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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M8771999-10-25025 October 1999 Requests That Industry Studies on long-term Spent Fuel Pool Cooling Be Provided to R Dudley at Listed Mail Stop ML20217M4331999-10-19019 October 1999 Submits Rept 17, Requal Tracking Rept from Operator Tracking Sys. Rept Was Used by NRC to Schedule Requalification Exams for Operators & Record Requal Pass Dates PY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20217F3901999-10-14014 October 1999 Discusses Request That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 ML20217F5841999-10-13013 October 1999 Requests Revocation of License OP-11038-1 for GE Kingsley. Individual Has Been Reassigned to Position within Naesco ML20217F5811999-10-13013 October 1999 Forwards Insp Data & Naesco Evaluation of a EDG Exhaust Insp Conducted on 990407.Insp Ensured That Unacceptable Wall Thinning Will Not Occur During 40-year Design Lifetime of Sys ML20217C7321999-10-0808 October 1999 Forwards Copy of Seabrook Station Videotape Entitled, Completion of Seal Barrier Installation. Videotape Documents Process of Selecting,Designing & Installing Seal Deterrent Barrier to Preclude Entrapment of Seals ML20217B8621999-10-0505 October 1999 Forwards Rev 28,change 1 to EPIP Er 1.1, Classification & Emergencies, Per 10CFR50.54(q).Rev to Procedure Does Not Decrease Effectiveness of Seabrook Station Radiological Emergency Plan ML20217B7471999-10-0101 October 1999 Provides Notification of Change in PCT of More than 50 F,Per Requirements of 10CFR50.46(a)(3)(i),(ii).Tabulation of Large Break LOCA PCT Margin Utilization Applicable to Seabrook Station,Encl ML20212K7921999-09-30030 September 1999 Confirms 990922 Telcon with J D'Antonio & T Grew Re Arrangements Made for NRC to Inspect Licensed Operator Requalification Program at Seabrook Facility ML20212J8271999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Seabrook Station. Staff Conducted Reviews for All Operating NPPs to Integrate Performance Info & to Plan for Insp Activities at Facility Over Next Six Months.Plant Issues Matrix & Insp Plan Encl ML20216J2381999-09-30030 September 1999 Responds to Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Nrc Expects All Licensees to Operate Nuclear Facilities Safety IAW NRC Regulations & Requirements ML20216J2421999-09-30030 September 1999 Responds to Card Received in Aug 1999,providing Comments on NRC Interim Enforcement Policy Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Informs That Naesc Reported Seabrook as Y2K Ready Prior to 990701 ML20216J2471999-09-30030 September 1999 Responds to Which Provided Comments on NRC Interim Enforcement Policy Re Enforcement Discretion for Nuclear Plants During Y2K Transition.Informs That Naesc Reported Seabrook as Y2K Ready Prior to 990701 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 ML20212J0301999-09-24024 September 1999 Forwards Insp Rept 50-443/99-10 on 990726-30 & 0809-13.No Violations Noted.Insp Discussed 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 ML20212G5071999-09-21021 September 1999 Submits Complaint to NRC Re NRC Failure to Cite Seabrook Station NPP Operators for Failing to Periodically Calibrate & Establish Adequate Measures to Insure That Relay Equipment Met All Required Calibration Settings Prior to Installation ML20212C1881999-09-20020 September 1999 Ack Receipt of Which Raised Concerns Re NRC Enforcement Actions at Plant & Issuance of NCVs ML20212D1401999-09-17017 September 1999 Forwards SE Accepting Request to Use Proposed Alternative to Certain Weld Repair Requirements in ASME Boiling & Pressure Vessel Code ML20212B9511999-09-17017 September 1999 Forwards NRC Form 396 for MG Sketchley,License SOP-10685, Along with Supporting Medical Exam Info.Nrc Form 396 Has Been Superceded by Revised Version Dtd 971222,which Was Previously Submitted to NRC on 990812.Encl Withheld 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 ML20212C3621999-09-15015 September 1999 Forwards Rev 34 to Seabrook Station Radiological Emergency Plan & Rev 85 to Seabrook Station Emergency Response Manual, Per 10CFR50,App E & 10CFR50.4 ML20212B5021999-09-14014 September 1999 Forwards Licensee Responses to EPA Questions Re Plant Seal Deterrent Barrier.Util Completed Installation of Subject Barriers on All Three Station Offshore Intake Structures on 990818.Barriers Will Preclude Entrapment of Seals 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 ML20211Q8521999-09-0808 September 1999 Informs That Rl Couture,License SOP-11027,terminated Employment at Naesco on 990907.Revocation of License Requested 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 ML20211J9291999-09-0303 September 1999 Forwards mark-ups & Retypes of Proposed Conforming License Changes Required in Connection with Transfers Being Sought in 990615 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests ML20211N8781999-09-0303 September 1999 Forwards Response to 990820 RFI Re NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams DD-99-10, Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-10) Expired.Commission Declined Review & Decision Became Final on 990830.With Certificate of Svc.Served on 9909021999-09-0202 September 1999 Informs That Time Provided by NRC Regulation within Which Commission May Act to Review Director'S Decision (DD-99-10) Expired.Commission Declined Review & Decision Became Final on 990830.With Certificate of Svc.Served on 990902 ML20211M3221999-09-0202 September 1999 Responds to NRC Re Violations Noted in Insp of License NPF-86 & Proposed Imposition of Civil Penalty. Corrective Actions:Conducted Prompt Review of Layoff Decision to Determine Relevant Facts ML20211J8411999-09-0101 September 1999 Forwards Updated NRC Form 396 for E Decosta,Nrc License OP-10655-1.Without Encl ML20211J8811999-09-0101 September 1999 Forwards Comments on Seabrook Station Review of Reactor Vessel Integrity Database (Rvid)(Version 2).Minor Discrepancies Were Noted.Proposed Changes Are Encl in Order to Correct Discrepancies 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 ML20211G9191999-08-27027 August 1999 Informs NRC That Name of New Company, Ref in Order Approving Application Re Corporate Merger Is Nstar Which Is Massachusetts Business Trust ML20211J0401999-08-26026 August 1999 Responds to 990819 Request,On Behalf of Gr Pageau & Williams Power Corp,For Addl Time in Which to Reply to Nov,Issued on 990803.Response Due to NRC by 991008 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 ML20211H0651999-08-25025 August 1999 Forwards Insp Rept 50-443/99-05 on 990621-0801.One Violation Re Failure to Include Multiple Components within Scope of ISI Test Program Was Identified & Being Treated as NCV, Consistent with App C of Enforcement Policy ML20211G7761999-08-24024 August 1999 Expresses Great Concern Re Lack of Enforcement Actions Against Seabrook Station Despite Citations NRC Has Issued for Violations of Seabrook Operating License ML20211J2171999-08-23023 August 1999 Expresses Disappointment with Lack of Enforcement Action Against Seabrook Station Despite Repeated Safety Violations ML20211J4971999-08-21021 August 1999 Submits Comments Re Violations Cited in Early Mar & 990509 Insps 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 ML20217F5811999-10-13013 October 1999 Forwards Insp Data & Naesco Evaluation of a EDG Exhaust Insp Conducted on 990407.Insp Ensured That Unacceptable Wall Thinning Will Not Occur During 40-year Design Lifetime of Sys ML20217F5841999-10-13013 October 1999 Requests Revocation of License OP-11038-1 for GE Kingsley. Individual Has Been Reassigned to Position within Naesco ML20217B8621999-10-0505 October 1999 Forwards Rev 28,change 1 to EPIP Er 1.1, Classification & Emergencies, Per 10CFR50.54(q).Rev to Procedure Does Not Decrease Effectiveness of Seabrook Station Radiological Emergency Plan ML20217B7471999-10-0101 October 1999 Provides Notification of Change in PCT of More than 50 F,Per Requirements of 10CFR50.46(a)(3)(i),(ii).Tabulation of Large Break LOCA PCT Margin Utilization Applicable to Seabrook Station,Encl 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 ML20212G5071999-09-21021 September 1999 Submits Complaint to NRC Re NRC Failure to Cite Seabrook Station NPP Operators for Failing to Periodically Calibrate & Establish Adequate Measures to Insure That Relay Equipment Met All Required Calibration Settings Prior to Installation ML20212B9511999-09-17017 September 1999 Forwards NRC Form 396 for MG Sketchley,License SOP-10685, Along with Supporting Medical Exam Info.Nrc Form 396 Has Been Superceded by Revised Version Dtd 971222,which Was Previously Submitted to NRC on 990812.Encl Withheld 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 ML20212C3621999-09-15015 September 1999 Forwards Rev 34 to Seabrook Station Radiological Emergency Plan & Rev 85 to Seabrook Station Emergency Response Manual, Per 10CFR50,App E & 10CFR50.4 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 ML20211Q8521999-09-0808 September 1999 Informs That Rl Couture,License SOP-11027,terminated Employment at Naesco on 990907.Revocation of License Requested ML20211J9291999-09-0303 September 1999 Forwards mark-ups & Retypes of Proposed Conforming License Changes Required in Connection with Transfers Being Sought in 990615 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests ML20211N8781999-09-0303 September 1999 Forwards Response to 990820 RFI Re NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20211M3221999-09-0202 September 1999 Responds to NRC Re Violations Noted in Insp of License NPF-86 & Proposed Imposition of Civil Penalty. Corrective Actions:Conducted Prompt Review of Layoff Decision to Determine Relevant Facts ML20211J8811999-09-0101 September 1999 Forwards Comments on Seabrook Station Review of Reactor Vessel Integrity Database (Rvid)(Version 2).Minor Discrepancies Were Noted.Proposed Changes Are Encl in Order to Correct Discrepancies ML20211J8411999-09-0101 September 1999 Forwards Updated NRC Form 396 for E Decosta,Nrc License OP-10655-1.Without Encl ML20211G9191999-08-27027 August 1999 Informs NRC That Name of New Company, Ref in Order Approving Application Re Corporate Merger Is Nstar Which Is Massachusetts Business Trust 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 ML20211G7761999-08-24024 August 1999 Expresses Great Concern Re Lack of Enforcement Actions Against Seabrook Station Despite Citations NRC Has Issued for Violations of Seabrook Operating License ML20211J2171999-08-23023 August 1999 Expresses Disappointment with Lack of Enforcement Action Against Seabrook Station Despite Repeated Safety Violations ML20211J4971999-08-21021 August 1999 Submits Comments Re Violations Cited in Early Mar & 990509 Insps ML20211H8361999-08-19019 August 1999 Submits Concerns Re Violations at Seabrook Station 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 ML20211J3241999-08-15015 August 1999 Expresses Disappointment in Apparent Failure of NRC to Cite Seabrook Station NPP for Recent Violations of Safety Regulations Uncovered During Recent Insps in Mar & May ML20211J1831999-08-15015 August 1999 Submits Concerns Over Serious Deficiencies at Seabrook Station That NRC Has Declined to Take Enforcement Actions Against ML20211J2071999-08-13013 August 1999 Expresses Concerns Re Violations Occurring Recently at Seabrook Nuclear Power Station.Requests Effort to See That Measures Taken to Stop Flagrant,Continuing Violations That Hold Danger to Workers & Community ML20210S2001999-08-12012 August 1999 Forwards NRC Forms 398 & 396 in Support of Applications for Renewal of Operator Licenses for Individuals Listed Below. Without Encls ML20210R9581999-08-11011 August 1999 Forwards ISI Exam Rept of Seabrook Station, for RFO 6, Period 3,for Insps Conducted Prior to & During Sixth Refueling Outage Concluded on 990510 ML20210R8401999-08-11011 August 1999 Forwards Response to NRC Second RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves 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-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-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 ML20210R7931999-08-10010 August 1999 Forwards Cycle 7 Startup Rept for Seabrook Station, IAW Requirements of TS 6.8.1.1 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 ML20210K3281999-07-30030 July 1999 Forwards Response to NRC RAI Re License Amend Request 98-17. North Atlantic Concurs with Staff That Bases Should State That Maintaining ECCS Piping Full of Water from RWST to Reactor Coolant Sys Ensures Sys Will Perform Properly ML20210H0921999-07-27027 July 1999 Forwards Naesc Semi-Annual Fitness-for-Duty Rept,Jan-June 1999, Per 10CFR26.71(d).Rept Includes Data from 990101- 0610 ML20210H8991999-07-27027 July 1999 Forwards Tabulation of Current LBLOCA & SBLOCA Peak Clad Temp Margin Utilization Tables Applicable to Seabrook Station 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 ML20210S9911999-07-18018 July 1999 Requests NRC Intervene for All Shareholders of New England Electric System & to Help with Merger with National Grid Group & That NRC Petition Security & Exchange Commission to Investigate Matter Relative to No Shareholder Options ML20210A2521999-07-15015 July 1999 Forwards Rev 33 to Seabrook Station Radiological Emergency Plan & Rev 84 to Seabrook Station Emergency Response Manual 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 ML20209J0601999-07-14014 July 1999 Forwards Rev 11 to Vols 1-10 of State of Nh Radiological Emergency Response Plan & Vols 11-50 to Town Radiological Emergency Response Plans,In Support of Vermont Yankee & Seabrook Station.Vols 17-19 of Were Not Included ML20209G1351999-07-0909 July 1999 Forwards Relief Request Re Repair Welding on SA-351 Matl to Be Installed in Seabrook Station SW Pumps & SW Cooling Tower Pumps ML20209D2871999-07-0606 July 1999 Submits Response to NRC AL 99-02,re Numerical Estimate of Licensing Actions Expected to Be Submitted in Fy 2000 & 2001.Schedule Does Not Include Activities Which Meet AL Definition of Complex Review 1999-09-09
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"\ N:rtheast 1 7 seiden stmt suun, cr 06037
' Utilities Syst:m Nonheut venues semce company P.o. Box 270 Hanford, cT 061410270 (203) 665-5000 MAY 2d 1996 Docket No. 50-443 NYN-96037 United States Nuclear Regulatory Conunission Attention: Document Control Desk Washington, D.C. 20555 Seabrook Station Reolv to a Notice of Violation In a letter dated April 29,1996' the NRC described two violations regarding Foreign Material Exclusion controls and Security Unescorted Access Authorization at Seabrook Station.
Accordingly, the enclosure provides North Atlantic Energy Service Corporation's (North Atlantic) response to these violations. North Atlantic is making certain commitments in response to these violations. The commitments are fully described in the enclosure to this letter.
Should you have any questions concerning this response, please contact Mr. Anthony M.
Callendrello, Licensing Manager, at (603) 474-952), extension 2751.
Very truly yours, NORTH ATLANTIC ENERGY SERVICE CORP.
6WM & =
T. C. Feigenb Executive ce President and Chief Nuclear Officer cc: T. T. Martin, Regional Administrator A. W. De Agazio, Sr. Project Manager J. B. Macdonald, NRC Senior Resident Inspector 9605280283 960524 PDR ADOCK 05000443 O PDR s 2
NRC Inspection Report %-02, dated April 29,1996, J. F. Rogge to T. C. Feigenbaum.
osam arv. im
,i
s
, United States Nuclear Regulatory Comnussion NYN-96037 /Page 2 i
REPLY TO A NOTICE OF VIOLATION Cuoco,L. NU DiPro6o, W. A. 49-SS
- Gar 6 eld, G. DB&H McKenna, K. A. Millstone 475/5 4
Millstone Licensing cc: Mail Sovetsky, E. J. 49-SS
, Warnock, J. J. 02-07 Letter Distribution cc: Mail File 0001 01-48 RMD 02-06 i
l l
1 i
8 e9 0 0 4
ENCLOSURE 1 TO NYN-96037 l
, REPLY TO A NOTICE OF VIOLATION NRC la==+ ion Report 96-02 described two apparent violations regarding Foreign Material Exclusion (FME) controls and Security Access Authorization, respectively.
North Atlantic's response to these violations is provided below.
L Descrintion of Violations The following are restatements of the respective violations.
A. Formion Ma*arial Frein= ion: VIO 96-02-01 Seabrook Station Technical Speci6 cation 6.7.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in A,WN A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33 requires licensees to establish and implement administrative procedures for safety-related activities.
Station Management Manual, Chapter 2, Policies, Section 7, Housekeeping / Cleanliness / Foreign Material Exclusion requires that controls for foreign material exclusion from systems and components shall be implemented per procedure MA 3.4, Foreign Material Exclusion. Procedure MA 3.4, Section 4.1, General Requirements, requires critical equipment important to safe operation and shutdown of the plant shall i receive foreign material exclusion (FME) considerations and that openings shall be appropriately covered to prevent entry ofdust, dirt, or other foreign objects.
Contrary to the above, on February 27, 1996, the 'mspector identi6ed that temporary jumpers, which are used to perform surveillance testing ofinstrument air check valves associated with the steam admission valve MS-V-395 for the risk signi6 cant safety-related turbine driven emergency feedwater (EFW) pump in accordance with procedure OX l 1436.02, Section 8.2.43, did not have FME covers installed.
This is a Severity Level IV violation (Supplement I).
B. Uworted Acce== Authorivation: VIO 96-02-03 The Seabrook, Units 1 and 2, Physical Security Plan, Revision 19, dated April 26,1995, Section 3.1, states, in part, that all elements of NRC Regulatory Guide 5.66 have been implemented to satisfy the requirements of 10 CFR 73.56.
One of the requirements of 10 CFR 73.56, es stated in Section (b)(2)(iii), is that the unescorted access authorization program must include behavioral observation, conducted by supervisors and management personnel, designed to detect individual behavioral changes which, ifleft unattended, could lead to acts detrimental to the public health and safety. Additionally, one of the elements of Regulatory Guide 5.66, as noted in Section 3, under the "Clari6 cation of Guidelines," is that prior to the reinstatement of an employee's 1
l' access authorization, it is reasonable to expect that the licensee will ascertain that the activities the employee was engaged in during his or her absence would not have the l potential to affect the employee's trustworthiness and reliability.
l To satisfy the physical security plan commitments, the licensee's continual behavioral l observation program requires, as hmar*ed in the Seabrook Station Security Program i (SSSP), Revision 16, Section 3.9, titled " Reinstatement of Unescorted Access i Authorization," that if more than 30 days have lapsed since an individual was at Seabrook j Station, conduct an interview with the individual to ascertain that the activities of the
- individual during his or her absence would not affect his or her trustworthiness and
! reliability.
[ Contrary to the above, the licensee had developed a procedure which addressed
- contractors with unescorted access into the protected area that are awsy from Seabrook l Station for more than 30 days and have not been under a continual behavior observation j program, but the North Atlantic Energy Service Corporation failed to effectively j implement the procedure. Therefore, the requirements for the reinstatement of unescorted
- access authorization relative to the continual behavioral observation program were not l being met.
i
! This is a Severity Level IV Violation (Supplement III).
IL Realv to Violations i
l A. FME Violation i l j Reason for FME Violation '
l North Atlantic agrees with this violation and notes that it is consistent with our internal i
findings and observations regarding the consistent application of FME controls. North j Atlantic had scheduled enhancement of the FME program in 1996 based on industry l experience and best practices in this area. However, this plan was to address only
! maintenance related aspects ofFME.
, North Atlantic has determined that Station personnel have historically viewed FME as the j responsibility of the Maintenance Group without the full understanding that FME is the i responsibility of all plant personnel. Additionally, with regard to this specific occurrence, j Operators were not aware of FME requirements regarding small components that j interface with plant systems. Maintenance procedure MA 3.4, " Foreign Material Exclusion," provides the administrative controls to prevent the m' troduction of foreign l
material into open systems and components. Although the procedure is not limited to j large systems or components, it primarily addressed methods of FME for large
, components (e.g., steam generators) and large areas where FME controls are desired i (e.g., Spent Fuel Pool, cavity, etc.). This procedure primarily provides guidance on how
] to establish FME areas, prepare work packages, provide administrative controls, retrieve i 2 1
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L dropped items, and it designates mandatory FME areas However, it does not address -
j routine and non-routine activities performed by personnel outside of the Maintenance
- Group. North Atlantic has reviewed the training provided to support MA 3.4 and j determined that enhancement is also required to broaden the scope to address activities
- performed outside of the Maintenance Group.
I i corrective Antians Pertainina to FME Viniatian
- 1. North Atlantic initiated Adverse Condition Report (ACR)96-308 to evaluate the
! cause for this violation and to develop corrective actions.
- 2. As an interim corrective action, caps were installed on the tube jumpers utilized to
- perform the Emergency Feedwater Turbine Driven Quarterly Pump Surv4HW4 to
! prevent foreign material from entering the tubing. Additionally, a procedure search was i performed for other tube jumpers installed by the Operations Department and two other j instances were found. Caps were installed on these other tube jumpers. It should be l noted that caps may not be utilized in the future if other FME controls are determined to I be more appropriate.
i 3. North Atlantic will review the evaluation for ACR 96-308 with appropriate site i personnel. It is anticipated that this review will be completed by July 31,1996.
- 4. North Atlantic is evaluating staffing a new position that will be responsible for 4
overseeing the conduct of FME and housekeep*mg practices in the plant and will act as an
- information source for management to ensure that adverse plant materiel conditions are j identi6ed, prioritized and resources appropriately applied. This will include oversight of j production activities including those of Operations, Maintenance, Construction, l Chemistry, Health Physics, and Radioactive Waste. With regard to FME, the individual in
- this new position will assist the responsible line organizations in implementing sound FME j practices. This individual will coach workers and supervision in these practices to ensure l comprehensive understanding, consistent application, and ownership ofFME.
1 I 5. North Atlantic will evaluate the existing FME program at Seabrook Station to identify potential short-term progra.. r.atic anhaar-ts. The applicable FME
- procedures will be revised, as appropriate, to reflect the results of this evaluation. It is
! anticipated that the evaluation of the FME program and any procedural enhancements will i be completed by June 28,1996.
j 6. For the longer term, North Anntic will evaluate industry best practices regarding
, FME and will revise the FME program, as appropriate. This will include a review ofFME l, related trairlig. It is anticipated that this action will be completed by January 1997.
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I j, B. S~nrity Vial =+ian P==an for Senrity Vialation i In order to understand the reason for this violation, it is first necessary to provide
- background information on unescorted access authorization as it is described in the
- statement of the viotr. tion.
i j Seabrook Station Quality Assurance Audit Report 95-A03-01 identified that unescorted 4
access does not expire when individuals are away from the Seabrook Station Continual j Behavior Observation Program (CBOP) for more than 30 days. The audit cited j procedural requirements contained in the Seabrook Station Security Manual, Rev.16,
- Chapter 2, Section 3.9, " Reinstatement of Unescorted Access Authorization." For the
- responsibilities of the Processing Center Supervisor, the procedure stated, in part:
1 If more than 30 days have lapsed since the individual was at Seabrook Station, j conducts an interview with the individual to ascertain that the activities of the
{ individual during his or her absence would not have the potential to affect the
- individual's trustworthiness and reliability.
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! Notwith=*=ading the Quality Assurance audit finding, the referenced section of the ,
j Security Manual pertains only to the reinstatement of unescorted access authorization if l j access had been previously terminated, not an absence from the site greater than 30 days
) while maintaining unescorted access However, to address the intent of the audit finding, i the Security Department had agreed to revise the Security Manual to ensure that
] unescorted access would be denied for individuals who were away from the Seabrook l Station or other approved CBOP for 30 days or more. Unescorted access would be l
- granted only after ascertaining that the activities the individual was engaged in during his
- or her absence from a CBOP did not have the potential to affect the individual's
- trustworthiness and reliability, i
1 J The Security Department planned to perform the above described procedure change in the
! next routee revision to the Security Manual. This was believed to be adequate since the i procedure change was not necessary to satisfy regulatory requirements. This position was
]' based on the existing regulatory requirements and endorsed suidara pertaining to unescorted access authorization.
1 North Atlantic had committed to implement the provisions of Regulatory Guide 5.66,
" Access Authorization Program for Nuclear Power Plants," dated June 1991 to satisfy the l access authorization requirements of 10 CFR 73.56. This Regulatory Guide endorses, j with r. few exceptions and clarifications, NUMARC 89-01, " Industry Guidelines for
! Nuclear Power Plant Access Authorization Programs," dated August 1989. These
- documents do not contain any pruidarse or requirements for the verification of an
- individwl's trustworthiness whea an individual is away from an approved CBOP for more l than 3a days if their unescorted access had not previously been terminated. Additionally, I
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L these documents do not contain any provisions for terminating access if an individual is
- away from a CBOP for more than 30 days. This is also consistent with Regulatory Guide l 5.66, Clari6 cation No. 3, which pertains to the reinstatement of unescorted access for j individuals whose access was previously terminated. Clari6 cation No. 3 also does not
- address situations where an individual is away from a CBOP and their eccess had nct been i terminaM This clari6 cation states:
l The NUMARC Guidelines allow reinstatement of unescorted access authorization
! within 365 days of its - ., f. i if the authorization was terminated under i favorable conditions. Requiring a complete psychological assessment and i background investigation after every break of 365 days or less in the behavioral l ot,servation program is not feasible. However, there is information available to the i licensee from other sources. For example, if an authorization kan because an
! employee took a leave of absence, it is reasonable to assume that the licensee has
! some indication of the intended activities of the employee during such leave.
l Furthermore, prior to reinstatement of the access authorization, it is reasonable to l
expect that the licensee will ascertain that whatever activities the employee
! engaged in during his or her absence would not have the potential to affk.t the i employee's trustworthiness and reliability. (Emphasis added) i i NRC Temporary Instruction 2515/127, " Access Authorization," as issued on January 17, 1995, provided further clari6 cation on the issue of reinstatement. In contrast with j Regulatory Guide 5.66 and NUMARC 89-01, Temporary Instruction 2515/127 requires i licensees to ascertain the activities of employees during their absence from a CBOP for l more than 30 days when + heir unescorted access had not previously been terminated.
- Section 04.05.b states, in part
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{ Also, if an individual granted UA [ unescorted access) is away from a licensee or
- licensee approved BOP for more than 30 days, prior to the individual gaming UA l again, the licensee, or approved contractor or vendor, must ascertain that the j activities that the employee engaged in during his or her absence from the BOP did i not have the potential to affect the employee's trustworthiness and reliability. This
- is required for individuals whose UAA [ unescorted access authorization) is not
{ terminated (e.g., employees on extended vacations, leave, on business travel j without behavioral observation by a trained supervisor, contractor / vendor i employees away from a licensee program and not under the observation of a j trained supervisor in an approved contractor / vendor program), as well as for
! transfer of UAA or reinstatement of a favorably terminated UAA.
North Atlantic Security Department personnel had recognized that this aspect of Tw+erery Instruction 2515/127 was different than the provisions of the Security Manual.
North Atlantic Security Department personnel were also aware of confusion in the industry regarding how this aspect of the Temporary Instruction appeared to expand upon the existing regulations. Hence, while the Security Department intended to revise the 5
1 i6 Secu-ity Manual to address this issue during the next routine revision, they only intended to expedite the revision if the regulatory requirements were amended.
l i Subsequently, the status of the procedure changes to address the Quality Assurance audit
, fmding was questioned during the NRC Integrated Performance Assessment Process j (IPAP) inspection. Based on discussions with North Atlantic Licensing personnel, l Security Department personnel recognized that their interpretation of the regulations
! regarding this issue may have been too narrow. While the Security Manual was in j compliance with the literal requirements of the existing regulation, it did not fully meet the j underlying intent of the requirements for a CBOP.
I j Corrective kelann Pertainino to Swity Violatinn
- 1. On February 29, 1996, North Atlantic reviewed the Security computer to i determine those individuals who had not entered the protected area for the last 30 days. A
! total of 29 individuals were identified. North Atlantic reduced the access level for these
! individuals to prevent them from gaining protected area unescorted access
- 2. North Atlantic initiated Adverse Condition Report 96-140 to docwnent and l evaluate the conditions pertaining to why the Quality Assurance finding regarding the CBOP was not resolved in a timaly manner.
i 3. North Atlantic reviewed the small subset of those individuals who had ths j unescorted access authorization revoked for adverse behavioral reasone. It was i determined that none of these individuals had previously been absent from Seabrook l Staico for more than 30 days, returned, and then exhibited adverse behavior that i warranted termination ofunescorted access authorization. It should also be noted that the
- existing program mairai-l individuals who were absent from Seabrook Station eligible for Fitness For Duty random testing. If any of these individals were selected for random testing during their absence, then prior to entry to the protacted area, these individuals were subjected to a Fitness For Duty test.
! 4. On March 4,1996, the Security Manual wts revised (Revis>n 18) to clarify the
- CBOP policy. Speci6cally, when ar. individual with unescorted access is away from either l Seabrook Station's, another licensee's, or a contracto?veulor's approved CBOP for more l than 30 continuous days, their access !cvel will be reduced to prevent protected area
! unescorted access. The Security Department will notify the individual's North Atlantic l sponsor to further determine the individual's need for unescorted access Pithe individual l still requires protected area access, the individual, upon returning to Seahrrak Station, will be required to complete ed sign a determination letter ascertaining the activities of l the individual during the absence. Upon satisfactory completion of the Mter, the j individual's access level will be reinstated. Individuals who do aot require continued j unescorted access will be removed from the Security computer.
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l ', It should be noted that the foregoing provisions of access denial aRer 30 days also applies l l for individuals whose unescorted access authorization is not terminated. For example, this 3
1 would include ecyloyees on extended vacations, leave, on business travel without
, behavioral observation by a trained supervisor, contractor / vendor employees away from a
- licensee program and not under the observation of a trained supe visor in an approved l contractor / vendor program l
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- The Security Manual revision also included a provision to terminate protected area I i
unescorted access for individuals who have been away from a CBOP for more than 60 continuous days. This is in addition to their access level being reduced aRer 30 days to
- prevent entry into the protected area.
! 5. On March 8,1996, the Seabrook Station Security Department Instruction
, SDI0015.00, " Processing Center Operations," was revised to reflect the aforementioned l changes to the CBOP.
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! 6. Security Department management personnel were counseled on the need to l maintain focus on the underlying intent of regulations and the applicable guidance.
! IIL Date When Full Comolhace Will be Achieved j North Atlantic is currently in full compliance with regulatory requirements.
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