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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20212J9991999-10-0101 October 1999 Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected ML20212L1831999-10-0101 October 1999 Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health ML20212L2081999-10-0101 October 1999 Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance ML20212L2171999-10-0101 October 1999 Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island ML20212L1971999-10-0101 October 1999 Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety ML20212K1241999-10-0101 October 1999 Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected ML20112E8911996-05-24024 May 1996 FOIA Request to Inspect & Copy Original OL Issued by Aec/Nrc for Util & EPP Issued as App B to Plant OL SNRC-2192, Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank1995-05-15015 May 1995 Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank ML20082B9131995-03-13013 March 1995 Submits Corrected Page for Insertion Into Final Rept Re Confirmatory Survey of RB & Phase 4 Systems at Plant ML20081A9321995-03-0707 March 1995 Forwards Final Rept Orise 95/B-81, Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A6531995-03-0707 March 1995 Forwards Final Rept Orise 95/B-80, Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081A6841995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Radwaste Bldg, Suppression Pool,Phase 2 & Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081B5801995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A7001995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 & Phase 3 Sys, Shoreham Nuclear Power Station,Brookhaven,Ny ML20081A7111995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys,Shoreham Nuclear Power Station, Brookhaven,Ny SNRC-2189, Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 19941995-01-20020 January 1995 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 1994 SNRC-2188, Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey1995-01-20020 January 1995 Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey SNRC-2187, Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring1995-01-11011 January 1995 Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring SNRC-2182, Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning1994-11-0101 November 1994 Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning ML20077L3331994-10-25025 October 1994 Forwards Revised Proposed Confirmatory Survey Plan for Reactor Bldg Shoreham Nuclear Power Station Brookhaven,Ny ML20076K3881994-10-20020 October 1994 Forwards Proposed Confirmatory Survey Plan for Reactor Bldg, Shoreham Nuclear Power Station,Brookhaven,Ny,For Review & Comment ML20077M8351994-10-20020 October 1994 Forwards Draft Rept, Confirmatory Survey of Radwaste Bldg, Suppression Pool & Phase 2 Systems,Shoreham Nuclear Power Station,Brookhaven,Ny SNRC-2184, Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld1994-10-12012 October 1994 Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld SNRC-2185, Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-10-0404 October 1994 Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl ML20076F9251994-09-26026 September 1994 Forwards Final Rept Orise 94/I-80, Confirmatory Survey of Turbine Bldg,Site Grounds & Site Exteriors Shoreham Nuclear Power Station Brookhaven,Ny SNRC-2183, Forwards Amend 6 to Indemnity Agreement B-871994-09-23023 September 1994 Forwards Amend 6 to Indemnity Agreement B-87 SNRC-2181, Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 11994-09-14014 September 1994 Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 1 SNRC-2180, Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-021994-09-0101 September 1994 Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-02 SNRC-2179, Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-09-0101 September 1994 Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl SNRC-2178, Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4))1994-08-17017 August 1994 Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4)) ML20072P1591994-08-17017 August 1994 Forwards Revised, Confirmatory Survey Plan for Radwaste Bldg & Suppression Pool for Plant SNRC-2176, Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-821994-08-0404 August 1994 Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-82 SNRC-2177, Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld1994-08-0404 August 1994 Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld ML20071L8741994-07-29029 July 1994 Forwards Confirmatory Survey Plan for Radwaste Building & Suppression Pool for Review & Comment SNRC-2175, Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively1994-07-18018 July 1994 Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively SNRC-2173, Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790)1994-06-14014 June 1994 Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790) SNRC-2172, Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-821994-06-0707 June 1994 Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-82 SNRC-2171, Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel1994-06-0202 June 1994 Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel SNRC-2170, Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan1994-05-20020 May 1994 Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan SNRC-2168, Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc1994-05-13013 May 1994 Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc SNRC-2169, Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project1994-05-11011 May 1994 Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project ML20029E1731994-05-11011 May 1994 Informs That Based on Recent Discussions Between Officials, Licensee Decided to Retain Organizational Position at Least Until Fuel Removed from Site ML20029D1991994-04-29029 April 1994 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program Annual Radiological Environ Operating Rept Jan-Dec 1993. ML20029D2571994-04-28028 April 1994 Advises That Jc Brons Resigned to Pursue Employment W/ Another Util Co,Effective 940429 ML20029C7111994-04-22022 April 1994 Submits Technical Info on Biological Shield Wall Blocks to Be Surveyed SNRC-2163, Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util1994-04-21021 April 1994 Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util ML20065M3701994-04-20020 April 1994 Responds to NRC Verbal Request for Info Re Estimated Cost for Decommissioning SNRC-2161, Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station1994-03-30030 March 1994 Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station SNRC-2160, Forwards Financial Info Required by 10CFR50.71(b)1994-03-30030 March 1994 Forwards Financial Info Required by 10CFR50.71(b) SNRC-2148, Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases1994-03-0808 March 1994 Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases 1999-10-01
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20112E8911996-05-24024 May 1996 FOIA Request to Inspect & Copy Original OL Issued by Aec/Nrc for Util & EPP Issued as App B to Plant OL SNRC-2192, Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank1995-05-15015 May 1995 Forwards Both Copies,Signed by Util President Cv Giacomazzo, of Amend 7 to Indemnity Agreement B-87.Util Returning Copies Because Effective Date Left Blank ML20082B9131995-03-13013 March 1995 Submits Corrected Page for Insertion Into Final Rept Re Confirmatory Survey of RB & Phase 4 Systems at Plant ML20081A9321995-03-0707 March 1995 Forwards Final Rept Orise 95/B-81, Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A6531995-03-0707 March 1995 Forwards Final Rept Orise 95/B-80, Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081B5801995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys Shoreham Nuclear Power Station Brookhaven,Ny ML20081A6841995-02-21021 February 1995 Forwards Final Rept Confirmatory Survey of Radwaste Bldg, Suppression Pool,Phase 2 & Phase 3 Sys,Shoreham Nuclear Power Station,Brookhaven,Ny ML20081A7111995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Reactor Bldg & Phase 4 Sys,Shoreham Nuclear Power Station, Brookhaven,Ny ML20081A7001995-01-30030 January 1995 Forwards Rev 1 to Draft Rept Confirmatory Survey of Radwaste Bldg,Suppression Pool,Phase 2 & Phase 3 Sys, Shoreham Nuclear Power Station,Brookhaven,Ny SNRC-2188, Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey1995-01-20020 January 1995 Responds to NRC Request for Addl Info Re Certain Elevated Levels Found During Phase 4 Confirmatory Survey SNRC-2189, Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 19941995-01-20020 January 1995 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program,Annual Radiological Environ Operating Rept, Jan-June 1994 SNRC-2187, Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring1995-01-11011 January 1995 Forwards Snps Annual Man-Rem Rept, Including Individuals for Whom Personnel Monitoring Provided During CY94,per 10CFR20.407(a) & (B).Rept Also Includes Individuals Identified in 10CFR20.202(a),who Require Monioring SNRC-2182, Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning1994-11-0101 November 1994 Forwards Final Annual Radioactive Effluent Release Rept for Cy 1994, Including Last Revised Copies of ODCM & Pcp.Rept Prepared for Closeout Purposes as Part of Completion of Plant Decommissioning ML20077L3331994-10-25025 October 1994 Forwards Revised Proposed Confirmatory Survey Plan for Reactor Bldg Shoreham Nuclear Power Station Brookhaven,Ny ML20077M8351994-10-20020 October 1994 Forwards Draft Rept, Confirmatory Survey of Radwaste Bldg, Suppression Pool & Phase 2 Systems,Shoreham Nuclear Power Station,Brookhaven,Ny ML20076K3881994-10-20020 October 1994 Forwards Proposed Confirmatory Survey Plan for Reactor Bldg, Shoreham Nuclear Power Station,Brookhaven,Ny,For Review & Comment SNRC-2184, Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld1994-10-12012 October 1994 Forwards Shoreham Decommissioning Project Termination Survey Final Rept Phase 4. Portions Withheld SNRC-2185, Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-10-0404 October 1994 Summarizes Results from Revised Exposure Pathway Analysis Using Corrected Dcf for External Exposure for Cs-137.Rev 1 to Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl ML20076F9251994-09-26026 September 1994 Forwards Final Rept Orise 94/I-80, Confirmatory Survey of Turbine Bldg,Site Grounds & Site Exteriors Shoreham Nuclear Power Station Brookhaven,Ny SNRC-2183, Forwards Amend 6 to Indemnity Agreement B-871994-09-23023 September 1994 Forwards Amend 6 to Indemnity Agreement B-87 SNRC-2181, Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 11994-09-14014 September 1994 Notifies of Equipment Changes to Shoreham Facility Which Have Occurred Subsequent to Rept on Phase I Final Survey Status,Provided in Util .Equipment Changes Described in Encl Table 1 SNRC-2180, Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-021994-09-0101 September 1994 Forwards 940829 Memo Entitled, Technical Evaluation of Dusting from Concrete Blocks, Addressing Issue Discussed in Insp Rept 50-332/94-02 SNRC-2179, Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl1994-09-0101 September 1994 Proposes That Release Criterion for Soil Be Applied to Certain Other Bulk Matls Which Will Remain at Plant Upon Completion of Decommissioning.Analysis of Bulk Matl Reconcentration Potential & Possible Exposure Pathways Encl ML20072P1591994-08-17017 August 1994 Forwards Revised, Confirmatory Survey Plan for Radwaste Bldg & Suppression Pool for Plant SNRC-2178, Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4))1994-08-17017 August 1994 Forwards Proprietary Response to NRC Concerns Re Survey Instruments Used for Termination Survey.Extensive Discussion Provided in Interest of Rapidly Bringing Outstanding Concerns to Close.Response Withheld (Ref 10CFR2.790(a)(4)) SNRC-2176, Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-821994-08-0404 August 1994 Informs of near-term Completion of Decommissioning of Shoreham Nuclear Power Station & Hereby Respectfully Requests Support in Achieving Timely Termination of Facility possession-only License NPF-82 SNRC-2177, Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld1994-08-0404 August 1994 Forwards Rev 3 to Shoreham Decommissioning Project Termination Survey Plan. Portions of Rept Withheld ML20071L8741994-07-29029 July 1994 Forwards Confirmatory Survey Plan for Radwaste Building & Suppression Pool for Review & Comment SNRC-2175, Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively1994-07-18018 July 1994 Provides Notification of Survey Location Changes to Shoreham Facility Which Have Occurred Subsequent to Repts on Phases 1,2 & 3 Final Survey Status Provided in Refs 1,2 & 3 Respectively SNRC-2173, Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790)1994-06-14014 June 1994 Forwards Termination Survey Final Rept Phase 3. Proprietary Pages to Rept Also Encl.Proprietary Pages Withheld (Ref 10CFR2.790) SNRC-2172, Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-821994-06-0707 June 1994 Certifies That All SNM as Irradiated Fuel Permanently Removed from Site & That Decommissioning/Decontamination Work on Biological Shield Wall Complete,In Accordance W/Nrc Approving Amend 11 to Pol NPF-82 SNRC-2171, Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel1994-06-0202 June 1994 Submits Resolution of Items Identified by NRC Region I Project Inspector,Pertaining to Planned Final Draindown & Discharge of Spent Fuel Storage Pool,Following Complete Removal of Irradiated Fuel SNRC-2170, Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan1994-05-20020 May 1994 Requests Approval of Proposed Change to Shoreham Decommissioning Plan for Addl Remedial Decontamination of Shoreham Spent Fuel Storage Pool Beyond That Originally Specified in Decommissioning Plan SNRC-2168, Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc1994-05-13013 May 1994 Notification to NRC of Transfer of Device Containing 30 Uci Cs-137 Source.Device Transferred to JW Merkel,Terra Analytics,Inc SNRC-2169, Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project1994-05-11011 May 1994 Advises of Listed Clarification to Util Re Resignation of Jc Brons from Position of Executive Vice President of Shoreham Decommissioning Project ML20029E1731994-05-11011 May 1994 Informs That Based on Recent Discussions Between Officials, Licensee Decided to Retain Organizational Position at Least Until Fuel Removed from Site ML20029D1991994-04-29029 April 1994 Forwards Shoreham Nuclear Power Station Radiological Environ Monitoring Program Annual Radiological Environ Operating Rept Jan-Dec 1993. ML20029D2571994-04-28028 April 1994 Advises That Jc Brons Resigned to Pursue Employment W/ Another Util Co,Effective 940429 ML20029C7111994-04-22022 April 1994 Submits Technical Info on Biological Shield Wall Blocks to Be Surveyed SNRC-2163, Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util1994-04-21021 April 1994 Provides Notification of Equipment Changes to Facility Which Have Occurred Subsequent to Report on Phase I Final Survey Status Provided in Util ML20065M3701994-04-20020 April 1994 Responds to NRC Verbal Request for Info Re Estimated Cost for Decommissioning SNRC-2160, Forwards Financial Info Required by 10CFR50.71(b)1994-03-30030 March 1994 Forwards Financial Info Required by 10CFR50.71(b) SNRC-2161, Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station1994-03-30030 March 1994 Forwards 1994 Internal Cash Flow Projection for Shoreham Nuclear Power Station SNRC-2148, Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases1994-03-0808 March 1994 Forwards Info Supporting Licensee Proposed Amend,Submitted on 941104.Specifically,info Supports Estimates & Conclusions Re Small Quantity of Remaining Radioactive Matl & Low Radiological Significance of Potential Accident Releases SNRC-2145, Provides Comments Prepared by Util on Draft NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination1994-03-0808 March 1994 Provides Comments Prepared by Util on Draft NUREG/CR-5849, Manual for Conducting Radiological Surveys in Support of License Termination SNRC-2157, Forwards 1993 Rept of Personnel & Man-Rem by Work & Job Function. 1993 Personnel Exposures Extremely Low as Majority of Radioactivity Removed from Site1994-02-28028 February 1994 Forwards 1993 Rept of Personnel & Man-Rem by Work & Job Function. 1993 Personnel Exposures Extremely Low as Majority of Radioactivity Removed from Site SNRC-2158, Submits Notification of Pending Change to Decommissioning Plan Submitted 901229.Safety Evaluation for Change Encl1994-02-28028 February 1994 Submits Notification of Pending Change to Decommissioning Plan Submitted 901229.Safety Evaluation for Change Encl SNRC-2156, Forwards Annual Radioactive Effluent Release Rept for 1993. Latest Revised Copies of Offsite Dose Calculation Manual & Process Control Program Also Encl as Apps to Rept1994-02-25025 February 1994 Forwards Annual Radioactive Effluent Release Rept for 1993. Latest Revised Copies of Offsite Dose Calculation Manual & Process Control Program Also Encl as Apps to Rept ML20067C9271994-02-22022 February 1994 Forwards Fitness for Duty Program Performance Data for Period of Jul-Dec 1993 SNRC-2144, Forwards Vols 1-4 to Shoreham Decommissioning Project Termination Survey Final Rept. Twenty Proprietary Pages of Rept Withheld (Ref 10CFR2.790)1994-02-0404 February 1994 Forwards Vols 1-4 to Shoreham Decommissioning Project Termination Survey Final Rept. Twenty Proprietary Pages of Rept Withheld (Ref 10CFR2.790) 1996-05-24
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20043B4951990-05-0707 May 1990 Requests Voluntary Suspension of Effectiveness of Prospective NRC Administrative Actions to Modify Util Security Plan to Discontinue Local Offsite Emergency Response Measures,Pending Us Court of Appeals Action ML20044A1021990-05-0303 May 1990 FOIA Request for SECY-89-247 on Proposed Action Re Shoreham & Documents Referred to in SECY-89-247 ML20011D5421989-12-11011 December 1989 Forwards Signature Page of Util 891208 Request for Exemption from Primary Containment Leak Rate Testing Requirements,Per 10CFR50.54(o) & App J,Paragraphs III.D.1 Through III.D.3 ML19353B1041989-12-0808 December 1989 Forwards Request for Exemption from Primary Containment Leak Rate Testing Requirements of 10CFR50.54(o) & App J,III.D.1 Through III.D.3 ML19325D6171989-10-0404 October 1989 Forwards Handwritten Changes Made to Pages 83-86 of 890928 Upper Mgt Conference Between NRC & Long Island Lighting Co ML20247B8111989-09-0808 September 1989 Forwards Util Renewed Request for Exemption from Onsite Property Damage Insurance Requirements of 10CFR50.54(w). WE Steiger Affidavit Also Encl ML20247H9621989-07-21021 July 1989 Requests Immediate Reconsideration of 890720 Preliminary Review of Shoreham-Wading River Central School District 10CFR2.206 Request to Prevent Further Deterioration of Valuable Electric Resource ML20247L3181989-07-19019 July 1989 Suppls Shoreham-Wading River Central School District 890714 Request Re Margin of Safety Provided by Placement of Fuel in Spent Fuel Pool at Facility ML20245G8851989-04-21021 April 1989 FOIA Request for Records Re Decommissioning of Facility, Decommissioning of Nuclear Power Plants in General & 890413 Testimony of DOE Opposition to Decommissioning of Plant Before Senate Committee on Energy & Natural Resources ML20245D3421989-03-20020 March 1989 Forwards Listed Endorsements,Including Endorsements 14,163, 144,94,75,39 & 31 to Nelia Policies NF-295,NF-100,MAELU Policy MF-29,NELIA Policy NF-182,MAELU Policy MF-61,NELIA Policy NF-281 & Maelu Policy MF-112,respectively ML20247N5371989-03-0202 March 1989 FOIA Request for Records Re Emergency Plan Dtd Sept 1988 or Later ML20246P1331989-02-21021 February 1989 Urges That 100% License Be Issued for Plant.Long Island Has Vital & Current Need for Addl Electrical Need Which Only Plant Can Satisfy.Economy of Long Island in Serious Jeopardy Unless License for Plant Promtly Issued ML20196F6551988-12-0202 December 1988 Forwards Corrected Cover Page to Lilco Answer to Intervenors Brief on School Bus Driver Role Conflict & Emergency Broadcast Sys, ML20195K0001988-11-17017 November 1988 FOIA Request for Records Re 881109 Decision to Certify to Commission Appeal of OL-3 Decision to Dismiss Govts in Licensing Proceeding ML20154P9791988-09-27027 September 1988 Advises That Listed Individuals Representing Suffolk County, State of Ny & Town of Southampton Should Remain on All Svc Lists & Continue to Receive Correspondence Re Plant.Svc List Encl ML20151C5151988-07-18018 July 1988 Advises That Witnesses Will Have to Appear in Order of F Jones,Regan Sheppard & Davidoff at Hearing Tomorrow Due to Presence of Sheppard ML20150A9621988-07-0505 July 1988 Forwards Endorsements 30 & 21 to Nelia Policy NF-269 & Maelu Policy MF-115,respectively ML20153H3361988-06-23023 June 1988 Appeals Denial of FOIA Request for Documents Re Plant. Requests That NRC Response Be as Detailed as Possible in Order to Better Enable Client to Determine Need for Further Legal Action ML20151C7141988-05-23023 May 1988 FOIA Request for Documents Re FEMA Graded Exercise on Adequacy of Radiological Emergency Response Planning & Preparedness for Plant & Rev 9 to Licensee Emergency Plan for Plant Including FEMA Review of Subj Plan ML20154H7101988-05-17017 May 1988 Forwards Emergency Planning Contentions Re 860213 Exercise, Inadvertently Omitted from Govt Brief in Response to NRC Staff Brief Supporting Lilco Appeal from LBP-88-2 ML20154B5851988-05-10010 May 1988 Clarifies Matter on Hearing Schedule Issue & Forwards Three Ltrs Bearing on Parties Scheduling Efforts.Matters Will Be Addressed During Conference ML20154B4771988-05-0606 May 1988 Corrects Error Noted in Util Suppl to Lilco Response to Govts 880413 Objection & Motion in Alternative to Compel Discovery. Changes Listed ML20151P0711988-04-20020 April 1988 Discusses Board 880413 Memorandum & Order (Ruling on Govts Motion for Reconsideration of Board Memorandum & Order on Section 50.47(c)(1)(i)(ii) Compliance).Govts Neither Seek Further Reconsideration Nor Agree W/Views Expressed ML20148K1111988-03-22022 March 1988 Forwards Listed Endorsements to Listed Policies,Including Endorsement 102 to Maelu Policy MF-26,Endorsement 123 to Nelia Policy NF-76,Endorsement 71 to Maelu Policy MF-56 & Endorsement 89 to Nelia Policy NF-189 ML20153H4101988-03-16016 March 1988 Confirms Content of 880303 Telcon Re Numbered Paragraph 2 of FOIA Request 88-63.Paragraph Clarified to Read as Stated. NRC Response to Request Due on 880317.Task Action Plan for Evaluation of Request to Operate Plant at 25% Power Encl ML20149K9101988-02-19019 February 1988 Comments on Util Motion for Discovery Cutoff & for Summary Termination of Witness Designations & Ltr from Util Attys Re New York Court of Appeals Decision in Cuomo Vs Lilco. Suffolk County Disagrees W/Allegations Re Purposeful Delay ML20149F1961988-02-0505 February 1988 Ack Receipt of ASLB 880201 Memorandum & Order (Ruling on Applicant Motion of 871208 for Summary Disposition of Hosp Evacuation Issue).Aslb Must Follow Rules to Avoid Waste of Resources Caused by Action.Certificate of Svc Encl ML20151D6591988-01-27027 January 1988 FOIA Request for All Records Including Preparatory Matls & Contemporaneous Notes & Info Submitted by Util Re 880114 Meeting Involving NRC & Util Concerning Facility ML20149F1741988-01-22022 January 1988 Discusses Concerns Re NRC 880114 Secret Meeting W/Util in Which NRC Refuses to Prepare Written Summary Describing Discussion of Meeting.Preparation of Complete Record of Meeting Requested ML20148J1361988-01-20020 January 1988 Advises That Affidavits of Fr Jones,Gj Blass,Fp Petrone & Fg Palomino Filed on 880119 W/Suffolk County,State of Ny & Town of Southampton Response in Opposition to Lilco Motion. Encl Original Signature Pages Being Filed Today ML20147B9731988-01-12012 January 1988 Forwards Emergency Planning Contention Re Lilcos New Emergency Broadcast Sys Proposal.Three Comments on Contention Listed ML20234B9791987-12-30030 December 1987 Requests That Util 871218 Request for Full Participation Exercise Be Denied.Request Grossly Premature Since Many Inadequacies in Rev 8 to Plan Remain & Upcoming Rev 9 to Plan Requires Thorough Rac Review ML20238D0891987-12-29029 December 1987 Requests Verbatim Transcript Be Kept of All Conference Calls Re Hearing Argument & Reaching Expedited Decision on Govts Motion ML20238D0721987-12-28028 December 1987 Opposes Motion for Extension of Time to Respond to Lilco Seven Realism Summary Disposition Motions.Requests Opportunity to Provide Views Prior to ASLB Final Ruling on Govt Extension Motion ML20237E5391987-12-18018 December 1987 Forwards Motions for Summary Disposition of Legal Authority Issues & Contentions EP 1-2 & 4-10.Certificate of Svc Encl ML20236F0071987-10-27027 October 1987 Advises That Commission Actions Have Fouled Emergency Planning Rulemaking & Requests That Commission Either Reject & Disregard Ltrs by Members of Congress or Commence Fresh Rulemaking & Afford Public Opportunity to Comment ML20235Y4291987-10-15015 October 1987 Requests That Studies Relied Upon in Proposed Rule Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Participate in Offsite Emergency Planning Be Published & That Comment Period Be Reopened ML20235X5841987-10-0707 October 1987 Notifies of Minor Typo in Govt Opposition to Lilco Motion for Certification to Commission,Served on Board & Parties on 871001.Word Not Should Be Deleted from Line Next to Last Line of Page 5 of Opposition ML20214U7081987-06-0202 June 1987 Forwards Endorsements 25 & 16 to Nelia Policy NF-269 & Maelu Policy MF-115,respectively ML20245B8191987-05-29029 May 1987 FOIA Request for Documents Re Util Application for & NRC Denial of License for Low Power Testing,Emergency Backup Power Source & Use of Transamerica Delaval Generators at Any Other Nuclear Facility Including All Production ML20214N2281987-05-22022 May 1987 Advises That Util 870512 Request That NRC Distribute Util Reply to Intervenor Opposition to Expedited Consideration of 25% Power Request Should Be Rejected Due to Being Unauthorized Pleading Not Permitted by NRC Regulations ML20215M0031987-05-0707 May 1987 Forwards Motion to Limit cross-examination of State of Ny & Suffolk County,Inadvertently Omitted on 870505.W/o Motion. Certificate of Svc Encl ML20206T1851987-04-13013 April 1987 Forwards Transcripts of Direct Testimonies Re Lilco Reception Ctrs & Motion Requesting Board to Reschedule Commencement of Hearing of Reception Ctr Issues Until Ongoing Litigation Completed.Related Correspondence ML20206H2231987-04-0707 April 1987 Forwards Suffolk County,State of Ny & Town of Southampton Motion for Conference of Counsel.Motion Constitutes Interim Response to Util 870320 Summary Disposition Motion on Legal Authority Issues Re Contentions 1-10 ML20205R8341987-04-0202 April 1987 Requests Addl Info Re Lilco Request for Exemption from 10CFR50,App E.Expresses Dissatisfaction at NRC Ignoring Author Ltrs While Replying to Util Ltrs on Same Subj ML20212J5691987-03-0303 March 1987 Responds to Util Seeking to Rationalize Plea That NRC Grant Section 50.12 Exemption from 1 Yr Exercise Requirement.Nrr Does Not Have Jurisdiction to Make Factual Findings Re Exemption Request ML20212D4361987-02-27027 February 1987 Forwards Direct Testimonies of Rc Roberts,Ej Michel,R Dormer,P Mcguire,D Harris,M Mayer & Gc Minor Re 860213 Emergency Plan Exercise.Certificate of Svc Encl.Related Correspondence ML20211E8711987-02-19019 February 1987 Responds to H Brown Re Util 870122 Request for Waiver of 10CFR50,App E Provision Concerning Emergency Planning Exercises.Issuance of Exemption Recommended. Certificate of Svc Encl.Related Correspondence ML20235B2741987-02-19019 February 1987 FOIA Request for Documents Indicated on Encl Docket Sheets. Request Does Not Encompass Matl Already Available in PDR or Lpdr Denoted by Three or Four Asterisks on List ML20210F3341987-02-0606 February 1987 Informs That NRR Lacks Jurisdiction to Consider Lilco Request for Exemption from 10CFR50,App E,Dtd 870122.Filing Must Be Returned to Lilco W/Instructions for Proper Filing Either W/Commission or Presiding Licensing Board 1990-05-07
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\ KIRKPATRICK & LOCKHART 1900 M STREET. N.W.
WASHINGTON, D.C. 200M .' ONE BO!FON PLACE BOSTON, MA 02108 TELEPHONE (202) 4524000 ,
(6171 9755400
, 1428 BRICKELL AVENUE TELECOMER (202) 45240$2 -" ' 14h4L FL 3)llt M
.,(101) 174 4112 February 11, 19*85 r, isa mvER BuitaNo g- rnTsseRcn. PA llM MUERMXRECT DIAL NUMBER ;R f 2 %p 452-7011 , . , _
BY HAND Nunzio J. Palladino, Chairman Commissioner James K. Asselstine Commissioner Frederick M. Bernthal 80C884TNuesta Commissioner Thomas M. Roberts PROC &gmt,pg,*$d. '
Commissioner Lando W. Zech, Jr.
U. S. Nuclear Regulatory Commission 1717 H Street, N. W.
Washington, D. C. 20555 Re: Additional Comments Concerning " Board Notification 85-009 Exemption from General Design Criterion 17 Regarding Low Power Operation of the Shoreham Nuclear Power Station"
Dear Members of the Commission:
Suffolk County submits these additional comments which relate to the significance of Board Notification 85-009. We have been authorized by the Special Counsel to Governor Cuomo to state that the S'; ate of New York agrees with the content of this letter.
There is a critical threshold issue which the Commission must address: the problem concerning the single failure criterion that was raised by the Staff's Board Notification of February 1, 1985, directly contradicts specific findings of the Miller Board and the facts within the evidentiary record of this proceeding.
This new information is clearly material to the safety of Shoreham and to the Miller Board's October 29, 1984 Decision.
The question of compliance with the single failure criterion war a significant factor in the Miller Board's "as safe as" determination.
The evidentiary record in the proceeding is closed.
! Therefore, to consider the new data in the context of LILCO's exemption request pending before the Commission, the Commission would have to reopen the record, either sua sponte or in response to a motion by the Staff or some other party. If the record were reopened, all parties would then have to be given a fair opportunity to confront the new facts, assess these facts, and present their views to the decisionmaker under normal.'
adjudicatory procedures.
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m C KIRKPATRICK & LOCKHART 2.
It is essential to follow such a reopening procedure so that the State and County have the opportunity to gain an understanding of the implications of the " solution" which was l proposed by the Staff and LILCO outside the closed evidentiary record. In short, given the clear relevance of the Board Notification, it would be improper for the Commission to take any action concerning this matter without first assuring that the record is reopened and the rights of the parties are protected.
The County and State also bring the following related points to the NRC's attention:
- 1. Attached hereto is an affidavit prepared by Gregory C.
Minor, a Suf engineering.-{p1kInCounty consultant the short who he time since hasreceived degreesthe in electrical Board Notification, Mr. Minor has reviewed the underlying data which are available and has set forth his preliminary views of the situation. The affidavit demonstrates that the data in the Notification and in LILCO's January 29 letter are significant, thus emphasizing that if the Commission wants to evaluate this matter, either it or LILCO and/or the Staff will have to reopen the record in accordance with 10 C.F.R. Part 2.
- 2. Part of the " solution" proposed by LILCO to the Breaker 460 problem is to utilize the Wildwood substation to reroute power from the 20 MW gas turbine to the emergency 4 KV bus. The Wildwood substation is located about une mile south of the Shoreham plant. LILCO stated as follows:
(E]ven if a fault occurred as postulated in the breaker number 460 it is still possible for the 20 MW gas turbine to supply power to Shoreham. In such an event, the EMD diesels could not be connected to the failed bus 11 and the failure of breaker number 460 would also cause a trip of the RSST protective relays which would trip all 7 RSST 4 KV breakers, the 69 KV switchyard supply breaker 640 and the 20 MW gas turbine breaker. The Plant Operator can open ABS 623 and the 4 KV switch gear breaker 450 thereby isolating bus number 11 and the faulted 4 KV breaker 460. The Plant Operator can then reset the RSST lock out relay 86T4B, thereby allowing the 20 MW gas turbine to start,in a dead line mode. The System Operator, by rearranging system breakers, can reroute power from the gas turbine via the 69 KV system and the 138/69 KV step up transformer.at the Wildwood substation on the Shoreham property to the Shoreham 138 KV A/ An executed version of the affidavit will be submitted shortly. Mr. Minor is attending meetings in Bethesda today and
.thus was unavailable to execute the final copy.
U i o KIRKPATRICK 66 LOCKHART 3.
l i
switchyard. Power is then connected te the emergency 4 KV bus from the normal station service i transformer.
LILCO SNRC-1140, Jan. 29, 1985. In the Notification, the Staff mentions this purported ability. However, there are multiple problems with this portion of the " solution," each of which can only be dealt with properly on the record rather than in the present extra-record context.
l (a) The initiating event which is postulated under the deterministive analyses of the Staff for Shoreham low power
, operation is_a LOOP /LOCA event. In a LOOP /LOCA, there is no basis for the Staff or LILCO to assume that it will be possible to reroute power to the Wildwood substation, located about a mile from the Shoreham plant. Rather, in a loss of offsite power event, it is necessary to assume that it is impossible to use the offsite grid.
(b) Our preliminary assessment is that the rerouting,
. if feasible, will be a complex operation requiring detailed training and procedures. Minor Affidavit, 1 5. Thus, in order to test the adequacy of this proposed solution, it is necessary to assess what, if any, procedures and/or training exist for this rerouting of 20 MW gas turbine power to the emergency busses via Wildwood. Has the Staff reviewed any such training or procedurcs? Has the Commission? How lona will it take? The County and State have a right to test the adequacy of such procedures and training before any reliance is placed on this part of the " solution."
- 3. The other part of the proposed " solution" involves
" racking out" Breaker 460. This is the third or fourth situation that has needed.to be altered due to single failure problems --
~
the first since the record closed. See Minor Affidavit, 1 3.
This, again, raises multiple problems.
(a) The belated discovery of a single failure criterion deficiency' highlights the fact that no systematic analyses of the. potential for such faults has yet been conducted.
This is unacceptable, given the recent revelation that the instant problem was discovered by the Shoreham Project Manager during, presumably, a nontechnical review of the alternate AC power configuration. As set forth'in Mr. Minor's affidavit (1 4), there is a need for systematic failure analysis before anybody considers licensing action.
(b) Concerning Breaker 460 itself, there are many unanswered questions about the " racking down" solutions what procedures have been prepared and training provided to ensure that this new configuration is effectively implemented; can operators alter the " racked out" position of Breaker 460 under certain conditions; if not, why not; and if so, what assurance is there that an electrical fault will not then occur, disabling the
. KIRKPATRICK & LOCKHART 4.
ability to supply power from the gas turbine and EMD diesels by normal routes? See Minor Affidavit, 1 5. Answers to these questions must be provided before any licensing action can be contemplated.
(c) The Breaker 460 " solution" means that if the EMD diesels do not function, Bus 11 loads can be served by the gas turbine only via the Wildwood rerouting, which is suspect for its own reasons. See items 2(a) and 2(b), supra. lias the Staff or LILCO assessed the Bus 11 loads to determine the significance of failing to supply power to them in a timely manner? Minor Affidavit, 1 5(d). Again, all of these questions need to be
. answered in the reopened proceeding.
- 4. It is obvious that there is no need to perform Phase III/IV testing of Shoreham. As the Commission knows, the State and County believe a " critical path" analysis is both inappropriate and impossible here, because there is such great uncertainty that Shoreham will ever qualify for a full power license, liowever, even assuming, arguendo, that the Commission eventually were to authorize a there are so manymilestonestobeovercome2pu11pwerlicense, that one cannot reasonably predict such a decision before 1986. Nevertheless, during the Commission's questioning of the Staff and LILCO on Friday, it was suggested by those parties that perhaps low power testing should be considered on a " critical path" due to the possibility of problems during low power testing.
The speculation about low power testing problems is just that -- speculation. At a Staff briefing this morning, Mr.
Jeff Smith of LILCO stated that even assuming problems during low power testing, LILCO expects to complete it in "about 6 weeks."
Further, last summer, in an attachment to a June 15, 1983 letter to Congressman Markey, the Commission reviewed plants that had received licenses since the TMI accident. The longest period between initial criticality and exceeding 5 percent power was less than three months; 6 plants took less than one month. Thus, thern is no basis to " justify" testing Shoreham now to avoid potential delays due to prob 1 cms with the plant that might be revealed during testing. Indeed, if Shoreham were to encounter problems of the magnitude that would affect the nearly' year-long
" critical path" to full power operation, the Commission would 2/
The milestones includes a favorable decision to LILCO on all contested emergency planning and TDI diesel issues; a decision favorable to LILCO on all State law legal authority issues pending in New York State Supreme Court; the scheduling of, planning for, and successful completion of a FEMA-graded exercise, which would be conducted over the objections of the State and County, contrary to the policy of President Reagan, probably only following a separate lawsuit to halt such an exercise; the conduct of post-exercise administrative litigation, and a decision favorable to LILCO; and a 30-day immediate effectiveness review.
. KIRKPATRICK & LOCKHART 5.
have another Diablo Canyon on Long Island. Surely, the Commission does not expect this, given the seals of approval that the Licensing Board and Appeals Board affixed to LILCO's QC/QA programs.
- 5. During questioning at the February 8 oral argument about the "as safe as" standard, there were questions about whether the single failure problem might be deemed immaterial in the context of the NRC's licensing decision. As noted at the outset of this letter, this cannot be done. Some additional points must be set forth.
(a) the "as safe as" standard was articulated in the May 16 Order as a deliberate requirement of the Commission. The "as safe as" standard is unambiguous: compare a fully qualified system and LILCO's alternative to see how they match up. It would be unacceptable -- indeed unlawful -- for the Commission now to change that mandated standard (as the Miller Board did) into a " safe enough" standard. The NRC may not conduct a proceeding on one theory and then decide it on another. Such a change would be lawful only if the Commission provided fair notice to the parties and gave them an opportunity to put in evidence the new theory. See Public Service Co. of Indiana (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-459, 7 NRC 179, 186 (1978), citing Niagara Mohawk Power Co. (Nine Mile Point Nuclear Station, Unit 2), ALAB-264, 1 NRC 347, 353-55 (1977). Accord, Pennsylvania Power and Light Co. (Susquehanna Steam Electric Station, Units 1 ond 2), LBP-82-30, 15 NRC 771, 781-82 (1982).
(b) The fact that assumed compliance with the single failure criterion is crucial to the Miller Board's "as safe as" decision must be stressed. In addition to the portion of the Initial Decision quoted in my February 7 letter (Decision at 50-51), please note also the following statement by the Miller Board:
The Board has reviewed all of the pertinent parts of the record in this proceeding. We have concluded that the enhanced offsite system has the required redundancy, meets the single failure criterion and has sufficient capacity, capability and reliability to supply adequate emergency power for low power operation of the Shoreham unit. We find that there is adequate assurance that the enhanced system can supply sufficient power within 55 minutes in tne event of a concurrent LOCA and loss of offsite power. We therefore further find that the enhanced system provides a comparable level of protection as a fully-qualified system would and thus meets the "qq safe as" standard set by the Commission in CLI-84-8.4' d! Decision at 54-55 (footnotes omitted; emphasis added).
r
- KIRKPATRICK & LOCKHART 6.
And the Board later stated:
The gas turbine and the EMDs are considered a system (Smith, Tr. 2482) whose two parts (turbine, EMDs) are adequately independent of one another for compliance with the single failure criterion (Staff Ex. 2, SSER 6, ff Tr. 721 at 8-5, 8-6).1/
In addition, the Commission should review the Staff's Appeal Board Brief of January 22, 1985 (especially pages 17-19) wherein the Staff urges affirmance of the Miller Board Decision, particularly because of alleged compliance with the single failure criterion. For example, the Staff states:
The second argument advanced by the State and County is that alternate configuration is itself vulnerable to single failures. Brief at 40. This claim would be significant if true. The State and County provide no basis for this claim other than a brief cite to their findings below. . . . Moreover, the proposed findings are simply inaccurate; they ignore the license conditions that will be imposed by the Staff to ensure that the alternate configuration does in fact meet the single failure criterion. . . . The Board's finding that the alternate configuration meets the single failure criterion (Initial Decision at 50-51, 54) is supported by the record; the County and State provide no basis to question that determination.
Staff Brief at 18 (citations omitted; emphasis added). Again, therefore, it is clear that compliance / noncompliance with the single failure criterion is a material question in determining whether the "as safe as" standard is met. This must be dealt with in a reopened proceeding.
Sincerely yours, KIRKPATRICK & LOCKHART By: ArmE [M)
Lawrence Coe'Lanpher '
Attorneys for Suffolk County cc: Judge Marshall E. Miller Judge Glenn O. Bright Judge Elizabeth B. Johnson Alan S. Rosenthal, Esq.
Howard Wilber Gary J. Edles, Esq.
Herzel Plaine, Esq.
Remainder of Shoreham Service List 1/ Decision at 91 (emphasis added).
m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission j
)
In the Matter of ) -
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-4 ,
) (Low Power)
(Shoreham Nuclear Power Station, )
Unit 1) )
)
AFFIDAVIT OF GREGORY C. MINOR CONCERNING SINGLE FAILURE CRITERION AND SHOREHAM EMERGENCY POWER SUPPLIES
- 1. My name is Gregory C. Minor. I am Vice President of MHB Technical Associates ("MHB"). My education background is in electrical engineering (with a power systems option) in which I received-a Bachelor of Science and Master of Science degrees. I have over 24 years of experience in the nuclear industry, includ-ing design and testing of systems for use in nuclear power plants. Since 1976, I have been employed by MHB and have acted-as a consultant to domestic and foreign government agencies and other groups on nuclear power plant safety and licensing matters.
Between 1965 and 1976, .I was employed by the-GE Nuclear Engineer-ing Division as a design engineer and manager of engineering design organizations. My responsibilities included.the design, testing, qualification, and pre-operational testing of safety equipment and control rooms for use in nuclear power plants.
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- 2. General Design Criterion 17 requires that emergency power systems for nuclear power plants meet the single failure criterion. It specifically states:
The onsite electric power supplies,
' including the batteries, and the onsite electric distribution system, shall have r
sufficient independence, redundancy, and
^-
testability to perform their safety functions assuming a single failure.
Therefore, the alternative means of supplying emergency power proposed by LILCO, in order to be as safe as the safety-related system originally proposed for Shoreham, must also meet the single failure criterion.
- 3. During the low power proceeding conducted before Judge Miller, testimony was provided by LILCO, the NRC Staff and Suffolk County regarding single failure vulnerability of the alternate sources of power proposed by LILCO. In the NRC's testimony of John Knox and Edward Tomlinson, the NRC stated that the proposed system does meet the single failure criterion and
' independence which would be required for the normal safety-
-related diesel generators located at an operating nuclear power plant. Testimony of Knox and Tomlinson, at page 6. Their testi-mony' included their view that the supplemental power sources were not connected to each other and therefore were independent of each other. The Staff also relied on their SER to conclude that the electrical cross-connections between the two alternate pro-pos'ed power sources'had been sufficiently corrected to preclude a single event or single failure causing failure of both sources of power. SSER 6, at 8-5. The Board in making its decision regard-
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-3 a
l . .W Jing' low power operation for Shoreham accepted the NRC's position withJregard to the single failure criterion. Board Decision at 50-51, 54-55, 91. However, the configurations proposed by LILCO 9 _;as alternate power sources were not acceptable as first proposed.
.The;NRC in th_eir brief review of this system disclosed at least several potential single failure points which needed to be modi-
, fled. The first was to leave open breakers which interconnect
. busses lla.and 12a, llb and 12b, lle and 12c, and lld and 12d, as a' ..
shown on FSAR Figure 8.2.1'-1.
gy The Staff also required that the r %Q L , . .
Technical Spec.ifications for Shoreham be revised to require h "
verification th'at these. breakers are open once every-12 hours.
An additional possible interconnection which. represented a poten-tial' single. failure was. discovered by the Staff at the point UV%gg wh'ere two-breakers feed the 4.16-kV' emergency busses, numbered
. 9:
4lj;l($;101, 102 and 103. .To resolve this problem,~the Staff required
.that the. automatic. transfer between the pairs of breakers on
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these? busses be eliminated. This' prevented failures in the'~ auto-matickransfersystemorrelated.wiringfromcausingasingle
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' i 'J e._ event or single failure;which'would cause failure of both-sources yY
.of: alternate power.1 .Here again,1the Shoreham' Technical-Specifi-cations.were changed lto reflec't:the absencesof the automatic <
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L~ transfer system and therefore:to eliminate the need for testing ~
1 sthat; system. :Another: single failureLvulnerability related to:
2 fire :wastidentified 'by ' the -Staf f Land -resulted inLthe' requirement
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- lofLphysi~ cal separation of' circuits near the RSST.andithe NSST.
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- 4. Despite the fact that the Staff felt the system met the single failure criterion during the low power hearings, the
. latest disclosures of yet another single failure point detract from this finding and in fact render it incorrect. Breaker 460 between the RSST and bus 11 is yet another point whose single failure could interconnect with the alternate power sources and, cause both of them to fail in the event of a short. None of the single failures which have been identified to date and addressed by changes to the Technical Specifications or plant requirements has been part of a formalized, detailed and documented analysis of potential single failures of the alternate configuration pro-posed by LILCO. Absent such a formalized and documented study, it is impossible to say that these single failures, discovered at different periods of time, represent all the single failures in the system created by the unothordex addition of-external power sources to replace inoperative safety-related emergency diesel generators.
- 15. The "fix" proposed in Board Notification 85-009 is to rack out or effectively remove breaker 460. This solution does appear on the basis.of preliminary review to solve the identified single failure problem, but there is insufficient analysis to
~
show that the "fix" has not created additional problems. In fact, the documentation provided to date= indicates that several problems do exist. These are described in the following sub-paragraphs.
s L. _.
6 (a) There is no evidence that the procedures which govern operator action during a loss of offsite power (LOOP) have been modified to reflect a change created by removing bre'aker 460. Thus, the procedures presume that there is a path which would allow the operator to connect RSST to bus 11, when in fact this cannot be accomplished through the ordinary breaker techniques.
If the operator is to follow alternate procedures in order to power bus 11, such procedures have apparently not been written and have not been reviewed by the NRC.
Further, the use of revised procedures specifically created to get around the single failure problems introduced by the alternate power sources, would have no meaning during and in fact may be misleading for full power operation. Under full power operation, it is assumed that safety-related emergency diesel gener-ators will be available and such expedient and system degrading techniques as racking.out breakers and removing automatic transfer functions would not be tolerated. Thus,.the procedures for full power should be different procedures than the ones that would be created for low power. Thus, the experience gained by operators in using-the alternate AC power system will' in fact be' counter productive.in terms of training for-later higher levels of power.
y (b) Training of the operators to use the procedures created for low power operation also appears not to have been completed at this time. Once the procedures are pre-pared and reviewed by the NRC, there will need to operator training in their use in order to have any assurance that the procedures will be followed during emergency conditions.
(c) In the event of a need to power bus 11 during a LOOP event, one option is to re-rack breaker 460 and close it in to bring power from the RSST to the bus 11. If this action were taken and a short were to occur during the re-racking or closing of breaker 460, the single failure and shorted condition could cause a loss of both alternate power sources. In such an event, the alternative routing proposed by Shoreham would be to go through the Wildwood Substation and reenter the plant through the NSST. This routing involves additional procedures which have not been developed at this time, and would require a longer time because of the greater number of steps, the necessary precautions, and the involvement of~ system operators.
(d) The loads on-bus 11, according to the FSAR, appear to^
be mainly 4160 volt, . normal station service motor
' loads. Most ofLthese loads probably would not be needed during the initial phases of an emergency, but may be useful at later stages. However, because LILCO
s has presented no study showing whether they are needed or not and if they are, how they would be powered in the event the EMDs did not start, there is no assurance that the operators will not attempt to power bus 11 from alternate sources.
- 6. The modification proposed by LILCO of racking down breaker 460 removes one fundamental element of flexibility from the system as proposed in the FSAR. Originally, the system consisted of two sources (RSST and NSST) and two load centers (bus 11 and bus 12), connected both directly and by cross-linking through breakers. 'This is a classic configuration of connecting two loads to two sources. However, by elminating the one cross-tie possibility (breaker 460), the system has lost flexibility and is therefore not of the same degree of reliability or safety in the event of an emergency at Shoreham. At the same time, by-eliminating some of the system versatility, there has been an element of uncertainty introduced into the operation of the sys-tem due to the unknown method the operator will use to recreate
..that path if called upon to do so. When alternate paths are used to replace the routes otherwise provided by breacer 460, other systems, other busses, and even other substations may.have to be called into play. These actions.could well introduce new prob-lems which have not been discovered to.date. Until there has been-a thorough, study, detailed procedures, and operator train-ing, the "fix" proposed by LILCO for this single failure problem
m-may actually have introduced additional problems, possibly even single failure problems, which are yet to be discovered.
Gregory C. Minor Sworn-to before me this day of February 1985.
Notary Public
- My commission expires:
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