ML20094R038

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

ML20094R038
Person / Time
Site:	Cooper
Issue date:	12/09/1994
From:	Brungardt R NEBRASKA PUBLIC POWER DISTRICT
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE)
Shared Package
ML20094Q932	List: ML20094Q958 ML20094Q971 ML20094Q976 ML20094Q986 ML20094R001 ML20094R012 ML20094R028 ML20094R038 ML20094R059 ML20094R067 ML20094R076 ML20094R086 ML20094R115
References
FOIA-95-262 NUDOCS 9512040242
Download: ML20094R038 (4)

Text

. _ _ _ _ __ ._

f

, 3/

Nebraska Public Power District Cooper Nuclear Station P.O. Box 96 Brownville, NE 68321 December 9, 1994 i i

Mr. James Lieberman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Lieberman:

- The purpose of this letter is to respond to the letter I received from Mr. Joseph R. Gray of your office dated November 10, '

1994, which contained a copy of the Demand for Information (DFI) transmitted to the Nebraska Public Power District by letter dated November .0, 1994.

, Since receiving Mr. Gray's letter, I have had the opportunity to review the events during the March 1993 refueling outage, particularly the approval by the Station Operations Review Committee (SORC) on March 9, 1993 of changes to procedures governing reactor pres e vessel (RPV) di embly. At the time, I held the position of perations Manage d was also a voting member of SORC. I atte d the March 9, 1 93 SORC meeting at which time the changes to the RPV disassembly procedures (7.4.4, 7.4.5 and 7.4.6) were approved.

Exclanation of SORC's Action I recall that prior to the SORC meeting on March 9, 1993, l there was dif ficulty in meeting the secondary containment integrity criteria for a couple of days because of high wind conditions. l rior to the SORC ting, operators were watching the wind. As perations Manage I was not directly involved with the RPV 1 isassembly, which was delayed because of procedural requirements associated with containment integrity. My responsibilities during the outage primarily began with flooding up, after the steam dryer had been removed from the RPV. My responsibilities included helping to manage the outage and managing the Instrumentation and Control Department.

My recollection of the March 9, 1993 SORC meeting is not very clear at this point. I do recall at the meeting a lot of discussion about what loads could damage fuel in the RPV. There

.wm 10 9512040242 951122 l l

PDR FOIA PATTERS95-262 PDR ,

?

h Mr; James Lieberman December 9, 1994

-Page 2 was an issue about smaller objects that could'be dropped onto the core from.. above . I recall discussing assurances from GE (SORC members may have received them before the meeting via Tom Black, the GE site representative) that there was no way the . head, separator or dryer could damage the fuel in the RPV if dropped

'during the lift. I. remember discussion on NUREG-0612, including perhaps some specific event at another plant, but not many specific details. There was a lot of discussion by SORC on the issue.of which loads could damage fuel, such as those that weighed less than a certain amount (say, 750 or 1000 lbs., -I don't recall specifically).

I was aware that discussions had been held prior to the meeting, which I was rea not p t of. . I remember also being aware at the meeting that ick Fous he did not attend the SORC meeting) had expressed some disagreement with the proposed 3roce ure chang involving R disassembly before the m et,ipg.

Lic sworked for m Flahere t the time.and I presume, imIqas aNa e of icfs ews prior to the SORC meeting.

I recall each SORC member having a copy of the proposed change and maybe some other supporting documents, I'm not sure. A typical SORC meeting might cover a number of procedure changes. I don' t ' remember any SORC member disagreeing with the changes to the RPV disassembly procedure. I remember feeling comfortable at the time that only smaller loads (i.e., not the head, dryer or separator) were of concern.

I do not recall having any significant technical concerns with the changes. I have no reluctance speaking u at SORC meetings if I have concerns. Although I was aware tha ick Foust disagreed with the changes, I felt that enough info tion anc ,

research was available for SORC. If J thought otherwise, I wo dn't have h sjtated to ask that .ous,Qqttend the SORC meeting.

If John Meacha Gas present at th SORC meeting (I don't remember i he was or not , it would not have inf enced m judgment. I do not remember having any discussions wit jeacha son the procedure  :

changes.

I recall tha the PCN for referenced TS Amendments 147 and 150, as a result o im Flaherty] s preparation for the meeting.

As I' recall, the yes o'r no box .af i the bottom of the form (item I number 5) was checked during the meeting. I recall other SORC j meetings when the box was checked during the meeting. ,

l i

l l

• r

)r Mr. James Lieberman December 9, 1994 .

Page 3 I - recall that there was uncertainty at the meeting on' '

when the technical specifications required secondary containment integrity, and that one of the two amendments (147.or 150) either

. eliminated or clarified the . issue that secondary containment integrity was required only for actually handling fuel. I don't remember seeing a memorandum by Mr. Long of the NRC at the meeting.

But I do remember someone having previous, discussions with Mr. Long on- the issue .of,when secondary containment integrity was a requirement in' relation to moving loads, perhaps in connection with amendments to clean up the technical specifications.

I' don't recall things dragging on at the meeting. Also, I don't remember feeling pressured to reach a decision. If a dissenting vote arose, even from a non-voting member, the procedure l ' changes would not have been approved by SORC.

Exclanation why NRC Sanctions Are Inanorocriate I respectfully suggest that sanctions against me personally as suggested in the November 10, 1994 Demand for Information would be inappropriate. .As explained above, my recollection is that there was a lot of free-and-open discussion both prior to and during the March 9,-1993 SORC meeting. I felt '

comfortable at the ' time with SORC's approval of the procedure changes. Any sanctions against me personally would result in personal hardship for me because of my significant investmen as a nuclear' power professional. I graduat from H School i 95 Since then, I have accumulated ove 3 year f progressive y responsible experience in the nuclea wer fi .

\

My .

experience at Cooper Nuclear Station includes l

.Operati s Manager (1985 to Present), Operations Supervisor (1983 to 1985) , Shift Supervisor (1969 to 1983). I was licensed as a Senior Reactor Operator at Cooper Nuclear Station and previously obtained a Reactor Operator's license at the Hallam Nuclear Power Facility (1963). As Operations Manager, I am responsible for all aspects of - operation and maintenance of the plant. Operations, Instrumentation and Control, and Operations Support Group departments report directly to the Operations Manager.

Surveillance coordinat n is a direct- responsibility of the Opera ion Department I have served as a SORC representative j sinc 98 i

I affirm that this letter is true and correct to the best of  !

my knowledge and belief. I hereby request that this letter be l

t

• t

,h

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

Sincerely, fM'-j:"-

obert Brungard p

Sworn to and subscribed gefore me this=/f day of B h r e_.h , 1994.

AM. h La,LLA ,

Notary ( Public

(

My Commission Expires: A GENERAL 1107Alff Stule of kirisks

• MARY FRANCES ARMSTRONG "l/;h- My cons.Emp.Jan. I1,1ses l Q, g jl f@f O  !

1 l

1 i

l l