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| | issue date = 04/03/1986 | | | issue date = 04/03/1986 |
| | title = Opposes Util 860304 Request for Exemption for Emergency Preparedness Exercise Requirements of 10CFR50,App E to Conduct Full Participation Exercise within 1 Yr Prior to Issuance of OL | | | title = Opposes Util 860304 Request for Exemption for Emergency Preparedness Exercise Requirements of 10CFR50,App E to Conduct Full Participation Exercise within 1 Yr Prior to Issuance of OL |
| | author name = EDDLEMAN W | | | author name = Eddleman W |
| | author affiliation = EDDLEMAN, W. | | | author affiliation = EDDLEMAN, W. |
| | addressee name = DENTON H R | | | addressee name = Denton H |
| | addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) | | | addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) |
| | docket = 05000400 | | | docket = 05000400 |
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| =Text= | | =Text= |
| {{#Wiki_filter:ACCESSION NBR: FAC IL'0-400 AUTH.NAME EDDLEMAN>M.RECIP.NAME DENTONi H.R.REGULATORY FORMATION DISTRIBUTION S EM (RIDS)8604080127 DOC.DATE: 86/04/03 NOTARIZED: | | {{#Wiki_filter:REGULATORY FORMATION DISTRIBUTION S EM (RIDS) |
| NO DOCKET 0 Shearon Harris Nuclear Power Planti Unit ii Carolina 0500040Q AUTHOR AFFILIATION Ed d l emani M.RECIPIENT AFFILIATION Office of Nuclear Reactor Regulationi Director (post 851125 | | ACCESSION NBR: 8604080127 DOC. DATE: 86/04/03 NOTARIZED: NO DOCKET 0 FAC IL'0-400 Shearon Harris Nuclear Power Planti Unit ii Carolina 0500040Q AUTH. NAME AUTHOR AFFILIATION EDDLEMAN> M. l Ed d emani M. |
| | RECIP. NAME RECIPIENT AFFILIATION DENTONi H. R. Office of Nuclear Reactor Regulationi Director (post 851125 |
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| ==SUBJECT:== | | ==SUBJECT:== |
| Responds opposing util 860304 request for exemption for emergency preparedness exercise requirements of 10CFR50i App E to,conduct full participation exercise within 1 gr prior to issuance of OL.DISTRIBUTION CODE: YOOED COPIES RECEIVED: LTR~ENCL 0 EIIE: TITLE: Distribution for Atypical 50 Dkt Matel ial NOTES: Application f or permit renewal f iled.~05000400 RECIPIENT ID CODE/NAME PNR-A ADTS 09'NR-A PD2 PD Q7 DENTONz H.R.06 INTERNAL: ELD/HDS1 16 RGN2 COPIES LTTR ENCL RECIPIENT ID CODE/NAME Pl4R-A PD2 LA 08 BUCKLEY'S B 01 FIL 04/MIB 17 COPIES LTTR ENCL EXTERNAL: 24X NRC PDR 02 LPDR NSIC 03 05 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 3ZIB TjlldI RIDZH 38ANX3QGD QI R~>A.l'HC~f 6-AWR kV Ca g~'3)ADlfQ tlat s Eddleman 81 Yancey St.Durham, NC 27701-3152 3'V.1986 Ph (919)688-0076 Harold R.Denton Director Office of=Nuclear Reactor Regulation USNRC Mhshington DC 20555 a Pl<A)IOO<O)~ID", Gl&OA , IXI%OK IXIO L. | | Responds opposing util 860304 request for exemption for emergency preparedness exercise requirements of 10CFR50i App E to,conduct full participation exercise within gr 1 prior to issuance of OL. |
| | DISTRIBUTION CODE: |
| | TITLE: |
| | YOOED Distribution for Atypical COPIES RECEIVED: LTR 50 Dkt Matel |
| | ~ |
| | ial ENCL 0 EIIE: |
| | NOTES: Application for permit renewal f iled. ~ 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PNR-A ADTS Pl4R-A PD2 LA 08 PD2 PD Q7 09'NR-A BUCKLEY'S B 01 DENTONz H. R. 06 INTERNAL: ELD/HDS1 16 FIL 04 RGN2 /MIB 17 EXTERNAL: 24X LPDR 03 NRC PDR 02 NSIC 05 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL |
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| ==Dear Harold.Denton,==
| | 3ZIB TjlldIRIDZH 38ANX3QGD QI R~> A.l 'HC~f 6-AWR kV Ca g~'3 )ADlfQ |
| This is in reference Co Carolina Power L Light's letter to you of g March, 1986, Serial NLS-86-053, requesting an exemption from the emergency preparedness exercise requirements of lo C.F.R.50, Appendix E, Section IV.F.l to c onduct a full-participation emergency preparedness exercise within one year prior to issuance of the first 6psratinag.
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| License for full power and.prior to operation above 5 percent of rated power, for the Shearon Harris Nuclear Power Plant (" HArris" or SHNPP).First, the delay in operation of Harris is entirely due to CPKLIs action in delaving the plant, which evidently stemmed from too-ophimisticm scheduling and inability Co comply with NRC requirements in a timely manner.CP8cL cannot claim that anything but their own failures and.errors caused the delay.Second, granting this exemption would violate my, and the general public Is, right to a hearing under section 189(a)of'he Atomic Energy Act, Q2 USC 2239(a), which provides"'...in an proceeding under this chapter for the granting, suspending, revok ng or amending of any license...and in~an proceeding for the issuance or modification of rules and regulations dealing with the activities of licensees the Commission shall grant a hearing upon the request of any person whose intezest may Se affected by the pzoceeding and shall admit any such person as a party to the proceeding." Since this exemption request is outside the licensing hearing procedures of the NRC, I hereby petition to intervene in this matter, which is effectively an amendment to the operating license application by request to remove a requirement of the NRC.The regulations governing the timing of full participation tests of emergency response plans are in place, and Applicants (CPSL for SHNPP)should not be allowed to change Che regulations by this end-run, which is illegal as a way to avoid a hearing.My interest is that I both live and work withe@30 miles of SHNPP and spend time in the EPZ while conducting my energy and environ-mental consulting work as well;these interests are more fully set forth in my petition to intervene in the Harris OL proceeding, Dkt 50-Jj00, Feb.1982, which is incorporated by reference hereing to establish my meeting the requirements to intervene under 10 CFR part 2, e.g.2.71$.My interest in the proceeding ih to rebut Che false or misleading-assertions of CPS'with regard Co this license amendment by request for exemption, and to protect the public health and safety, including my own and Chat of others dear to me.I assert further that the NRC has no right to grant this exemption on any economic ground since the Atomic Energy Act under thich the NRG apex'ates x squires NRC'o put pp health and safety first, and 5o author%sation is in Chat act fo r exemptions on grounds of cost.I Moreover, FEME has not zhaekeNmxnnR formall evaluated the corrections or corrective actions proposed for problems identified during the 1985 emergency planning exercise at SHNPP.FEMA officials have stated they could not evaluate the implementation of proposed corrective actI.ions uhtil the next full-participation exercise (5<<87)(2-11-86 conference call in NRC Dkt.50-400;see Hells Eddleman~s Response to Summary Msposition on Contentions EPX-2 and 8, 2-18-86 at pp 2'-37.Besides, there is no NRC IU~~~~~~~~lh 0 a~finding that the Plans are adequate, and none can be made without FEME.fi.ndings which cannot be made without another'full>>participation exerci,se.(But even if NHC~s ASLB approves the plan, the arguments In Che first sentence of this paragraph, last page, remai.n valid and X stand on them).CP8:L~s claimed'")ustification" for this exemption is specious or wrong in its aspect also.First, issuance of an operating license (10 CFH 50.57)is premised on complIance with the regulatIons.
| | tlat s Eddleman 81 Yancey St. |
| So by avoiding compliance with a regulation, that's a substantial amendment Co the operating license.Moreover, the request doep~ot meet part (a)of 10 CFR 50.12>>-the requirement Chat there be noM~azard.Xt doesn't say small hazard or minimal hazard, it says ("'No"~~Qq.zard. | | Durham, NC 27701-3152 3 'V.1986 Ph (919) 688-0076 Harold R. Denton Director Office of= Nuclear Reactor Regulation USNRC Mhshington DC 20555 |
| There's a hazard in 2 senses, first that FIRMA has not evalua%ecC formally the"fixes"'f deficiencies found by FEMA and others (including State of NC evaluatorsII during the past exercise, and second, there Is no assurance the ability'o respond is maintained, for nuclear emergencies, beyond one year, The rule so premises, I.e.that Che length of time for which 1C can be assumed, that the exercise remains amQ.Id measure of emergency response f'r nuclear accidents is at most one year./~~~a 1"~kgg Moreover, CP8cg admits it is still working on<3 improvement item'b"with Che goal of having them ready for NHC inspection'n t'une 1986".The NRC's mandate in the atomi.c energy act Co put safety first means Chat CP8cL cannot claim any hazard is a"due" hazard (as distinct from the'"undue hazard" of 10 CFR 50.12(a)); | | |
| NRC may not base its decision on activities CP8cL and others vill propose Co undertake (Exemption request p.2)either, because those Eave not happen'ed and vannot be assumed Co be successful. | | ==Dear Harold. Denton,== |
| For example,'in CP8cL's training of teachers, it was reqported that CP8cL represeritatives told Wake County teachers they would never have Co Implemerit the emergency plan (I.e.Chat no accident Chat serious would happen, appears to be the Chrust of the reported remakzrks). | | |
| Moreover, only the"completed portions" of emergency plan training were found adequate by NRC.Xf training is not complete, how can the personnel be ready'or a nuclear emergency????? | | This is in reference Co Carolina Power L Light's letter to you of g March, 1986, Serial NLS-86-053, requesting an exemption from the emergency preparedness exercise requirements of lo C.F.R. 50, Appendix E, Section IV.F.l to c onduct a full-participation emergency preparedness exercise within one year prior to issuance of the first 6psratinag. |
| Radiological workshops (Exemption request, page 3)are also not evidently complete, so there is still a lack of training.As noted above, the corrective actions by the State (CP8cL buries them in the end of'he last paragraph on part b of page 3 of their exemption request)cannot be formally reviewed.and evaluated by FEMA f'r effectiveness unt11 the next full-participation test.Much of the training i.n part (c)on page 3 has also not taken place.The planned exercises of Lee County and.CP8cL (bottom of page g)have also not yet taken place, apparently, and It i.s not clear how many, (or for CPLL drills, if any)offsite emergency response personnel will particip'ate. | | License for full power and. prior to operation above 5 percent of rated power, for the Shearon Harris Nuclear Power Plant ("HArris" or SHNPP). |
| The drills in parts,(h)and (I), p.5, seem non-nuclear. | | First, the delay in operation of Harris is entirely due to CPKLIs action in delaving the plant, which evidently stemmed from too-ophimisticm scheduling and inability Co comply with NRC requirements in a timely manner. CP8cL cannot claim that anything but their own failures and. |
| Hardship or costs: CP8cL assumes the public interest is reducIng theIr costs, but the increased cost is due to CP8cL~s own error in scheduling tpe origirial full-participation exercise and bei.ng unable to complete their nuclear plant in time Moreover, the dollar costs mentioned are riot that large, and NHC may not put costs above saf'ety even if the costs were much larger (the costs not being large compared Co the cost of n'uclear delays created by CP8cL, f'r example, which probably run over$500,000 a day).The relI8f requested Is NOT temporary (criterion (v), p.6)since the requirement only occurs prior to licensing. | | errors caused the delay. |
| The exemption is there-.fore permanent unless CP8cL flubs INC again and has to have a 3d exercise.Criterion (Ui)p.7 is'P8cL~s si.lliest argument, X think.Xf'he.second exercIse reveals new flaws, that Isn't redundant at all, and is litigable under UCS v.NHC.Xf it reveals the.same or similar flaws, It peag'gre~tivg action failed and this is also litigable,-"-'n'ot because rection failed.UCS v.'RC requires s up ca ive'ut because the dor aws ound in the exerci e, and CP8cL must not avo~<d+>his requirement via"exemption" p/w Q~cu+5'~~~~ | | Second, granting this exemption would violate my, and the general public Is, right to a hearing under section 189(a) of'he Atomic Energy Act, Q2 USC 2239(a), which provides "'...in an proceeding under this chapter for the granting, suspending, revok ng or amending of any license ... and in ~an proceeding for the issuance or modification of rules and regulations dealing with the activities of licensees the Commission shall grant a hearing upon the request of any person whose intezest may Se affected by the pzoceeding and shall admit any such person as a party to the proceeding." Since this exemption request is outside the licensing hearing procedures of the NRC, I hereby petition to intervene in this matter, which is effectively an amendment to the operating license application by request to remove a requirement of the NRC. The regulations governing the timing of full participation tests of emergency response plans are in place, and Applicants (CPSL for SHNPP) should not be allowed to change Che regulations by this end-run, which is illegal as a way to avoid a hearing. My interest is that I both live and work withe@ 30 miles of SHNPP and spend time in the EPZ while conducting my energy and environ-a mental consulting work as well; these interests are more fully set forth Pl<A ) in my petition to intervene in the Harris OL proceeding, Dkt 50-Jj00, IOO |
| 0 II I 1~~~~lt t~I[I I I CI xc:-NRC Docketing and Service, 3x Richard E.'ones, VP h head of legal dept, CPSL Box 1551 Raleigh NC 27602 Tom Baxter, counsel for CPKL Shaw, Pittman Potts 5 Trowbridge 1800 M St Kf X Washingtoh DC'0036 Wells Zddleman 812 Yancey St.Durham NC 27701-3152 0 e~V I L II A f'p p~c~'I-g C I~p}} | | <O Feb. 1982, which is incorporated by reference hereing to establish |
| | )~ID my meeting the requirements to intervene under 10 CFR part 2, e.g. 2.71$ . |
| | My interest in the proceeding ih to rebut Che false or misleading-Gl& |
| | assertions of CPS' with regard Co this license amendment by request for exemption, and to protect the public health and safety, including OA IXI% my own and Chat of others dear to me. I assert further that the NRC has no right to grant this exemption on any economic ground since the OK Atomic Energy Act under thich the NRG apex'ates x squires NRC'o put pp IXIO L. health and safety first, and 5o author%sation is in Chat act fo r exemptions on grounds of cost. I Moreover, FEME has not zhaekeNmxnnR formall evaluated the corrections or corrective actions proposed for problems identified during the 1985 emergency planning exercise at SHNPP. FEMA officials have stated they could not evaluate the implementation of proposed corrective actI.ions uhtil the next full-participation exercise (5<<87) (2-11-86 conference call in NRC Dkt. 50-400; see Hells Eddleman~s Response to Summary Msposition on Contentions EPX-2 and 8, 2-18-86 at pp 2'-37. Besides, there is no NRC |
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| | 0 finding that the Plans are adequate, a ~ |
| | and none can be made without fi.ndings which cannot be made without another 'full>>participation FEME. |
| | exerci,se. (But even if NHC~s ASLB approves the plan, the arguments In Che first sentence of this paragraph, last page, remai.n valid and X stand on them). |
| | CP8:L~s claimed '")ustification" for this exemption is specious or wrong in its aspect also. First, issuance of an operating license (10 CFH 50.57) is premised on complIance with the regulatIons. So by avoiding compliance with a regulation, that's a substantial amendment Co the operating license. Moreover, the request doep~ot meet part (a) of 10 CFR 50.12 >>- the requirement Chat there be noM~ azard. Xt doesn't say small hazard or minimal hazard, it says ("'No"~~Qq.zard. There's a hazard in 2 senses, first that FIRMA has not evalua%ecC formally the "fixes"'f deficiencies found by FEMA and others (including State of NC evaluatorsII during the past exercise, and second, there Is no assurance the respond is maintained, for nuclear emergencies, beyond one year, ability'o The rule so premises, I.e. that Che length of time for which 1C can be assumed, that the exercise remains amQ.Id measure of emergency response f'r nuclear accidents is at most one year. |
| | it is still /~~~a 1"~kgg Moreover, CP8cg admits working on<3 improvement item'b "with Che goal of having them ready for NHC inspection'n t'une 1986". |
| | The NRC's mandate in the atomi.c energy act Co put safety first means Chat CP8cL cannot claim any hazard is a "due" hazard (as distinct from the '"undue hazard" of 10 CFR 50.12(a)); |
| | NRC may not base its decision on activities CP8cL and others vill propose Co undertake (Exemption request p.2) either, because those Eave not happen'ed and vannot be assumed Co be successful. For example, 'in CP8cL's training of teachers, it was reqported that CP8cL represeritatives told Wake County teachers they would never have Co Implemerit the emergency plan (I.e. Chat no accident Chat serious would happen, appears to be the Chrust of the reported remakzrks). Moreover, only the "completed portions" of emergency plan training were found adequate by NRC. Xf training is not complete, how can the personnel be nuclear emergency????? |
| | ready'or a |
| | Radiological workshops (Exemption request, page 3) are also not evidently complete, so there is still a lack of training. |
| | As noted above, the corrective actions by the State (CP8cL buries them in the end of'he last paragraph on part b of page 3 of their exemption request) cannot be formally reviewed. and evaluated by FEMA f'r effectiveness unt11 the next full-participation test. |
| | Much of the training i.n part (c) on page 3 has also not taken place. |
| | The planned exercises of Lee County and. CP8cL (bottom of page g) have also not yet taken place, apparently, and (or for CPLL drills, if It i.s not clear how many, any) offsite emergency response personnel will particip'ate. The drills in parts,(h) and (I), p.5, seem non-nuclear. |
| | Hardship or costs: CP8cL assumes the public interest is reducIng theIr costs, but the increased cost is due to CP8cL~s own error in scheduling tpe origirial full-participation exercise and bei.ng unable to complete their nuclear plant in time Moreover, the dollar costs mentioned are riot that large, and NHC may not put costs above saf'ety even if were much larger (the costs not being large compared Co the cost of n'uclear the costs delays created by CP8cL, f'r example, which probably run over $ 500,000 a day). The relI8f requested Is NOT temporary (criterion (v), p.6) since the requirement only occurs prior to licensing. The exemption is there- |
| | .fore permanent unless CP8cL flubs INC again and has to have a 3d exercise. |
| | Criterion (Ui) p.7 is'P8cL~s si.lliest argument, X think. Xf'he. |
| | second exercIse reveals new flaws, that Isn't redundant at all, and is it litigable under UCS v. NHC. Xf reveals the. same or similar flaws, It peag'gre~tivg s up ca ive 'ut action failed and this is also litigable, -"-'n'ot because because the dor rection failed. UCS v.'RC requires aws ound in the exerci e, and CP8cL must not avo~<d +>his requirement via "exemption" p/w Q~cu+5'~ ~~~ |
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| | Wells Zddleman 812 Yancey St. |
| | Durham NC 27701-3152 xc: -NRC Docketing and Service, 3x Richard E.'ones, VP h head of legal dept, CPSL Box 1551 Raleigh NC 27602 Tom Baxter, counsel for CPKL Shaw, Pittman Potts 5 Trowbridge 1800 M St Kf X Washingtoh DC'0036 |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18017A9241999-10-15015 October 1999 Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools 'C' & 'D' in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18017A9141999-10-12012 October 1999 Forwards Addl Info Re Second 10-year ISI Program Plan Relief Requests,As Requested During 990923 Telcon ML18017A9131999-10-0606 October 1999 Provides Notification That Three SROs Licensed at Shnpp Have Been Reassigned from Position for Which Util Previously Certified Need for SRO License.Name,Docket Number & License Number for Subject Sros,Encl.Encl Withheld ML18017A8911999-09-30030 September 1999 Submits Comment on Encl 2 to 990617 Memo Titled Summary of Meeting with Nuclear Energy Inst. Encl 2 Was Titled Draft Technical Study of Spent Fuel Pool Accidents for Decommissioning Plants. Rept Which Provides Info Encl Also ML20216G3501999-09-29029 September 1999 Confirms Conversations Re NRC Staff Voluntary Response to Orange County Discovery Requests.Staff Will Voluntarily Answer Discovery Requests & Will Not Waive Any Objection or Privilege Under NRC Regulations.Related Correspondence ML20212M1081999-09-29029 September 1999 Confirms Intent to Meet with Utils on 991025 in Atlanta,Ga to Discuss Pilot Plants,Shearon Harris & Sequoyah Any Observations & Lessons Learned & Recommendations Re Implementation of Pilot Program ML20212J0741999-09-29029 September 1999 Refers to Proposed License Amend for Harris NPP Which Would Allow Licensee to Activate Two of Plant Spent Fuel Pools.Serves Copy of Orange County Second Set of Document Requests to NRC Staff,Dtd 990929.Related Correspondence ML18017A8941999-09-29029 September 1999 Forwards Response to NRC 990414 RAI Re GL 95-07, Pressure- Locking & Thermal-Binding of SR Power-Operated Gate Valves. ML18017A8881999-09-27027 September 1999 Submits Info Re Estimated Effect of Changes or Errors in ECCS Evaluation Models or in Application of Models,Per 10CFR50.46(a)(3)(ii) ML18017A8861999-09-21021 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18017A8821999-09-14014 September 1999 Provides Notification That RO Licensed on Harris Plant No Longer Meets Requirements of 10CFR50.21,effective 990826. Name,Docket Number & License Number for Individual Provided in Encl.Encl Withheld,Per 10CFR2.790(a)(6) ML18017A8651999-09-0808 September 1999 Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety ML18017A8581999-09-0303 September 1999 Provides Response to NRC 990805 RAI Re Amend Request to Increase Fuel Storage Capacity ML18017A8551999-09-0101 September 1999 Forwards Marked Up Copy of Approved FSAR Section 17.3 with Applicable Duplicated TS Requirements,As Committed to in 990602 Application for Rev to TS ML18017A8541999-08-20020 August 1999 Submits Closure Info for Rev 1,Suppl 1 to GL 92-01, Reactor Vessel Structural Integrity. Identified Discrepancies from Review of NRC Rvid Provided HNP-99-134, Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.211999-08-18018 August 1999 Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.21 ML18017A8351999-08-10010 August 1999 Corrects Statement Made in 980923 Ltr,By Clarifying That Operation of Inner & Outer Pal Doors Can Be Operated by Control Panels Located Inside & Outside Containment ML18016B0531999-08-0606 August 1999 Forwards Exercise Scenario with Controller Info & Simulation Data for Harris Nuclear Plant Emergency Preparedness Exercise Scheduled for 990921.Without Encl ML18016B0461999-08-0404 August 1999 Forwards LER 99-006-01 Describing Condition Which Resulted in Exceeding TS Requirements for CIVs & TS 4.0.4 for Generic Requirements for Surveillance Testing.Rev Includes Results of Investigation Into Failure to Recognize TS Requirements ML18016B0391999-07-30030 July 1999 Forwards Rev 35 to PLP-201, Emergency Plan. Rev Replaces All Pages of Previous Rev with Exception of EAL Flow Path, Side 1 & 2 & Annex H,Operations Map & Aperature Card. Changes Made by Rev,Listed ML18016B0421999-07-30030 July 1999 Informs That in Ltr Dtd 950330 CP&L Committed to Complete Assessment of Severe Accident Mgt Capabilities & Make Any Identified Enhancements by 981231.Actions Were Completed in July 1998 ML18016B0221999-07-26026 July 1999 Informs That CP&L Proposes to Provide Response to NRC 990414 RAI Re GL 95-07, Pressure-Locking & Thermal-Binding of SR Power-Operated Gate Valves, by 990930 ML18016B0171999-07-16016 July 1999 Forwards Corrected Pages to Annual Radioactive Effluent Release Rept, for 1998 for HNP ML18016B0051999-07-0101 July 1999 Informs of Scheduled Emergency Preparedness Exercise for Shnpp on 990921,per Requirements of 10CFR50,App E.List of 26 Objectives Selected for Evaluation During Exercise,Encl. Without Encl ML20212H7741999-06-23023 June 1999 Responds to Re Petition Filed by Orange County Board of Commissioners Re Proposed Expansion of Sf Storage Capacity at Shearon Harris Npp.Public Meeting Will Be Held at Later Date.With Certificate of Svc.Served on 990624 ML18016A9871999-06-14014 June 1999 Forwards Response to NRC 990429 RAI Re License Amend Request to Place Spent Fuel Pools C & D in Service,Dtd 981223.Info Does Not Change Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18016A9831999-06-10010 June 1999 Submits Notification That Reactor Operator Licensed at HNP Has Terminated Employment with Cp&L.Reactor Operator Info Encl.Effective 990528,individuals License Is No Longer Required & CP&L Requests That License Be Terminated ML20212H7521999-06-0404 June 1999 Encourages NRC to Schedule Open Public Forum Which Would Allow Local Citizens to Express Concerns Re Proposed Expansion of high-level Radwaste Storage Capacity at Shearon Harris Npp.With Certificate of Svc.Served on 990624 ML18016A9721999-05-28028 May 1999 Responds to 990309 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. ML18016B0011999-05-26026 May 1999 Forwards Ltr Received from Hj Jaffe Expressing Concern Re Cpl Proposal to NRC on Dec of 1998 to Make Harris Nuclear Plant Largest Storage Area for High Level Nuclear Waste in Nation ML18016A9631999-05-25025 May 1999 Forwards Periodic Update to FSAR for Hnp.Amend 49 Is Current Through 981128 (End of RFO 8).Some Changes & Analysis Completed After 981128 Have Also Been Included in Amend ML20206R2511999-05-19019 May 1999 Responds to Addressed to Chairman Jackson Requesting That NRC Grant Standing to Orange County Board of Commissioners in Shearon Harris Proceeding Currently Before Board.With Certificate of Svc.Served on 990519 ML20206Q5281999-05-17017 May 1999 Responds to 990304 Request for Two Rail Routes to Be Used for Transport of Spent Fuel from Brunswick Steam Electric Plant,Southport,Nc & Hb Robinson Steam Electric Plant, Hartsville,Sc to Shearon Harris Npp,Near New Hill,Sc ML18016A9511999-05-13013 May 1999 Submits Info Re Estimated Effect of Change to ECCS Evaluation Model,As Required by 10CFR50.46 ML18016A9601999-05-11011 May 1999 Forwards Resolution Adopted by Carrboro Board of Aldermen at 990504 Meeting.Resolution Expresses Town Concern Re Util Plans to Double high-level Nuclear Waste Storage at Shnpp ML18016A9481999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Examination by Facility Licensee, for Senior Reactor Operator Licensed to Operate Hnp.Individuals Info Is Proprietary & Is Being Withheld from Public Disclosure,Per 10CFR2.790(a)(6) ML20206R2611999-05-0505 May 1999 Requests That NRC Grant Standing to Intervention Sought by Orange County Board of Commissioners Re Proposal by CP&L to Expand Storage of Hlrw at Shnpp.With Certificate of Svc. Served on 990519 ML18016A9451999-05-0404 May 1999 Provides Proprietary Notification That One SRO Has Been Reassigned from Position for Which Util Certified Need for SRO License & Another SRO Has Terminated Employment with Util.Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9441999-05-0404 May 1999 Notifies NRC of Util Completion of Actions Re GL 96-01, Testing of Safety-Related Logic Circuits at Plant ML18016A9351999-04-30030 April 1999 Forwards Info Requested in 990324 RAI as Suppl to 981223 Application for Amend to License NPF-63 for Alternative Plan for Spent Fuel Pool Cooling & Cleanup Sys Piping ML18016A9311999-04-30030 April 1999 Forwards Annual Radioactive Effluent Release Rept for Jan- Dec 1998 & Rev 11 to ODCM for Shnpp HNP-99-068, Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld1999-04-28028 April 1999 Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld ML18016A9211999-04-27027 April 1999 Provides Rev 2 to ISI Relief Request 2RG-008, ISI of Class 1,2 & 3 Snubbers (Code Category F-A) Per Plant TS in Lieu of ASME Code Section XI, in Response to 990408 Telcon with NRC ML18016A9221999-04-27027 April 1999 Forwards Proprietary Notification That SRO Licensed on Shnpp Has Terminated Employment with Cp&L,Per 10CFR50.74(b). Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9161999-04-22022 April 1999 Forwards Proprietary NRC Form 396, Certification of Medical Exam by Facility Licensee, for SRO Licensed to Operate Hnp. License for Individual Should Be Amended IAW Change Noted on Form.Proprietary Encl Withheld,Per 10CFR2.790(a)(6) ML18016A9201999-04-20020 April 1999 Informs of HNP Personnel Changes to Facilitate Proper Distribution of Correspondence.Records Should Be Updated to Reflect Noted Change ML20205M0431999-04-13013 April 1999 Eighth Partial Response to FOIA Request for Records.App Q & R Records Encl & Being Made Available in PDR ML18016A9121999-04-12012 April 1999 Forwards Diskette Containing Data Re Annual Exposure Rept for Individual Monitoring for Personnel Shnpp,Per 10CFR20.2206(b).Without Encl ML18016A9021999-04-12012 April 1999 Forwards Rev 34 to PLP-201, Shearon Harris NPP Emergency Plan, Replacing All Pages of Previous Rev with Exception of EAL Flow Path,Side 1 & 2 & Annex H Operations Map & Aperture Card.Changes,Listed.Rev Summary,Encl IR 05000400/19982011999-04-12012 April 1999 Discusses Safeguards Insp Rept 50-400/98-201 (Operational Safeguards Response Evaluation) on 980908-11.No Violations Noted.Licensee Performance During Evaluation Indicated Excellent Overall Contingency Response Capability 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18017A9241999-10-15015 October 1999 Provides Supplemental Info Re 981223 Lar,Placing Plant Spent Fuel Pools 'C' & 'D' in Service.Info Provided Does Not Change Util Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18017A9141999-10-12012 October 1999 Forwards Addl Info Re Second 10-year ISI Program Plan Relief Requests,As Requested During 990923 Telcon ML18017A9131999-10-0606 October 1999 Provides Notification That Three SROs Licensed at Shnpp Have Been Reassigned from Position for Which Util Previously Certified Need for SRO License.Name,Docket Number & License Number for Subject Sros,Encl.Encl Withheld ML18017A8911999-09-30030 September 1999 Submits Comment on Encl 2 to 990617 Memo Titled Summary of Meeting with Nuclear Energy Inst. Encl 2 Was Titled Draft Technical Study of Spent Fuel Pool Accidents for Decommissioning Plants. Rept Which Provides Info Encl Also ML20212J0741999-09-29029 September 1999 Refers to Proposed License Amend for Harris NPP Which Would Allow Licensee to Activate Two of Plant Spent Fuel Pools.Serves Copy of Orange County Second Set of Document Requests to NRC Staff,Dtd 990929.Related Correspondence ML18017A8941999-09-29029 September 1999 Forwards Response to NRC 990414 RAI Re GL 95-07, Pressure- Locking & Thermal-Binding of SR Power-Operated Gate Valves. ML18017A8881999-09-27027 September 1999 Submits Info Re Estimated Effect of Changes or Errors in ECCS Evaluation Models or in Application of Models,Per 10CFR50.46(a)(3)(ii) ML18017A8861999-09-21021 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18017A8821999-09-14014 September 1999 Provides Notification That RO Licensed on Harris Plant No Longer Meets Requirements of 10CFR50.21,effective 990826. Name,Docket Number & License Number for Individual Provided in Encl.Encl Withheld,Per 10CFR2.790(a)(6) ML18017A8651999-09-0808 September 1999 Requests Relief from Section XI,IWA-5242(a) Requirement for HNP Class 2 Bolted Connections in Borated Sys.Compliance with Requirement Would Result in Unusual Difficulty Without Compensating Increase in Level of Quality & Safety ML18017A8581999-09-0303 September 1999 Provides Response to NRC 990805 RAI Re Amend Request to Increase Fuel Storage Capacity ML18017A8551999-09-0101 September 1999 Forwards Marked Up Copy of Approved FSAR Section 17.3 with Applicable Duplicated TS Requirements,As Committed to in 990602 Application for Rev to TS ML18017A8541999-08-20020 August 1999 Submits Closure Info for Rev 1,Suppl 1 to GL 92-01, Reactor Vessel Structural Integrity. Identified Discrepancies from Review of NRC Rvid Provided HNP-99-134, Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.211999-08-18018 August 1999 Forwards Rev 11 to Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p)(2) & 10CFR50.4(b)(4). Description of Changes Is Provided as Encl 2 to Ltr.Rev Withheld,Per 10CFR73.21 ML18017A8351999-08-10010 August 1999 Corrects Statement Made in 980923 Ltr,By Clarifying That Operation of Inner & Outer Pal Doors Can Be Operated by Control Panels Located Inside & Outside Containment ML18016B0531999-08-0606 August 1999 Forwards Exercise Scenario with Controller Info & Simulation Data for Harris Nuclear Plant Emergency Preparedness Exercise Scheduled for 990921.Without Encl ML18016B0461999-08-0404 August 1999 Forwards LER 99-006-01 Describing Condition Which Resulted in Exceeding TS Requirements for CIVs & TS 4.0.4 for Generic Requirements for Surveillance Testing.Rev Includes Results of Investigation Into Failure to Recognize TS Requirements ML18016B0421999-07-30030 July 1999 Informs That in Ltr Dtd 950330 CP&L Committed to Complete Assessment of Severe Accident Mgt Capabilities & Make Any Identified Enhancements by 981231.Actions Were Completed in July 1998 ML18016B0391999-07-30030 July 1999 Forwards Rev 35 to PLP-201, Emergency Plan. Rev Replaces All Pages of Previous Rev with Exception of EAL Flow Path, Side 1 & 2 & Annex H,Operations Map & Aperature Card. Changes Made by Rev,Listed ML18016B0221999-07-26026 July 1999 Informs That CP&L Proposes to Provide Response to NRC 990414 RAI Re GL 95-07, Pressure-Locking & Thermal-Binding of SR Power-Operated Gate Valves, by 990930 ML18016B0171999-07-16016 July 1999 Forwards Corrected Pages to Annual Radioactive Effluent Release Rept, for 1998 for HNP ML18016B0051999-07-0101 July 1999 Informs of Scheduled Emergency Preparedness Exercise for Shnpp on 990921,per Requirements of 10CFR50,App E.List of 26 Objectives Selected for Evaluation During Exercise,Encl. Without Encl ML18016A9871999-06-14014 June 1999 Forwards Response to NRC 990429 RAI Re License Amend Request to Place Spent Fuel Pools C & D in Service,Dtd 981223.Info Does Not Change Initial Determination That Proposed License Amend Represents No Significant Hazards Consideration ML18016A9831999-06-10010 June 1999 Submits Notification That Reactor Operator Licensed at HNP Has Terminated Employment with Cp&L.Reactor Operator Info Encl.Effective 990528,individuals License Is No Longer Required & CP&L Requests That License Be Terminated ML20212H7521999-06-0404 June 1999 Encourages NRC to Schedule Open Public Forum Which Would Allow Local Citizens to Express Concerns Re Proposed Expansion of high-level Radwaste Storage Capacity at Shearon Harris Npp.With Certificate of Svc.Served on 990624 ML18016A9721999-05-28028 May 1999 Responds to 990309 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. ML18016B0011999-05-26026 May 1999 Forwards Ltr Received from Hj Jaffe Expressing Concern Re Cpl Proposal to NRC on Dec of 1998 to Make Harris Nuclear Plant Largest Storage Area for High Level Nuclear Waste in Nation ML18016A9631999-05-25025 May 1999 Forwards Periodic Update to FSAR for Hnp.Amend 49 Is Current Through 981128 (End of RFO 8).Some Changes & Analysis Completed After 981128 Have Also Been Included in Amend ML18016A9511999-05-13013 May 1999 Submits Info Re Estimated Effect of Change to ECCS Evaluation Model,As Required by 10CFR50.46 ML18016A9481999-05-0606 May 1999 Forwards NRC Form 396, Certification of Medical Examination by Facility Licensee, for Senior Reactor Operator Licensed to Operate Hnp.Individuals Info Is Proprietary & Is Being Withheld from Public Disclosure,Per 10CFR2.790(a)(6) ML20206R2611999-05-0505 May 1999 Requests That NRC Grant Standing to Intervention Sought by Orange County Board of Commissioners Re Proposal by CP&L to Expand Storage of Hlrw at Shnpp.With Certificate of Svc. Served on 990519 ML18016A9451999-05-0404 May 1999 Provides Proprietary Notification That One SRO Has Been Reassigned from Position for Which Util Certified Need for SRO License & Another SRO Has Terminated Employment with Util.Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9441999-05-0404 May 1999 Notifies NRC of Util Completion of Actions Re GL 96-01, Testing of Safety-Related Logic Circuits at Plant ML18016A9351999-04-30030 April 1999 Forwards Info Requested in 990324 RAI as Suppl to 981223 Application for Amend to License NPF-63 for Alternative Plan for Spent Fuel Pool Cooling & Cleanup Sys Piping ML18016A9311999-04-30030 April 1999 Forwards Annual Radioactive Effluent Release Rept for Jan- Dec 1998 & Rev 11 to ODCM for Shnpp HNP-99-068, Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld1999-04-28028 April 1999 Forwards Rev 0 to Physical Security & Safeguards Contingency Plan. Description of Changes Provided.Encl Withheld ML18016A9221999-04-27027 April 1999 Forwards Proprietary Notification That SRO Licensed on Shnpp Has Terminated Employment with Cp&L,Per 10CFR50.74(b). Proprietary Info Withheld,Per 10CFR2.790(a)(6) ML18016A9211999-04-27027 April 1999 Provides Rev 2 to ISI Relief Request 2RG-008, ISI of Class 1,2 & 3 Snubbers (Code Category F-A) Per Plant TS in Lieu of ASME Code Section XI, in Response to 990408 Telcon with NRC ML18016A9161999-04-22022 April 1999 Forwards Proprietary NRC Form 396, Certification of Medical Exam by Facility Licensee, for SRO Licensed to Operate Hnp. License for Individual Should Be Amended IAW Change Noted on Form.Proprietary Encl Withheld,Per 10CFR2.790(a)(6) ML18016A9201999-04-20020 April 1999 Informs of HNP Personnel Changes to Facilitate Proper Distribution of Correspondence.Records Should Be Updated to Reflect Noted Change ML18016A9121999-04-12012 April 1999 Forwards Diskette Containing Data Re Annual Exposure Rept for Individual Monitoring for Personnel Shnpp,Per 10CFR20.2206(b).Without Encl ML18016A9021999-04-12012 April 1999 Forwards Rev 34 to PLP-201, Shearon Harris NPP Emergency Plan, Replacing All Pages of Previous Rev with Exception of EAL Flow Path,Side 1 & 2 & Annex H Operations Map & Aperture Card.Changes,Listed.Rev Summary,Encl ML18016A8911999-04-0505 April 1999 Forwards non-proprietary App 4A,pages 20-25 & Proprietary Page 4-6 to re-issued Rev 3 of Holtec International Licensing Rept HI-971760.Pages Were Inadvertently Omitted from Reissued Rept.Proprietary Page 4-6 Withheld ML18016A8891999-04-0101 April 1999 Forwards Rev 99-1 to Plant EALs for NRC Review & Approval, Per 10CFR50,App E.Encl Provides Comparison of Currently Approved EALs & Proposed Rev 99-01.Approval of EALs Prior to June 1999,requested.With Four Oversize Drawings ML18016A8811999-03-31031 March 1999 Responds to NRC 990301 Ltr Re Violations Noted in Insp Rept 50-400/98-11.Corrective Actions:Post Trip/Safeguards Actuation Rept for 981023,RT Was Corrected,Required Reviews Completed & Approval Obtained on 990219 ML18016A8671999-03-19019 March 1999 Submits Response to RAI Re Spent Fuel Pool Water Level & Revised Fuel Handling Accident Analyses,Per 990317 Telcon with NRC ML18016A8631999-03-19019 March 1999 Forwards Shnpp Operator Training Simulator,Simulator Certification Quadrennial Rept, IAW 10CFR55.45(b)(5)(ii). NRC Form 474 & Required Info Re Simulator Performance Test Results & Schedules Also Encl ML18016A8691999-03-18018 March 1999 Forwards Resolution Adopted by Lee County,North Carolina Board of Commissioners Re Proposed Expansion of high-level Radioactive Waste Storage Facilities at Carolina Power & Light Shearon Harris Nuclear Power Plant ML18016A8511999-03-15015 March 1999 Forwards Proprietary & non-proprietary Version of Rev 3 to HI-971760, Licensing Rept for Expanding Storage Capacity in Harris SFPs 'C' & 'D'. Repts Are Reissued to Reflect Reduction in Proprietary Info.Proprietary Info Withheld ML18016A8601999-03-15015 March 1999 Informs NRC of Mod to Commitment for Hnp,Re Comprehensive Review of Implementation of TS Sr.Upon Completion of Listed Reviews,Surveillance Procedure Review Project Will Be Considered Complete 1999-09-08
[Table view] Category:PUBLIC ENTITY/CITIZEN/ORGANIZATION/MEDIA TO NRC
MONTHYEARML20238B7731987-08-0707 August 1987 FOIA Request for Records Explaining Status of Listed LERs Omitted from List,Previously Received from Nrc,Of LERs Filed by Commercial Nuclear Power Plant Licensees for Operating Year 1986 ML18004B7691987-03-11011 March 1987 Requests Guidance Re Acquisition of Current & Accurate Info Re Local Nuclear Power Plant for Distribution to Public by Proposed Committee.W/O Stated Attachments ML18004B6931987-01-11011 January 1987 Requests That Util Request for Exemption from Requirement Under 10CFR50,App E Be Denied.Util Should Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr Before Beginning Commercial Operation of Plant ML18004B6751987-01-0606 January 1987 Protests Granting of Full Power OL Based on Stunted Growth of State of Nc Economy.Continuance of Tradition That Made Country Grow W/Bright Future Recommended.Public Util Monopoly Should Not Be Allowed ML20212M7931987-01-0606 January 1987 FOIA Request for Documents Re Util Request for Exemption from Requirement to Hold Emergency Drill 1 Yr Prior to Operation Above 5% Capacity,Including SECY-86-352 & Hearing Request on Util Petition Re Drill Requirements ML18004B6741987-01-0505 January 1987 Urges Delay in Facility Full Operation Until Investigation & Resolution of Safety Problems,Complete Emergency & Evacuation Plan Drills & Test at Low Level Operation ML20207L1141987-01-0505 January 1987 Opposes Proceeding W/Licensing Proceedings for Facility on 870108.Granting of Exemption from Required Full Scale Exercise of Emergency Response Plan Seen as Possible Violation of NRC Regulations ML18004B6631987-01-0505 January 1987 Advises That Safety Violations & Const Defects at Plant Should Be Thoroughly Investigated & Completely Corrected Before Granting Util Full Power License.Emergency Evacuation Plan Needs to Be Tested Prior to Licensing ML20207P7151987-01-0404 January 1987 Forwards Summary of Remarks on Behalf of Coalition for Alternatives to Shearon Harris at Hearing Scheduled for 870108 Re Licensing of Plant,Per Request ML20207P7241987-01-0404 January 1987 Summary of Remarks on Behalf of Coalition for Alternatives to Shearon Harris at Hearing Scheduled for 870108 Re Full Power Licensing of Plant.Opposes Issuance of Full Power License Due to Unresolved Issues Before NRC ML18004B6601987-01-0202 January 1987 Expresses Appreciation & Urges Continued Effort to Ensure Safety of Residents by Requiring Util to Abide by All Federal Regulations.Util Should Complete Successful Testing of Plant Before License Granted ML18004B6571986-12-31031 December 1986 Requests Denial of Util Request for Exemption from Requirements of 10CFR50,App E Re Full Participation Exercise of Emergency Response Plan.Exercise Should Be Conducted Before Plant Permitted to Operate ML18004B6451986-12-15015 December 1986 Urges Denial of Util Request for Exemption from Requirement of 10CFR50,App E to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation. Concern Also Expressed Re Full Power OL Hearing on 870108 ML20211L5621986-12-0909 December 1986 Urges Commission to Postpone 861218 Meeting Re Full Power License for Facility Until All Safety Issues Resolved & Low Power License Testing Fully & Satisfactorily Concluded ML20215E7891986-12-0505 December 1986 FOIA Request for Documents Re Hearing Scheduled on 861218 Re Issuance of Full Power Ol,Issues to Be Resolved Before Issuing License & All Info Presented to Commission Since 860601 on License ML18004B5931986-11-12012 November 1986 Package of Two Comments Urging Denial of Util Request for Exemption from 10CFR50,App E Requirements Re Conduct of Full Participation Exercise of Emergency Response Plan 1 Yr Prior to Commercial Operation ML18004B5841986-11-12012 November 1986 Package of Two Comments Urging Denial of Util Request for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr Before Commercial Operation ML18004B5831986-11-12012 November 1986 Urges Denial of Util Request for Exemption from Requirements of 10CFR50,App E Re Conduct of Emergency Response Plan 1 Yr Prior to Commercial Operation ML18004B6001986-11-11011 November 1986 Requests NRC Look at Problems Cited in 861017 2.206 Petition Re Insp of Placements of Alleged Violations ML20214Q1271986-11-0303 November 1986 FOIA Request for Records Re Investigation of Allegations, Complaints or Arguments Presented to Nrc,Nrr or Inspector Auditor by P Mirriello ML18004B5751986-11-0101 November 1986 Urges Denial of Util Request for Exemption from 10CFR50, App E Requirement to Conduct Full Participation Exercise of Emergency Response Plan 1 Yr Prior to Commercial Operation. Exercise Should Be Conducted Prior to Any Plant Operation ML18004B5741986-10-31031 October 1986 Urges Denial of Util Request for Exemption from Requirement Under 10CFR50,App E That Full Participation Exercise of Emergency Response Plan Be Conducted for Plant within 1 Yr Prior to Commercial Operation ML18004B5591986-10-30030 October 1986 Package of 11 Comments Urging Denial of Util Request for Exemption from Requirements for Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation or Before Operation at More than 5% Power ML18004B5701986-10-28028 October 1986 Urges Denial of Util Request for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr Before Beginning Commercial Operation ML18004B5581986-10-27027 October 1986 Urges Denial of Util Request for Exemption from Requirement of 10CFR50,App E That Util Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr Before Beginning Commercial Operation of Plant ML18004B5711986-10-27027 October 1986 Urges Denial of Util Request for Exemption from 10CFR50, App E Requirement to Conduct Full Participation Exercise of Plant Emergency Response Plan within 1 Yr Prior to Commencement of Commercial Operation ML18004B5431986-10-27027 October 1986 Urges Denial of Util Request for Exemption from Requirement for Conduct of Full Participation Exercise of Emergency Response Plan within 1 Yr Before Beginning Commercial Plant Operation,Per 10CFR50,App E ML18004B5621986-10-25025 October 1986 Urges Denial of Util Request for Exemption from Requirements of 10CFR50,App E to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation ML18004B5561986-10-23023 October 1986 Requests Denial of Licensee Request for Exemption from Conducting Full Participation Emergency Exercise.Concerns Re Safety Issues Also Expressed.Utils Irresponsible & Negligent to mind-boggling Degrees ML18004B5611986-10-23023 October 1986 Package of Three Postcards Urging Denial of Util Request for Exemption from Requirement of 10CFR50,App E to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation ML18004B5291986-10-21021 October 1986 Urges Denial of Util Request for Exemption from 10CFR50, App E Requirement for Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation or Before Operating at Greater than 5% Rated Power ML18004B5211986-10-20020 October 1986 Urges Denial of Util Request for Exemption from 10CFR50, App E Requirement of Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation or Before Operating at Greater than 5% of Rated Power ML18004A5841986-10-16016 October 1986 Package of Three Citizen Comments Urging Denial of Util Request for Exemption from 10CFR50 App E Requirement for Conduct of Full Participation Exercise of Emergency Response Plan for Plant within 1 Yr Before Operation Above 5% Power ML18004A5971986-10-15015 October 1986 Urges Denial of Util Request for Exemption from 10CFR50, App E Requirement for Full Participation Exercise of Emergency Response Plan within 1 Yr of Beginning Commercial Operation.Evacuation Plan Changes Needed ML18004B5181986-10-15015 October 1986 Urges Denial of Util Request for Exemption from 10CFR50,App E Requirement for Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation or Before Operating at Greater than 5% Rated Power ML20214Q2791986-10-15015 October 1986 FOIA Request for Nine Categories of Documents Re Physical Independence of Electrical Cables at Facility.Info Requested Will Be Provided to Petitioners Before NRC on Ref Application for Amend to License ML18004A5981986-10-14014 October 1986 Opposes Util Request for Exemption from Emergency Preparedness Exercise Requirements of 10CFR50,App E to Conduct Full Participation Exercise within 1 Yr Prior to Beginning Commercial Operation ML18004A5901986-10-10010 October 1986 Package of 29 Postcards Urging NRC to Deny Util Request for Exemption from 10CFR50,App E Requirement Re Full Participation Exercise of Emergency Response Plan Prior to Commercial Operation of Plant ML18004A5891986-10-0909 October 1986 Urges Denial of Util Request for Exemption from Requirement Under 10CFR50,App E That Full Participation Exercise of Emergency Response Plan Be Conducted for Plant within 1 Yr Prior to Commercial Operation ML18004A5821986-10-0808 October 1986 Urges Denial of Util Request for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr Before Commercial Operation ML18022A4371986-10-0707 October 1986 Package of Three Postcards Urging NRC to Deny Util Request for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr Prior to Start of Commercial Operation ML18022A4391986-10-0101 October 1986 Urges NRC Denial of Util Request for Exemption from Requirements of full-scale Drill of Evacuation Plan. Full-scale Drill Needed to Resolve Deficiencies in 1985 Exercise & to Address Util & Counties Rev to Plan ML18004A5731986-10-0101 October 1986 Package of Three Comments Urging Denial of Util Request for Exemption from Requirement Under 10CFR50,App E That Full Participation Exercise of Emergency Response Plan Be Conducted within 1 Yr Prior to Commercial Operation ML18116A0691986-09-30030 September 1986 Urges Denial of Util Request for Exemption from Requirement Under 10CFR50,App E That Full Participation Exercise of Emergency Response Plan Be Conducted for Plant within 1 Yr Prior to Commercial Operation ML18004A5751986-09-27027 September 1986 Urges Denial of Util Request for Exemption from Requirement Under 10CFR50,App E That Full Participation Exercise of Emergency Response Plan Be Conducted for Plant within 1 Yr Prior to Commercial Operation ML18004A5521986-09-27027 September 1986 Urges Denial of Util Request for Exemption from full-scale Drill of Evacuation Plan.Problems W/May 1985 Drill Underline Need for Addl Drill ML18004A5511986-09-27027 September 1986 Package of Two Comments Urging Denial of Util Request for Exemption from Requirements of 10CFR50,App E to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr of Commercial Operation ML18004A5661986-09-27027 September 1986 Urges Denial of Util Request for Exemption from 10CFR50,App E Requirement to Conduct Full Participation Exercise of Emergency Response Plan within 1 Yr of Beginning Commercial Operation Greater than 5% of Rated Power ML18004A5531986-09-25025 September 1986 Urges Denial of Util Request for Exemption from full-scale Drill of Evacuation Plan.Problems W/May 1985 Drill Underline Need for Addl Drill ML18022A4291986-09-23023 September 1986 Package of Five Comments Urging Denial of Util Request for Exemption from 10CFR50,App E Requirements Re Emergency Response Plan Full Participation Exercise within 1 Yr Prior to Commercial Operation of Plant 1987-08-07
[Table view] |
Text
REGULATORY FORMATION DISTRIBUTION S EM (RIDS)
ACCESSION NBR: 8604080127 DOC. DATE: 86/04/03 NOTARIZED: NO DOCKET 0 FAC IL'0-400 Shearon Harris Nuclear Power Planti Unit ii Carolina 0500040Q AUTH. NAME AUTHOR AFFILIATION EDDLEMAN> M. l Ed d emani M.
RECIP. NAME RECIPIENT AFFILIATION DENTONi H. R. Office of Nuclear Reactor Regulationi Director (post 851125
SUBJECT:
Responds opposing util 860304 request for exemption for emergency preparedness exercise requirements of 10CFR50i App E to,conduct full participation exercise within gr 1 prior to issuance of OL.
DISTRIBUTION CODE:
TITLE:
YOOED Distribution for Atypical COPIES RECEIVED: LTR 50 Dkt Matel
~
ial ENCL 0 EIIE:
NOTES: Application for permit renewal f iled. ~ 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PNR-A ADTS Pl4R-A PD2 LA 08 PD2 PD Q7 09'NR-A BUCKLEY'S B 01 DENTONz H. R. 06 INTERNAL: ELD/HDS1 16 FIL 04 RGN2 /MIB 17 EXTERNAL: 24X LPDR 03 NRC PDR 02 NSIC 05 TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL
3ZIB TjlldIRIDZH 38ANX3QGD QI R~> A.l 'HC~f 6-AWR kV Ca g~'3 )ADlfQ
tlat s Eddleman 81 Yancey St.
Durham, NC 27701-3152 3 'V.1986 Ph (919) 688-0076 Harold R. Denton Director Office of= Nuclear Reactor Regulation USNRC Mhshington DC 20555
Dear Harold. Denton,
This is in reference Co Carolina Power L Light's letter to you of g March, 1986, Serial NLS-86-053, requesting an exemption from the emergency preparedness exercise requirements of lo C.F.R. 50, Appendix E,Section IV.F.l to c onduct a full-participation emergency preparedness exercise within one year prior to issuance of the first 6psratinag.
License for full power and. prior to operation above 5 percent of rated power, for the Shearon Harris Nuclear Power Plant ("HArris" or SHNPP).
First, the delay in operation of Harris is entirely due to CPKLIs action in delaving the plant, which evidently stemmed from too-ophimisticm scheduling and inability Co comply with NRC requirements in a timely manner. CP8cL cannot claim that anything but their own failures and.
errors caused the delay.
Second, granting this exemption would violate my, and the general public Is, right to a hearing under section 189(a) of'he Atomic Energy Act, Q2 USC 2239(a), which provides "'...in an proceeding under this chapter for the granting, suspending, revok ng or amending of any license ... and in ~an proceeding for the issuance or modification of rules and regulations dealing with the activities of licensees the Commission shall grant a hearing upon the request of any person whose intezest may Se affected by the pzoceeding and shall admit any such person as a party to the proceeding." Since this exemption request is outside the licensing hearing procedures of the NRC, I hereby petition to intervene in this matter, which is effectively an amendment to the operating license application by request to remove a requirement of the NRC. The regulations governing the timing of full participation tests of emergency response plans are in place, and Applicants (CPSL for SHNPP) should not be allowed to change Che regulations by this end-run, which is illegal as a way to avoid a hearing. My interest is that I both live and work withe@ 30 miles of SHNPP and spend time in the EPZ while conducting my energy and environ-a mental consulting work as well; these interests are more fully set forth Pl<A ) in my petition to intervene in the Harris OL proceeding, Dkt 50-Jj00, IOO
<O Feb. 1982, which is incorporated by reference hereing to establish
)~ID my meeting the requirements to intervene under 10 CFR part 2, e.g. 2.71$ .
My interest in the proceeding ih to rebut Che false or misleading-Gl&
assertions of CPS' with regard Co this license amendment by request for exemption, and to protect the public health and safety, including OA IXI% my own and Chat of others dear to me. I assert further that the NRC has no right to grant this exemption on any economic ground since the OK Atomic Energy Act under thich the NRG apex'ates x squires NRC'o put pp IXIO L. health and safety first, and 5o author%sation is in Chat act fo r exemptions on grounds of cost. I Moreover, FEME has not zhaekeNmxnnR formall evaluated the corrections or corrective actions proposed for problems identified during the 1985 emergency planning exercise at SHNPP. FEMA officials have stated they could not evaluate the implementation of proposed corrective actI.ions uhtil the next full-participation exercise (5<<87) (2-11-86 conference call in NRC Dkt. 50-400; see Hells Eddleman~s Response to Summary Msposition on Contentions EPX-2 and 8, 2-18-86 at pp 2'-37. Besides, there is no NRC
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0 finding that the Plans are adequate, a ~
and none can be made without fi.ndings which cannot be made without another 'full>>participation FEME.
exerci,se. (But even if NHC~s ASLB approves the plan, the arguments In Che first sentence of this paragraph, last page, remai.n valid and X stand on them).
CP8:L~s claimed '")ustification" for this exemption is specious or wrong in its aspect also. First, issuance of an operating license (10 CFH 50.57) is premised on complIance with the regulatIons. So by avoiding compliance with a regulation, that's a substantial amendment Co the operating license. Moreover, the request doep~ot meet part (a) of 10 CFR 50.12 >>- the requirement Chat there be noM~ azard. Xt doesn't say small hazard or minimal hazard, it says ("'No"~~Qq.zard. There's a hazard in 2 senses, first that FIRMA has not evalua%ecC formally the "fixes"'f deficiencies found by FEMA and others (including State of NC evaluatorsII during the past exercise, and second, there Is no assurance the respond is maintained, for nuclear emergencies, beyond one year, ability'o The rule so premises, I.e. that Che length of time for which 1C can be assumed, that the exercise remains amQ.Id measure of emergency response f'r nuclear accidents is at most one year.
it is still /~~~a 1"~kgg Moreover, CP8cg admits working on<3 improvement item'b "with Che goal of having them ready for NHC inspection'n t'une 1986".
The NRC's mandate in the atomi.c energy act Co put safety first means Chat CP8cL cannot claim any hazard is a "due" hazard (as distinct from the '"undue hazard" of 10 CFR 50.12(a));
NRC may not base its decision on activities CP8cL and others vill propose Co undertake (Exemption request p.2) either, because those Eave not happen'ed and vannot be assumed Co be successful. For example, 'in CP8cL's training of teachers, it was reqported that CP8cL represeritatives told Wake County teachers they would never have Co Implemerit the emergency plan (I.e. Chat no accident Chat serious would happen, appears to be the Chrust of the reported remakzrks). Moreover, only the "completed portions" of emergency plan training were found adequate by NRC. Xf training is not complete, how can the personnel be nuclear emergency?????
ready'or a
Radiological workshops (Exemption request, page 3) are also not evidently complete, so there is still a lack of training.
As noted above, the corrective actions by the State (CP8cL buries them in the end of'he last paragraph on part b of page 3 of their exemption request) cannot be formally reviewed. and evaluated by FEMA f'r effectiveness unt11 the next full-participation test.
Much of the training i.n part (c) on page 3 has also not taken place.
The planned exercises of Lee County and. CP8cL (bottom of page g) have also not yet taken place, apparently, and (or for CPLL drills, if It i.s not clear how many, any) offsite emergency response personnel will particip'ate. The drills in parts,(h) and (I), p.5, seem non-nuclear.
Hardship or costs: CP8cL assumes the public interest is reducIng theIr costs, but the increased cost is due to CP8cL~s own error in scheduling tpe origirial full-participation exercise and bei.ng unable to complete their nuclear plant in time Moreover, the dollar costs mentioned are riot that large, and NHC may not put costs above saf'ety even if were much larger (the costs not being large compared Co the cost of n'uclear the costs delays created by CP8cL, f'r example, which probably run over $ 500,000 a day). The relI8f requested Is NOT temporary (criterion (v), p.6) since the requirement only occurs prior to licensing. The exemption is there-
.fore permanent unless CP8cL flubs INC again and has to have a 3d exercise.
Criterion (Ui) p.7 is'P8cL~s si.lliest argument, X think. Xf'he.
second exercIse reveals new flaws, that Isn't redundant at all, and is it litigable under UCS v. NHC. Xf reveals the. same or similar flaws, It peag'gre~tivg s up ca ive 'ut action failed and this is also litigable, -"-'n'ot because because the dor rection failed. UCS v.'RC requires aws ound in the exerci e, and CP8cL must not avo~<d +>his requirement via "exemption" p/w Q~cu+5'~ ~~~
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Wells Zddleman 812 Yancey St.
Durham NC 27701-3152 xc: -NRC Docketing and Service, 3x Richard E.'ones, VP h head of legal dept, CPSL Box 1551 Raleigh NC 27602 Tom Baxter, counsel for CPKL Shaw, Pittman Potts 5 Trowbridge 1800 M St Kf X Washingtoh DC'0036
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