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Category:CORRESPONDENCE-LETTERS
MONTHYEARNOC-AE-000675, Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested1999-10-21021 October 1999 Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested NOC-AE-000680, Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan1999-10-20020 October 1999 Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan NOC-AE-000683, Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii)1999-10-19019 October 1999 Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii) ML20217K9341999-10-15015 October 1999 Forwards SER Accepting Util 990609 Relief Request RR-ENG-2-4 for Relief from ASME Code,Section XI, Nondestructive Exam Requirements Applicable to Stp,Units 1 & 2,reactor Vessel Closure Head Nuts ML20217K9091999-10-15015 October 1999 Forwards SER Accepting Util 990609 Relief Request RR-ENG-2-3 from ASME Code,Section Xi,Nondestructive Exam Requirements Applicable to South Texas Project,Units 1 & 2, Pressurizer Support Attachment Welds 05000498/LER-1999-008, Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER1999-10-12012 October 1999 Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER NOC-AE-000674, Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule1999-10-12012 October 1999 Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule NOC-AE-000625, Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future1999-10-0707 October 1999 Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future NOC-AE-000610, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i) NOC-AE-000653, Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i) ML20217C3221999-10-0707 October 1999 Forwards Insp Repts 50-498/99-16 & 50-499/99-16 on 990808-0918.No Violations Noted.Insp Generally Characterized by safety-conscious Operations,Sound Engineering & Maint Practices & Careful Radiological Work Controls 05000499/LER-1999-006, Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment1999-09-30030 September 1999 Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment ML20212L1651999-09-30030 September 1999 Responds to STP Nuclear Operating Co 981012 & s Which Provided Update to TS Bases Pages B 3/4 8-14 Through B 3/4 8-17.NRC Staff Found Change Consistent with TS 3/4.8.2 DC Sources. Staff Found & Deleted Typographical Error NOC-AE-000664, Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr1999-09-30030 September 1999 Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr ML20212J7141999-09-29029 September 1999 Forwards Insp Repts 50-498/99-15 & 50-499/99-15 on 990920-24 at South Texas Project Electric Generating Station.No Violations Noted.Insp Covered Requalification Training Program & Observation of Requalification Activities NOC-AE-000646, Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr1999-09-28028 September 1999 Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr ML20212J0651999-09-27027 September 1999 Discusses Licensee 980330 Response to GL 97-06, Degradation of SG Internals. Concludes That Response to GL Provides Reasonable Assurance That Condition of SG Internals in Compliance with Current Licensing Bases for Facility ML20212F1791999-09-24024 September 1999 Discusses 990923 Meeting Conducted in Region IV Ofc Re Status of Activities to Support Confirmatory Order, ,modifying OL & to Introduce New Director,Safety Quality Concerns Program.List of Attendees Encl ML20212E9091999-09-23023 September 1999 Discusses GL 98-01, Year 2000 Readiness of Computer Sys at Npps, Supplement 1 & STP Nuclear Operating Co Response for STP Dtd 990629.Understands That at Least One Sys or Component Listed May Have Potential to Cause Transient ML20212F2111999-09-22022 September 1999 Forwards Review of SG 90-day Rept, South Texas Unit-2 Cycle 7 Voltage-Based Repair Criteria Rept, Submitted by Util on 990119 NOC-AE-000633, Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 19971999-09-21021 September 1999 Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 1997 NOC-AE-000634, Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl1999-09-21021 September 1999 Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl NOC-AE-000649, Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P1999-09-21021 September 1999 Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P 05000499/LER-1999-005, Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER1999-09-20020 September 1999 Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER ML20212D9171999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of South Texas Project & Identified No Areas in Which Performance Warranted Insp Beyond Core Insp Program.Details of Insp Plan Through Mar 2000 & Historical Listing of Plant Issues,Encl ML20216F5471999-09-15015 September 1999 Discusses 990914 Meeting Conducted at Region Iv.Meeting Was Requested by Staff to Introduce New Management Organization to Region IV & to Discuss General Plant Performance & Mgt Challenges IR 05000498/19990121999-09-14014 September 1999 Forwards Insp Repts 50-498/99-12 & 50-499/99-12 on 990816-19.Three Violations Occurred & Being Treated as Ncvs. Areas Examined During Insp Included Portions of Access Authorization & Physical Security Programs 05000498/LER-1999-007, Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER1999-09-13013 September 1999 Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER ML20211P8201999-09-0909 September 1999 Forwards SE Authorizing 990224 Submittal of First 10-year Interval ISI Program Plan - Relief Request RR-ENG-24,from ASME Section XI Code,Table IWC-2500-1 NOC-AE-000638, Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6)1999-09-0909 September 1999 Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6) ML20211P7671999-09-0909 September 1999 Forwards SER Authorizing Licensee 990517 Alternative Proposed in Relief Request RR-ENG-2-8 to Code Case N-491-2 for Second 10-year Insp Interval of South Texas Project, Units 1 & 2,pursuant to 10CFR50.55a(a)(3)(i) ML20211P7871999-09-0909 September 1999 Forwards Safety Evaluation Re First 10-yr Interval Inservice Insp Program Plan Request for Relief RR-ENG-31 IR 05000498/19990141999-09-0303 September 1999 Forwards Insp Repts 50-498/99-14 & 50-499/99-14 on 990627-0807.Apparent Violations Identified & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy NOC-AE-000562, Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i)1999-08-31031 August 1999 Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i) ML20212A4351999-08-27027 August 1999 Discusses Investigation Rept OI-4-1999-009 Re Activites at South Texas Project.Oi Investigation Initiated in Response to Alleged Employment Discrimination Complaint. Allegation Not Substantiated.No Further Action Planned NOC-AE-000617, Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d)1999-08-26026 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d) ML20211J2511999-08-26026 August 1999 Discusses Proposed TS Change on Replacement SG Water Level Trip Setpoint for Plant,Units 1 & 2 NOC-AE-000585, Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-4811999-08-25025 August 1999 Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-481 ML20211F4421999-08-24024 August 1999 Forwards SE Authorizing Licensee 990513 Request for Relief RR-ENG-2-13,seeking Relief from ASME B&PV Code Section Xi,Exam Vessel shell-to-flange Welds for Second ISI Intervals ML20211F5031999-08-23023 August 1999 Forwards SE Authorizing Licensee 990315 Request for Relief RR-ENG-30,seeking Relief from ASME B&PV Code,Section Xi,Nde Requirements Applicable to Stp,Unit 2 SG Welds ML20212A4391999-08-17017 August 1999 Discusses Investigation Rept OI-4-1999-023 Re Activities at South Texas Project.Oi Investigation Initiated in Response to Alleged Employment Discrimination for Initiating Condition Report to Document Unauthorized Work Practices ML20210U1271999-08-16016 August 1999 Forwards Insp Repts 50-498/99-08 & 50-499/99-08 on 990517-21 & 0607-10.No Violations Noted.Corrective Action Program Was Reviewed ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams NOC-AE-000603, Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6)1999-07-29029 July 1999 Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6) NOC-AE-000470, Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl1999-07-28028 July 1999 Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl NOC-AE-000599, Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr1999-07-28028 July 1999 Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr NOC-AE-000589, Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/20001999-07-26026 July 1999 Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/2000 ML20210F3851999-07-26026 July 1999 Forwards Exam Repts 50-498/99-301 & 50-499/99-301 on 990706- 15.Exam Included Evaluation of 9 Applicants for SO Licenses & 8 Applicants for RO Licenses 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARNOC-AE-000675, Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested1999-10-21021 October 1999 Forwards Clarification on Items Included in 990531 Response to RAI Re Proposed License Amend Associated with Operator Action for Sbloca,As Requested NOC-AE-000680, Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan1999-10-20020 October 1999 Forwards Rev 5 to 0PGP03-ZV-0001, Severe Weather Plan NOC-AE-000683, Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii)1999-10-19019 October 1999 Forwards 30-day Rept Concerning Significant Changes to Accepted Large Break Loss of Coolant Accident ECCS Evaluation Model for South Tx Project,Units 1 & 2,IAW 10CFR50.46(a)(3)(ii) NOC-AE-000674, Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule1999-10-12012 October 1999 Forwards Requested Estimates of Needs for Operator Licensing Exams,Per AL-99-03, Operator Licensing National Exam Schedule 05000498/LER-1999-008, Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER1999-10-12012 October 1999 Forwards LER 99-008-00 Re Turbine Trip That Occurred While Performing Main Turbine Emergency Trip Test.Commitments Made by Licensee Are Listed in Corrective Actions Section of LER NOC-AE-000625, Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future1999-10-0707 October 1999 Requests Partial Relief from ASME Section XI Visual Exam Requirements of IWA-5242(a).Relief Request Is Based on Provisions of Draft ASME Section XI Code Case N-616,which Is Expected to Be Published in Near Future NOC-AE-000610, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of IWA-5250(a)(2) for Second Inservice Insp Interval,Per Provisions of 10CFR50.55a(3)(i) NOC-AE-000653, Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i)1999-10-0707 October 1999 Requests Relief from ASME Section XI Code Requirements of Table IWE-2500-1 for VT-3 Visual Exam of Seals & Gaskets on Airlocks,Hatches & Other Devices Required to Assure Containment leak-tight Integrity,Per 10CFR50.55a(a)(3)(i) 05000499/LER-1999-006, Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment1999-09-30030 September 1999 Forwards LER 99-006-00,re Entry Into TS 3.0.3.Licensee Commitments Listed in Corrective Actions Section of Attachment NOC-AE-000664, Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr1999-09-30030 September 1999 Forwards Rev 1 to STP Electric Generating Station Unit 1 Cycle 9 COLR & Rev 1 to STP Electric Generating Station Unit 2 Cycle 7 Colr NOC-AE-000646, Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr1999-09-28028 September 1999 Informs NRC That STP Nuclear Operating Co Is Y2K Ready IAW Nei/Nusmg 97-07 Guidelines & Also Provides Response to NRC Ltr NOC-AE-000633, Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 19971999-09-21021 September 1999 Forwards Rev 3 to SG-99-04-005, STP 1RE08 Outage Condition Monitoring Rept & Final Operational Assessment. Rept Satisfies Reporting Requirements of NEI 97-06,dtd Dec 1997 NOC-AE-000634, Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl1999-09-21021 September 1999 Forwards Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Povs. MOV design-basis Review Checklist,Encl NOC-AE-000649, Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P1999-09-21021 September 1999 Forwards Current Annual Financial Data for STP Electric Generating Station Per 10CFR50.71(b),acting on Behalf of Central Power & Light Co,City of Austin,Tx,City Public Svc Board of San Antonio & Hl&P 05000499/LER-1999-005, Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER1999-09-20020 September 1999 Forwards LER 99-005-00,re Esfa Following Loss of Power to Standby Transformer 2 Due to Electrical Fault.Licensee Commitments Are Listed in Corrective Actions Section of LER 05000498/LER-1999-007, Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER1999-09-13013 September 1999 Forwards LER 99-007-00 Re Train 'B' CR Makeup & Cleanup Filtration Sys Being Inoperable for Greater than Aot.Util Intends to Append Addl Info Section of LER with Brief Description of Test Results,Rather than Submit Separate LER NOC-AE-000638, Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6)1999-09-0909 September 1999 Forwards License Renewal Applications & Certifications of Medical Exam for Seven Listed Licensed Operators at Stp,Per 10CFR55.57.Encl Withheld,Per 10CFR2.790(a)(6) NOC-AE-000562, Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i)1999-08-31031 August 1999 Requests Relief from Contruction Code non-destructive Exam Requirements for Repair/Replacement Activities During Second Inservice Insp Interval of Units 1 & 2,IAW Provisions of 10CFR50.55a(a)(3)(i) NOC-AE-000617, Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d)1999-08-26026 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d) NOC-AE-000585, Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-4811999-08-25025 August 1999 Provides Notification That South Texas Project Has Completed Integrity Evaluation of Units 1 & 2 Reactor Coolant Pump Casings Required by Paragraph (D) of Code Case N-481 NOC-AE-000603, Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6)1999-07-29029 July 1999 Informs of Addition of Restriction to SRO License 42658, for KM Espinoza,Effective 990721,per 10CFR50.74.Encl Info Withheld,Per 10CFR2.790(a)(6) NOC-AE-000599, Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr1999-07-28028 July 1999 Forwards STP Unit 1,Cycle 9 Startup Testing Summary Rept. No New Licensing Commitments Contained in Ltr NOC-AE-000470, Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl1999-07-28028 July 1999 Forwards Amend 12 to STP Fire Hazards Analysis Rept. Summary of Changes Made Under Provision of 10CFR50.59 Also Encl 05000498/LER-1999-006, Forwards LER 99-006-00 Re Automatic Reactor Trip Due to over-temp delta-temp Actuation.Licensee Commitments Are Listed in Corrective Actions Section of LER1999-07-26026 July 1999 Forwards LER 99-006-00 Re Automatic Reactor Trip Due to over-temp delta-temp Actuation.Licensee Commitments Are Listed in Corrective Actions Section of LER NOC-AE-000589, Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/20001999-07-26026 July 1999 Forwards Rev to 1RE08 ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests,Corecting Date of End of Insp Interval Provided in Item 9 of from NIS-1 from 09/24/99 to 09/24/2000 NOC-AE-000582, Forwards 1RE08 ISI Summary Rept for Welds & Component Supports of STP Electric Generating Station,Unit 1. Summary Rept Satisfies Reporting Requirements of IWA-6000 of Section XI for Welds & Component Supports1999-07-26026 July 1999 Forwards 1RE08 ISI Summary Rept for Welds & Component Supports of STP Electric Generating Station,Unit 1. Summary Rept Satisfies Reporting Requirements of IWA-6000 of Section XI for Welds & Component Supports NOC-AE-000597, Forwards voltage-based Criteria 90-day Rept for SG Tube Exam Performed Under NRC GL 95-05 During Refueling Outage 1RE08. Rept Contains Info Required by Section 6.b of Attachment 2 to GL 95-051999-07-23023 July 1999 Forwards voltage-based Criteria 90-day Rept for SG Tube Exam Performed Under NRC GL 95-05 During Refueling Outage 1RE08. Rept Contains Info Required by Section 6.b of Attachment 2 to GL 95-05 NOC-AE-000598, Forwards Four Copies of 1RE08 Refueling Outage ISI Summary Rept for Steam Generator Tubing1999-07-23023 July 1999 Forwards Four Copies of 1RE08 Refueling Outage ISI Summary Rept for Steam Generator Tubing NOC-AE-00586, Forwards Results of Control Rod Testing,In Response to NRC Bulletin 96-01, Control Rod Insertion Problems, Dtd 960308.Core Map Provided to Assist in Understanding Test Data1999-07-21021 July 1999 Forwards Results of Control Rod Testing,In Response to NRC Bulletin 96-01, Control Rod Insertion Problems, Dtd 960308.Core Map Provided to Assist in Understanding Test Data NOC-AE-000595, Forwards Chapters 1.0 & 16.0 to Operations QA Plan for South Texas Project.Rev Is Strictly Administrative & All Content Was Previously Submitted to NRC on 990503 & 9906151999-07-21021 July 1999 Forwards Chapters 1.0 & 16.0 to Operations QA Plan for South Texas Project.Rev Is Strictly Administrative & All Content Was Previously Submitted to NRC on 990503 & 990615 NOC-AE-000518, Requests Exemption from Various Special Treatment Requirements of 10CFR50,as Described in Encls to Ltr.Stp Believes That Pilot Application Will Assist NRC in Development & Implementation of risk-informed 10CFR501999-07-13013 July 1999 Requests Exemption from Various Special Treatment Requirements of 10CFR50,as Described in Encls to Ltr.Stp Believes That Pilot Application Will Assist NRC in Development & Implementation of risk-informed 10CFR50 NOC-AE-000536, Submits Request for Exemption from Requirements of 10CFR50.34(b)(11),10CFR50,App A,Gdc 2 & 10CFR100,App a, Section VI(a)(3) Re Maint of Seismic Instrumentation.Revised Page to Procedure OERP01-ZV-IN01 Included1999-07-13013 July 1999 Submits Request for Exemption from Requirements of 10CFR50.34(b)(11),10CFR50,App A,Gdc 2 & 10CFR100,App a, Section VI(a)(3) Re Maint of Seismic Instrumentation.Revised Page to Procedure OERP01-ZV-IN01 Included NOC-AE-000580, Forwards Response to NRC 990415 RAI Re Implementation of Commitments Related to GL 89-10, Safety-Related MOV Testing & Surveillance & GL 96-05, Periodic Verification of Design Basis Capability of Safety-Related Movs1999-07-13013 July 1999 Forwards Response to NRC 990415 RAI Re Implementation of Commitments Related to GL 89-10, Safety-Related MOV Testing & Surveillance & GL 96-05, Periodic Verification of Design Basis Capability of Safety-Related Movs NOC-AE-000574, Forwards ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests Performed Between 971004 & Completion of Eighth RO on 9904281999-07-0606 July 1999 Forwards ISI Summary Repts for Repairs & Replacements & for Sys Pressure Tests Performed Between 971004 & Completion of Eighth RO on 990428 NOC-AE-000557, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of App III,III-3410 for Second ISI Interval.Proposed Alternatives for Ultrasonic Exam of Piping Sys Welds,Attached1999-07-0606 July 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements of App III,III-3410 for Second ISI Interval.Proposed Alternatives for Ultrasonic Exam of Piping Sys Welds,Attached NOC-AE-000498, Requests Relief from ASME Section XI Code Nondestructive Exam Requirements Applicable to SG Main Steam Nozzle inside- Radius Sections.Attachment Includes Discussion of Basis & Justification for Request & Implementation Schedule1999-07-0606 July 1999 Requests Relief from ASME Section XI Code Nondestructive Exam Requirements Applicable to SG Main Steam Nozzle inside- Radius Sections.Attachment Includes Discussion of Basis & Justification for Request & Implementation Schedule NOC-AE-000573, Requests Relief from Requirements of ASME Section XI Code Case N-498,exempting Isolated Class 1 Reactor Vessel Head Vent Atmospheric Vent Piping & Valve from Being Tested at Full RCS Pressure1999-07-0606 July 1999 Requests Relief from Requirements of ASME Section XI Code Case N-498,exempting Isolated Class 1 Reactor Vessel Head Vent Atmospheric Vent Piping & Valve from Being Tested at Full RCS Pressure NOC-AE-000541, Submits Response to GL 98-01,Suppl 1, Y2K Readiness of Computer Systems at Npps. Readiness Disclosure for STP, Encl1999-06-29029 June 1999 Submits Response to GL 98-01,Suppl 1, Y2K Readiness of Computer Systems at Npps. Readiness Disclosure for STP, Encl NOC-AE-000571, Forwards Final Operating Exam Matls for STP Exam Scheduled for 990705.Revised Operating Exam Outline & post-validation Change Summary Has Been Included.Without Encls1999-06-24024 June 1999 Forwards Final Operating Exam Matls for STP Exam Scheduled for 990705.Revised Operating Exam Outline & post-validation Change Summary Has Been Included.Without Encls NOC-AE-000512, Responds to NRC 981201 Telcon Re Jco 93-0004,per Revised MSLB Analysis1999-06-23023 June 1999 Responds to NRC 981201 Telcon Re Jco 93-0004,per Revised MSLB Analysis NOC-AE-000560, Forwards LER 99-S02-00,re Failure to Maintain Positive Control of Vital Area Security Key.Licensee Commitments Are Found in Corrective Action Section of LER1999-06-23023 June 1999 Forwards LER 99-S02-00,re Failure to Maintain Positive Control of Vital Area Security Key.Licensee Commitments Are Found in Corrective Action Section of LER 05000498/LER-1999-005, Forwards LER 99-005-00,re Failure to Meet Requirements of TS Surveillance 3.7.1.2 Action B for Auxiliary FW Sys.Only Commitments Contained in Ltr Are Located in Corrective Action Section of LER1999-06-17017 June 1999 Forwards LER 99-005-00,re Failure to Meet Requirements of TS Surveillance 3.7.1.2 Action B for Auxiliary FW Sys.Only Commitments Contained in Ltr Are Located in Corrective Action Section of LER NOC-AE-000565, Forwards Amended Pages for Insertion Into South Texas Project Nuclear Operating Co Previously Submitted Response to NRC Rai.New Pages Include Expanded Answer to Question 4.b1999-06-16016 June 1999 Forwards Amended Pages for Insertion Into South Texas Project Nuclear Operating Co Previously Submitted Response to NRC Rai.New Pages Include Expanded Answer to Question 4.b NOC-AE-000548, Forwards Response to RAI Re Proposed Amends on Replacement SG Water Level Trip Setpoint Differences for Stp,Units 1 & 2.Nothing Contained in Response Should Be Considered Commitment Unless So Specified in Separate Correspondence1999-06-16016 June 1999 Forwards Response to RAI Re Proposed Amends on Replacement SG Water Level Trip Setpoint Differences for Stp,Units 1 & 2.Nothing Contained in Response Should Be Considered Commitment Unless So Specified in Separate Correspondence NOC-AE-000561, Forwards Change QA-042 to Operations QAP, Rev 13, Reflecting Current Organizational Alignment for STP & Culminating Organizational Realigment That Has Been Taking Place During Past Several Months1999-06-15015 June 1999 Forwards Change QA-042 to Operations QAP, Rev 13, Reflecting Current Organizational Alignment for STP & Culminating Organizational Realigment That Has Been Taking Place During Past Several Months NOC-AE-0559, Forwards STP Commitment Change Summary Rept for Period 981209-990610.Rept Lists Each Commitment for Which Change Was Made During Reporting Period & Provides Basis for Each Change1999-06-15015 June 1999 Forwards STP Commitment Change Summary Rept for Period 981209-990610.Rept Lists Each Commitment for Which Change Was Made During Reporting Period & Provides Basis for Each Change NOC-AE-000499, Forwards Relief Request RR-ENG-2-3,proposing to Perform Alternative Ultrasonic Examination from Outside Surface of Skirt Attachment Weld as Described in Encl,In Lieu of Surface Examination from Inside Pressurizer Skirt1999-06-0909 June 1999 Forwards Relief Request RR-ENG-2-3,proposing to Perform Alternative Ultrasonic Examination from Outside Surface of Skirt Attachment Weld as Described in Encl,In Lieu of Surface Examination from Inside Pressurizer Skirt NOC-AE-000502, Forwards Relief Request RR-ENG-2-6,proposing That Boroscopic VT-1 Visual Examination Be Allowed as Alternative to Section XI Surface Examination of Pump Casing Welds,Or Portions of Welds within Pits1999-06-0909 June 1999 Forwards Relief Request RR-ENG-2-6,proposing That Boroscopic VT-1 Visual Examination Be Allowed as Alternative to Section XI Surface Examination of Pump Casing Welds,Or Portions of Welds within Pits NOC-AE-000500, Forwards Relief Request RR-ENG-2-4,proposing to Perform Alternative Ultrasonic Examination from Outside & End Surfaces of Reactor Vessel Closure Head Nuts,As Described in Encl in Lieu of Surface Examination of Threaded Region1999-06-0909 June 1999 Forwards Relief Request RR-ENG-2-4,proposing to Perform Alternative Ultrasonic Examination from Outside & End Surfaces of Reactor Vessel Closure Head Nuts,As Described in Encl in Lieu of Surface Examination of Threaded Region NOC-AE-000545, Forwards Response to NRC 990416 RAI Re Util Proposed Amend on Operator Action for Small Break Loca, .Draft EOP Re Small Break Loca,Encl to Aid Discussion of Proposed Amend1999-05-31031 May 1999 Forwards Response to NRC 990416 RAI Re Util Proposed Amend on Operator Action for Small Break Loca, .Draft EOP Re Small Break Loca,Encl to Aid Discussion of Proposed Amend 1999-09-09
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20055H8731990-05-25025 May 1990 FOIA Request for Records Re Minor Leak of Radioactive Steam from Containment Bldg ML20005G1381989-12-27027 December 1989 J Corder Subpoena.* Requests Opportunity to Reply to NRC Brief Prior to Consideration by Commission,Per Author 891211 Motion to Modify & for Protective Order ML20005G1411989-12-11011 December 1989 in Matter of Subpoena of J Corder.* Forwards Motion to Modify Subpoena & for Protective Order for J Corder ML20246A7461989-06-20020 June 1989 FOIA Request for Records Re Jaecon Corp Seismic Lines 2M & 4M & Interpretation of Lines ML20196A4761988-06-21021 June 1988 Requests That City of Austin,Tx Be Added to Document Control List in Order to Receive Documents Re Amend 10 to Application for CPs & OLs Matter ML20195D8121987-10-0505 October 1987 FOIA Request for Entire NRC File Re E Stites Charge of Discriminatory Employment Practices Filed Against Houston Lighting & Power Co & Documents Prepared for Use at 861103 Meeting Between NRC & Util ML20235C8421987-06-11011 June 1987 Urges Commission Denial of Gap 870529 Motion to Quash Subpoena Issued by EDO for Appearance of B Garde to Present Info Re Plant Safety Allegations & Denial of 10CFR2.206 Petition.Util to B Garde Encl ML20235Z0901987-05-22022 May 1987 Submits Signed Agreement in Order to Memorialize Further Understanding Reached During Telcon.Billie Will Not Answer Any Questions Pursuant to Subpoena,Except Under Court Order. Related Info Encl ML20207E5111986-07-14014 July 1986 Forwards Applicant Responses to ASLB 860623 Questions Re Design of Nonconforming Structures to Withstand Hurricanes & Tornadoes.Certificate of Svc Encl ML20198E2881986-05-19019 May 1986 Advises That Changes,Listed in Jg Dewease 860218 Affidavit, Necessary to Update FSAR Description of Organization, Identified & Incorporated Into FSAR by Amend 53 Filed on 860409.W/Certificate of Svc.Related Correspondence ML20210L3211986-04-25025 April 1986 Responds to 860321 Request for Comments on Newspaper Article Addressing Adequacy of Certain Portions of Plant HVAC Sys to Withstand Tornado Missiles.Certificate of Svc Encl.Related Correspondence ML20154M8861986-03-10010 March 1986 Informs That Cg Robertson Resigned from Houston Lighting & Power on 860310 & Is Now Director of Nuclear Svcs at TVA Per Robertson 860221 Affidavit.W/Certificate of Svc.Related Correspondence ML20153E8591986-02-21021 February 1986 Forwards Affidavit of Cg Robertson Re Lack of Util Licensing Engineer Presence at Briefing Given by Quadrex to Brown & Root Prior to Finalization & Submission of Quadrex Rept,Per ASLB Request ML20151T5501986-02-0303 February 1986 Informs of 860203 Filing of Util Response to Motion to Reopen Phase II Record:Iv;For Discovery & to Suspend Further Activity in Phase Iii. Supporting Documentation Re Exchange of Correspondence Encl.W/Certificate of Svc ML20138R5701985-12-27027 December 1985 Notifies That Agreement Settling Litigation Between Util & Brown & Root,Inc/Halliburton Formally Executed & Final Judgement Signed on 851220,terminating Litigation. Certificate of Svc Encl.Related Correspondence ML20138P4911985-12-20020 December 1985 Forwards cross-reference Table for Parties Phase II Proposed Findings,Including Proposed Findings for Reopened Proceeding,Per Author .Corrected Apps a & B to Applicant Proposed Findings Also Encl.W/Certificate of Svc ML20138P5891985-12-20020 December 1985 Forwards City of Austin 851206 Amended Petition in Lawsuit Against Applicant Seeking Reformation of South Texas Project Participation Agreement ML20138M5781985-12-17017 December 1985 Forwards L Stanley Affidavit Re 810102 Telcon W/Jr Sumpter Concerning Util Desire to Review Brown & Root Engineering, Including Scope of Proposed Review & Schedule ML20137L6171985-11-29029 November 1985 Forwards Excerpts from DG Barker Nov 1980 Notes,L Stanley 810102 Telcon Notes & Exhibit 5 Ref on Page 2,091 of Thrash Notes from 810220 Mgt Committee Meeting.W/O Encls.W/ Certificate of Svc.Related Correspondence ML20137H9461985-11-27027 November 1985 Forwards Reply to Proposed Findings of Fact & Conclusions of Law Submitted by Other parties-Phase Ii.Table of cross-ref Between Applicant Proposed Findings & Those Submitted by Other Parties Forthcoming ML20137D3931985-11-26026 November 1985 Provides Change of Address for La Sinkin,Effective 851110 ML20138S0191985-11-14014 November 1985 Forwards 851113 Press Release Stating That Unit 1 Presently 2 Months Behind Schedule.Development Should Not Affect Undertaking & Completion of Phase III of OL Hearings.W/ Certificate of Svc.Related Correspondence ML20209H2871985-11-0707 November 1985 Forwards Proposed Findings of Fact & Conclusions of Law in Form of Partial Initial Decision ML20138N2321985-10-31031 October 1985 Forwards Applicant Response Opposing Citizens Concerned About Nuclear Power (Ccanp) 851016 Motion to Reopen Phase II Record:Ii.Pleading Addressing Both Motion III & Ccanp Withdrawal Will Be Filed Upon Receipt of Withdrawal ML20133K3511985-10-17017 October 1985 Advises of Error in Applicant 851014 Motion to Establish Schedule for Phase III Indicating That NRC Would Not Be Filing Response.Nrc Will Submit Response.Related Correspondence ML20133J7281985-10-17017 October 1985 Forwards Citizens Concerned About Nuclear Power Exhibit 148 for Inclusion in Facility Docket,Per ASLB 851016 Order ML20133F7201985-10-0808 October 1985 Informs of No Intentions to Suppl Records for Phase II Hearings Re Util 850730 Supplemental Response to NRC Notice of Violation Concerning Issue B/D-1,adequacy of Ebasco Backfill Activities.Certificate of Svc Encl ML20205G8321985-10-0808 October 1985 Apologizes for Glibness in Transmittal Ltr Accompanying Citizens Concerned About Nuclear Power Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20135A0191985-09-0606 September 1985 Forwards Affidavit of C Thrash Re Questions Agreed Upon in 850820 Telcon Concerning Process for Preparing Minutes of Mgt Committee 850427,0626,0723 & 24 Meetings ML20133L0541985-08-0606 August 1985 Forwards INPO Const Project Evaluation Rept.Suggested Areas of Improvement Addressed.Addl Measures to Meet INPO Objectives Will Be Addressed by 860131.One Deficiency Identified.W/Certificate of Svc.Related Correspondence ML20128H1071985-07-0202 July 1985 Forwards Memorandum Re Permissibility of & Need for Calling Certain Attys as Witnesses & Documents,Including Drafts, Generated Between 810401 & 0924 Re Decision to Seek Replacement of B&R,Per ASLB 850618 Memorandum & Order ML20127L5771985-06-26026 June 1985 Forwards Testimony of Individuals to Be Presented on Behalf of Applicants in Phase II of Proceeding Scheduled to Begin on 850711.List of Exhibits Intended to Be Offered Into Evidence Encl.Related Correspondence ML20127L4971985-06-25025 June 1985 Forwards Addl Listed Documents Appearing within Scope of ASLB Request in 850226 Memorandum & Order for Preparation of Testimony Being Filed in Proceeding.Certificate of Svc Encl. Related Correspondence ML20126C4261985-06-12012 June 1985 Informs That L Stanley Will Present Testimony in Phase II Hearings Re Design Review of Brown & Root Engineering Work for Plant.Certificate of Svc Encl.Related Correspondence ML20126J9231985-06-0707 June 1985 Forwards Applicant Identification of Witnesses for Phase II of Proceeding,Per 850517 Sixth Prehearing Conference Order. Related Correspondence ML20128N9201985-05-30030 May 1985 Forwards Util 850530 Press Release Announcing Agreement Reached on Lawsuit Settlement Against Halliburton Co & Subsidiary,Brown & Root,Inc Re Engineering & Const of Facility.Certificate of Svc Encl.Related Correspondence ML20117G0801985-05-0808 May 1985 Forwards Proposed Corrections to Transcript of 850430 & 0501 Prehearing Conferences,Correcting Erroneous Citations. Certificate of Svc Encl ML20116P1311985-05-0303 May 1985 Forwards Previously Withheld Documents Per ASLB 850226 Memorandum & Order Releasing Documents Listed in Attachment B to .Certificate of Svc Encl.Related Correspondence ML20116G4311985-04-26026 April 1985 Forwards Two Addl Documents,Including Typed & Handwritten Versions of Excerpts from Cg Thrash 810721 Notes Re Util Mgt Meeting,Per ASLB 850226 Memorandum & Order.Certificate of Svc Encl.Related Correspondence ML20116G4471985-04-26026 April 1985 Forwards Reply to Citizens Concerned About Nuclear Power Response to ASLB 850226 Memorandum & Order Re Quadrex Rept & Suggested Spec of Quadrex Findings to Be Litigated & Suggested Spec of Issue Re Soils ML20116D8131985-04-25025 April 1985 Forwards Util Response to Citizens Concerned About Nuclear Power 850417 Motion to Reopen Phase I Record in Two Pleadings,In Response to ASLB 850418 Order.First Pleading Responds to Motion & First Two Questions of Order ML20205A9531985-04-22022 April 1985 Advises That ASLB Will Receive Jh Goldberg Re Specs of Brown & Root & Plaintiff Claims & Issues Based on Refs to Design & Const.Certificate of Svc Encl.Related Correspondence ML20116B3161985-04-19019 April 1985 Forwards Documents Generated Between 810301 & 0928 Re Reportability to NRC of Quadrex Rept & Info in Rept Reflecting QA Violations,Per ASLB 850226 Memorandum & Order. Certificate of Svc Encl.Related Correspondence ML20112A5901985-03-14014 March 1985 Advises That No Further Applicant Response Will Be Filed to 841221 Staff Affidavit Re Const Qa/Qc Under New Contractors at Facility.Certificate of Svc Encl.Related Correspondence ML20111C6541985-03-13013 March 1985 Forwards Corrected Page 9 to Applicant 850312 Motion for Summary Disposition on Citizens Concerned About Nuclear Power Contention 4 Re Wind Speed ML20112B0161985-03-12012 March 1985 Forwards Applicant Motion for Summary Disposition on Citizens Concerned About Nuclear Power Contention 4. Adoption of Listed Schedule for Response Requested ML20099F5371985-03-0808 March 1985 Responds to Ah Gutterman 850225 Request to Aslab to Reconsider Granting Time Extension for Intervenor to File Motion for Reconsideration of Decision ALAB-799.Request Should Be Denied.Certificate of Svc Encl ML20107G7001985-02-25025 February 1985 Forwards Joint Affidavit of MR Wisenburg & Je Geiger Supplementing Info Contained in 841221 Rept on Const Qa/Qc Under New Contractors,Per 840314 Partial Initial Decision & 841116 Fifth Prehearing Conference Order ML20107K4851985-02-25025 February 1985 Requests Reconsideration & Denial of Citizens Concerned About Nuclear Power Request for 10-day Extension for Filing Petition for Reconsideration of ALAB-799.Certificate of Svc Encl.Related Correspondence ML20101E7701984-12-21021 December 1984 Requests Approval of Encl Proposed Corrections to 841213 Transcript.Certificate of Svc Encl 1990-05-25
[Table view] |
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q '~ p VINSON & ELKiNS '
ATTORN EYS AT LAW rimstcTYTo g E,i-1 P' 9 HOUSTON, TEXAS 77oO2 6760 TELtowo.sg 7 3 ess.2222 TWE 9608816391 TELEX 762146 ,
HOs CossatCTICUT Avt..s.w sufft 900 47 CHARLES ST,.stmaELEY SOUAmt WASNINGTON,0.c.2OO36 4303 INTtmFansT Towsm LONDON wtx 7Ps. ENGLAND AUSTIN, TEXAS 737Cl*3898 TELEPM ON E 202 862-6800 TELEPHOut 44 Op mee-723e TELEPMONE sat 47e 2500 cA.Le wNeu. ..TakeX . O coativi. woo . rstra 0 September 27, 1984 is ;r .
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, , i *t Mr. Charles Bechhoefer Chairman ' U U. ty.,q,'$d
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Atomic Safety and Licensing Board M -y9 U. S. Nuclear Regulatory Commission Washington, DC 20555 d(
SE)!yED g
Dear Mr. Bechhoefer:
I write as lead counsel representing Brown & Root, Inc.
in the multi-billion dollar lawsuit brought against it by Houston Lighting & Power Company ("HL&P") and the three other co-owners of the South Texas Project, Units 1 and 2
("STP") . As you may be aware, this lawsuit currently is pending before Judge G. P. Hardy, Jr., in the District Court of Matagorda County, Texas, 130th Judicial District, Case No. 81-H-0686-C.
I have reviewed your Partial Initial Decision ("PID"),
dated March 14, 1984, on the Phase I NRC proceedings re-lating to HLSP's application to operate STP, and your more recent decis:.ons of May 22, 1984, June 11, 1984, July 10, 1984, and September 7, 1984, describing the Licensing Board's intentions with respect to the Phase II litigation of Quadrex F.eport issues, i
Your ?ID makes a number of negative observations about Brown & Rcot, even though Brown & Root is not a party and no party has presented Brown & Root's side with regard to any controvert 3d iscue. While we do not object to your deter-minations as to HL&P's character and competence, we are concerned by the negative statements contained in your PID about Brown & Root.
If you reflect upon it, I believe you will recognize that you have no basis acceptable under American administra-tive law standards, or, indeed, any basis that can be sup-ported with logical integrity to reach conclusions regarding Brown & Root. The evidentiary record is flawed and either incomplete or non-existent, for example, on the following issues 8410020310 840927 PDR ADOCK 05000490 C)g g PDR \ -
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Mr. Charloc Dachhoefcr S ptemb3r 27, 1984 j Page 2 i
(1) The experience of the project team Brown &
Root assembled for the South Texas Project.
(2) The impact of cost and schedule pressure from the owners on Brown & Root's efforts and on quali-
_ _ ty assurance at the Project.
(3) The involvement of HL&P' as project manager with complete contractual control over . Brown &
Root in Brown & Root's efforts to design and engi-neer the project and to perform quality assurance functions.
(4) The legitimacy of the Show Cause allegations (which HL&P for tactical reasons chose not to
.- controvert) and the proper allocation of responsi-bility between HL&P and Brown & Root for problems that did exist on the South Texas Project.
~
(5) The possibility that HL&P's decision to re-move Brown & Root as architect / engineer was done to provide HL&P a scapegoat to deflect criticism from its co-owners and others.
Ny purpose in writing is to ask that you refrain from reaching conclusions regarding Brown & Root where you do not have an evidentiary record developed in accordance with the settled standards of American jurisprudence and, indeed, elementary fairness. Negative observations or conclusions are devastating to Brown & Root's standing in the industry and are harmful to its defense of the multi-billion dollar lawsuit brought against it by the South Texas Project owners. There are no claims against Brown & Root to which we cannot give meritorious answers in the lawsuit when given the opportunity to respond.
Let me add additional reasons why the record before you prcvides no legitimate bisis for reaching conclusions vis-a-vis Brown & Root. We now know that at the very time hearings before you were underway, HL&P had, unbeknownst to Brown & Root, decided to remove BroWIT & Root as architect-engineer and construction manager. It had already taken steps to begin the selection of a replacement. In these circumstances, it is obvious that HL&P and its lawyers had every reason to foist on Brown & Root blame for every problem real or imagined, making Brown & Root a scapegoat.
While Brown & Root witnesses were presented during the
,,-s n -- - - ,--- __ _
,. . Mr. Ch2rlo;:; Bachhoaf;r Saptcmber 27, 1984 -
Page 3 hearings, their. selection and the content of their direct testimony was controlled by HL&P's attorneys.
Further, the unreliability of the record concerning Brown & Root was compounded by the agreement of the NRC staff and HL&P to present the case to you on a " stipulated" set of facts. As you know, counsel for HL&P stipulated that HL&P would not challenge the factual findings in the 79-19 Investigation Report, Notice of Violation or Show Cause Order. See Transcript at 8023-24.1/
HL&P had made a tactical decision, taken contrary to Brown & Root's advice, not to dispute the allegations in the Notice of Violation and Show Cause Order. The allegations prior to HL&P's decision not to contest them were solely claims. Had HL&P chosen to show cause why they were incor-rect in whole, or in part, the NRC could have concluded no penalty was appropriate. After HL&P had already responded by not contesting the allegations, a careful 1/ In pertinent part, HL&P's counsel Mr. Axelrad stated:
As we have previously indicated, it is not the purpose of this panel's testimony to respond to any of the statements of fact set forth in Section A-1 of the Notice of Violation, which are based on I&E Report 79-19. We have not prepared our case with a view to responding to those statements of fact because. . .we do not take issue with the ultimate conclusions on these matters drawn by the NRC Staff in the Notice of Violation.
Although some of this panel's [ Messrs. Warnick, Singleton & Wilson) testimony overlaps the time period covered by I&E Report No. 79-19, neither it nor the ecrlier particular testimony of other witnesses, e.g. Mr. Oprea and Dr. Broom, is intended to derogate in any way the admissions contained in our earlier filings, nor to contro-vert in any *?ay t.he conclusions drawn by the NRC Staff in the Notice of Violation which is already in evidence in this proceeding. [Tr. 8023-24 (September 14, 1981)].
Mr. Charlec B;chhosfer Stptcmber 27, 1984 Page 4 review of the factual assertions set forth in these docu-ments by Brown & Root and HL&P demonstrated that many of the NRC Staff findings were in material error, contained substan-tial misunderstandings, and did not present an accurate picture of activities at STP in late 1979 and early 1980.
Indeed, HL&P's attorneys expressly represented to the Department of Justice that they consented to the Show cause-charges even though many of them were unsubstantiated. (See Silbert-to Lippe letter of June 2, 1981 at page 3, attached as Exhibit A.) The stipulation entered in your hearing
, deprived the Licensing Board of the opportunity to gain a real insight into Brown & Root's true role at STP.
Let me also briefly allude to the Licensing Board's reliance in the PID on Mr. Goldberg's commissioning of the Quadrex Report, ara. your intention in Phase II to " assume (as did the Staff) that the various safety deficiencies alluded to in that Report in fact occurred." We respectful-ly submit that the Board's treatment is without legitimate basis. Because of a prctective order in our litigation with HL&P, I am not free to call to your attention evidence developed in discovery. I do want to call to your attention evidence in your own proceeding.
First, Mr. Goldberg's testimony criticizing Brown &
Root was given in 1982, after HL&P terminated Brown & Root and commenced its multi-billion dollar lawsuit against Brown
& Root. The PID makas no mention of Mr. Goldberg's and HL&P's obvious bias against Brown & Root in 1982 Second, in his September 27, 1983 deposition in your proceeding, Mr. Goldberg questioned the experience, objec-i tivity, and competence of the Quadrex Report reviewers. Mr.
Goldberg has given similar testimony undermining the STP
.Quadrex Review during the Allens Creek NRC construction permit proceeding in April 1982. As you may know, Brown & j Root and Bechtel have both prepared extensive analyses of '
the Quadrex Report findings. They demonstrate the unrelia-bility of the Quadrex findings. Mr. Goldberg in his deposi-tion even acknowledged that he shared some of Brown & Root',s
" rebuttals" to Quadrex's findings. September 27, 1983 NRC Deposition of Jerome H. Goldberg at Tr.99-100.
Thus, there is no basis to " assume" that the safety deficiencies alleged in the Quadrex Report "in fact oc-curred." They did not. As with the allegations in the Show Cause Order and Notice of Violation, at the trial stage
~
Mr. Chnrles Bschhonfsr '
S;ptcmb r 27, 1984 Page 5 in the pending litigation we intend to rebut the Quadrex allegations and HL&P's involvement in that faulty report.
While considerable harm to Brown & Root's reputation has already been unfairly caused by your PID, we again respectfully urge that your Board, in its future considera-tion of STP matters, avoid making conclusions regarding Brown & Root. We respectfully submit that the integrity of the NRC's licensing process cannot be assured otherwise.
Si rely, rf r y 1. Rea e Attorney o B & Root, Inc.
HMR/ld cc: Dr. James C. Lamb Mr. Ernest E. Hill Alan S. Rosenthal, Esq.
Dr. W. Reed Johnson Christine N. Kohl, Esq.
Finis E. Cowan, Esq. (Houston Lighting &, Power)
Jack R. Newman, Esq. (Houston Lighting & Power)
Ferd. C. Meyer, Jr., Esq. (City of San Antonio)-
William W. Vernon, Esq. (City of Austin)
Thomas J. Heiden, Esq. (City of Austin)
James W. Wray, Esq. (Central Power & Light) ,
Joe H. Foy, Esq. (Central Power & Light)
, Dan M. Berkovitz, Esq.
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.-e w p. - c=u.uw Iawrence Lippe, Chief General Litication and
. Legal Advice Section
. Criminal Division . .
Department of Justs..ce
. Washington, D.C. 20530 Re: Houston Lighting & Power Company,
. South Texas Project
Dear Mr. Lippe:
Immediately upon receipt of the letter dated March 26, 1981, from Karen A. Morrissette of your Section to the Presi-dent of Houston Lighting & Power Company (HL&P),the Company's General Counsel consulted me with respect to the matters there-in. Subs ecuen.tly, I had the opportunity t.o meet with you, Julian Greenspun of your Section,' and Ms. Morrissette to dis-cuss the letter, an opportunity I certainly appreciated and
- which I believe was mutually beneficial.
I requested the meeting because of HL&P's serious concern about Ms. Morrissette's letter. The letter alleges
. that information from the Nuclear Reculatorv Commission (WRC) indicates that certain employees at the .Sout.h Texas Proj ect (STP) have falsified reports in violation of 18 U.S. Code S 1001. The letter further alleces, that the "historv of deficiencies in the Quality A'ssurance Prograr." at STP "also indicates that the actions of. these empicyees are merely HL&P and symptomatic its contractor,of an overall Brown & Root (B pattern
&R) . of neglect" /.by/4 ff
_ c HL&P rescectfully but firml~v desiTs ' as Ene~cM& a t e ;-~ -
and unjustified this wholly conclusorv a$d"unEUo'occ'dEd. d10.E.r i. - -
~ , cation of an overall cattern of neclect.1> HL&P'c - - -* ae-c.CS.ygges l beyond quesi: ion that it has bean conbcientiously] I.
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1 EXHIBIT A J ERRawan ~ .
U 5 DE?;mMENT OF fusitci G_
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- June 2, 1981 Page Two .
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responsive to matters brought to its attention by NRC Staff--
an ! that the Company has taken tangible steps mentioned be-construc-Icw to assure the soundness and safety of the STP tion. .
First, howevei, with respect to the specific instance.
referred to in the first paragraph of Ms. Morrissette's letter I understand from our discussiens that the matters involved are covered by NRC Inspection and Enforcement Reports Nos.
80-14 and 80-21. You should be aware that the responsible This m.nployees, one a supervisor,. were promptly terminated.
is proof of management's deterWation not to tolerate con-duct of this nature. .The Justice Department, moreover, de-This is not surprising since the alleged clined prosecution.
false statements involved were not, based on my fifteen years' experience as a federal prosecutor, of the kind for which the Justice Department 'would authorice criminal prosecution of those who made* them.
At our meeting, I was told that because ofthe theJustic:
safet.
considerations associated with nuclear f acilities ,
Depart =ent might . bring. charges where otherwise it 'would not.
Even assuming the soundess of this policy, it is important that the Department be aware of the fact that the quality of the structures and equipment in place at STP have recently been examined by NRC personnel, as well as consultants a.nd independent review' committees retained by HI,&P and Brown &
Root and that'-- with the exception of certain welding work which is now being remedied -- all work in place meets appli-cable- requirements and there are no major safety related proble=s. ,
In responding to the general charge in the second
- _caragraph of Ms. Morrissette's letter, HLi.P's record should be evaluated in light of the extraordinary enforcement sys-tem within which the Ccmpany and all NRC licensees, must op-erate. In the case of STP, prior to November,1979, NRC had conducted fif t/-nine (59)* inspecticns at STP: in 19 80, NRC conducted thirty-eight (38) inspections; and in 19 Furthe..- 81 thr'ough c ra ,
April 13, seven (7) inspecticns were conducted.
ERC has had a resident reactor inspector stationed at the STP construction site itself to review aspects of the con-struction program on a daily basis.
Enen from time to time as a re uit of their intensi.
- oversight, NRC inspectors found problems at STP, Thus, whenmanagement a number of responded promptly and effectively.
items of ncn-compliance were called to the Cc,mpany's attenti::
"' ' - --~_ _ _ _ _ . _ _ _ . _.
awrenca O_p*,- jT. Tie d ' a s .--
June 2, 1951 ,
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in Dece=ber, 1979, -- items which led to a Show Cause Order en April 30, 19 80, -- HL&? informed NRC almost contempor-annously of its adoption of a nine point action program for specific improvements in the STP quality assurance program.
It further described its extensive correction program by latter to NRC in February,19 80.
Although after investigation EL&P could not affirm er deny certain of the alleged items of non-compliance, it decided to treat all violations as " substantiated" and to pro.ceed to a much more f ar-reaching evaluation of the " root causes" of these non-compliances:
-- The Company and its contractor, Brown
& Root, undertook a sienificant review and revision of work procedures to pro-vide clearer and more easily understand-
., able guidance to the crafts and inspec-
~
tion personnel. ,
-- Procedures for tracking non-conforming conditions were changed to provide manage-ment with-batter tools for identifying and correcting any underlying problems.
-- Programs to control field design daanges were. modified to assure consistency with basic design requirements.
-- Training and indoctrination programs stress-
. ing the importance of quality-related activ-ities wars intensified. .
-- Work procedures were reviewed to incorporate appropriate ' notice of inspection requirements '
and proper docu=entation of completed inspec-tien activities.
-- Deficiencies En* kudit programs were corrected and the audit staff, as uell as personnel responsible for inspection activities, was i significantly augmented.
-- As discussed below, major changes were made '
to increase the participation and visibility of upper management in OA/Ac activities.
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'ia*.cronca Lippu .Chiof ,
"* Juno 2, 1981 .
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The activities were undertaken.with the advice and
assistance of highly qualified consultants.
A major part of.the C==pany's corrective measures is a more' prominent role for upper management in quality-
- Mr. Jordan, President and Chief Executive Office of EL&P, met with NRC I&E Staff in Washington i= mediately after issuance of -
the NRC's enforcement order to obtain a first-hand impression of the gravity with which the Commission regarded the observed '
t deficiencies. He has since that data par- '
- ticipated in numerous meetings at the con- '
struction site to review problems and' prog-1 ress at the STP.
~
- Mr. Jordan assigned the Company's Execu-tive Vice President and nest senior'engin-
. eering-oriented executive, Mr. Oprea, to (
essentia11v f_ull-time service on the STP.
> -- Mr. Oprea is on the site regularly, and directly supervises the work of the corpor- l ate quality assurance dire = tor, who has been
~
moved to the site.
-- The Company has cbtained a highly. respected
. pers'6n with more than twenty years of experi-anc's to serve as Vice President for Nuclear '
.Ingineering and Construction. Additional qualified personnel have been hired and others are being recruited.-
)
The effort to' assure the viability of the quality program at the STP is a continuing tash, but very significant i
improvements have already been realized. Nearly all of dozens I l
l of corrective measures to which the Company has committed it-self to the NRC havi been accomplished. At our meeting, you i F
stated the interest of your Section in "scod faith efforts" by manage.ent of a nuclear facility in.a quality assurance program.' Ms. Morrissette's latter refers to " meaningful efforts." Given the corrective acticns outlined in this letter!
l it is dif ficult to conceive of a more impressive array of good '
ML&P managanent
. faith and meaningful effor:s by ntnsgement.
e 0 .
lawrence Lipps, Chief 4
' June 2, 1981
. . E
< has worked. closely with the MRC to assure that its prograns ce= ply with the conditions of its construction permits and NEC regulations. Under these circumstances, any suggestion by the Justice Depart =ent that future misconduct by individual employees at STP, particularly e=ployees of its independent s centractor or subcontractors, may be attributed to EL&P or its responsible officers would be unf air and unwarranted.
The NRC's continuing interest in these matters is evidenced in a special early hearing .new underway on the issuance of the operating licenses for the STP which is -
basically directed to questions concerning past and current i=plementatien.of the quality programs at the STP. EL&P appreciates your statement that you do not view the fun =-
tien of your Section in the Justice Department to be a -
" regulator." This is, of. course, the function and responsi-bility of the NRC. . .But EL&P wishes to assure you that if probl=-= of concern to your Section arise, it would welcome the opportunity to review them with you to assure that the
. Department fully understands the associated circumstances and corrective actions taken to comply with NRC requirements.
obviously'; it is ~ 1 ways possible that some individual
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e=plcyees at STP will make mistakes, and may even try to conceal them. Although HL&P is taking every step within its power to encourage employees to act in a responsible and professional manner, the size of the Project is too vast and the nurber of a=ployees and documents too many for any management, how-ever vigilant, to prevent these occurrences altogether. It
. is, of course, EL&P's responsibility to make itself aware of '
such occurrences, to th.e extent practicable, and to take appropriate corrective ~ actions. -
The record is clear that EL&P has done this.
Moreover, as I mm certain you are aware, the construc-tion of nuclear power facilities is controversial. There is i
determined and strenuous opposition on the part of some to the South Texas Project. This has resulted in numerous allegations of violations at STP, some well publicized, which prompt investi gatien by NBC has not substantiated. The significance of other alleg'ations, even if confirmed as occurring, has been . grossly exaggerated. Finally, there are particular sensitivities en the part of all -- regulators and regulated alike -- resulting frca the Three Mile Island incident. -
All cf this makes it especially important that there be adequate ccenunication and cooperation between STP nanage-nent and the gRC and your Section, where advisable, so that S'gP
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aschle=s which confide'nt thatarise youcan willbe findplaced. EL&P in p =per
- r. cst anxious persp'to 'do What' is expected to construct and operate the South Texas Project in ec=pliance with its pe==its and NRC regulations. -
Thank you again for the opportunity to meet with you,
- 1r. Greenspun, and Ms. Morrissette, and to review this =atter with you. -
Sincerely,
[ l* ,,
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. Earl J. Silbert
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