Similar Documents at Ginna |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML17250B3041999-10-20020 October 1999 Forwards Changes to Tech Specs Bases for Re Ginna Nuclear Power Plant.Change Bars Indicate Those Revs Which Have Been Incorporated IR 05000244/19990081999-10-14014 October 1999 Forwards Insp Rept 50-244/99-08 on 990809-0919.Severity Level IV Violation of NRC Requirements Occurred & Being Treated as non-cited Violation Consistent with App C of Enforcement Policy ML17265A7651999-10-0808 October 1999 Forwards Fifteen Relief Requests That Will Be Utilized for Ginna NPP Fourth Interval ISI Program That Will Start on Jan 1,2000.Attachment 1 Includes Summaries & Detailed Description of Each Relief Request ML17265A7631999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 43 to Address Volumetric Examination Limitations (Less than 90%) Associated with a & B RHR Heat Exchanger Outlet Nozzle to Shell Welds.Approval Is Requested by Dec 31,2000 ML17265A7641999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 42 to Address Volumetric Examinations Limitations (Less than 90%) Associated with Eight Class 1 Identified Welds or Areas of Reactor Pressure Vessel ML20212J3561999-09-30030 September 1999 Forwards Four Copies of Re Ginna NPP Training & Qualification Plan for Security Officers, Rev 7,dtd 990930. Synopsis of Changes,Encl.Encl Withheld Per 10CFR73.21 ML20212J3801999-09-30030 September 1999 Forwards Four Copies of Rev to Re Ginna NPP Security Plan.Rev Changes Contingency Weapons Available to Response Force to Those Most Effective in Current Defensive Strategy.Encl Withheld Per 10CFR73.21 IR 05000244/19990051999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7571999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs IR 05000244/19992011999-09-24024 September 1999 Forwards Insp Rept 50-244/99-201 (Operational Safeguards Response Evaluation) on 990621-24.No Violations Noted. Primary Purpose of Osre to Assess Licensee Ability to Respond to External Threat.Insp Rept Withheld ML17265A7461999-08-31031 August 1999 Submits Response to NRC Administrative Ltr 95-03,rev 2, Availability of Reactor Vessel Integrity Database,Version, Dtd 990726 ML17265A7401999-08-26026 August 1999 Requests Approval for Use of Relief Request Number 35 Re Use of ASME Section XI Code,1995 Edition,1996 Addenda.Code Will Be Used to Develop Plant Fourth 10-year Interval ISI Program on Class 1,2 & 3 Components ML17265A7411999-08-26026 August 1999 Forwards LER 99-004-01 Re Plant Being Outside Design Basis Due to Containment Recirculation Fan Moisture Separator Vanes Being Incorrectly Installed.Part 21 Notification of 990512 Is Being Rescinded ML17265A7451999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Rept for Six Months Ending 990630,per 10CFR26.71(d) ML17250B3021999-08-23023 August 1999 Informs That Util & NRC Had Conference Call on 990816 to Review Approach in Responding to Questions,As Result of Questions Re Main Steam Check Valve Performance Included in Insp Rept 50-244/99-05,dtd 990806 ML17265A7271999-07-30030 July 1999 Forwards 10CFR21 Interim Rept Per Reporting of Defects & Noncompliance,Section 21 (a) (2).Interim Rept Prepared Because Evaluation Cannot Be Completed within 60 Days from Discovery of Deviation or Failure to Comply ML17265A7151999-07-23023 July 1999 Forwards LER 99-007-01 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Reactor Trip.Further Investigation of Event Identified Addl Corrective Actions ML17265A7061999-07-22022 July 1999 Forwards LER 98-003-02,re Actuations of CR Emergency Air Treatment Sys.All Creats Actuations,Including Those Originally Believed to Be Valid Actuations,Were,In Fact Invalid Actuations ML17265A7191999-07-21021 July 1999 Forwards Ginna Station ISI Rept for Refueling Outage Conducted in 1999 ML17265A7141999-07-21021 July 1999 Withdraws Relief Request 35 for Plant Inservice Insp Program Section XI Requirements,Submitted on 980806.Licensee Plans to Resubmit Relief Request,Which Includes Addl Level of Detail,In Near Future ML17265A7041999-07-16016 July 1999 Submits Info Re Specific Licensing Actions Which May Be Expected to Generate Complex Reviews,In Response to Administrative Ltr 99-02,dtd 990603 ML17265A6911999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Readiness Disclosure Attached ML17265A6871999-06-22022 June 1999 Forwards Response to RAI Made During 990225 Telcon Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Calculation Encl. Encl ML17265A6841999-06-21021 June 1999 Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment ML17265A6741999-06-15015 June 1999 Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT ML17265A6751999-06-11011 June 1999 Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification ML17309A6551999-06-0707 June 1999 Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML17265A6671999-06-0101 June 1999 Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301 ML17265A6641999-05-25025 May 1999 Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested ML17265A6611999-05-24024 May 1999 Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730 ML20206U0921999-05-13013 May 1999 Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21 ML17265A6461999-05-12012 May 1999 Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP ML17265A6411999-05-12012 May 1999 Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630 ML20206E7221999-04-29029 April 1999 Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21 ML20206H6911999-04-22022 April 1999 Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls ML17265A6271999-04-19019 April 1999 Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5 ML17309A6501999-04-14014 April 1999 Forwards Revised Ginna Station EOPs & Procedures Index ML17265A6121999-03-29029 March 1999 Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231 ML17265A6041999-03-24024 March 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618 ML17265A5671999-03-0101 March 1999 Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl ML17265A5641999-03-0101 March 1999 Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl ML17265A5551999-02-25025 February 1999 Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr ML17265A5561999-02-22022 February 1999 Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d) ML17265A5451999-02-12012 February 1999 Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii) ML17309A6491999-02-12012 February 1999 Forwards Ginna Station EOPs ML17265A5431999-02-0909 February 1999 Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301 ML17265A5361999-02-0202 February 1999 Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl ML17311A0691999-01-25025 January 1999 Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date ML17311A0671999-01-14014 January 1999 Forwards Revised Emergency Operating Procedures for Re Ginna NPP ML17265A5131999-01-12012 January 1999 Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17250B3041999-10-20020 October 1999 Forwards Changes to Tech Specs Bases for Re Ginna Nuclear Power Plant.Change Bars Indicate Those Revs Which Have Been Incorporated ML17265A7651999-10-0808 October 1999 Forwards Fifteen Relief Requests That Will Be Utilized for Ginna NPP Fourth Interval ISI Program That Will Start on Jan 1,2000.Attachment 1 Includes Summaries & Detailed Description of Each Relief Request ML17265A7631999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 43 to Address Volumetric Examination Limitations (Less than 90%) Associated with a & B RHR Heat Exchanger Outlet Nozzle to Shell Welds.Approval Is Requested by Dec 31,2000 ML17265A7641999-10-0505 October 1999 Requests Approval for Use of Relief Request Number 42 to Address Volumetric Examinations Limitations (Less than 90%) Associated with Eight Class 1 Identified Welds or Areas of Reactor Pressure Vessel ML20212J3561999-09-30030 September 1999 Forwards Four Copies of Re Ginna NPP Training & Qualification Plan for Security Officers, Rev 7,dtd 990930. Synopsis of Changes,Encl.Encl Withheld Per 10CFR73.21 ML20212J3801999-09-30030 September 1999 Forwards Four Copies of Rev to Re Ginna NPP Security Plan.Rev Changes Contingency Weapons Available to Response Force to Those Most Effective in Current Defensive Strategy.Encl Withheld Per 10CFR73.21 IR 05000244/19990051999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7571999-09-24024 September 1999 Forwards More Detailed Response Re Main Steam Check Valve Performance Questions Arising from NRC Insp Rept 50-244/99-05 Following Completion of Independent Assessment Being Performed by Duke Engineering & Svcs ML17265A7461999-08-31031 August 1999 Submits Response to NRC Administrative Ltr 95-03,rev 2, Availability of Reactor Vessel Integrity Database,Version, Dtd 990726 ML17265A7401999-08-26026 August 1999 Requests Approval for Use of Relief Request Number 35 Re Use of ASME Section XI Code,1995 Edition,1996 Addenda.Code Will Be Used to Develop Plant Fourth 10-year Interval ISI Program on Class 1,2 & 3 Components ML17265A7411999-08-26026 August 1999 Forwards LER 99-004-01 Re Plant Being Outside Design Basis Due to Containment Recirculation Fan Moisture Separator Vanes Being Incorrectly Installed.Part 21 Notification of 990512 Is Being Rescinded ML17250B3021999-08-23023 August 1999 Informs That Util & NRC Had Conference Call on 990816 to Review Approach in Responding to Questions,As Result of Questions Re Main Steam Check Valve Performance Included in Insp Rept 50-244/99-05,dtd 990806 ML17265A7451999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Rept for Six Months Ending 990630,per 10CFR26.71(d) ML17265A7271999-07-30030 July 1999 Forwards 10CFR21 Interim Rept Per Reporting of Defects & Noncompliance,Section 21 (a) (2).Interim Rept Prepared Because Evaluation Cannot Be Completed within 60 Days from Discovery of Deviation or Failure to Comply ML17265A7151999-07-23023 July 1999 Forwards LER 99-007-01 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Reactor Trip.Further Investigation of Event Identified Addl Corrective Actions ML17265A7061999-07-22022 July 1999 Forwards LER 98-003-02,re Actuations of CR Emergency Air Treatment Sys.All Creats Actuations,Including Those Originally Believed to Be Valid Actuations,Were,In Fact Invalid Actuations ML17265A7191999-07-21021 July 1999 Forwards Ginna Station ISI Rept for Refueling Outage Conducted in 1999 ML17265A7141999-07-21021 July 1999 Withdraws Relief Request 35 for Plant Inservice Insp Program Section XI Requirements,Submitted on 980806.Licensee Plans to Resubmit Relief Request,Which Includes Addl Level of Detail,In Near Future ML17265A7041999-07-16016 July 1999 Submits Info Re Specific Licensing Actions Which May Be Expected to Generate Complex Reviews,In Response to Administrative Ltr 99-02,dtd 990603 ML17265A6911999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701.Readiness Disclosure Attached ML17265A6871999-06-22022 June 1999 Forwards Response to RAI Made During 990225 Telcon Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Calculation Encl. Encl ML17265A6841999-06-21021 June 1999 Informs That Util Wishes to Amend Extend of Alternate Exams Provided for Relief Request Re ISI Program ASME Section XI Require Exams for First 10-Yr Interval for Containment ML17265A6741999-06-15015 June 1999 Submits Annual ECCS Rept IAW 10CFR50.46(a)(3)(ii) Requirements.No Changes Have Been Made to Large Break LOCA PCT & Small Break LOCA PCT ML17265A6751999-06-11011 June 1999 Responds to NRC RAI Re Licensee GL 96-05 Program.Encl Info Verifies That Util Is Implementing Provisions of JOG Program on MOV Periodic Verification ML17309A6551999-06-0707 June 1999 Responds to NRC 990310 RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML17265A6671999-06-0101 June 1999 Requests Approval of Ginna QA Program for Radioactive Matl Packages,Form 311,approval Number 0019.Ginna QA Program for Station Operation, Was Most Recently Submitted to NRC by Ltr Dtd 981221 & Supplemented on 990301 ML17265A6641999-05-25025 May 1999 Forwards Addl Info on Use of GIP Method a for Re Ginna Nuclear Power Plant.Copy of Re Ginna Station USI A-46 Outlier Resolution Table as Requested ML17265A6611999-05-24024 May 1999 Forwards LER 99-007-00 Re Personnel Error Which Caused Two Channels to Be in Tripped Condition,Resulting in Rt.Util Is Planning to Submit Suppl to LER by 990730 ML20206U0921999-05-13013 May 1999 Forwards Four Copies of Rev R to Gnpp Security Plan,Per Provisions of 10CFR50.54(p).Rev Clarifies Armed Response Team Assignments & Does Not Degrade Physical Security Effectiveness.Rev Withheld,Per 10CFR73.21 ML17265A6461999-05-12012 May 1999 Forwards 1998 Annual Radioactive Effluent Release Rept & 1998 Annual Radiological Environ Operating Rept, for Re Ginna NPP ML17265A6411999-05-12012 May 1999 Forwards LER 99-004-00 IAW 10CFR50.73 & 10CFR21.Further Assessment Will Be Provided in Suppl to LER by 990630 ML20206E7221999-04-29029 April 1999 Forwards Four Copies of Rev Q to Re Ginna Nuclear Power Plant Security Plan,Per 10CFR50.54(p).Changes Do Not Degrade Physical Security Effectiveness.Encl Withheld,Per 10CFR73.21 ML20206H6911999-04-22022 April 1999 Forwards Info Requested During Informal Telcon on 980408 Concerning Upcoming Osre at Ginna Station.Info Requested Listed.Without Encls ML17265A6271999-04-19019 April 1999 Forwards Rev 0 & Rev 1 to Colr,Cycle 28 for Re Ginna NPP, Per TS 5.6.5 ML17309A6501999-04-14014 April 1999 Forwards Revised Ginna Station EOPs & Procedures Index ML17265A6121999-03-29029 March 1999 Forwards Rept on Status of Decommissioning Funding for Re Ginna Npp,For Which Rg&E Is Sole Owner,Per 10CFR50.75. Data Presented Herein,Current as of 981231 ML17265A6041999-03-24024 March 1999 Forwards LER 99-001-00,IAW 10CFR50.73(a)(2)(ii)(B) & 10CFR21.Addl Analyses Are Being Performed to Support Future Cycle Operation & Supplemental LER Is Scheduled to Be Submitted by 990618 ML17265A5641999-03-0101 March 1999 Forwards Response to NRC 990217 RAI Concerning Changes to QA Program for Re Ginna Station Operation.Rg&E Is Modifying Changes Requested in 981221 Submittal.Modified QA Program,Encl ML17265A5671999-03-0101 March 1999 Forwards Application for Amend to License DPR-18,to Revise TSs Battery Cell Parameters Limit for Specific Gravity (SR 3.8.6.3 & SR 3.8.6.6).Supporting Tss,Encl ML17265A5551999-02-25025 February 1999 Informs That Util Is in Process of Revising fitness-for-duty Program,Developed in Accordance with 10CFR26.Util Will Continue to Use Dept of Health & Human Svcs Certified Test Facility for Majority of Tests During Yr ML17265A5561999-02-22022 February 1999 Forwards FFD Performance Data Rept for Six Months Ending 981231,per 10CFR26.71(d) ML17265A5451999-02-12012 February 1999 Forwards Simulator Four Year Certification Rept,Per 10CFR55.45(b)(5)(ii) ML17309A6491999-02-12012 February 1999 Forwards Ginna Station EOPs ML17265A5431999-02-0909 February 1999 Supplements 980806 Relief Request with Attached Table.Util Third 10-Yr ISI of Reactor Vessel Being Performed During 1999 Refueling Outage,Beginning on 990301 ML17265A5361999-02-0202 February 1999 Forwards Response to NRC 981203 RAI Re Resolution of Unresolved Safety Issue USI A-46.Util Does Not Agree with NRCs Interpretation.Detailed Bases,Encl ML17311A0691999-01-25025 January 1999 Forwards Revs to Ginna Station Emergency Plan Implementing Procedures (Epips).Previous Rev Had Incorrect Effective Date ML17311A0671999-01-14014 January 1999 Forwards Revised Emergency Operating Procedures for Re Ginna NPP ML17265A5131999-01-12012 January 1999 Forwards Revised Cover Page for Ginna Station Technical Requirements Manual (Trm), Rev 7,correcting Error in Effective Date ML17265A5111999-01-11011 January 1999 Requests Relief Per 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME Bp&V Code for ISI Program.Relief Requests 37,38 & 39 Encl ML17265A5101999-01-11011 January 1999 Requests Relief Per to 10CFR50.55a(a)(3)(ii) from Certain Requirements of Section XI of ASME B&PV Code for ISI Program.Relief Request 40 Encl 1999-09-30
[Table view] Category:STATE/LOCAL GOVERNMENT TO NRC
MONTHYEARML20079F4231983-01-10010 January 1983 Requests ASLB Issue Order Indicating That State of Ny,Party to Proceeding & Not Required to File Addl Petition for Leave to Intervene.If Request Denied,Submittal Should Be Considered as Petition to Intervene as Interested State ML20070J8061982-11-0101 November 1982 FOIA Request for Seven Categories of Info.Documents Will Be Used in PSC Case 28166 on Behalf of Rochester Gas & Electric Corp Ratepayers Re 820125 Accident at Facility.Waiver of Fees Requested ML20065B2921982-10-0404 October 1982 Forwards Rept Rochester Gas & Electric Corp Re Ginna Incident of 820125. Affidavits from J Lyons & R Zimmerman Attesting to Accuracy of Original Conclusions Re Steam Generator Tube Failure Requested ML19309D5321980-02-13013 February 1980 Comments on Proposed Rule 10CFR50:plant Should Be Kept Open While Emergency Plan Is Upgraded for Monroe County ML19260C1361979-08-0101 August 1979 Endorses Friends of the Earth Request That Reactor Activity at Etcheverry Hall,Univ of Ca,Be Suspended.Ca Assembly 790911 Endorsement Encl 1983-01-10
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' STATE'0F NEW YORK DEFARTMENT OF PUBLIC SERVICE THREE EMPIRE STATE PLAZA, ALBANY 12223 PUSUC SERVICE COMMISSION 0.SUL L. GIOI A DAVID E. BLABEY Chairmen . Counael EDWAID P. LARK 8N SAMUEL R. MADISON CAZMEL CARRINGTON MARR ) Secretary HAROLD A. JERRY, JR.
ANNE F. MEAD ClTHA D E SCHULER COSEMARY S. POOLER October 4, 1982
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Mr. William J. Dircks Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Dircks:
My purpose in writing is to seek the cooperation of your staff in a matter concerning the January 25, 1982, forced outage at the Ginna nuclear facility operated by the Rochester Gas & Electric Corporation (RG&E) due to a tube failure in the plant's steam generator.
The New York State Public Service Commission (PSC) has instituted a proceeding to investigate the causes of this outage and to determine whether replacement fuel costs incurred by the utility as a result of thic outage should be passed on to consumers. As a prelude to this proceeding, the Department of Public Service (DPS) staff submitted a report to the PSC on the ,
Ginna outage. The statement and conclusions contained in this i report are the focal point of the current proceeding.
The DPS report in itself relies in large part upon the NRC report, NUREG 0916. More importantly, several statements in the DPS report are based upon DPS staff discussions with NRC !
staff (Mr. James Lyons of your office and Mr. Roy Zimmerman of 1 the NRC's Region I office) . The Administrative Law. Judge in the PSC proceeding has requested that the accuracy the conclusions .
attributed to the NRC staff be verified.
- Enclosed is a copy of the DPS report. Also enclosed is a copy of a DPS response to a Consumer Protection Board information request regarding the DPS characterization of the views of Messrs. Lyons and Zimmerman. I request that Mr. Lyons review these documents and prepare an affidavit attesting to the accuracy of the representations of his conclusions that they l
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William J. Dircks October 4, 1982 contain, or noting any statements that are incorrect and require modification. A similar affidavit.will be sought from Mr. Zimmerman as well, although I understand that arrangements for his statement will have to be made through the regional office. Hopefully, the submission of these affidavits will obviate the need for formal appearances by any NRC personnel in the PSC proceeding.
Please note that DPS staff must submit testimony in the PSC proceeding on October 22, 1982. I hope to present the requested affidavits with that testimony. Please call me at (518) 474-4535 after you have reviewed the enclosed documents so that we may discuss the arrangement I have proposed. Thank you for your cooperation in this matter.
Very truly yours, yh FAMES W. BREW Staff Counsel Encs.
cc: Mitzi Young, Esq.
a y.-
INTERROGATORY #1 With regard to page 11 of the report, who at the NRC told DPS staff that "The NRC did not believe that RG&E's prior practices were inadequate based upon the information and circum-stances existing at the time of the accident"? To what prior practices does this statement refer? Please provide the names and titles of any NRC personnel who provided such an indication to DPS staff plus copies of any written materials or transcriptions of oral conversation in which such an indication was given. Please provide the approximate date upon which the indication was given.
Please indicate whether this is an official NRC position or determination or a personal view on the part of NRC staff personnel.
RESPONSE
Staff's statement that "the NRC did not believe that RG&E's prior practices were inadequate based upon the information and circumstances existing at the time of the accident" is based upon numerous telephone conversations between the DPS and NRC staffs. Conversations were held, primarily with Roy Zimmerman (NRC-Resident Inspector - Ginna) and Jim Lyons (NRC - Operating Reactors Project Manager for Ginna), at various times in February, March, April and May of 1982. Mr. Lyons was responsible for th'e NRC review of the Ginna repair program and the development of NUREG 0916, the report which identifies the " deficiencies" concerning RG&E's removal of the downcomer resistance rings. Mr. Lyons, in consultation with NRC management, outlined areas for NRC review, made assignments for individual areas of study by other NRC technical staff, received input from these staff members, and edited and developed NUREG 0918.
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INTERROGATORY #1 I Mr. Zimmerman was assigned the task of completing and submitting to Mr. Lyons a response to an NRC Task Interface Agreement (TIA) form regarding the quality assurance aspects of both the 1975 and 1982 repairs. That TIA identified three action steps that the Washington Office wanted Region I to complete, namely; 1) review the 1975 steam generator modification quality control procedures; 2) evaluate the adequacy of current steam generator maintenance procedures in terms of eleminating any identified problems; and, 3) prepare input for the Ginna restart Safety Evaluation Report and transmit to Mr. Jim Lyons.
Many of the conversations between Staff amd Messrs. Zimmernan and '.yons were for the purpose of understanding the NRC's point-of-view or nasis for finding these deficiencies. In our discussions, these gentlemen (and other members of the NRC's Quality Assurance Branch) indicated that they did not view RG&E's quality assurance program, including housekeeping practices, to be inadequate, either at the present time or in the past. The purpose of the NRC review and their point-of-view, noted above, should be closely considered when aSalyzing their reports.
No transcriptions of these telephone conversations were made.
The " prior practices" quoted from page 11 of Staff's report refers to RG&E practices in 1975.
In these discussions and meetings, the NRC staff personnel gave Staff their expert technical opinions; not official NRC rulings.
NRC staff reports NUREG 0909 and 0916 were, however, accepted by the NRC and serve as the basis for an official NRC ruling. The fact that RG&E was not cited by the NRC, as is usually the case when a nuclear
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plant does not meet NRC standards leads Staff to conclude that the of ficial NRC view comports with those technical opinions,
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INTERROGATORY # 2 With regard to page 11 of the report, who at the NRC told DPS staff.that "the purpose of this assessment was to point out that RG&E had improved its practices"? Please provide the names and titles of any NRC staff personnel who made such a statement or gave such an indication to DPS staff. Please provide copies of any written materials or transcriptions of oral conversations in which such a statement was made or indication given. Please identify whether this is an official NRC position or determination or a personal view on the part of NRC staff personnel.
RESPONSE
Messrs. Lyons and Zimmerman of the NRC explained to DPS staff that the purpose of their review of quality assurance and maintenance work was primarily to ensure that RG&E would take adequate precautions to eliminate the possibility of introducing foreign objects into the steam generators during 1982 repair and modification work. In conducting its review the NRC examined the 1975 quality assurance and maintenance practices, then compared the two methods.
They concluded that the 1982 methods were improved over the 1975 me thods . -
As noted in the response to question #1, no transcriptions of these conversations were made. The answers to the remainder of this question are the same as in response fl.
4 INTERROGATORY #4 With regard to page 11 of the report, did DPS Staff ask RG&E whether the company had performed a post-maintenance accountability inspection of the removed resistance plates to ensure all pieces were accounted for? If not, why not? If yes, please explain RG&E's response. Did DPS Staff discuss this criticism with NRC or ask for further explanation or substantiating evidence? If yes, please provide any material provided by NRC and explain NRC's response.
RESPONSE
Yes, Staff discussed this matter with RG&E personnel.
The company explained that the process of removing the downcomer flow resistance ring was carefully preplanned.
This planning involved consultation with Westinghouse, developing written procedures, training personnel and establishing routine quality control surveillance. The procedure called for blanketing the area and using catch troughs to collect foreign objects. The flow resistance rings that were removed were radioactive and upon removal from the steam generator were bagged in plastic and removed from the work area and the site as radioactive waste. No subsequent accountability inspection was performed because the company believed that it had taken the adequate precautions necessary to preclude the introduction of foreign objects. Staff's discussiom with the NRC are described in responses #1 and #2. No additional materials were requested of the NRC.
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INTERROGATORY #5 With regard to page 11 of the report, did DPS Staff ask RG&E whether the company had inspected and ensured that the blanket material was properly sealed prior to the initiation of work on the removal of the downcomer flow resistance plate? If not, why not? If yes, please provide RG&E 's res]pnse. Did DPS discuss this criticism with NRC or ask for further explanation or substantiating evidence or materials? If yes, please provide any material provided by NRC and explain NRC's response.
RESPONSE
Staff's discussions with RG&E on this matter were the same as those described in the answer to interrogatory #3.
Staff discussed this item with the NRC in order to determine the basis for their identification of the company's deficiency.
The NRC found that RG&E's procedure did not independently document quality control inspec'tions aimed to ensure that the blanket material was properly sealed prior to the initiation of work.
The NRC found no surveillance reports which documented that the seal was inspected. The procedure did, however, document that personnel performing the work properly installed the blanket prior to cutting operations. NRC's criticism went to the fact that the quality control inspector did not make an independent record of his observations of the work being done.
Attached for your information is a copy of the downcomer flow resistance ring removal procedure.
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INTERROGATORY #6 With regard to page 11 of the report, did DPS Staff ask RG&E to respond to the NRC criticism that the company i had failed to provide a mechanical barrier to catch dropped '
material of a sufficient design to compensate for the poor blanket seal? If not, why not? If yes, please explair. RG&E's response. Did DPS Staff discuss this criticism with NRC or ask for further explanation or substantiating evidence or materials? If yes, please provide any material provided by NRC and explain NRC's response.
RESPONSE
Staff's discussions with RG&E concerning the NRC's criticisms are described in the response to Interrogatory ' 3.
Staff's discussions with the NRC concerning these criticisms are discussed in the response to Interrogatories #1 and #2.
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Did DPS Staff ask RG:.E --
.- .ond to the NRC criticism that the company had failed te ,.urfc1 an adequate inspection of the steam generator secondary s:de t, asure identification and retrieval of all foreign materiele If act, why not? If yes, please explain RG&E's response. Did DP.1 M.cff discuss this criticism with NRC or ask for further e>.pk nation or substantiating evidence or materials? If yes, please provide e , material provided by NRC and explain NRC's response.
RESPONSE
Staff did not specifically ask RG&E to respond to this NRC noted " deficiency". As noted previously, the NRC report compares the quality control methods and practices used in 1982 with those used in 1975 but does not cite the company for violating any standards applicable in 1975.
Staff has discussed visual secondary side inspections with RG&E and the NRC. Certainly, the extensive video camera and fiber optic inspections performed by the company in 1982 were a marked improvement to the lac:. of secondary side visual inspection in 1975. However, neither PSC Staff, the NRC nor the company is aware of whether the inspection technology used in 1982 was available in 1975. If it was, it was not used by either RG&E or the industry in general for secondary side steam generator inspections.
The NRC is developing requirements for steam generator secondary side video inspections, but no such requirements are currently effective.
Staff did not request additional supporting evidence from the NRC.
INTERROGATORY #8 r With regard to the statement on page 12 of the report that "The NRC's quality assurance concerns which existed in 1975 were generally implemented in a manner consistent with NRC and industry philosophy at that time." How did DPS staff learn what the " industry practice" was "at that time"? Please provide the names, titles, addresses and telephone numbers of all individuals to whom DPS staff spoke to learn the " industry practice at that time." Provide copies of any materials identifying the " industry practice" in 1975 of which DPS staff has possession and the titles of any other such materials of which DPS staff does not have possesslun.
RESPONSE
Staff's knowledge of industry practice in 1975 is based upon first hand experience in the field of nuclear power at the time. The Consumer Protection Boarl may wish to review such items as the 1974 American Society of Mechanical Engineers - Boilers and Pressure Vessel Code with its subsequent Addenda; the 1974 through 1982 copies of 10 CFR Parts 0 through 199; copies of NRC Regulatory Guides (formerly AEC Regulatory Guides) in effect at the time; correspondence between the NRC and various utilities regarding issues of quality assurance at that time; or what is..
known as the NRC rainbow books on quality assurance. Staff has a copy of the Brown Book in which the NRC outlined its position as of October 26, 1973.
Staff confirmed its opinions concerning industry ,
practice with the NRC personnel previously referenced.
These' documents are very voluminous, and it is not practical to provide copies of all of this material. Staff will, however, make these documents available for review as we have in the past.