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Category:CORRESPONDENCE-LETTERS
MONTHYEARSVP-99-181, Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 9906301999-10-20020 October 1999 Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 990630 ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217K7011999-10-13013 October 1999 Provides Response to Questions Related to Request for License Amend,Per 10CFR50.90, Credit for Containment Overpressure. Supporting Calculations Encl 05000254/LER-1999-004, Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action1999-10-12012 October 1999 Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action ML20217F6321999-10-0707 October 1999 Forwards Insp Repts 50-254/99-01 & 50-265/99-01 on 990721- 0908.No Violations 05000254/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee1999-10-0707 October 1999 Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee ML20212K9421999-10-0505 October 1999 Informs That NRC Accepts 990513 Inservice Inspection Relief Request CR-31 for Quad Cities Nuclear Power Station,Units 1 & 2 ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr SVP-99-189, Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage1999-09-22022 September 1999 Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage ML20212J0451999-09-21021 September 1999 Forwards Safety Evaluation of Licensee USI A-46 Program at Quad Cities Nuclear Power Station,Units 1 & 2,established in Response to GL 87-02 Through 10CFR50.54(f) Ltr ML20212D8231999-09-20020 September 1999 Informs That Effectieve 991101,NRC Region III Will Be Conducting Safety System Design & Performance Capability Pilot Insp at Quad Cities Nuclear Power Station.Insp Will Be Performed IAW NRC Pilot Insp Procedure 71111-21 ML20212C6961999-09-15015 September 1999 Forwards Insp Repts 50-254/99-17 & 50-265/99-17 on 990823- 0827.No Violations Noted SVP-99-190, Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys1999-09-13013 September 1999 Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys ML20211Q7961999-09-0909 September 1999 Forwards Correction to Administrative Error on Page 8 of NRC Insp Repts 50-254/99-16 & 50-265/99-16,transmitted by Ltr, ML20217H5661999-09-0909 September 1999 Discusses 990907 Pilot Plan Mgt Meeting Re Results to-date of Pilot Implementation of NRC Revised Reactor Oversight Process at Prairie Island & Quad Cities.Agenda & Handouts Provided by Utils Encl ML20211Q6511999-09-0808 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Quad Cities Operator License Applicants During Wk of 000327.Validation of Exam Will Occur at Station During Wk of 000306 ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) ML20211F8251999-08-25025 August 1999 Forwards Insp Repts 50-254/99-15 & 50-265/99-15 on 990816-20.No Violations Noted.Insp Evaluated Effectiveness of Maint Rule Program & Review Periodic Evaluation Specifically Required for 10CFR50.65 ML20211B8691999-08-20020 August 1999 Forwards Insp Repts 50-254/99-10,50-265/99-10,50-454/99-09, 50-455/99-09,50-456/99-10 & 50-457/99-10 on 990628-0721. Action Plans Developed to Address Configuration Control Weaknesses Not Totally Effective as Listed ML20211D1491999-08-19019 August 1999 Forwards Insp Repts 50-254/99-16 & 50-265/99-16 on 990719-22.Staff Identified Major Discrepancy Re Accuracy of Data Submitted to NRC for Protected Area Security Equipment Performance ML20211C7601999-08-19019 August 1999 Confirms NRC Intent to Meet with NSP & Ceco on 990807 in Lisle,Il to Discuss with Region III Pilot Plants,Any Observations,Feedback,Lessons Learned & Recommendations Relative to Implementation of Pilot Program ML20210R7451999-08-13013 August 1999 Forwards Insp Repts 50-254/99-11 & 50-265/99-11 on 990601-0720.NRC Identified Several Issues Which Were Categorized as Being of Low Risk Significance.Two Issues Involved NCVs of Regulatory Requirements SVP-99-147, Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl1999-08-13013 August 1999 Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl SVP-99-170, Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety1999-08-13013 August 1999 Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety ML20210T9941999-08-13013 August 1999 Forwards Insp Repts 50-254/99-12 & 50-265/99-12 on 990628-0716.Violations Noted SVP-99-154, Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated1999-08-13013 August 1999 Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated ML20210R9541999-08-10010 August 1999 Informs That During 990804 Telcon Between J Bartlet & M Bielby,Arrangements Were Made for NRC to Insp License Operator Requalification Program at Plant.Insp Planned for Wks of 991018 & 25 ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M5461999-08-0606 August 1999 Discusses 990804 Telcon Between J Bartlet & M Bielby,Where Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant.Insp Planned for Wks of 991018 & 25 ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed ML20210L8371999-08-0202 August 1999 Forwards SE Accepting Licensee 60-day Response to GL 96-05, Periodic Verification of Design-Basis Capability of Safety Related Motor-Operated Valves ML20210M4691999-07-30030 July 1999 Forwards Insp Repts 50-254/99-14 & 50-265/99-14 on 990713-15.One NCV Was Identified & Discussed in Encl Insp ML20210H4661999-07-29029 July 1999 Forwards Insp Repts 50-254/99-13 & 50-265/99-13 on 990628-0702.No Violations Noted.Insp Consisted of Selective Examination of Procedures & Representative Records, Observations of Activities & Interviews with Personnel 05000254/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed1999-07-29029 July 1999 Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed SVP-99-151, Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 21999-07-23023 July 1999 Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 2 SVP-99-150, Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept1999-07-23023 July 1999 Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept SVP-99-146, Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 9906251999-07-21021 July 1999 Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 990625 ML20210B7071999-07-16016 July 1999 Responds to Requesting Review & Approval of Three Proposed Changes to Ceco QA TR,CE-1A Per 10CFR50.54(a)(3) & 10CFR50.4(b)(7) ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes SVP-99-139, Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage1999-06-30030 June 1999 Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 05000265/LER-1999-002, Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action1999-06-25025 June 1999 Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action SVP-99-122, Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 9906011999-06-25025 June 1999 Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 990601 SVP-99-066, Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested1999-06-25025 June 1999 Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested SVP-99-103, Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period1999-06-25025 June 1999 Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period ML20196F7921999-06-24024 June 1999 Forwards Meeting Summary,Nrc Meeting Handout & Licensee Handout from 990608 Meeting ML20196E7131999-06-23023 June 1999 Forwards Insp Repts 50-254/99-09 & 50-265/99-09 on 990421-0531.One Violation of NRC Requirements Occurred & Being Treated as non-cited Violation,Consistent with App C of Enforcement Policy ML20196E4821999-06-21021 June 1999 Discusses 990617 Meeting by Region III Senior Reactor Analysts (SRA) in Cordova,Il to Meet with PRA Staff to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PRA Staff 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARSVP-99-181, Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 9906301999-10-20020 October 1999 Forwards Biennial Update to Quad Cities Ufsar,Iaw 10CFR50.71(e).Update Includes Changes to Facility & Procedures & Are Current Through 990630 ML20217H4661999-10-18018 October 1999 Forwards Changes to EPIPs IAW 10CFR50.54(q) & 10CFR50,App E, Section V.Details of Changes Encl ML20217K7011999-10-13013 October 1999 Provides Response to Questions Related to Request for License Amend,Per 10CFR50.90, Credit for Containment Overpressure. Supporting Calculations Encl 05000254/LER-1999-004, Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action1999-10-12012 October 1999 Forwards LER 99-004-00,IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Is Committed to Listed Action 05000254/LER-1999-003, Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee1999-10-0707 October 1999 Forwards LER 99-003-00 IAW 10CFR73(a)(2)(v)(A).Commitment Made by Util,Listed.Any Other Actions Described in LER Represent Intended or Planned Actions by Licensee ML20216J8241999-09-30030 September 1999 Notifies of Removal of NRC Headquarters & Region III Offices from Controlled Copy Distribution of Certain CE Documents. Specific Documents,Associated Controlled Copy Numbers & NRC Location Affected Are Shown on Attachment to Ltr SVP-99-189, Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage1999-09-22022 September 1999 Confirms Completion of Actions Identified During Review of NRC Safety Evaluation of Boiling Water Reactor Owners Group Rept, Utility Resolution Guidance of ECCS Suction Strainer Blockage SVP-99-190, Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys1999-09-13013 September 1999 Clarifies Statement Contained in NRC Insp Repts 50-254/99-12 & 50-265/99-12,dtd 990813,paragraph 4OA1.3B, Observation & Findings, Re Sys Mod to DG Air Start Sys ML20211G1221999-08-27027 August 1999 Forwards fitness-for-duty Program Performance Data for Each of Comm Ed Nuclear Power Stations & Corporate Support Employees within Scope of Rule for six-month Period Ending 990630,IAW 10CFR26.71(d) SVP-99-154, Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated1999-08-13013 August 1999 Notifies NRC That M Price,License SOP-31389,is No Longer Required to Maintain Operator License.Price Was Removed from Licensed Duty on 990729 & Comm Ed Requests License Be Terminated SVP-99-170, Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety1999-08-13013 August 1999 Forwards Relief Requests CR-25,CR-26,CR-27,CR-28,PR-11, PR-12 & PR-13,on Basis That Compliance with Specified Requirements Would Result in Hardship or Unusual Difficulty Without Compensating Increase in Level of Quality & Safety SVP-99-147, Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl1999-08-13013 August 1999 Notifies of Change to Bases of TS to Licenses DPR-29 & DPR- DPR-30.Change to TS Section 3/4.9 Provides Clarity & Consistency with Sys Design Description in Ufsar,Sections 8.3.2.1 & 8.3.2.2.TS Bases Page,Encl ML20210N5651999-08-0606 August 1999 Forwards Rev 8 to Nuclear Generating Stations Emergency Plan, for Plants.With Summary of Changes ML20210M9131999-08-0202 August 1999 Forwards Response to NRC AL 99-02, Operating Reactor Licensing Action Estimates, for Fys 2000 & 2001 for Comed 05000254/LER-1999-002, Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed1999-07-29029 July 1999 Forwards LER 99-002-01,IAW 10CFR50.73(a)(2)(iv).Rev Includes Cause Codes & Energy Industry Identification Sys Identifiers Which Were Erroneously Omitted in Original Ler.Commitments Listed SVP-99-150, Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept1999-07-23023 July 1999 Forwards Responses to 990520 RAI Re Annual 10CFR50.46 Rept SVP-99-151, Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 21999-07-23023 July 1999 Responds to NRC 990701 Telcon RAI Re Licensee Amend Request Re Use of Containment Overpressure to Support NPSH Available for ECCS at Quad Cities Nuclear Power Station,Units 1 & 2 SVP-99-146, Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 9906251999-07-21021 July 1999 Informs of Termination of License SOP-31132-1,for G Green, as Required by 10CFR50.74(b).Individual Was Removed from License Duty on 990625 ML20196J9061999-07-0101 July 1999 Provides Evidence That Util Maintains Guarantee of Payment of Deferred Premiums in Amount of $10 Million for Each of Thirteen Reactors,Per 10CFR140.21 ML20196J9131999-07-0101 July 1999 Submits Status of Nuclear Property Insurance Currently Maintained for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR50.54(w)(3) ML20209B8241999-06-30030 June 1999 Forwards Five 3.5 Inch Computer Diskettes Containing Revised Annual Dose Repts for 1994 Through 1998 for Individuals Receiving Neutron Dose Not Previously Included in Reported Total Effective Dose Equivalent Values.Without Diskettes SVP-99-139, Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage1999-06-30030 June 1999 Forwards Revised Action 2 & Associated TS Bases Changes, Describing Specific Alternate Method for Determining Drywell Floor Drain Sump Leakage SVP-99-103, Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period1999-06-25025 June 1999 Informs NRC of Results of Subject Evaluation as Committed to in .Evaluation Consisted of Analytically Demonstrating That Cfu Factor for Rv Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period SVP-99-122, Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 9906011999-06-25025 June 1999 Forwards Regulatory Commitment Change Summary Rept, Containing Summary Info from 980601 Through 990601 05000265/LER-1999-002, Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action1999-06-25025 June 1999 Forwards LER 99-002-00 for Quad Cities Nuclear Power Station IAW Requirements of 10CFR50.73(a)(2)(i)(B).Util Commits to One Listed Action SVP-99-066, Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested1999-06-25025 June 1999 Informs That J Reed,License SOP-31034-1,was Removed from License Duty in 990618.Termination of License Is Requested SVP-99-125, Forwards Technical Info Re ECCS Suction Strainers at Quad Cities Nuclear Power Station Units 1 & 2,to Support Review of 990129 Lar.Rev 0 to TR-VQ1500-02, Clean ECCS Suction Strainer Head Loss Test Rept, Encl1999-06-15015 June 1999 Forwards Technical Info Re ECCS Suction Strainers at Quad Cities Nuclear Power Station Units 1 & 2,to Support Review of 990129 Lar.Rev 0 to TR-VQ1500-02, Clean ECCS Suction Strainer Head Loss Test Rept, Encl ML20195E3491999-06-0707 June 1999 Withdraws Util Requesting License Change for Plant Security Plan Rev.Licensee Will re-evaluate Situation & May Request Approval of Change in Future ML20207G1451999-06-0707 June 1999 Forwards Rev 45 to Comed Quad Cities Nuclear Power Station Security Plan.Rev Includes Changes Listed.Security Plan Is Withheld from Public Disclosure Per 10CFR73.21 ML20195D6351999-06-0404 June 1999 Notifies NRC of Actions That Has Been Taken in Accordance with 10CFR26, Fitness for Duty Programs SVP-99-105, Informs NRC of Rev to Schedule for Completing Setpoint/ Uncertainty Calculations & Procedure Changes,Originally Planned for Completion on 9905291999-05-20020 May 1999 Informs NRC of Rev to Schedule for Completing Setpoint/ Uncertainty Calculations & Procedure Changes,Originally Planned for Completion on 990529 ML20195B2301999-05-19019 May 1999 Requests Approval of Proposed Changes to QA Topical Rept CE-1-A,rev 66a.Attachment a Describes Changes,Reason for Change & Basis for Concluding That Revised QAP Incorporating Proposed Changes Continues to Satisfy 10CFR50AppB SVP-99-111, Informs NRC of Current Status of Actions on Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions1999-05-17017 May 1999 Informs NRC of Current Status of Actions on Response to GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions SVP-99-098, Fulfills Thirty Day & Annual Reporting Requirements of 10CFR50.46 for Plant.Eccs Evaluation Change Rept Transmitted in Entirety,Fulfilling Thirty Day & Annual Reporting Requirements Specified in 10CFR50.46(a)(3)(i)1999-05-17017 May 1999 Fulfills Thirty Day & Annual Reporting Requirements of 10CFR50.46 for Plant.Eccs Evaluation Change Rept Transmitted in Entirety,Fulfilling Thirty Day & Annual Reporting Requirements Specified in 10CFR50.46(a)(3)(i) SVP-99-099, Requests Relief from Requirements of 10CFR50.55a(g) Re Submittal of Relief Requests for Those Welds for Which Examinations of Greater than 90% of Weld Vol Was Not Acheived During 2nd ISI Program Interval1999-05-13013 May 1999 Requests Relief from Requirements of 10CFR50.55a(g) Re Submittal of Relief Requests for Those Welds for Which Examinations of Greater than 90% of Weld Vol Was Not Acheived During 2nd ISI Program Interval SVP-99-096, Provides Suppl Response to Violations Noted in Insp Repts 50-254/98-20 & 50-265/98-23.Corrective Actions:Listed Multidiscipline Team Will Perform self-assessment IAW Station Program for self-assessments in May 19991999-05-12012 May 1999 Provides Suppl Response to Violations Noted in Insp Repts 50-254/98-20 & 50-265/98-23.Corrective Actions:Listed Multidiscipline Team Will Perform self-assessment IAW Station Program for self-assessments in May 1999 05000254/LER-1999-001, Forwards LER 99-001-00 for Quad Cities Nuclear Power Station.Licensee Shall Rept Any Operation or Condition Prohibited by Plant Tech Specs.Util Committing to Listed Actions1999-05-12012 May 1999 Forwards LER 99-001-00 for Quad Cities Nuclear Power Station.Licensee Shall Rept Any Operation or Condition Prohibited by Plant Tech Specs.Util Committing to Listed Actions ML20206F5381999-04-30030 April 1999 Forwards Magnetic Tape Containing Annual Dose Repts for 1998 for Braidwood,Byron,Dresden,Lasalle County,Quad Cities & Zion Nuclear Power Stations,Per 10CFR20.2206(c).Without Magnetic Tape SVP-99-108, Forwards Quad Cities 1998 Radiological Environ Operating Rept, IAW Plant TS 6.9.A.3.Rept Contains Results of Radiological Environ & Meteorological Monitoring Programs. Radioactive Effluent Release Rept Was Submitted 9903301999-04-30030 April 1999 Forwards Quad Cities 1998 Radiological Environ Operating Rept, IAW Plant TS 6.9.A.3.Rept Contains Results of Radiological Environ & Meteorological Monitoring Programs. Radioactive Effluent Release Rept Was Submitted 990330 SVP-99-036, Forwards Reg Guide 1.16 Rept Number of Personnel-Rem by Work & Job Function for 1998. Associated Collective Deep Dose Equivalent Reported According to Work & Job Functions1999-04-29029 April 1999 Forwards Reg Guide 1.16 Rept Number of Personnel-Rem by Work & Job Function for 1998. Associated Collective Deep Dose Equivalent Reported According to Work & Job Functions SVP-99-088, Informs That Util Is Withdrawing IST Relief Rquests RV-02B & RV-03B1999-04-29029 April 1999 Informs That Util Is Withdrawing IST Relief Rquests RV-02B & RV-03B ML20205T1141999-04-22022 April 1999 Provides Comments from Technical Review of Draft Info Notice Re Unanticipated Reactor Water Draindown at Quad Cities Nuclear Power Station,Unit 2,ANO,Unit 2 & JAFNPP ML20206B2471999-04-20020 April 1999 Informs That SE Kuczynski Has Been Transferred to Position No Longer Requiring SRO License.Cancel License SOP-31030-1, Effective 990412 SVP-99-065, Requests That License SOP-31516,for Jf Graham,Be Terminated, Per 10CFR50.74(b).Individual Was Removed from License Duty on 990319 & No Longer Requires Operator License1999-04-14014 April 1999 Requests That License SOP-31516,for Jf Graham,Be Terminated, Per 10CFR50.74(b).Individual Was Removed from License Duty on 990319 & No Longer Requires Operator License SVP-99-058, Submits Plant Specific ECCS Evaluation Changes,Per Annual Reporting Requirements of 10CFR50.46.Attachments Include Current Assessment Data Re PCT Info Limiting LOCA Evaluations1999-04-14014 April 1999 Submits Plant Specific ECCS Evaluation Changes,Per Annual Reporting Requirements of 10CFR50.46.Attachments Include Current Assessment Data Re PCT Info Limiting LOCA Evaluations SVP-99-063, Responds to NRC Re Violations Noted in Insp Repts 50-254/98-21 & 50-265/98-21.Corrective Actions:Revised Site ISI Procedure Qcap 0410-06, ISI Plan Implementation for Third Ten Year Insp Interval1999-04-0909 April 1999 Responds to NRC Re Violations Noted in Insp Repts 50-254/98-21 & 50-265/98-21.Corrective Actions:Revised Site ISI Procedure Qcap 0410-06, ISI Plan Implementation for Third Ten Year Insp Interval JAFP-99-0129, Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick1999-04-0909 April 1999 Submits Comments on Technical Review of Draft Info Notice Describing Unanticipated Reactor Water Draindown at Quad Cities Unit 2,ANO & FitzPatrick SVP-99-057, Notifies of Change to Bases for TSs Section 3/4.5, ECCS, Re1999-04-0505 April 1999 Notifies of Change to Bases for TSs Section 3/4.5, ECCS, Re ML20205K5841999-03-31031 March 1999 Submits Rept on Status of Decommissioning Funding for Reactors Owned by Comm Ed.Attachment 1 Contains Amount of Decommissioning Funds Estimated to Be Required Pursuant to 10CFR50.75(b) & (C) SVP-99-062, Informs NRC of Rev to Schedule for Analytically Demonstrating That Cumulative Usage Factor for Reactor Vessel Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period1999-03-31031 March 1999 Informs NRC of Rev to Schedule for Analytically Demonstrating That Cumulative Usage Factor for Reactor Vessel Head Closure Studs Will Remain Below 1.0 for Remainder of Current License Period 1999-09-30
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20055E8111990-03-26026 March 1990 FOIA Request for Records Re Indemnification Agreements Between Util & AEC or NRC & Public Liability Insurance ML20195G7961988-11-21021 November 1988 Responds to NRC Re Violations Noted in Insp Repts 50-254/86-21,50-254/87-11,50-265/86-21 & 50-265/87-11 Re Use of Unqualified AMP nylon-insulated Butt Splices in GE Foi Containment Penetration Enclosures at Facility ML20235G2321987-04-0101 April 1987 FOIA Request for Documents Re Forged NDE Inspectors Certification Supplied by Barclay Intl for Use at Quad Cities Nuclear Station & Stated Investigations at Plants 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 ML20154R1091986-02-0606 February 1986 FOIA Request for Accident or Incident Repts Filed by Commonwealth Edison Co & Iowa-Illinois Gas & Electric Co Re 850507 Electrical Explosion ML20154B8781985-11-25025 November 1985 FOIA Request for Seven Categories of Documents Re Hydrodynamic Loads in BWR Pressure Suppression Containments ML20137B0971985-11-15015 November 1985 Forwards Complaints Re Carborundum Co & Comm Ed Cases.Util Case Concerns J O'Connor Nonspecific Injuries Allegedly Resulting from Radiation Exposures at Plant ML20052G8841982-05-13013 May 1982 Forwards Citizens for Safe Energy & Quad Cities Alliance for Safe Energy & Survival 820511 Ltr Which Has Not Been Served on All Parties ML20052A8931982-04-26026 April 1982 Forwards Draft Order Per ASLB Request at 820423 Conference Call & Draft Procedures Re Racking Operation ML20042C3301982-03-26026 March 1982 Advises That Refueling Outage for Unit 2 Deferred Until Sept 1983,enabling Util to Continue Reracking Operation ML20049J5881982-03-11011 March 1982 Summarizes Util Response to ASLB 820226 Order.Responses Were Provided During 820210 Telcon ML20049J1741982-03-0808 March 1982 Forwards Citizens for Safe Energy & Quad Cities Alliance for Safe Energy & Survival Response to Util Interrogatories, Which Should Be Treated as Motion to Withdraw Contention 7. Util & NRC Do Not Object.Related Correspondence ML20041C3521982-02-22022 February 1982 Forwards D Collins 820217 Ltr.Ltr Should Be Treated as Motion to Withdraw Contested Contentions 1-4.Util & NRC Do Not Object to Withdrawal ML20040H0791982-02-10010 February 1982 Forwards Suppl 7 to Revision 1 of Licensing Rept on High Density Spent Fuel Racks for Quad Cities Units 1 & 2. ML20039D8541981-12-29029 December 1981 Forwards Suppl 6 to Joseph Oat Corp Licensing Rept Prepared for Util.Related Correspondence ML20038A8991981-11-17017 November 1981 Forwards Tj Rausch 811102 Ltr Transmitting Suppl 5 to Revision 1 of Licensing Rept of High Density Spent Fuel Racks for Quad Cities Units 1 & 2. Related Correspondence ML20010B4441981-08-10010 August 1981 Forwards Suppl 1 to Revision 1 to Joseph Oat Corp Rept, Licensing Rept on High Density Spent Fuel Racks for Quad Cities,Units 1 & 2. Related Correspondence ML17341B6341981-06-29029 June 1981 Withdraws Licensee Objections to Quad-City Alliance for Safe Energy & Survival,Citizens for Safe Energy & Older Americans for Elderly Rights Standing to Intervene.Requests Prehearing Conference Re Contested Contentions.Related Correspondenc ML19248C9011979-05-0303 May 1979 Forwards NRDC Annual Rept & Matls & Citizens for Better Environ Matls Supporting Applicant Position Re Involvement of Both Organizations in Broad Environ Litigation.Matl Provided in Response to 790419 Memo & Order.Svc List Encl 1990-03-26
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. . 000 rEtaE .. 4.a November 21, 1988 Mr. James Lieberman, Director Office of Enforcement U.S. 11uclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk (
Re: Quad Cities Station, Units 1 and 2 Answer to tiot. ice of Violation Report tios. 50-254/8C021; 50-254/87011; 50-265/86021; 50-265/87011 11RC Docket tios . 50-254 and 50-265 Reference (a): October 20, 1988 A. B. Davis Letter to J. J. O'Connor (b): tiovember 21, 1988 L. O. Do1 George Lett..>r to J. Lieberman (c): April 29, 1988 A. B. Davis Letter to J. J. O'Connor (d): June 20, 1988 P. Steptoe Letter to J. Lieberman and L. O. DelGeorge Letter to A. B. Davis and accompanying affidavits of J. Abel, I. M. Johnson, M. S. Turbak, V, tioonan and R. LaGrange (e): October 21, 1988 A. B. Davis Letter to Lee Liu
Dear Mr. LieM cma n :
T' i answer is submitted on behalf of our et4.nt.,
Commonweal'h Edison Company, ("CECO" or "the Compani"' 1 response to the 11RC staff's (the "Staif") letter dis' 1 Octobor 20, 1988, including a 14otice of Violation and proposing imposition of a civil penalty in the amount of $150,000. The proposed civil penalty relates to CCCo's use of unqualified A:'P nylon-insulated butt splices in General Electric F01 containment tC kjjy,;4 ,,
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.. c SIDLEY & AUSTIN CHICAoO Mr. James Lieberman, Director flovember 21, 1988 Page 2 penet;0 tion enclosures at Quad Cities, Units 1 and 2. See Reference (s). Commonwealth Edison's qualified admission of the alleged violation is contained in Reference (b).
Commonwealth Edison maintains that the imposition of an additional civil penalty in this case would be inconsistent with the flRC's Modified Enforcement Policy for EQ Requirements (the "Modified Enforcement Policy" or "Policy"). First, the "violation" alleged in the Staff s October 20, 1988 letter and flotice of Violation ("Second 110V") is identical to the violation alleged in a prior April 29, 1988 A. E. Davis letter to J. J.
O'Connor and accompanying tiotice of Violation ("First 110V"). See Reference (c). Such a double penalty for a single violation is net consistent with the intent of the Modified Enforcement Policy and is patently unfair. Second, the newly proposed civil penalty is inconsistent with the Modified Enforcement Policy for the reasons set forth in CECO's Answer to the First flOV. See June 28, 1988 Steptoo letter to James Lieberman (in Reference (d)).
The Staff's finding that CECO "clearly should have known that the AMP splices were not qualified is based on impermissible hindsight. In addition, the amount of the proposed civil penalty should be reduced because of the f . lure to give any credit to CECO for taking the initiative tt -3t the AMP splices. Third, and finally, the proposed civil pe. .lty should be reduced because it is unfair in light of the smaller civil penalty the Staff has recently proposed for another licensee in virtually identical circumstances.
A. The tiotice of Violation Proposes to Penalize Edison Twice for_a_ Single Alloqed EO Violation.
A licenuee should not be penalized twice for the same alleged environmental qualification ("EQ") violation. The Modif led Enforcement Policy recognizes this obvious principle.
The very first observation of the Policy with respect to determining civil penalties is that "(s]ignificant EQ violations
. . . are to be considered together, in the aggregate. . . . "
The flRC, the Policy reiterates elsewhere, "will consider the EQ violations in aggregate, not based on individual violations."
Indeed, this rule embodies a deliberate and explicit change to prior EQ enforcement policy. See Generic Letter 88-07.
The Second 110V contravenes this rule. It alleges an EQ violation identical in overy respect to the one alleged la the First flOV . Indeed, the only conceivable rationale for the proposed double penalty is that CECO's decisions regarding the AMP splices happened to be implemented at two stations at once --
1 SInt.uv & AUSTIN CnicAco Mr. James Lieberman, Director flovember 21, 1988 Page 3 Dresden and Quad Cities. These are sister stations built in the same time period with virtually the same design.
The facts underlying both proposed civil penalties are identical. General Electric ("GE") contemporaneous 1y furnished CECO with AMP nylon-insulated butt splice components, for installation in GE F01 containment penetration enclosures at both Dresden and Quad Cities. The EQ documentation for the splices installed in both plants was the same and consisted primarily of test reports generated by GE prior to 1978.
In 1978, the flRC issued Inspection Report tios. 50-254/78-24 and 50-265/78-25 for CECO's Quad Cities Station. This inspection included, among other things, an examination of the qualification of AMP butt splices in GE penetrations. The flRC concluded:
Electrical cable splices located in the drywell. The RIII Inspector determined that the "Butt Splices" were constructed using AMP preinsulated butt connectors (nylon window splices). Qualification of these butt splices was accomplished during the electrical r,netration test and is documented in GE letter dated
'fril 28, 1978 (Chron 8878). The Inspector determined that the results were satisfactory.
The 11RC examined the qualification of AMP splicos again during a May 19-23, 1986, EQ inspection at Dresden. Although CECO's basis for qualification of these items was the same as it had been in 1978, the f1RC questioned whether the EQ file adequately demonstrated similarity between the tested splices and those installed at Dresden and Quad Cities. This issue was reasonably treated by the Staff and CECO as a documentation problem, not. calling int o question continued operat. ion of the Dresden and Quad Cities units. To resolve this question, CECO, at its own initiative, conducted a test to confirm the qualification of the splices at both stations on October 2-7, 1986 as part of ongoing LaSalle Ray Chem splice tests. A second test of four splices removed from the Quad Cities drywell was conducted on flovember 21-26, 1986. Both of these tests were conducted according to the LaSalle County profile. After discussion with the f1RC, CECO decided that. this profile was inaccurate and too stringent for Quad Cities and Dresden Stations. Accordingly, four splice samples were removed from the Quad Cities drywell and tested using a Dresden/ Quad Cities profilo on Decembor 4-5, 1986. The samples failed, to the surprino not only of CECO, but of pcrsonnel at f1RC Region III.
Sne June 28, 1988 Irene M. Johnson affidavit (in Reference (d)).
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SIDLEY & AUSTIN '
CIHCAco Mr. James Lieberman, Director November 21, 1988 Page 4 Dresden Unit 3 and Quad Cities Unit 1 were shutdown the next day, December 6, 1986, for the repair of the splices. Dresden Unit 2 and Quad Cities Unit 2 were in refueling outages and repairs were made in the course of these outages. The NRC witnessed these repairs.
Based on CECO's test results, the NRC and CECO contacted other licensees to alert them of the AMP splice problem. As a result Iowa Electric Light and Power Company shut down its Duane Arnold station to repair AMP splices installed in the drywell penetrations there.
The complete identity of the violation alleged in the First and Second NOVs is reflected in the two NOVs themselves.
The Staff's analysis of whether CECO "clearly should have known" that the splices were not qualified is word for word the same in the April 29, 1988 and October 20, 1988 letters. The Staff's '
analysis of the four escalation / mitigation factors is also virtually identical.
In short, the facts and the two NOVs establish that at no point did either CECO or the NRC make any decision or engage in any conduct differentiating the AMP splices installed in Dresden from those installed in Quad Cities. Thus, there is but a single alleged violation. Accordingly, a double penalty would be unfair in light of the Modified Enforcement Policy.
1 The Second Proposed Penalty Is Inconsistent with the Modified Enforcement Policy for the Reasons Set Forth in CECO's An_swer to the First NOV.
CECO's Answer to the First NOV maintains that the proposed civil penalty is inconsistent with the Modified Enforcement Policy. First, the finding that CECO "clearly should have known" that thn AMP splices were not qualified is based on impermissible hindsight. Finding that CECO clearly should have known of the alleged violation prior to the November 30, 1985 deadline is particularly inappropriate in view of the NRC's 1978 determination that the splices were qualified. Second, the amount of the proposed civil penalty should be reduced because the Staff's analysis of two of the mitigation / escalation factors warrants reconsideration.
Given t. hat the Pirat and Second NOVs are based on an identical set of decisions and facts, this former Answer is also applicable to the new Notice of Violation. Accordingly, such Answer is hereby incorporated by reference along with the accompanying affidavits of Irene M. Johnson, Michael S. Turbak,
l SIDLuv & AUSTIN CIIICAGo i
I Mr. James Lieberman, Director November 21, 1988 Page 5 James S. Abel, Vincent S. Noonan and Robert G. LaGrange. All discussion of Dresden Unit 3 in such Answer applies equally to Quad Cities. Enclosed with this Answer is a supplemental affidavit submitted by Mr. Abel confirming that there was no difference in CECO's decisionmaking or conduct with respect to the AMP splices at Dresden 3 and Quad Cities 1 and 2. CECO will also submit in the near future an affidavit by Philip Holtzman,
, President of Star Strategic Resources and Technology, Inc.,
underscoring the benefit of CECO's Ray Chem testing program to other licensees.
C. The Proposed Civil Penalty Is Unfair Given the Civil Penalty Proposed in A Similar Case.
CECO's Answer to the First NOV requested the Staff to reconsider its analysis of two of the mitigation / escalation factors. The merit of this request has been substantially bolstered by a Notice of Violation the I;RC issued October 21, 1980 to the Iowa Electric Light and Power Company ("Iowa Electric"). See Reference (e). This Iowa Electric NOV concerns the very AMP butt splice issue addressed in the First and Second NOVs.
Iowa Electric discovered that the AMP butt splicos installed in its Duane Arnold station were unqualified based on CECO's testing of the AMP splices in December, 1986. Like CECO, Iowa Electric was required to shut down to repair the splices.
The Staff found that Iowa Electric had operated the plant from November 30, 1985 to December 9, 1986 with unqualified equipment, or three days longer than it had taken CECO to shut down Dresden Unit 3 and Quad Cities Unit 1. The Staff also found that Iowa Electric suffered the very EQ documentation deficiency as had CECO: the splices tested by the manufacturer were not demonstrated to be identical to the installed splices. The Staff found that the Iowa Electric vio'.ation involved several hundred unqualified splices and recommended a base civil penalty of
$150,000.
Despite these striking similarities, the Staff concluded that with respect to two of four mitigation / escalation factors, Iowa Electric deserved mitigation. On the other hand, the Staff concluded that CECO was not entitled to mitigation or even deserved escalation. Thus, Iowa Electric's penalty was mitigated to $50,000, whereas CECO's double penalties remain at
$150,000 each., or $300,000 total.
In regard to the first mitigation / escalation factor, the Staff concluded that CECO's penalty should be escalated 501
4 Stunny & AUSTIN CIHCAGO Mr. James Lieberman, Director November 21, 1988 Page 6 because "the NRC identified this violation and the licensee failed to take advantage of the identification of the degrading
" In Iowa Electric's case, the splices in Dresden Unit 2 . . . .
Staff found mitigation appropriate because the violations, it found, were identified by the licensee. The fact is that the violation was identified not by Iowa Electric, but as a direct result of Commonwealth Edison's voluntary testing activities.
With respect to the third mitigation / escalation factor the Staff found that CECO was not entitled to mitigation because "while the licensee did shut down Unit 2 on October 11, 1986 and Unit 1 on December 6, 1986 and repair the splices, these actions were not done in a reasonable time in that the unqualified splices were identified at Dresden in May 1986." In the case of Iowa Electric, 50% mitigation was applied for "prompt and extensive corrective actions," namely, that Iowa Electric shutdown and promptly repaired or replaced the splices.
As set forth in CECO's Answer to the First NOV, CECO did not have prior notice that EQ deficiencies might exist.
Prior to the November 30, 1985 EQ deadline, CECO justifiably relied on its EQ documentation which had been found to be satisfactory by the NRC during its 1978 inspection. The Dresden, Unit 2 splicos identified by CECO in September, 1985 as degraded had been subjected to a high-temperature event. Inspection of splices in other units did not reveal any degradation. The inspection report following the Staff's May, 1986 inspection emphasized only a documentation deficiency. CECO monitored the AMP snlices and also undertook to test them. It was only this testing -- undertaken at CECO's own initiative -- that revealed, to the surprise of both CECO and the NRC, that the splices were not qualifled and alerted other licensees to this fact. Such conduct is hardly dilatory or irresponsible and should not be penalized. Indeed, the very documentation defect emphasized in escalating CECO's penalty was also present in Iowa Electric's EQ files in May, 1986 and never discovered by that licensee until it was alerted to the results of CECO's tests.
The Staff's disparate analysis of these two factors unfairly fails to mitigate CECO's penalty when CECO took steps --
on its own initiative and to the benefit of other licensees including Iowa Electric -- to resolve conclusively whether or not the AMP splices were environmentally qualifjed. At the same time, it grants mitigation to Iowa Electric despite the fact that t
that company took no action until CECO conducted its test program and then merely followed CECO's lead in shutting down and repairing the splices. Indeed, Ceco shut down within one any of
9 SInLur & Ausrix Cnicaoo Mr. James Lieberman, Director flovember 21, 1988 Page 7 the final test results whereas Duane Arnold took several days longer to shut down.
Given the penalty proposed for Iowa Electric in these circumstances, any penalty on CECO, with respect to either Quad Cities or Dresden, should in no event exceed $50,000.
Ver truly yours,
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UNITED STATES OF AMERICA NUCLEAD REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of: )
)
COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-254 and
) 50-265 (Quad Cities, Units 1 and 2) )
SUPPLEMENTAL AFFIDAVIT OF JAMES S. ABEL I, James S. Abel, being first duly sworn, depose and state as follows:
I am employed by Commonwealth Edison Company as Boiling Water Reactor Engineering (BWRE) Department Manager. BWRE is responsible for plant design and technical service for the Commonwealth Edison BWR plants which are Dresden, Quad Cities and LaSalle County Stations. Included in the technical services provided is coordination of the establishment of the Environmental Qualification Program and preparation and review of the environmental quallfication documentation files. Prior to this present assignment, I was employed by Commonwealth Edison as Station Nuclear Engineering Department (SNED) Manager from 1981 to 1987. In this assignment my responsibilities were the same as the BWRE manager except the plants included al1 Commonucalth Edison operating nuclear plants. During the 1981 to 1987 period, SNED was responsible for engineering activities associated wit h the Quad Cities and I have Dresden of a Bachelor Stations ScienceEnvironmental in MechanicalQualification Engineering Programs.
degree from the Rose Nulman Institute of Technology, and over 20 years of experience as a mechanical engineer in the nuclear industry.
The purpose of this affidavit is to confirm that Ed' ~:on always understood and treated the AMP butt splice issue raised by the NRC at its May 19-23, 1986 inspection as equally concerning the splices installed at Quad Cities, Units 1 and 2 as well as at Dresden Unit 3. The problem was understood to be a unitary one.
At no time did Edison make any significant decision or take any signifiCant action that distinguished between the AMP splices installed at Dresden, Unit 3 and Quad Cities, Units 1 and 2.
T e
Indeed, the basis of the qualification of the AMP splices at both Dresden and Quad Cities was the same documentation, the testing program CECO undertook at its own initiative applied to both stations, the monitoring program for both stations' splices was the same, the CECO engineer making the EQ decisions regarding the AMP splices was the same and the management decision makers and decisions were identical.
The statements made in my July 5, 1988 affidavit (attached hereto) with respect to Dresden Unit 3 are equally true for Quad Cities, Units 1 and 2, subject to the following clarifications:
- 1. Third paragraph: The Company shut down Quad Citles Unit 1 on December 6, 1986. Quad Cities Unit 2 was already in a refuel outage.
- 2. Fourth paragraph: The evaluation of the Quad Cities penetration splices was performed prior to tJovember 30, 1985. The Quad Cities Units 1 and 2 inspectiono were performed on tJovember 29, 1985 and October 24, 1985, respectively.
- 3. Seventh and ninth paragraphs: The May, 1986 tJRC inspection occurred at Dresden.
These minor clarifications excepted, all references to Dresden Unit 3 in my July 5, 1988 affidavit should be read to include Quad Cities, Units 1 and 2.
'W & /* g
, . -. James S. Abel EUBSCRIBE' A!JD SWORf1 to befcce x4 this df 2 day of '_' g gb a , 1988.
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