Similar Documents at Perry |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARPY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20217F3901999-10-14014 October 1999 Discusses Request That Proprietary Document NEDE-32907P,DRF A22-0084-53, Safety Analysis Rept for Perry NPP 5% Power Uprate, Class III Dtd Sept 1999 Be Withheld.Determined Document Proprietary & Will Be Withheld ML20217G9201999-10-14014 October 1999 Discusses Utils Request for Approval of Quality Assurance Program Changes PY-CEI-NRR-2435, Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect1999-10-13013 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect ML20212K9271999-09-30030 September 1999 Refers to 990927 Meeting Conducted at Perry Nuclear Power Plant to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PSA Staff ML20212J1451999-09-30030 September 1999 Forwards Order,In Response to 990505 Application PY-CEI/NRR- 2394L.Order Approves Conforming License Amend Which Will Be Issued & Made Effective When Transfer Completed ML20217E7111999-09-30030 September 1999 Documents Telcon Conducted on 990929 Between M Underwood of Oh EPA & D Tizzan of Pnpp,Re Request to Operate Pnpp Sws,As Is,Until Resolution Can Be Obtained ML20212G4161999-09-24024 September 1999 Informs of Completion of Licensing Action for Generic Ltr 98-01, Y2K Readiness of Computer Systems at Nuclear Power Plants, for Perry Nuclear Power Plant ML20212G5811999-09-23023 September 1999 Informs That Licenses for Ta Lentz,License SOP-31449,PJ Arthur,License SOP-30921-1 & Dp Mott,License SOP-31500 Are Considered to Have Expired,Iaw 10CFR50.74(a),10CFR55.5 & 10CFR55.55 PY-CEI-NRR-2432, Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams1999-09-21021 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams PY-CEI-NRR-2428, Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions1999-09-16016 September 1999 Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions ML20212D0151999-09-14014 September 1999 Requests Cancellation of NPDES Permit 3II00036.Permit Has Been Incorporated in Permit 3IB00016*ED.Discharge Point Sources & Associated Fees Currently Covered Under Permit 3IB00016*ED ML20212A8371999-09-13013 September 1999 Forwards Insp Rept 50-440/99-13 on 990712-30 & Notice of Violation.Insp Included Evaluation of Engineering Support, Design Change & Modification Activities,Internal Assessment Activities & Corrective Actions ML20217A8971999-09-0909 September 1999 Forwards Insp Rept 50-440/99-09 on 990709-0825.One Violation of NRC Requirements Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy PY-CEI-NRR-2431, Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages1999-09-0909 September 1999 Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages ML20211Q6911999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Perry Operator License Applicants During Wks of 010108 & 15.Validation of Exam Will Occur at Station During Wk of 001218 IR 05000440/19990011999-08-31031 August 1999 Requests That Page Number 4, P2 Status of EP Facilities, Equipment & Resources, of Insp Rept 50-440/99-01 Be Replaced with Encl Rev PY-CEI-NRR-2425, Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.21999-08-26026 August 1999 Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.2 PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20210Q8421999-08-13013 August 1999 First Final Response to FOIA Request for Documents.Records Listed in App a Being Released in Entirety & Records Listed in App B Being Withheld in Part (Ref FOIA Exempt 5) ML20210R7861999-08-12012 August 1999 Forwards Insp Rept 50-440/99-12 on 990712-16.No Violations Noted.New Emergency Preparedness Program Staff & Mgt Personnel Were Professional & Proactive ML20210S3961999-08-11011 August 1999 Requests That Ten Listed Individuals Be Registered to Take 991006 BWR Gfes of Written Operating Licensing Exam.Two Listed Personnel Will Have Access to Exams Before Exams Are Administered PY-CEI-NRR-2423, Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready1999-08-10010 August 1999 Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready PY-CEI-NRR-2421, Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-9906301999-08-10010 August 1999 Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-990630 ML20210Q7981999-08-10010 August 1999 Informs That Intention to Utilize Sulfuric Acid in Pnpp Circulating Water Sys to Lower Ph Is Anticipated to Be Completed in Nov ML20210Q5831999-08-10010 August 1999 Requests Permission to Chemically Treat CWS for Algae Due to Cooling Water Basin Becoming Infected with Algae of Various Types PY-CEI-NRR-2422, Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 9808261999-08-10010 August 1999 Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 980826 ML20210K6331999-08-0404 August 1999 Submits Response to Requests for Addl Info to GL 92-01,Rev 1, Reactor Vessel Structural Integrity, for Perry Nuclear Plant,Unit 1 PY-CEI-NRR-2417, Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-60001999-08-0202 August 1999 Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-6000 ML20210G8411999-07-28028 July 1999 Informs That Based on Determination That Rev 14 Changes to Various Portions of Perry Nuclear Power Plant Emergency Plan Does Not Decrease Effectiveness of Licensee Emergency Plan & Meets Standard of 10CFR50.47(b),no NRC Approval Required ML20210E0661999-07-22022 July 1999 Forwards Insp Rept 50-440/99-08 on 990518-0708.No Violations Noted.Overall Conduct of Activities at Perry Facility, Conservative & Professional with Continuing Focus on Safety PY-CEI-NRR-2419, Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld1999-07-21021 July 1999 Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld PY-CEI-NRR-2415, Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates1999-07-19019 July 1999 Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates ML20210A6441999-07-15015 July 1999 Advises That Listed Operator Licenses for Company Personnel Have Expired,As of 990715,per 10CFR50.74(a) & 10CFR55.5. Individuals Listed Have Assumed Responsibilities at Pnpp That Do Not Require Operator Licenses ML20209E5951999-07-0909 July 1999 Ltr Contract:Task Order 46, Perry Engineering & Technical Support (E&Ts) Insp, Under Contract NRC-03-98-021 ML20209D5931999-07-0101 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Investigation Rept 3-98-005 Issued on 990510.Corrective Actions Will Be Examined During Future Inspections ML20211A3881999-06-30030 June 1999 Supplements Re NRC Incomprehensible Enforcement Inactions.Understands That NRC Claiming Hands Tied in Matter Re Discrimination Violation at Perry Npp.Requests That NRC Take Listed Two Actions PY-CEI-NRR-2410, Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant1999-06-29029 June 1999 Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant PY-CEI-NRR-2413, Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 9907061999-06-29029 June 1999 Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 990706 PY-CEI-NRR-2403, Submits Response to RAI Re GL 96-05 Program at Plant1999-06-29029 June 1999 Submits Response to RAI Re GL 96-05 Program at Plant ML20196H9641999-06-29029 June 1999 Confirms 990615 Telcon Request with J Lieberman for Addl Time to Respond to Enforcement Action 99-012.FirstEnergy Has 60 Days to Respond to EA PY-CEI-NRR-2412, Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-19991999-06-28028 June 1999 Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-1999 ML20211A3991999-06-28028 June 1999 Submits Concerns Re Proposed Changes to Enforcement Policy. Believes That NRC Existing Regulations & Policies Provide Adequate Controls & That NRC Not Administering Consistent Enforcement Policies in Response to Discriminatory Actions ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 PY-CEI-NRR-2405, Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt1999-06-14014 June 1999 Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt ML20195H9051999-06-10010 June 1999 Forwards Two License Renewal Applications Consisting of NRC Form 398 & NRC Form 396 for Bk Carrier,License OP-30997 & Jt Steward,License OP-30564-1 ML20212H5841999-06-10010 June 1999 Responds to NRC Notice of Level III Violation Received by K Wierman.Corrective Actions:K Wierman Has Been Dismissed from Position at Perry NPP PY-CEI-NRR-2408, Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval1999-06-10010 June 1999 Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval ML20195G6741999-06-10010 June 1999 Forwards Insp Rept 50-440/99-03 on 990407-0517.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy PY-CEI-NRR-2407, Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records1999-06-0909 June 1999 Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARPY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl PY-CEI-NRR-2435, Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect1999-10-13013 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect ML20212G5811999-09-23023 September 1999 Informs That Licenses for Ta Lentz,License SOP-31449,PJ Arthur,License SOP-30921-1 & Dp Mott,License SOP-31500 Are Considered to Have Expired,Iaw 10CFR50.74(a),10CFR55.5 & 10CFR55.55 PY-CEI-NRR-2432, Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams1999-09-21021 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams PY-CEI-NRR-2428, Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions1999-09-16016 September 1999 Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions ML20212D0151999-09-14014 September 1999 Requests Cancellation of NPDES Permit 3II00036.Permit Has Been Incorporated in Permit 3IB00016*ED.Discharge Point Sources & Associated Fees Currently Covered Under Permit 3IB00016*ED PY-CEI-NRR-2431, Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages1999-09-0909 September 1999 Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages PY-CEI-NRR-2425, Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.21999-08-26026 August 1999 Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.2 PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20210S3961999-08-11011 August 1999 Requests That Ten Listed Individuals Be Registered to Take 991006 BWR Gfes of Written Operating Licensing Exam.Two Listed Personnel Will Have Access to Exams Before Exams Are Administered PY-CEI-NRR-2421, Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-9906301999-08-10010 August 1999 Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-990630 PY-CEI-NRR-2423, Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready1999-08-10010 August 1999 Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready PY-CEI-NRR-2422, Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 9808261999-08-10010 August 1999 Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 980826 PY-CEI-NRR-2417, Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-60001999-08-0202 August 1999 Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-6000 PY-CEI-NRR-2419, Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld1999-07-21021 July 1999 Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld PY-CEI-NRR-2415, Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates1999-07-19019 July 1999 Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates ML20210A6441999-07-15015 July 1999 Advises That Listed Operator Licenses for Company Personnel Have Expired,As of 990715,per 10CFR50.74(a) & 10CFR55.5. Individuals Listed Have Assumed Responsibilities at Pnpp That Do Not Require Operator Licenses ML20211A3881999-06-30030 June 1999 Supplements Re NRC Incomprehensible Enforcement Inactions.Understands That NRC Claiming Hands Tied in Matter Re Discrimination Violation at Perry Npp.Requests That NRC Take Listed Two Actions PY-CEI-NRR-2403, Submits Response to RAI Re GL 96-05 Program at Plant1999-06-29029 June 1999 Submits Response to RAI Re GL 96-05 Program at Plant PY-CEI-NRR-2413, Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 9907061999-06-29029 June 1999 Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 990706 PY-CEI-NRR-2410, Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant1999-06-29029 June 1999 Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant ML20211A3991999-06-28028 June 1999 Submits Concerns Re Proposed Changes to Enforcement Policy. Believes That NRC Existing Regulations & Policies Provide Adequate Controls & That NRC Not Administering Consistent Enforcement Policies in Response to Discriminatory Actions PY-CEI-NRR-2412, Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-19991999-06-28028 June 1999 Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-1999 ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 PY-CEI-NRR-2405, Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt1999-06-14014 June 1999 Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt ML20212H5841999-06-10010 June 1999 Responds to NRC Notice of Level III Violation Received by K Wierman.Corrective Actions:K Wierman Has Been Dismissed from Position at Perry NPP ML20195H9051999-06-10010 June 1999 Forwards Two License Renewal Applications Consisting of NRC Form 398 & NRC Form 396 for Bk Carrier,License OP-30997 & Jt Steward,License OP-30564-1 PY-CEI-NRR-2408, Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval1999-06-10010 June 1999 Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval PY-CEI-NRR-2407, Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records1999-06-0909 June 1999 Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records PY-CEI-NRR-2404, Submits Rept of Reduction in PCT Greater than 50 F Due to Implementation of Ge,Safr/Gestr LOCA Methodology for Fuel Cycle 8.Methodology Replaces Original LOCA Methodology1999-06-0707 June 1999 Submits Rept of Reduction in PCT Greater than 50 F Due to Implementation of Ge,Safr/Gestr LOCA Methodology for Fuel Cycle 8.Methodology Replaces Original LOCA Methodology ML20195E4561999-05-25025 May 1999 Submits Petition Per Other Actions Provision of 10CFR2.206,requesting That Radiation Protection Manager at Perry NPP Be Banned by NRC from Participation in Licensed Activities at & for Any NPP for at Least Five Yrs PY-CEI-NRR-2401, Forwards Changes to ERDS Data Point Library & Communication Survey for Perry Nuclear Power Plant.Changes Are Identified by Margin Rev Bars1999-05-20020 May 1999 Forwards Changes to ERDS Data Point Library & Communication Survey for Perry Nuclear Power Plant.Changes Are Identified by Margin Rev Bars PY-CEI-NRR-2402, Notifies of Completion of Plant Core Shroud Insp in Accordance with GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs,1999-05-18018 May 1999 Notifies of Completion of Plant Core Shroud Insp in Accordance with GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, PY-CEI-NRR-2394, Forwards Application for Order & Conforming License Amend for Transfer of Interest in OL NPF-58 for Pnpp.Authorization of Ceic to Possess Dl 13.74% Undivided Ownership in Pnpp, Requested1999-05-0505 May 1999 Forwards Application for Order & Conforming License Amend for Transfer of Interest in OL NPF-58 for Pnpp.Authorization of Ceic to Possess Dl 13.74% Undivided Ownership in Pnpp, Requested PY-CEI-NRR-2397, Forwards Revised COLR Cycle 8, & Rev 1 to J11-03371SRLR, Supplemental Reload Licensing Rept for Pnpp,Unit 1 Reload 7,Cycle 8, IAW TS Section 5.6.51999-04-30030 April 1999 Forwards Revised COLR Cycle 8, & Rev 1 to J11-03371SRLR, Supplemental Reload Licensing Rept for Pnpp,Unit 1 Reload 7,Cycle 8, IAW TS Section 5.6.5 PY-CEI-NRR-2396, Provides post-examination Results of Weld Overlay Repair for FW Nozzle to safe-end Weld at Pnpp.Info Supplements Licensee 990325 & 0401 Ltrs Submitted to NRC That Requested Approval of Repair Plan for 1B13-N1C-KB FW Nozzle to safe-en1999-04-28028 April 1999 Provides post-examination Results of Weld Overlay Repair for FW Nozzle to safe-end Weld at Pnpp.Info Supplements Licensee 990325 & 0401 Ltrs Submitted to NRC That Requested Approval of Repair Plan for 1B13-N1C-KB FW Nozzle to safe-end Weld 05000440/LER-1999-002, Forwards LER 99-002-00, LCO 3.0.3 Entered Due to TS Bases Statement Interpretation. Action Occurred After RHR Pump Failed to Start.Plant at No Time Was in Condition Where Required Decay Heat Removal System Were Not Available1999-04-26026 April 1999 Forwards LER 99-002-00, LCO 3.0.3 Entered Due to TS Bases Statement Interpretation. Action Occurred After RHR Pump Failed to Start.Plant at No Time Was in Condition Where Required Decay Heat Removal System Were Not Available PY-CEI-NRR-2388, Forwards Annual Environ & Effluent Release Rept for Pnnp Unit 1 for 1998. Pnpp Had No Liquid Effluent Discharges in 1998 & All Other Release Points Were Well Below Applicable Limits1999-04-22022 April 1999 Forwards Annual Environ & Effluent Release Rept for Pnnp Unit 1 for 1998. Pnpp Had No Liquid Effluent Discharges in 1998 & All Other Release Points Were Well Below Applicable Limits PY-CEI-NRR-2371, Provides Suppl Response to Violations Noted in Insp Rept 50-440/98-18.Corrective Actions:Two Condition Rept Investigations Were Performed to Evaluate Issues Re Fire Protection Program & Addl Training Was Conducted1999-04-21021 April 1999 Provides Suppl Response to Violations Noted in Insp Rept 50-440/98-18.Corrective Actions:Two Condition Rept Investigations Were Performed to Evaluate Issues Re Fire Protection Program & Addl Training Was Conducted PY-CEI-NRR-2382, Forwards 1998 Annual Rept for Firstenergy Corp, for Perry Nuclear Power Plant & Davis-Besse Nuclear Power Station.Form 10-K Annual Rept to Us Securities & Exchange Commission for FY98 Also Encl1999-04-21021 April 1999 Forwards 1998 Annual Rept for Firstenergy Corp, for Perry Nuclear Power Plant & Davis-Besse Nuclear Power Station.Form 10-K Annual Rept to Us Securities & Exchange Commission for FY98 Also Encl PY-CEI-NRR-2392, Forwards Diskette Containing Pnpp Thermoluminescent Dosimeter Doses in Format Requested by Reg Guide 8.7.Without Diskette1999-04-19019 April 1999 Forwards Diskette Containing Pnpp Thermoluminescent Dosimeter Doses in Format Requested by Reg Guide 8.7.Without Diskette PY-CEI-NRR-2387, Documents Telcon Held Between NRC Staff & Members of Perry Nuclear Power Plant Staff on 990406,re Safety Evaluation for License Amend 1051999-04-14014 April 1999 Documents Telcon Held Between NRC Staff & Members of Perry Nuclear Power Plant Staff on 990406,re Safety Evaluation for License Amend 105 PY-CEI-NRR-2386, Forwards Copy of Application Submitted to FERC Proposing Transfer of Jurisdictional Transmission Facilities of Firstenergy Corp Operating Companies to American Transmission Sys,Inc.With One Oversize Drawing1999-04-0606 April 1999 Forwards Copy of Application Submitted to FERC Proposing Transfer of Jurisdictional Transmission Facilities of Firstenergy Corp Operating Companies to American Transmission Sys,Inc.With One Oversize Drawing ML20206N3361999-04-0505 April 1999 Informs NRR of Continued Events Re Transfer of Generation Assets Between Duquesne Light Co & Firstenergy.No Negotiated Settlement Between Firstenergy & Local 270 Pertaining to Generation Asset Swap Has Been Reached PY-CEI-NRR-2384, Provides Supplemental Info Re 990325 Request for Approval of Repair Plan for Feedwater Nozzle to safe-end Weld. Clarification Provided on Listed Three Items,Per 990329 Telcon with NRC1999-04-0101 April 1999 Provides Supplemental Info Re 990325 Request for Approval of Repair Plan for Feedwater Nozzle to safe-end Weld. Clarification Provided on Listed Three Items,Per 990329 Telcon with NRC PY-CEI-NRR-2383, Withdraws Inservice Exam Relief Requests IR-036 & IR-041, Submitted in Licensee to Nrc.Relief Request IR-041 Is Being Clarified with Respect to Alternative Proposed1999-04-0101 April 1999 Withdraws Inservice Exam Relief Requests IR-036 & IR-041, Submitted in Licensee to Nrc.Relief Request IR-041 Is Being Clarified with Respect to Alternative Proposed L-99-052, Forwards Info Concerning Dls Decommissioning Planning for Bvps,Units 1 & 2 & Pnpp Unit 1.DL Is Continuing to Utilize External Sinking Funds to Provide Financial Assurance for Nuclear Decommissioning Funding1999-03-30030 March 1999 Forwards Info Concerning Dls Decommissioning Planning for Bvps,Units 1 & 2 & Pnpp Unit 1.DL Is Continuing to Utilize External Sinking Funds to Provide Financial Assurance for Nuclear Decommissioning Funding ML20205H6171999-03-29029 March 1999 Forwards Util Consolidated Financial Statements for Twelve Month Period Ending 981231 & Internal Cash Flow Projection, Including Actual 1998 Data & Projections for 1999 PY-CEI-NRR-2377, Submits Decommissioning Repts for Bvps,Units 1 & 2,Davis- Besse Nuclear Power Station,Unit 1 & Perry Nuclear Power Plant,Unit 1,per 10CFR50.75(f)(1)1999-03-29029 March 1999 Submits Decommissioning Repts for Bvps,Units 1 & 2,Davis- Besse Nuclear Power Station,Unit 1 & Perry Nuclear Power Plant,Unit 1,per 10CFR50.75(f)(1) PY-CEI-NRR-2380, Requests Approval of Attached Repair Plan for Feedwater Nozzle to safe-end Weld N4C-KB.Proposed Weld Overlay Design & Installation Plan Details Included in Attachment 1. Attachment 2 Provides Applicable Preliminary Weld Procedure1999-03-25025 March 1999 Requests Approval of Attached Repair Plan for Feedwater Nozzle to safe-end Weld N4C-KB.Proposed Weld Overlay Design & Installation Plan Details Included in Attachment 1. Attachment 2 Provides Applicable Preliminary Weld Procedure 1999-09-09
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20059D6451990-08-31031 August 1990 Requests Dismissal of Ohio Edison Co Application to Suspend Antitrust License Conditions in OL & Follow Recommendation of Doj.Alleged Increase in Nuclear Power Costs Heightens Importance of Continued Imposition of Antitrust Conditions ML20059C9951990-08-27027 August 1990 Responds to Util Re Suspension of Antitrust License Conditions ML20059G1001990-07-24024 July 1990 Requests NRC Expeditious Disposition of Matter Re Ohio Edison 870918 Application to Suspend Antitrust License Conditions.Doj Position in Inconsistent W/Prior Analyses & W/Pertinent NRC Case Law.Jd Pace Affidavit Encl ML20151D8121988-07-15015 July 1988 Forwards Opposition of City of Clyde,Oh to Util Application to Suspend Antitrust Conditions at Facilities,Per 880616 53FR22589 & 53FR22590 ML20150D3541988-07-0505 July 1988 Forwards Response of Ohio Edison Co to Comments on Antitrust License Amend Application.Util Requests Commission Hold Present Proceeding on Application in Abeyance Pending Resolution of Court Action Filed on 880622 ML20197G9591988-06-0808 June 1988 Forwards Technical Rept, Analyses of Northeastern Ohio Seismicity & Tectonics, Which Responds to Ohio Citizens for Responsible Energy 880122 Petition for Immediate Action to Relieve Undue Risk Posed by Inadequate Seismic Design ML20155F2091988-05-27027 May 1988 Requests 30-day Extension Until 880703 to File Response to Cities of Clyde & Cleveland Re Util Antitrust License Amend Application,Due to Length of Comments.Nrc Antitrust Counsel Does Not Object to Granting Extension Based on Discussion ML20155F3831988-05-23023 May 1988 Forwards Tables of Contents & Appendices Inadvertently Omitted from City of Cleveland,Oh 880219 Answer to Util 870918 Application ML20147E8141988-02-29029 February 1988 Forwards American Municipal Power-Ohio,Inc Request for 30 Day Extension for Filing Comments ML20235A5361987-09-18018 September 1987 Forwards Application for Amend to License NPF-58,suspending Antitrust Conditions Insofar as Conditions Apply to Ohio Edison Co.Fee Paid ML20212N1301987-03-11011 March 1987 Forwards Final Draft Plant Operating Agreement Mentioned in Application for License Amend & Approval Re Sale & Leaseback Transactions.Agreement Currently Being Executed ML20212F4651987-03-0303 March 1987 Identifies Potential Equity Investors Wishing to Participate Directly or Through Subsidiary in Sale & Leaseback Transactions,Per Util 870123 Application for Amend to License NPF-58.Annual Repts & Supporting Documentation Encl ML20207Q5861987-01-23023 January 1987 Forwards Application for Amend to License NPF-58 Re Sale & Leaseback Transactions W/Ohio Edison Co.Fee Paid ML20206S2701986-09-17017 September 1986 Notifies of Address Change Effective on 860927.Requests Address on Encl List of Dockets Be Changed ML20214L6681986-09-0404 September 1986 Requests Encl Signature Page Be Substituted for Original Signature Page to MR Edelman 860902 Affidavit Attached to Licensee 860902 Response to Ocre Motion for Continuance.Svc List Encl ML20209B0071986-09-0202 September 1986 Advises That Sunflower Alliance Will Not Suppl or Amplify Notice of Reconsideration Filed on 860808.W Clements Directed to Destroy Notice of Appeal ML20212P0071986-08-28028 August 1986 Requests Scheduled 860905 Meeting Re Discussions/Possible Vote on Full Power OL for Unit 1 Be Stayed Pending Decision from Us Court of Appeals for Sixth Circuit in Ocre Vs NRC ML20214J9641986-08-12012 August 1986 Advises That Licensee Will Await Aslab Decision Before Responding to Ohio Citizens for Responsible Energy 860808 Petition to Reconsider Portions of Aslab 860725 Decision ALAB-841.Svc List Encl.Related Correspondence ML20203Q2991986-05-0505 May 1986 Advises That Per Encl Sec 860429 Order,Cleveland Electric Illuminating Co & Toledo Edison Co Now Subsidiaries of Centerior Energy Corp.Utils Will Continue as Electric Companies & as NRC Licensees & CP Holders ML20210L3931986-04-25025 April 1986 Confirms That Baseline Testing Referred to in Affidavit of Dr Green Completed Prior to Fuel Loading of Unit 1.Svc List Encl.Related Correspondence ML20203D7231986-04-16016 April 1986 Informs That Both Seismic Instrumentation & Hydrogen Control Equipment Will Be Accessible at Time of Aslab Visit,Per 860403 Telcon Re Hearing on Ocre Motion to Reopen Proceeding.Personal Info Requested by 860509.Svc List Encl ML20140A7291986-03-18018 March 1986 Forwards ACRS to Palladino Re ACRS Consideration of State of Oh 860131 Earthquake.Svc List Encl.Related Correspondence ML20141M9561986-02-25025 February 1986 Requests Denial of Ocre 860203 2.206 Petition to Prevent Fuel Loading or OL Issuance Until Assessment of 860131 Earthquake Complete.Encl Affidavits Confirm That Earthquake Did Not Adversely Affect Plant ML20214C8961986-02-19019 February 1986 Forwards Original Signature Page to Be Substituted in Affidavit of Ta Boss,Attachment 1 of Applicant to Commissioners ML20214C9961986-02-18018 February 1986 Responds to Dl Schlemmer 860204 2.206 Petition Requesting Plant Closure Due to Inadequate Seismic Design & Idcvp to Assess Integrity of Site QA Programs.Petition W/O Basis & Should Be Denied in All Respects ML20137U6861986-02-13013 February 1986 Forwards Amend 5 to Form U-1,recently Filed W/Securities & Exchange Commission,Providing Addl Info Re Proposed Affiliation Between Utils.W/Certificate of Svc ML20151U0301986-02-0505 February 1986 Informs of Intent to Respond to Assertions in Ocre Re Summary of 851218 Meeting Between NRC & Hydrogen Control Owners Group.Motion to Reopen Has Not Been Filed by Ocre.Svc List Encl.Related Correspondence ML20137N9701986-01-31031 January 1986 Forwards Amends 3 & 4 to Form U-1,recently Filed W/ Securities & Exchange Commission,To Provide Addl Info Re Proposed Affiliation Between Utils ML20137F1711986-01-14014 January 1986 Forwards 851213 Insp Rept Re 851120 Emergency Preparedness Exercise.Related Correspondence ML20136J0891986-01-0808 January 1986 Forwards Amend 2 to Sec Form U-1,providing Addl Info Re Proposed Affiliation Between Cleveland Electric Illuminating Co & Toledo Edison Co ML20141F5951986-01-0606 January 1986 Forwards Articles Re Turbine Missiles Cited in Memorandum & Order LBP-83-48,per Request.Related Correspondence ML20141F7161986-01-0606 January 1986 Informs of Typo in 851230 Applicant Answer to Ocre Motion to Reopen Record & Submit New Contentions. Steam Binding Should Read Steam Blanketing. W/Svc List ML20151P1341985-12-31031 December 1985 Forwards Original Signature Page to Affidavit of Kw Holtzclaw for Telecopy Attached to Applicant Answer to Ocre Motion to Reopen Record & to Submit New Contentions,Filed on 851230.Svc List Encl ML20138H9201985-12-12012 December 1985 Comments on Applicant Brief in Opposition to Intervenor Appeals from Concluding Partial Initial Decision.Footnote 94 Should Ref Defect W/Crankshaft Oil Hole Plugs as Failure Instead of Simply as Crack.W/Svc List ML20137U2571985-12-0404 December 1985 Forwards Corrected Table of Authorities to Applicant Brief in Opposition to Intervenors Appeals from Concluding Partial Initial Decision ML20205H2241985-11-13013 November 1985 Forwards Amend 1 to Form U-1 Recently Filed W/Securities & Exchange Commission to Provide Addl Info & Exhibits Re Proposed Affiliation Between Utils ML20133H9841985-10-14014 October 1985 Forwards Util to HR Denton Providing Updated Info on Facility Status & Readiness for Fuel Loading & Operation. Unit 1 May Be Ready to Load Fuel as Early as 851108.Svc List Encl.Related Correspondence ML20133J2571985-10-11011 October 1985 Forwards Original Signature Page to Gr Leidich Affidavit Attached to Applicant Response to Ocre Motion for Stay Pendente Lite ML20132C7691985-09-24024 September 1985 Forwards Util Re Unit 1 Status & Operational Readiness.Related Correspondence ML20135B7711985-09-0909 September 1985 Forwards News Release by State of Oh,Dept of Health Announcing State Policy on Distribution of Potassium Iodide.Svc List Encl.Related Correspondence ML20134G0511985-08-21021 August 1985 Forwards Util Updating Progress on Unit 1 During Jul 1985 for ASLB Info.Related Correspondence ML20134D2601985-08-14014 August 1985 Forwards 850805 Application & 850808 Registration Statement Filed W/Securities & Exchange Commission Re Proposed Affiliation Between Cleveland Electric Illuminating Co & Toledo Edison Co.Utils Will Be Subsidiaries of Holding Firm ML20133E5971985-08-0606 August 1985 Forwards Hydrogen Control Owners Group & Hydrogen Control Owners Group Rept on 1/4-Scale Scoping Test Results. Subj Test Program Part of Final Analysis Required by Hydrogen Rule.Related Correspondence ML20128M2761985-07-22022 July 1985 Forwards Util to NRC Re Progress Update for June 1985.Svc List Encl.Related Correspondence ML20129K1411985-07-19019 July 1985 Forwards EC Christiansen & WR Kanda Affidavits Re Placement, Operation & Safety Parameters of Check Valves Used in Lube Oil Generators & 850505 Fire in Reactor Bldg,Respectively ML20128R1171985-07-10010 July 1985 Forwards Recent Press Release Announcing Agreement Between Applicant & Toledo Edison Co to Combine Under Newly Formed Holding Company.Svc List Also Encl.Related Correspondence ML20128A5281985-06-28028 June 1985 Forwards M Edelman to H Denton,Setting Forth Applicant Proposed Schedule for Final Analysis of Plant Hydrogen Control Sys.Completion Expected by End of 1986.Svc List Encl.Related Correspondence ML20127B4821985-06-20020 June 1985 Forwards Addendum to Torsiograph Tests of Emergency Diesel Generators,Divs 1 & 2 at Perry Nuclear Power Plant-Unit 1 on Cylinder Imbalance, Prepared by Failure Analysis Assoc. Related Correspondence ML20127A9931985-06-19019 June 1985 Informs That Unit 1 12 Wks Negative Re 850614 Project Master Plan Fuel Load Date.Related Correspondence ML20126C3921985-06-10010 June 1985 Forwards Failure Analysis Assoc Rept FaAA-85-4-1, Torsiograph Tests of Emergency Diesel Generators,Divs 1 & 2 at Perry Nuclear Power Plant - Unit 1, Discussed During Evidentiary Hearings on Issue 16.Related Correspondence 1990-08-31
[Table view] |
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DOCHETING A NIU~
BRANC4 M ARRY H. GLASSPIEGEL February 18, 1986 Chairman Nunzio J. Palladino Commissioner James K. Asselstine U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Commissioner Thomas M. Roberts Commissioner Frederick M. Bernthal U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Commissioner Lando W. Zech, Jr.
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: The Cleveland Electric Illuminating Co.
(Perry Nuclear Power Plant Units 1 and 2)
Docket Nos. 50-440 and 50-441 - 7, 206
Dear Commissioners:
This letter is in response to the February 4, 1986 peti-tion of Mr. Donald L. Schlemmer, submitted on behalf of Western Reserve Alliance ("WRA") pursuant to 10 C.F.R. i 2.206, regard-ing the Perry Nuclear Power Plant (" Perry"). WRA's Petition requests the NRC to take the following actions:
- 1. Require the complete and permanent closure of the Perry nuclear plants because of the Perry plants' inadequate seismic design.
CEI and the NRC set the standards for the Perry plants' ability to withstand gravita-tional forces well-below the actual gravi-tational forces that the plants are being subjected to during actual earthquakes. g This was clearly demonstrated during the .
earthquake of January 31, 1986.
8602210421 960219 PDR ADOCK 0 % gO G
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4 e a i SHAw, PITTM AN, PoTTs & TROWBRiDGE t A PART.eER$Msp iMCLLOiNG PROFESSCNAL CCR*CRAtroNS Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 2 i
, 2. Require an independent design and construc-
, tion verification program (IDVCP) to assess the integrity of the Perry One and Perry Two site quality assurance (QA) programs and its implementation because the i
Cleveland Illuminating Company [ sic] (CEI) and its contractors have failed to imple-ment an acceptable denign and construction program for the Perry One and Perry Two nuclear plants that meet the requirements of 10 C.F.R. 50, Appendix B.
i
- 3. Review the Application before the Securi-i ties and Exchange Commission (SEC) of Cen-terior Energy Corporation (CEC) (formerly North Holding Company), which seeks, by its application, the SEC's approval to acquire all of the outstanding shares of the Cleveland Electric Illuminating Company i (CEI) and Toledo Edison (TE), Ohio corpora-tions, and approval of the related mergers by.which the transactions.will be effectu-
.ated."
For the reasons discussed below, WRA's 5 2.206 Petition is without basis and should be denied in all respects.
I. Section 2.206 Requirements WRA's Petition is filed under 6 2.206 of the Commission's regulations. Section 2.206 permits any person to file a re-quest for the NRC Staff 1/ to institute a proceeding pursuant to ,
5 2.202 to modify, suspend or revoke a license,.or for such 1/ Section 2.206 provides for requests to be " addressed to the Director of Nuclear Reactor Regulation, Director of Nuclear Material Safety and Safeguards, the Director, Office of Inspec-tion and Enforcement, as appropriate." See 10 C.F.R.
, S 2.206(a). Thus, WRA's Petition should not have been addressed to NRC Commissioners in the first instance.
SH Aw. PITTM AN. PoTTs & TROWBRIDGE A PARTNCR$8 48 'NCLUD'NG PRO *ESSsON AL CO#8cmattoM5 Chairman'Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 3 other action as may be proper. 10 C.F.R. $ 2.206(a). Section 2.206(a) states that "[t]he requests shall specify the action requested and set forth the facts that constitute the basis for the request." Id. (emphasis added).
As demonstrated below, WRA's Petition is grounded on unsupported, unspecified assertions. The Petition fails to set forth " facts that constitute the basis for the request," as re-quired by 10 C.F.R. $ 2.206. Nor does the Petition provide a basis ho believe that there are violations of Commission reg-ulations, potentially hazardous conditions, or other facts which would constitute sufficient grounds for the Staff to in-
, stitute a 6 2.202 proceeding.
i Further, petitions filed pursuant to 5 2.206 which are grounded on late-filed allegations are governed by the Commis-sion's Statement of Policy: Handling of Late Allegations, 50 Fed. Reg. 11030 (1985). See Union Electric Company (Callaway Plant, Unit 1), DD-85-7, 21 N.R.C. 1552 (1985). As discussed j below, WRA's late-filed allegations, set forth in Section III of the Petition, were not promptly raised.2/ The allegations raise issues that "are not material to any licensing decision or which on their face or after initial inquiry are determined to be frivolous or too vague or general in nature to provide sufficient information for the staff to investigate,"3/ as well as issues that are not "new in the sense of raising a matter not previously considered or tending to corroborate previously received but not yet resolved allegations."4/ Thus, WRA's 2/ See 50 Fed. Reg. at 11031.
3/ Id. See Attachment 1, Exhibit A, items 1-14, 18-22, 24-28, 30, 32-33, 35, 38-39, 41-47 (raising frivolous, vague or general allegations without sufficient information to investi-gate); items 23, 29, 34, 37 (raising commercial or other issues unrelated to licensing).
4/ Id. See Attachment 1, Exhibit A, items 15-17, 31, 36, 40, 48 (raising issues that were previously investigated and re-solved by CEI and the NRC).
3H Aw, PlTTM AN, PoTTs & TROWB RIDGE A PARTNEmSm89 INCWDea#O PmOFC$$c=A6 ComponAruoms Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstina Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 4 allegations are neither material nor new, as defined by the Commission's Statement of Policy, and therefore do not merit further review.
Even if the Staff were to apply the screening criteria for further review of new and material issues, set forth in the Statement of Policy, for the reasons discussed below and in Attachment 1 hereto, the allegations are not " correct," under screening criterion No. 1.5/ Similarly, for the reasons set forth in CEI's responses to WRA's allegations, WRA has failed to raise a significant safety concern. Accordingly, there is no basis for the Staff to give " prompt consideration of the al-legation recognizing the public interest in avoiding undue delay," under screening criterion No. 2 of the Policy State-ment. p/
Thus, for the reasons set forth in this letter, WRA has failed to satisfy the applicable Commission regulations and Policy Statement governing 5 2.206 petitions and late-filed al-legations.
5/ Under screening criterion No. 1 of the Statement of Poli- ,
cy, the Staff is to assess "[t]he likelihood that the allega-tion is correct, taking into consideration all available information including the apparent level of knowledge, exper-tise and reliability of the individual submitting the allega-tion in terms of the allegation submitted and the possible ex-istence of more credible contrary information." 50 Fed. Reg.
at 11031. WRA's bare, unsupported, unsworn allegations do not even attempt to establish the level of knowledge, expertise and reliability of the individual submitting the allegations. As discussed below, WRA's failure to suomit timely its allegations further calls into question its credibility in raising allega- 6 tions at this late date. The extensive CEI and NRC information available, as identified in the attached affidavit of Timothy A. Boss, constitutes "more credible contrary information," id.,
demonstrating that WRA's allegations are not correct. ,
s/ 50 Fed. Reg. at 11032.
(
4
SH Aw, PITTM AN, PoTTs & TROWBRIDGE A PARTNER 5mP a%CLUD*%G PmOFE SSiON A. Commonat'ONS
- Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 5 II. Seismic Design WRA makes a number of unsupported claims with respect to an earthquake that occurred in the vicinity of the Perry Plant on January 31, 1986. WRA asserts the following:
- 1. The Perry plants were designed to withstand extremely minimal gravitational forces (.15). The earthquake of January 31, 1986 subjected the Perry plants to substantially greater gravitational forces than the
! plants were designed to withstand (.19; .23; .25).
- 2. The epicenter of the January 31, 1985 [ sic] earth-quake was extremely close to the Perry nuclear plants.
- 3. The Perry plant site is literally on a fault line.
- 4. CEI filled the fault line with cement and said it was a glacial scar.
- 5. CEI built the plant at this dangerous location over the objections of consumer groups who raised the earthquake and fault line issue most vigorously.
- 6. A fault line can move at any time no matter how new or old.
- 7. Because of the vibration and ground acceleration, the soil conditions at the Perry site subject the plant to greater degrees of gravitational forces than would occur in other parts of the world.
Petition at 4 n.2. The Petition also contains the following I statement:
The Perry nuclear plants are built on a fault line that WRA contends is not a glacial scar. WRA contends that there will be more earthquakes of a greater magnitude.
The epicenters of these quakes may be even closer to the Perry plants. The current
SH Aw, PITTM AN, PoTTs & TROWBRIDGE A PARTa gm$sens speCLLDeteG PRCFE $$som AL COR* ORATIONS Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 6 delay in determining what the devices are that measure the gravitional forces is in-dicative of the shoddy attitude with which CEI constructed these plants. The current reports that these devices can only be read and interpreted by the vendors is most dis-turbing. Also, the delay in getting this information makes a reasonable person highly suspicious of the credibility of both CEI and the NRC.
Petition at 6. The Petition contains no technical support of justification for these assertions, which are without basis.
CEI and its geological, seismological, structural and equipment consultants have completed a detailed analysis of the January 31, 1986 earthquake, including an analysis of the im-i pact of the earthquake on Perry plant structures and components l and on the design capability of the Plant. A copy of CEI's
! report on the results of its reviews has been filed with the NRC Staff and placed on the Perry docket. See Seismic Event l Evaluation Report, Perry Nuclear Power Plant, Docket Nos.
50-440; 50-441, The Cleveland Electric Illuminating Company (February 1986) (" Seismic Event Evaluation"). CEI orally presented its findings to the NRC Staff on February 11, 1986, and to the Advisory Committee on Reactor Safeguards on February 12 and 13.
As set forth in CEI's Seismic Event Evaluation, the earth-quake
- 1) did not adversely affect the plant l structures, systems or components,
- 2) was within the design capability of the Perry Nuclear Power Plant, and (3) does not change the licensing basis or conclusions regarding the site geolo-gy, seismology or design basis earth-quake.
I L
i SH AW, PITTM AN, PoTTs & TROWBRIDGE 4 PantNER5ceim NCLucaNG p40FES$tCNAL Componar:ogs Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 7 Seismic Event Evaluation at $ 1.0. As discussed in CEI's report, the earthquake was of smaller magnitude (4.96, based on '
USGS data) and intensity (VI, based on preliminary evaluation of survey data) than the postulated earthquake used as the basis for the plant's seismic design (intensity 5.3 + .5 and magnitude VII). The many safety and non-safety related systems ~
which were operating or energized at the time of the earthquake responded in accordance with this design. Extensive plant walkdowns and inspections revealed no structural or equipment damage. And while certain recorded response spectra exceeded the design response spectra in the high frequency range, ex-ceedances are expected given the analytical methods of Regula-tory Guide 1.60 and are of no engineering significance.
- WRA's alleged " fault line" on the Perry site that CEI
" filled in . . . with cement and said it was a glacial scar" was examined in detail both at the construction permit stage and at the operating license stage. During the site excava-tion, CEI discovered and reported to the NRC geologic anomalies '
consisting of a series of minor folds and shallow faults. i Based on thorough examination, CEI, the NRC Staff, and geolo-gists from the USGS and the Corps of Engineers unanimously con-cluded that these geologic structures were nontectonic and are unrelated to any deep-seated crustal origin. Therefore, we conclude that these features pose no safety threat to the facility.
Supp. 3 to the NRC Staff Safety Evaluation (November 1975).
The Atomic Safety and Licensing Appeal Board agreed, finding that the geologic anomalies (a) are non-tectonic in origin, (b) are the result of glacial activity, and (c) cannot be expected to ,
cause earthquakes.
Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant), ALAB-449, 6 N.R.C. 884 (1977). The Staff has restated this conclusion in the operating license stage Safety Evalua- i tion report, NUREG-0887 (May 1982) at 2 2-23. The January ,
31 earthquake provides nothing which would change this '
i l
,.---,w a --. , , -- - - ---.-,,
). , .
i 1 SH Aw, PITTM AN. PoTTs & TRowBRIDGE a panTNER$*o# *NCLwD+%G P40 FESS *0N AL CO#pomatiONS Y
i Chairman Nunzio J. Palladino
- Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal
! Commissioner Lando W. Zech, Jr. -
l February 18, 1986 Page 8 I
conclusion. Certainly, WRA has pointed to no basis for challenging the scientific and technical opinions reached by CEI, its consultants, the NRC Staff, the USGS, the Corps of En-
! gineers and the Atomic Safety and Licensing Appeal Board.7/
) III. Integrity of the Perry Quality Assurance Program
- WRA's last-minute allegations regarding the Perry con-
> struction quality assurance / quality control ("QA/QC") program
, (Petition at 6-11) are untimely and without any basis. Section
- III of the Petition states that it contains "a list of allega-j tions and documentation 8/ given to GAP 9/ by various whis-I tieblowers through the coqrse of its investigations regarding
)
the Perry plants." Petitian at 6 (emphasic added). Thus, WRA does not even attempt to demonstrate that it has satisfied its j duty under the Commission's Statement of Policy to bring its I
7/ See Public Service Company of Indiana, Inc. (Marble Hill Nuclear Generating Station, Units 1 and 2), DD-79-21, 10 N.R.C.
l 717, 719 n.3 (1979) (parties must be prevented from using 10 i C.F.R. 5 2.206 procedures as a vehicle for reconsideration of issues previously decided).
] 8/ Applicants obtained a copy of WRA's Petition after reading j about it in Ohio newspapers and requesting a copy from Mr.
l Schlemmer and from the NRC Staff. Applicants received copies l of Mr. Schlemmer's letter from Mr. Schlemmer and from the
- Staff. The copies received contain no " documentation" other j than Mr. Schlemmer's ll-page letter. Although the letter
! contains references to " affidavits" (Petition at 7) and to i " documentation" submitted by the Government Accountability
- Project (" GAP") (Petition at 4 n.1), Applicants have no knowl-1 edge concerning any such affidavits or documentation.
t i 9/ The Petition states that " GAP has been advising and as-l sisting WRA in regard to dealing with the numerous allegations
! made by the large number of whistleblowers that contacted WRA,"
l and that GAP is playing "the lead role . . . in investigating 4 and submitting the allegations and documentation regarding the
> Perry site." Petition at 4 & n.l.
l l
i
SH Aw. PITTM AN. PoTTs & TROWBRIDGE
. .m..... . cwo.~a ..on ss o .c co..o. .o .
Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 9 l purported safety concerns "promptly to the attention of the applicant or licensee," or "directly to the NRC."10/ Nor are -
the allegations " specific and documented to the fullest extent possible,"11/ as the Policy Statement requires. Indeed, as noted above, many of the allegations are so vague as to pre-clude any but the most general response.
1 Last year, after reading press reports discussing allega-tions by Mr. Schlemmer, CEI's " Call For Quality" Ombudsman 12/
wrote to Mr. Schlemmer on July 9, 1985, to request details con-cerning the allegations. CEI's Ombudsman stressed the impor-tance of examining the claimed defects in the construction of the plant, and emphasized that it was not necessary for WRA to identify the individuals who may have provided information to WRA. See Attachment 1 and Exhibit "C" hereto. Mr. Schlemmer and Ms. Billie Pirner Garde of GAP responded to the Ombudsman's letter but refused to supply further details. See Attachment 1, Exhibits "D" and "E". The Ombudsman made a second request to Mr. Schlemmer and Ms. Garde for information (see Attachment 1, Exhibit "F" hereto), but received no response. ;
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10/ 50 Fed. Reg. at 11031. :
i 11/ Id.
12/ CEI's Call for Quality program, instituted in 1984, en-courages workers to contact the Perry Plant Ombudsman on a con-fidential basis if the workers are aware of any conditions ;
which they believe might affect the safety of the plant. See Attachment "1" and Exhibit "F" hereto (Affidavit and letter of Timothy A. Boss). The Call For Quality Program was instituted prior to,the Commission's official endorsement of such programs in Statement of Policy: Handling of Late Allegations. See 50 Fed. Reg. at 11031 n.l. ("The Commission encourages the estab-lishment of programs by utilities for the purpose of identi-fying and resolving allegations affecting safety in a timely manner as design and construction of a nuclear facility pro-ceeds.")
SH Aw, PITTM AN. PoTTs & TROWBRIDGE A PARTNE R$ e.p geuCLUQ6NG PROFESSION AL COR*CR4hoNS Chairman Nunzio J. Falladino
. Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal I Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 10 Thus, the timing'of WRA's Petition is highly suspect and seems to be little more than a thinly disguised attempt to delay fuel load. Since WRA and GAP have apparently known of allegations concerning the Perry construction program for some time, there is no justification for their failure to have dis-closed any concerns to CEI and the Commission prior to the com-pletion of construction, so that CEI and the NRC could have in-vestigated the concerns and taken any necessary corrective, 1
action. Such considerations are the basis for the Commiss' ion's requirement in its Statement of Policy that allegations be promptly disclosed to the applicant or to the NRC.13/
The WRA/ GAP excuse for failing to disclose safety concerns i to CEI, i.e., that management cannot be trusted to respond in good faith to safety concerns, see Attachment 1, Exhibits D and E, is unsupported by facts supplied by WRA in its Petition and is belied by the record of management responsiveness and con-cern for quality at Perry. Moreover, the Atomic Safety and Li-
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censing Board, after hearing extensive testimony on CEI's qual-ity assurance program, concluded that the program "has prevented, and will continue to prevent, unsafe conditions at the plant."14/ This well-founded conclusion contradicts WRA's unsupported allegations concerning CEI's management of hte QA/QC program at Perry.
, For these reasons, and for the reasons discussed in Sec-i tion I of this letter, and in Attachment 1 and Exhibit A hereto, the allegations in WRA's Petition (1) are not timely; i'
(2) fail to raise material or new issues; and (3) are incor-rect, and fail to raise safety issues. Thus, contrary to WRA's t assertion at pages 1, 5 of the Petition, there is no basis for a the Staff to require a further design and construction re-view 15/ to assess the integrity of the Perry QA/QC program. i
' I 13/ 50 Fed. Reg. at 11031 & n.1.
14/ See LBP-83-77, 18 N.R.C. 1365 (1983), affirmed ALAB-802, 21 N.R.C. 490 (1985).
i 15/ See Attachment 1, Exhibit A, items 1, 2, 21-22, 38, 41, 43 discussing examples of the extensive, multi-layered CEI and NRC (Continued next page)
SH AW. PITTM AN. PoTTs & TROWBRIDGE 4 PARTNCR$mp eMCLUONG PROFESSC%AL CCR*ORattoms Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 11 IV. 10 CFR Part 140 The third part of WRA's letter requests NRC to review the application pending before the Securities and Exchange Commis-sion to permit the formation of a holding company (Centerior Energy Corporation) which will own all the common stock of CEI and The Toledo Edison Company (TE). WRA argues without support that the proposed application between CEI and TE "will result in the violation of 10 CFR Part 140."
CEI has kept the NRC Staff fully informed as to the pro-posed CEI-TE affiliation. By letters dated August 14, 1985, November 13, 1985, January 8, 1986, January 31, 1986 and February 13, 1986, we have forwarded to the NRC the relevant CEI and TE filings with the SEC. By letter to the NRC Staff dated December 20, 1985, CEI further explained how the proposed affiliation would affect the management of the Perry plant.
WRA's allegations lack both specifics and an awareness of the requirements of 10 CFR Part 140. These regulations re-quire, for an operating nuclear power reactor, that the licensee maintain $160 million in financial protection plus secondary financial protection in the form of private liability insurance available under an industry retrospective rating plan providing for deferred premiums. CEI has in force liability insurance policies (American Nuclear Insurers Policy No. NF 291 and Mutual Atomic Energy Liability Underwriters Policy No. MF 124) which provide for $160 million in financial protection.
An indemnity agreement with the NRC (No. B-98) was issued on March 7, 1985 and will be amended on the date the operating license is issued. CEI has also submitted to the NRC Certifi-cates of Insurance for deferred premiums under. Nuclear Energy Liability Insurance Association / Mutual Atomic Energy Liability Underwriters Master Policy No. 1. This insurance provides an (Continued) inspections which have been carried out, and which have con-firmed the adequacy of the Perry QA/QC program; see also ASLB and ALAB decisions cited at n.14 supra.
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. SH Aw. PlTTM AN, PoTTs & TROWBRIDGE A PART%CRsmP eNCLUQlwG peorgsschab COneonaric%s Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 12 aggregate of $30 million per event in the event that utilities are unable to meet deferred premium obligations. CEI, and the co-owners of the Perry Plant, will also submit to NRC the cer-tified financial statements provided for by 10 CFR 5 140.21(e),
as CEI and Toledo Edison have annually done with respect to the Davis-Besse plant.
There is simply no relationship between the proposed CEI-TE affiliation and compliance with Part 140. Of course, TE as the operating licensee for the Davis-Besse facility is also meeting the same Part 140 requirements.
In connection with WRA's Part 140 allegations, it is worth recalling that the Director, Office of Nuclear Reactor Regula-tion, has already considered an earlier petition under 10 CFR S 2.206 which claimed that the Perry co-owners were not finan-cially qualified. The Director denied the petition. Cleveland Electric Illuminating Co. (Perry Nuclear Power Plant, Units 1 and 2), DD-85-14, 22 N.R.C. 635 (1985). The Director's Deci-elon explicitly noted that the proposed affiliation would not alter the Staff's conclusion on financial qualifications. The Director stated:
The Staff is aware that CEI and TE are con-sidering a merger. That fact does not alter the analyses set forth in this Deci-sion of the Perry Licensees' financial qualifications. One stated purpose of the possible merger is to strengthen the com-bined financial position of CEI and TE.
22 N.R.C. at 641 n.3. WRA has provided no information to the contrary. In language that applies equally here, the Director held: " Mere speculation that financial pressures will under-mine the safety of licensed activities is not enough." 22 N.R.C. at 637. WRA has not even shown " mere speculation."
SH Aw, PITTM AN, PoTTs & TROWBRIDGE A PamTNERSme* iNCLUD'*eG ##0FESSio'eAL Commonano%S Chairman Nunzio J. Palladino Commissioner Thomas M. Roberts Commissioner James K. Asselstine Commissioner Frederick M. Bernthal Commissioner Lando W. Zech, Jr.
February 18, 1986 Page 13 VI. Conclusion For the reasons set forth in this letter and in the Attachment and Exhibits hereto, WRA's Petition should be de-nied.
Respectfully submitted, Shaw, Pittman, Potts & Trowbridge By: IFY_ .
W[/ T Jay E. y.fberg, P . C .' /
Harry HE Glasspiegel Counsel for The Cleveland Electric Illuminating Company, for itself and as Agent for the Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company, and The Toledo Edison Company (Applicants)
Enclosurt.s cc: Harold R. Denton (Director, NRC Office of Reactor Regulation)
James G. Keppler (NRC Regional Administrator, Region III)
Chief, NRC Docketing and Service Branch
e o ATTACHMENT 1
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