, prior to the March 9th meeting, prevented  !

the performance of successful secondary containment testing. My t impression is that we could have used a little more time to address technical issues more thoroughly prior to the SORC meeting, but if SORC had been unsatisfied - with the information it needed for a decision it would not have made one. ,

As a voting member of SORC, I agreed with the proposed  !

changes to the RPV disassembly procedures. It appeared to me then that the changes made in 1991 to the RPV disassembly procedures,  !

subsequent to PRC-88-11, were in excess of the existing Technical  !

Specifications requirements. The procedure revisions considered by  ;

SORC on-March 9, 1993 were permissible and consistent with TS , 3.7.C, in my view, because there was no potential for damage to fuel in the RPV from movement of the RPV head, dryer and separator.

In my experience, SORC was objective in evaluating the issues.

SORC members were not reluctant to ask questions or challenge

. differing viewpoints.

I don't recal not have been unusualor[l him 6hnMeachahtthemeeting,butitwould to attend. I do not remember any strong challenges to conclusions reached by SORC during the meeting. I felt that SORC had made a reasonable decision based on the information it had before it. I would not have been reluctant to express technical concerns that I may have had at the time.

I. remember that someone obtained a copy of a memorandum by the NRC that supported SORC's interpretation of TS 3.7.C's requirements for secondary containment integrity (i.e.,

verif cation'not eregisite to RPV ieassembly). I recall also that ick Gardne and J ohn Meacha were aware of the NRC memo' dum. Also remember discussion at-the SORC meeting that there were other procedures addressing movement of loads, and that I

~ ,. .- . . .

iM , f l

q Mr. James Lieberman December-9, 1994 , j

'Pagei3;

. changes to those procedures similar to the proposed changes to RPV disassembly procedures would not be justified.

Exnlanation Why NRC Sanctions Are Inacorocriate  :

As explained above, I believe that SORC's decision on March 9, 1993 to approve the changes to the RPV disassembly -l procedures was appropriate based on all the factors it considered.  ;

Perhaps SORC's rationale and conclusions from the meeting could '

have been better documented, but at the time I agreed' with the i changes. Accordingly, I do not believe that any sanctions against  !

me personally are justified in connection with the November 10,  ;

1994 Demand for Information issued to the Nebraska Public Power.

District. i Any sanctions would impair my pu it of areer in the  !

nuclear power field, in which I have accrue year f experience  !

in positions of increasing responsibility. ourteen years of this i experience have included engineering and s pervisory experience at  !

Cooper Nuclear Station, including positions as: mechanical

• engineer; reactor engineer; lead reactor engineer and reactor i engineering supervisor, and operation engineering superviso ince 1986, I have been assigned as Operations l Engineer ng Supervisor. In that capacity, I am Supervisor of  !

Reactor Engineering, Operations Engineering and Performance  !

Engineering, reporting to the Engineering Manager. I am  !

responsible for all reactor engineering functions at the plant, '

including: planning of reactivity manipulations, control of fuel  !

movement; performance engineering, including system }

responsibilities and operating engineering, including systems re ponsibilitie I am a ember of SORC and also was qualified as  !

a hift Technic Adviso

\

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

i

D'

' tl Mr. James Lieberman December 9, 1994 Page 4 withheld from placement in the NRC Public Document Room and from disclosure pursuant to 10 C.F.R. S 2.790.

Sincerely, aul L. Ballinge y Sworn to and subscribed gefore me this f day of Ah /, At , 1994.

b1AAubAweJ b M W L -

NotarKlPublic (1 My Commission Expires: eB ER E ustas u ne,g m i IWirlWWct3Anusmose ku fl ' 19 9 [  % C "

• 4 h fl.Isat 0

i l

i i

. _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ __