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Category:INTERVENTION PETITIONS
MONTHYEARML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20206J9151986-06-24024 June 1986 Response to Petition of Coalition for Alternatives to Shearon Harris (Cash) for Leave to Intervene.Petition Filed on 860609,4 Yrs After Deadline.Cash Should Be Foreclosed from Participation.W/Certificate of Svc ML20205T4071986-06-0909 June 1986 Petition of Coalition for Alternatives to Shearon Harris for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20204A4891986-05-0808 May 1986 Response to Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 Re Falsification of Exposure Records.Request Should Be Denied. Certificate of Svc & SA Browne Affidavits Encl ML20210K6981986-04-22022 April 1986 Motion for Admission of New Contention WB-4, Falsification of Exposure Records. Records Systematically Falsified to Reflect Lower Doses to Workers.Requests Opportunity to Respond If Contention Opposed ML20136J4171986-01-0303 January 1986 Answer to W Eddleman 851223 Response to Contention 57-C-57 Re Contaminated Injured Persons.Contentions Should Be Limited to Issues Heard in Guard Vs Nrc.Contention Opposed. Certificate of Svc Encl ML20137H7251985-11-22022 November 1985 Petition of Atty General of State of Nc for Leave to Intervene ML20133J2301985-10-15015 October 1985 Response in Opposition to W Eddleman Proposed Contention Re Emergency Planning Exercise.Svc List,Exercise Evaluation Rept,Operations Journal & Insp Rept 50-400/85-20 Encl ML20133K6601985-10-15015 October 1985 Response to W Eddleman 850930 Proposed Contentions Based on Emergency Planning Exercise.Certificate of Svc Encl ML20133F3661985-09-30030 September 1985 Requests That Listed Contentions Based on May 1985 Emergency Planning Exercise Be Admitted as There Are No Other Means or Parties to Protect or Represent Author Interests in Matters.Certificate of Svc Encl ML20134H2051985-08-26026 August 1985 Response in Opposition to W Eddleman Contentions Re Spill of Reactor Water.Contention Should Be Rejected for Failure to Comply w/10CFR2.714(b).Certificate of Svc Encl ML20134H2201985-08-23023 August 1985 Response to W Eddleman Proposed Contentions EM-1,EM-2 & EM-3 Re Notification of State & Local Emergency Mgt Agencies. Contentions Should Not Be Admitted Due to Lack of Requisite Basis & Specificity.Certificate of Svc Encl ML20133A0341985-07-31031 July 1985 Petition of Lh Thornburg for Leave to Intervene ML20128H4071985-05-22022 May 1985 Response Opposing W Eddleman 850429 Proffered Contentions 227-CC & 227-DD Re Allegations That Public Info Brochure Must Provide Directions to Evacuation Shelters & Title on Evacuation Routes Chart Misleading.Certificate of Svc Encl ML20117H6751985-05-0909 May 1985 Response Opposing Eddleman Proposed Contentions 227-CC & 227-DD Re Brochure Evacuation Route Chart.Contentions Constitute Editing of Brochure & Therefore Not Litigable. Certificate of Svc Encl ML20116L7211985-04-29029 April 1985 Petition Requesting Admittance of Contentions 227-CC & DD Re Brochure Additions Served on 850416 Concerning Emergency Plan Evacuation & Shelter for Settlement or Litigation. Certificate of Svc Encl ML20102A7691985-02-0606 February 1985 Response Opposing Intervenor 850118 Request for New Contention WB-3 Re Drug Use During Const.Contention Lacks Basis & Specificity & Unsubtantiated Broad Issues Delay Proceeding.Certificate of Svc Encl ML20102A4201985-02-0404 February 1985 Submits Diesel Generator Info & Contentions 178-AA & 179-AA for Litigation,In Response to Past ASLB Order ML20113D9501985-01-18018 January 1985 Request for Admission of New Contention WB-3 Re Drug & Alcohol Abuse at Const Site.News Article Supporting Contention & Certificate of Svc Encl ML20108A2281984-11-13013 November 1984 Response to Late Filed Contentions of W Eddleman & Conservation Council of North Carolina Based on Cv Vo Affidavit.Contentions WB-1-2 & 41C-414H Should Be Rejected. Certificate of Svc Encl ML20096B8661984-08-31031 August 1984 Responses to Discovery on Emergency Planning Contentions (First Set).Certificate of Svc Encl.Related Correspondence ML20096B5131984-08-28028 August 1984 Response to Eddleman 840810 Contentions on Emergency Plan Brochure.Certificate of Svc Encl ML20094N1511984-08-10010 August 1984 Eddleman Contentions on Emergency Plan Brochure, Safety Info for Shearon Harris Nuclear Power Plant. Certificate of Svc Encl ML20093G1341984-07-20020 July 1984 Response in Support of Preamble to Revised Contention 9 Re Environ Qualification of Electrical Equipment.Certificate of Svc Encl ML20092N7151984-06-29029 June 1984 Response to Eddleman Proposed Contentions 65-A & 65-B Re Questionable Structural Integrity Due to Voids from out-of-spec Sump & Improper Vibration Technique. Certificate of Svc Encl ML20092D9521984-06-19019 June 1984 Response Opposing W Eddleman 840605 Motion to Reinstate Contention 58(2d) Re Financial Qualifications.Certificate of Svc Encl ML20197H3921984-06-14014 June 1984 New Eddleman Contention 65-A Re Questionable Structural Integrity Due to Voids from out-of-spec Slump,Improper Vibration Technique & Inadequate Strength of Harris Containment Concrete ML20091M5611984-06-0505 June 1984 Withdrawal of Eddleman Contentions 85/86 & Second Motion to Reinstate Contention 58(2d) Re Financial Qualifications ML20084E1331984-04-28028 April 1984 Answer Opposing Eddleman Proposed Contentions on Emergency Response Plans.Certificate of Svc Encl ML20084D0341984-04-27027 April 1984 Response Opposing R Wilson 840413 Contentions Re State of Nc Emergency Response Plan.All Contentions Should Be Rejected. Certificate of Svc Encl ML20083P7471984-04-16016 April 1984 Motion to Require Svc of All Amends & Changes to Emergency Plan on Intervenor & Motion to Amend Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20083L2951984-04-13013 April 1984 Contentions on State of Nc Emergency Response Plan. Certificate of Svc Encl ML20083M0871984-04-12012 April 1984 Contentions on Emergency Plan (Second Set).Plan Fails to Indicate Number of Volunteer Personnel Necessary or Assuredly Available to Perform Assigned Responsibilities. Certificate of Svc Encl ML20088A0771984-04-0505 April 1984 Suppl to Feb 1984 Petition for Leave to Intervene in Intervenor Charge Re State of Nc Emergency Response Plan. Certificate of Svc Encl ML20087P5211984-04-0303 April 1984 Partial Response & Contentions 157 & 151 Re Offsite Emergency Plan ML20087P8701984-04-0303 April 1984 Contentions Arising from Review of Emergency Response Plan, Per ASLB 840308 Order.Certificate of Svc Encl ML20086R9141984-02-28028 February 1984 Response Opposing W Eddleman Motion to Admit Contention 58(2d) on Financial Qualifications of co-applicants.ASLB Has No Basis or Authority to Reconsider Original Ruling on Contention & Motion Must Be Denied.Certificate of Svc Encl ML20086M8231984-02-15015 February 1984 Certification to Applicant 840118 Motion for Summary Disposition of Eddleman Contention 65.Motion Identifies One Instance of Honeycombing or Voids in Containment Base Mat, Exterior Walls & Dome.Certificate of Svc Encl ML20086N5051984-02-15015 February 1984 Motion to Withdraw Contention III Re Mgt Capability. Certificate of Svc Encl ML20080L0401984-02-13013 February 1984 Motion to Reconsider & Admit Contention 58 Re Financial Qualifications of co-applicants.Certificate of Svc Encl ML20080D2701984-02-0606 February 1984 Answer to W Eddleman Motion for Further Deferral of Parts of Contention 107 & Eddleman New Contentions & Amended Deferred Contentions in Response to NRC Ser.Aslb Should Deny Motion & Reject New SER Contentions.Certificate of Svc Encl ML20080G2391984-02-0606 February 1984 Request for Clarification & Objections to ASLB 840127 Order Re Eddleman Contentions 37A,37B & 8F2.Certificate of Svc Encl ML20079L4371984-01-23023 January 1984 Response Opposing Eddleman Contentions 169-172 Re Safety Parameter Display Sys.Contentions Wholly W/O Basis, Operate on Faulty Understanding of Sys & Should Not Be Admitted.Certificate of Svc Encl ML20079H4571984-01-17017 January 1984 New Contentions & Amended Deferred Contentions,In Response to NRC SER ML20083H5711984-01-0303 January 1984 Filing of New Contentions 169,170,171 & 172 Re Inadequate Safety Parameter Display Sys Design ML20081K0091983-11-0404 November 1983 Response to Applicant & NRC 830929 Responses to Joint Intervenors 830906 Contentions Re Security Plan.Encl Withheld (Ref 10CFR73.21).Certificate of Svc Encl ML20081E0091983-10-28028 October 1983 Response to Util Motion for Summary Disposition of Contention Ii.Veracity of All General Facts Disputed.List of Matters in Dispute on Contention II & Certificate of Svc Encl 1999-05-05
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20206J9151986-06-24024 June 1986 Response to Petition of Coalition for Alternatives to Shearon Harris (Cash) for Leave to Intervene.Petition Filed on 860609,4 Yrs After Deadline.Cash Should Be Foreclosed from Participation.W/Certificate of Svc ML20205T4071986-06-0909 June 1986 Petition of Coalition for Alternatives to Shearon Harris for Leave to Intervene & Request for Hearing.Certificate of Svc Encl ML20204A4891986-05-0808 May 1986 Response to Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 Re Falsification of Exposure Records.Request Should Be Denied. Certificate of Svc & SA Browne Affidavits Encl ML20210K6981986-04-22022 April 1986 Motion for Admission of New Contention WB-4, Falsification of Exposure Records. Records Systematically Falsified to Reflect Lower Doses to Workers.Requests Opportunity to Respond If Contention Opposed ML20136J4171986-01-0303 January 1986 Answer to W Eddleman 851223 Response to Contention 57-C-57 Re Contaminated Injured Persons.Contentions Should Be Limited to Issues Heard in Guard Vs Nrc.Contention Opposed. Certificate of Svc Encl ML20137H7251985-11-22022 November 1985 Petition of Atty General of State of Nc for Leave to Intervene ML20133J2301985-10-15015 October 1985 Response in Opposition to W Eddleman Proposed Contention Re Emergency Planning Exercise.Svc List,Exercise Evaluation Rept,Operations Journal & Insp Rept 50-400/85-20 Encl ML20133K6601985-10-15015 October 1985 Response to W Eddleman 850930 Proposed Contentions Based on Emergency Planning Exercise.Certificate of Svc Encl ML20133F3661985-09-30030 September 1985 Requests That Listed Contentions Based on May 1985 Emergency Planning Exercise Be Admitted as There Are No Other Means or Parties to Protect or Represent Author Interests in Matters.Certificate of Svc Encl ML20134H2051985-08-26026 August 1985 Response in Opposition to W Eddleman Contentions Re Spill of Reactor Water.Contention Should Be Rejected for Failure to Comply w/10CFR2.714(b).Certificate of Svc Encl ML20134H2201985-08-23023 August 1985 Response to W Eddleman Proposed Contentions EM-1,EM-2 & EM-3 Re Notification of State & Local Emergency Mgt Agencies. Contentions Should Not Be Admitted Due to Lack of Requisite Basis & Specificity.Certificate of Svc Encl ML20133A0341985-07-31031 July 1985 Petition of Lh Thornburg for Leave to Intervene ML20128H4071985-05-22022 May 1985 Response Opposing W Eddleman 850429 Proffered Contentions 227-CC & 227-DD Re Allegations That Public Info Brochure Must Provide Directions to Evacuation Shelters & Title on Evacuation Routes Chart Misleading.Certificate of Svc Encl ML20117H6751985-05-0909 May 1985 Response Opposing Eddleman Proposed Contentions 227-CC & 227-DD Re Brochure Evacuation Route Chart.Contentions Constitute Editing of Brochure & Therefore Not Litigable. Certificate of Svc Encl ML20116L7211985-04-29029 April 1985 Petition Requesting Admittance of Contentions 227-CC & DD Re Brochure Additions Served on 850416 Concerning Emergency Plan Evacuation & Shelter for Settlement or Litigation. Certificate of Svc Encl ML20102A7691985-02-0606 February 1985 Response Opposing Intervenor 850118 Request for New Contention WB-3 Re Drug Use During Const.Contention Lacks Basis & Specificity & Unsubtantiated Broad Issues Delay Proceeding.Certificate of Svc Encl ML20102A4201985-02-0404 February 1985 Submits Diesel Generator Info & Contentions 178-AA & 179-AA for Litigation,In Response to Past ASLB Order ML20113D9501985-01-18018 January 1985 Request for Admission of New Contention WB-3 Re Drug & Alcohol Abuse at Const Site.News Article Supporting Contention & Certificate of Svc Encl ML20108A2281984-11-13013 November 1984 Response to Late Filed Contentions of W Eddleman & Conservation Council of North Carolina Based on Cv Vo Affidavit.Contentions WB-1-2 & 41C-414H Should Be Rejected. Certificate of Svc Encl ML20096B8661984-08-31031 August 1984 Responses to Discovery on Emergency Planning Contentions (First Set).Certificate of Svc Encl.Related Correspondence ML20096B5131984-08-28028 August 1984 Response to Eddleman 840810 Contentions on Emergency Plan Brochure.Certificate of Svc Encl ML20094N1511984-08-10010 August 1984 Eddleman Contentions on Emergency Plan Brochure, Safety Info for Shearon Harris Nuclear Power Plant. Certificate of Svc Encl ML20093G1341984-07-20020 July 1984 Response in Support of Preamble to Revised Contention 9 Re Environ Qualification of Electrical Equipment.Certificate of Svc Encl ML20092N7151984-06-29029 June 1984 Response to Eddleman Proposed Contentions 65-A & 65-B Re Questionable Structural Integrity Due to Voids from out-of-spec Sump & Improper Vibration Technique. Certificate of Svc Encl ML20092D9521984-06-19019 June 1984 Response Opposing W Eddleman 840605 Motion to Reinstate Contention 58(2d) Re Financial Qualifications.Certificate of Svc Encl ML20197H3921984-06-14014 June 1984 New Eddleman Contention 65-A Re Questionable Structural Integrity Due to Voids from out-of-spec Slump,Improper Vibration Technique & Inadequate Strength of Harris Containment Concrete ML20091M5611984-06-0505 June 1984 Withdrawal of Eddleman Contentions 85/86 & Second Motion to Reinstate Contention 58(2d) Re Financial Qualifications ML20084E1331984-04-28028 April 1984 Answer Opposing Eddleman Proposed Contentions on Emergency Response Plans.Certificate of Svc Encl ML20084D0341984-04-27027 April 1984 Response Opposing R Wilson 840413 Contentions Re State of Nc Emergency Response Plan.All Contentions Should Be Rejected. Certificate of Svc Encl ML20083P7471984-04-16016 April 1984 Motion to Require Svc of All Amends & Changes to Emergency Plan on Intervenor & Motion to Amend Emergency Planning Contentions.Certificate of Svc Encl.Related Correspondence ML20083L2951984-04-13013 April 1984 Contentions on State of Nc Emergency Response Plan. Certificate of Svc Encl ML20083M0871984-04-12012 April 1984 Contentions on Emergency Plan (Second Set).Plan Fails to Indicate Number of Volunteer Personnel Necessary or Assuredly Available to Perform Assigned Responsibilities. Certificate of Svc Encl ML20088A0771984-04-0505 April 1984 Suppl to Feb 1984 Petition for Leave to Intervene in Intervenor Charge Re State of Nc Emergency Response Plan. Certificate of Svc Encl ML20087P5211984-04-0303 April 1984 Partial Response & Contentions 157 & 151 Re Offsite Emergency Plan ML20087P8701984-04-0303 April 1984 Contentions Arising from Review of Emergency Response Plan, Per ASLB 840308 Order.Certificate of Svc Encl ML20086R9141984-02-28028 February 1984 Response Opposing W Eddleman Motion to Admit Contention 58(2d) on Financial Qualifications of co-applicants.ASLB Has No Basis or Authority to Reconsider Original Ruling on Contention & Motion Must Be Denied.Certificate of Svc Encl ML20086M8231984-02-15015 February 1984 Certification to Applicant 840118 Motion for Summary Disposition of Eddleman Contention 65.Motion Identifies One Instance of Honeycombing or Voids in Containment Base Mat, Exterior Walls & Dome.Certificate of Svc Encl ML20086N5051984-02-15015 February 1984 Motion to Withdraw Contention III Re Mgt Capability. Certificate of Svc Encl ML20080L0401984-02-13013 February 1984 Motion to Reconsider & Admit Contention 58 Re Financial Qualifications of co-applicants.Certificate of Svc Encl ML20080D2701984-02-0606 February 1984 Answer to W Eddleman Motion for Further Deferral of Parts of Contention 107 & Eddleman New Contentions & Amended Deferred Contentions in Response to NRC Ser.Aslb Should Deny Motion & Reject New SER Contentions.Certificate of Svc Encl ML20080G2391984-02-0606 February 1984 Request for Clarification & Objections to ASLB 840127 Order Re Eddleman Contentions 37A,37B & 8F2.Certificate of Svc Encl ML20079L4371984-01-23023 January 1984 Response Opposing Eddleman Contentions 169-172 Re Safety Parameter Display Sys.Contentions Wholly W/O Basis, Operate on Faulty Understanding of Sys & Should Not Be Admitted.Certificate of Svc Encl ML20079H4571984-01-17017 January 1984 New Contentions & Amended Deferred Contentions,In Response to NRC SER ML20083H5711984-01-0303 January 1984 Filing of New Contentions 169,170,171 & 172 Re Inadequate Safety Parameter Display Sys Design ML20081K0091983-11-0404 November 1983 Response to Applicant & NRC 830929 Responses to Joint Intervenors 830906 Contentions Re Security Plan.Encl Withheld (Ref 10CFR73.21).Certificate of Svc Encl ML20081E0091983-10-28028 October 1983 Response to Util Motion for Summary Disposition of Contention Ii.Veracity of All General Facts Disputed.List of Matters in Dispute on Contention II & Certificate of Svc Encl 1999-05-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKETED UMOC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 33 gja-2 v.0.55 In the Matter of )
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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
APPLICANTS' RESPONSE TO INTERVENOR EDDLEMAN PROPOSED CONTENTION 161 (DS-416 CIRCUIT BREAKERS)
By a pleading dated May 7, 1983, as supplemented on May 34, 1983, Intervenor Wells Eddleman has supplemented his petition to intervene by proposing a new Contention 161 which alleges as follows: ,
Applicants have not demonstrated that the Harris nuclear reactors can be safely shut down when shut-down is required, because of defects and possible malfunction of Westinghouse DS-416 circuit breakers used in the safety related shutdown systems at Harris.
For the reasons set forth below, Applicants Carolina Powar & Light Company and North Carolina Eastern Municipal Power Agency submit that Contention 161 must be rejected for failure to state suf-ficient basis for the allegations made.-1/ Alternatively, the Board should defer its ruling on Contention 161, to allow Mr. Eddleman a period of time (thirty days) within which to review the proposed design change to the DS-416 reactor trip switchgear undervoltage attachments, and thereafter to amend, modify or withdraw his proposed Contention 161.
1/ Applicants are not addressing Mr. Eddleman's arguments for good cause for a late filed contention and do not here challenge the timeliness of the proposed contention.
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l BACKGROUND i
L .On March 31, 1983, Westinghouse Electric Corporation
(" Westinghouse") informed the NRC of the potential for' inter-
-mittent malfunction of reactor trip switchgear that employs the DS-416 undervoltage (UV) trip device. Pending further.inves-tigations, operating plants utilizing the identified undervoltage trip device were advised that control room operators.should actuate the manual reactor trip switch at the Main' Control Board when a demand for an automatic undervoltage trip is observed.
See letter from E. P. Rahe, Manager, Westinghouse Nuclear Safety Department, to R. C. DeYoung, Director, Division of.NRC Inspection and Enforcement, dated March 31, 1983 (Attachment A).
On April 12, 1983, Westinghouse informed the-Harris Project Staff at Carolina Power & Light Company -("CP&L") of the identified problem. See letter from R. L'. Whitney, Westinghouse, to L. I. Loflin, CP&L, dated April 12, 1983 (Attachment B). On April 20, 1983, Westinghouse reported the problem with the undervoltage attachments to the_DS-416 reactor trip switchgear to the NRC, pursuant to 10 C.F.R. Part 21 (for operating plants) and pursuant to 10 C.F.R.
S 50.55 (e) (for plants under construction). This report to the NRC was confirmed in correspondence with CP&L on April 21, 1983. See letter from R. L. Whitney to L. I. Loflin dated April 21, 1983.
(Attachment C). In Westinghouse's April 21, 1983 letter, a design discrepancy was described in the undervoltage attachment to the DS-416 reactor trip switchgear. The groove in the shaft receiving the retaining ring was not increased in width to be consistent
with an earlier retaining ring design change.. The new retaining ring is wider than the original design and does not properly seat in the existing grooves. Westinghouse committed to replace the undervoltage attachments on DS-416 reactor trip switchgear supplied by Westinghouse. The new attachments have modified (widened) grooves to accommodate the new retaining rings. Further-more, Westinghouse is developing and will implement a procedure for installation of the new-attachments on DS-416 reactor trip switchgear in the Harris plant, which will ensure proper alignment.
and interface of the attachment with the breaker trip shaft.
On May 26, 1983, Applicants submitted to the NRC an interim report on the identified problem with the undervoltage attachments to the DS-416 reactor trip switchgear pursuant to 10 C.F.R. S 50.55 (e) and 10 C.F.R. Part 21 (Attachment D). This report commits to implement the design change to correct the identified design deficiency. Applicants are also considering the implementation of another design change, currently undergoing industry review, which would provide redundant actuation of an undervoltage trip signal by activation of both the undervoltage attachment and the shunt coil attachment on the DS-416 reactor trip switchgear.
RESPONSE TO CONTENTION 161 Mr. Eddleman offers as basis for Contention 161 a report in INSIDE NRC of Westinghouse's April 20, 1983 report to the NRC.
But Contention 161 is far too sweeping an allegation to be supported by the identification of a design problem with the undervoltage attachment to the reactor trip switchgear. There is
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-4 no basis--for.the assertion that " Applicants have not demonstrated,that the Harris nuclear reactors can'be safely-shut down when shutdown is required, because of defects-and lpossible malfunction of West'inghouse DS-416 circuit breakers used.in the safety-related shutdown. systems at Harris." (emphasis supplied). The identified problem was only with an. automatic trip of the circuit breaker when an undervoltage signal was received. The immediate corrective action recommended by Hestinghouse for operating plants was to instruct reactor operators i
to initiate a manual shutdown (which would involve a trip of the DS-416 circuit breaker) . There has been no identified problem with the shutdown capability of nuclear reactors'using the DS-416 reactor trip switchgear-(i.e. with the circuit breaker actually tripping) , and the INSIDE NRC article cited by Mr. Eddleman as basis certainly does not support such an allegation. This,-
o'f course, is an extremely important distinction. Thus, while Mr. Eddleman has admittedly pointed to an identified design problem, his contention goes much too far and must be rejected for lack of any basis.
Applicants appreciate'that Mr. Eddleman did not have the correspondence attached to this pleading and' adequate technical information with which to assess the import of the deficiency i' identified in the trade press article. Applicants are willing to stipulate'that they will not raise timeliness as an objection to a revised contention filed by Mr. Eddleman within thirty days, if he so chooses, based on the information contained in this Response.
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5-Under the circumstances, Applicants'would not object to_the ,
Board's deferr'ing a huling on Contention 161, until such time as Mr. E'ddleman has had an opportunity to review Applicants' Response hereto,i similar to the procedure. adopted by the' Board for control' room design contentions. .Under such a procedure, Mr. Eddleman would have thirty days within which to amend, modify or withdraw Contention 161. Applicants and the NRC Staff would have fifteen and twenty days, respectively, to l reply. .
Counsel to Applicants discussed this Response to' proposed Contention 161 with Mr. Eddleman by telephone on-May 31, 1983. Mr. Eddleman authorized counsel to represent-to the. Board;that'if.the Board does not decide that Contention 161'is admissible as' written, he has no objection to adoption of the' procedure outlined by Applicants, which would allow him.
thirty days within which to review Applicants' technical response and to amend, modify or withdraw Contention 161, as he chooses, l
after such review.
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H. O'Neill, Jr.
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John AW PITTMAN, POTTS & TROWB.itIDGE 1 M Street, N.W.
Washington, D.C. 20036 (202) 822-1090 Richard'E.-Jones Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, North, Carolina 27602 Counsel for Applicants l Dated: May 31, 1983 , ,
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May 31, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Intervenor Eddleman Proposed Contention 161 (DS-416 Circuit Breakers)," dated May 31, 1983 are being served to all those on the attached Service List by deposit in the U.S. Mail, first class, postage prepaid, this 31st day of May, 1983.
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ohn H. O'Neill, Jr. [
Dated: May 31, 1983 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL "
AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY ) ,
) .
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
SERVICE LIST J ees L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety and Licensing Board Cm_=_arvation Counc:tl of North Carolina '
U.S. Nuclear Regulatory Cewmi=sion 307 Granville Road Washington, D.C. 20555 % l Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atanic Safety and Lie-ig Board Edelstein and Payne U.S. Nuclear Regulatory renmiasion P.O. Box 12643 l Wamhi5 ton, D.C. 20555 Raleigh, North Carolina 27605 l
Dr. Janes H. Carpaear Dr. Richard D. Wilson Atanic Safety and Limnsing Board 729 nw*ar Street U.S. Nuclear Regulatory Cemni_ssion Apex, North Carolina 27502 I Washington, D.C. 20555 Mr. Wells Eddlenan Charles A. Barth, Esquire 718-A Iredell Street Myron Kannan, Esquire Durhan, North Carolina 27705 Office of Executive Iegal Director U.S. Nuclear Regn1
- mry Cewmiasion Richard E. Jones, Esquire Wanhim3 ton, D.C. 20555 Vice President & Senior Counsel Carolina Power & Light Conpany Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Dr. Phyllis Ictchin 108 Bridle Run Mr. Daniel F. Pead, President Chapel Hill, North Carolina 27514 Chapel Hill Anti-Nuclear Group Effort P.O. Box 524 Chapel Hill, North Carolina 27514
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Deborah Greenblatt, Escuire 1634 Crest Ecad Raleigh, Nc: h Carolina 27606 Bradley W. Jcces, Esg'4re U.S. Nelaar Regulatory c=4 =sion ,
Region II 101 Marrietta Street Atlanta, Gecm:r!.a 30303 R*ha- G.. Miller, Esquire .
Atcznic Safety and Licensing Board Panel .
e U.S. Nuclear Regulatory C 4==icn -
Wa=hireten, D.C. 20555 Karen E. Long, Esq.
Staff Attorney Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 e
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3 Attachment A 1A .
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- m "i i 5222 Ecc:n: 2rsoration Divisions NS-E?R-2744 March 31, 1983 Mr.'R. C. DeYoung, Directer Division of Inspection and Enforcement U.S. Nuclear Regulatory Ccmmission Phillips Building 7920 Norfolk Avenue Bethesda, MD 20014
Dear Mr. DeYoung:
This is to confirm the telephone conversation of March 31, 1983 between R. A. Wiesemann and R. B. Miller of my staff and Mr Gecrge Lanik of the NRC. In that conversation, I reported that Westinghouse had informed its cperating utility custcmers of the potential for intermittent malfunction of reacter trip switchgear that employs the D5-416 undervoltage (UV) trip device. To minimize the potential on any reac:cr trip switchgear utilizing this device, Westinghouse has reccmmended inspections as discussion below.
Westinghouse recently has been advised by one utility that one of the two main reactor trip breakers at each plant did not trip during 4 preplanned testing. At one plant, three malfunctions occurred out of a total of 116 cycles. At the other plant, only one malfunction occurred in over 400 cycles. The reTiability of the D5-416 UV device is supported by functional factory tests, vendor qualification programs, and periodic surveillance testing at operating plants in which no malfunctions have been reported. Therefore, these malfunctions are considered to be random in nature.
The owner of the two plants involved, in close cooperation with Vestinghouse, has removed the UV trip device from one of the reacter trip breakers that malfunctioned and returned it to Westinghouse for a detailed examination to determine, if possible, the reason for such malfunctions.
Based upon a review at the piant site and at Westinghouse, the following have been identified as the potential factors for the reported occurrences.
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- a. Maruf acturing variations permitted interference between the moving cor'e and the reiler bracket on one of the UV devices unich a:: pears to be related to the intermittent malfunctions. A further facter may have been lack cf side-to-side clearance of the roITer bracket.
- b. Lack cf minimum ga:: between the UV trip reset lever and the breaker trip bar pin a:: pears :: be related tc :ne malfuncticn :f tne secen UV device.
To determine if other 05-416 UV trip devices installed in the field are also susceptible to similar malfunctions, the dimensions identified in Figure 1 must be verified. Westinghouse is requesting that the utilities listed in Table 1 make these dimensional measurements and provide us with the results for our further evaluation of this potential unreviewed safety question.
Until the dimensions are verified, Westinghouse has further reccamencec that the control rocm operators actuate the manuai reactor trip switen at the Main Control 5 card when a demand for an autcmatic reacter trip is observed. If the installed devices meet all the criticai dimensions identified in Figure 1, the recommendation for manual reacter trip may be removed. However, if either the UV trip device or the trip bar is found to be out of tolerance with respect to the dimensions identified in Figure 1, Westinghouse recer: rends that replacement devices be installed.
Westinghouse ocerating utility custcmers are being informed that Westinghouse is reporting this to the NRC as a potential unreviewed safety question under 10CFR50.59 for operating plants. Fcr piants under construction Westinghouse is requesting more information to determine if a significant deficiency exists.
If you have any additional questions, please contact me or Clarence Draughon of my staff at (412) 374-6761.
Sincerely,
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E. P. Rahe, Manager Nuciear 5afety. Department
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..l CQL-7343 I Attachment B Westinghause Water Reactor war C:Sa=s N'so Electric Corporation Divisions m 33 prs:urannsnama sm Mr. L. I. Loflin, Manager April 12,1983 Harris Project Engineering Carolina Power & Light Company P. O. Box 101 New Hill, NC 27562
Dear Mr. Loflin:
CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT DS-416 Reactor Trio Breakers Westinghouse was recently informed by a utility that one Model DS-416 main reactor trip breaker at each of two plants did not trip during preplanned testing of the undervoltage (UV) trip function.
Based upon a review at the plant site and at Westinghouse, the following items have been identified as the factors potentially involvecf in the reported occurrences:
- a. Manufacturing variations permitted interference between the moving core and the roller bracket on one of the UV devices.
A further factor may have been lack of side-to-side clearance of the roller bracket.
- b. Lack of minimum gap between the UV trip reset lever and the
, breaker trip bar pin appears to be related to the malfunction l of the second UV device.
To determine if any DS-416 UV trip devices installed at Harris 1 and 2 are susceptible to similar malfunctions, the dimensions identified in the attached Figure 1 must be verified. Westinghouse is requesting that you l
make those ' dimensional measurements for each DS-416 reactor trip breaker and provide us with the results for our further evaluation.
In addition, an estimate of the number of duty cycles experienced by each DS-416 reactor trip breaker and a report of failures experienced, if any, are also requested..
On March 30, 1983, the Westinghouse Water Reactor Divisions Safety Review Comittee reviewed this specific D5-416 issue and detennined that this item
/- represents a potential unreviewed safety question under 10CFR50.59 for RE0'D APR191983
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2- CQL-7343 operating plants. Westinghouse is currently involved in dialogue with the Nuclear Regulatory Commission on the subject of breaker malfunction in the reactor protection system. Westinghouse, therefore, notified the NRC of this issue both orally and in writing on March 31, 1983. A copy of the Westinghouse letter to the NRC, NS-EPR-2744, is attached.
Your response is requested by April 29, 1983.
If you have any questions, please do not hesitate to contact the undersi'gned.
Very truly yours, WESTINGHOUSE ELECTRIC CORPORATION
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. Carolina Power & Light Project RLW:bmf Attachment D. J. Scanlon, Ebasco, IL II J. L. Willis, CP&L Site, IL, lA N. J. Chiangi, CP&L Site, IL 1A J. J. Sheppard, CP&L, IL, lA L. H. Martin, CP&L, IL, l A R. M. Parsons, CP&L Site, IL, lA G. L. Forehand, CP&L Site, IL, l A E. M. Harris, CP&L Site, IL 1A J. F. Halifax, W Raleigh, IL E. Four, W Sales (Hillside), IL C. L. McKEnzie, CP&L, il lA 4
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.- CQL-7360 h Attachment C ,
Water Reactor wc:ev sme omsien estinghouse Electric Corporation Divisions gg3 esu;- cerse.a,a w Mr. L. I. Loflin, Manager April 21,1983 Harris Project Engineering Carolina Power & Light Company -
Ref: CQL-7343 P. O. Box 101 New Hil1, NC 27562
Dear Mr. Loflin:
CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT 05-416 Reactor Trio Switchgear This is to notify you that on April 20, 1983, Westinghouse advised the Nuclear Regulatory Comission of the potential for misoperation of DS-416 reactor trip switchgear undervoltage attachments. This was reported to the NRC under 10CFR21 for operating plants, and under 10CFR50.55(e) for plants under construction.
Westinghouse previously advised you of the potential for misoperation of these attachments based on reported malfunctions at one plant during testing.
With the referenced letter Westinghouse requested information from you rela-tive to dimensions of several clearances in the attachment to aid in our evaluation. The Westinghouse evaluation has concluded that deviations from the recommended clearances could increase the potential for misoperation of the attachment, thereby creating a condition wherein the reactor trip switchgear might not open on automatic demand from the reactor protection system.
After the earlier notification (CQL-7343), Westinghouse advised the opera-ting plants on April 15, 1983, of an additional misoperation of another 05-416 undervoltage attachment. Investigation of this event revealed a missing retaining ring on one of the two undervoltage attachment pivot shafts (shown in Attachment 1). This allowed the pivot shaft to move laterally such that one end came out of its guide hole in the frame of the undervoltage attachment, and did not permit the. attachment to operate on demand. A missing retaining ring was also identified at another plant. No misoperation of that attachment had been reported.
The Westinghouse evaluation of the retaining ring issue revealed a discrepancy in design. THe groove in the shaft receiving the retaining ring was not increased in width to be consistent with an earlier (1972) retaining ring -
design change. The new retaining ring is wider than the original design,and
L. I. Loflin CQL-7360 does not seat properly in the existing grooves. This discrepancy increases the potential for misoperation of the DS-416 undervoltage attachment, thereby creating a condition wherein the reactor trip switchgear might not' open on automatic demand from the reactor protection system.
Corrective Actions
- 1. Westinghouse is committing to its utilities to replace the undervoltage attachments on DS-416 reactor trip switchgear supplied by Westinghouse for its. Nuclear Steam Supply Systems.
- 2. The new attachments have modified (widened) grooves to accommodate the new retaining rings.
- 3. Manufacturing drawings have been revised and quality control procedures modified to 1ssure that critical design dimensions are maintained during manufacture.
- 4. Furthermore, Westinghouse is developing and will implement a procedure for installation of the new attachments on DS-416 reactor trip switch-gear in the Harris plant. This field installation procedure will provide for proper alignment and interface of the attachment with the breaker trip shaft.
Until replacement undervoltage attachments can be fabricated, shipped, and properly installed at operating plants, Westinghouse has recommended the following be verformed:
- a. Assure that control room operators are alerted to the potential for misoperation of the reactor trip switchgear due to possible malfunction of the undervoltage attachments. .
l
- b. Re-emphasize to the control room operators the indications available i
to detect failure of the rods to insert into the core following a deaand signal from the automatic protection' system.
- c. Re-emphasize to the control room operators the manual reactor trip 1
options available in the existing emergency operating procedures.
These procedures contain diverse methods of tripping the reactor which do not rely on the undervoltage trip attachment.
- d. Visually verify after operation of the reactor trip switchgear that retaining rings are located on the grooved ends of the two under-voltage pivot shafts identified in Attachment 1. This will provide increased confidence that the shaft will not disengage, and that the attachment will be operable for the next trip demand. After installa-l tion of the replacement DS-416 undervoltage attachments, the require-ment to visually verify the presence of retaining rings after opera-tion of the reactor trip switchgear can be eliminated.
L. I. Lof1-in
- 3- CQL-7360 If you require additional information on this, please contact me.
Very truly yours.
WESTINGHOUSE ELECTRIC CORPORATION R. L. Whitn y, Mahager Carolina Powe.r.& Light Project RLW:bmf cc: L. I. Loflin, CP&L Site, 2L R. K. Matzelle, Ebasco, il D. J. Scanlon, Ebasco, IL J. L. Willis, CP&L Site, IL N. J. Chiangi, CP&L Site, il J. J. Sheppard, CP&L, IL L. H. Martin, CP&L, IL R. M. Parsons, CP&L Site, IL J. F. Halifax, W Raleigh, IL E. Four, W Sales (Hillside), IL C. L. McKenzie, CP&L lL l
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P. O. Box 101,-New Hill, N. C. 27562 May 26, 1983 Mr. James P. O'Reilly NRC-73 United States Nuclear. Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 3100)
Atlanta, Georgia 30303 CAROLINA PO~a'ER & IIGHT COMPAhT SHEARON HARRIS SUCLEAR POWER PLANT 1986-90.-_900,000 KW - UNITS 1 & 2 MAIN REACIOR TRIP BREAKERS, SHOP ORDER 386, ITEM 130
Dear Mr. O'Reilly:
Attached is an in: erin report on the subject item which was deemed reportable per the provisions of 10CFR50.55(e) and 10CFR, Part 21, on April 27, 1983. CP&L is pursuing this matter, and it is currently projected that corrective action and submission of the final report will be accocplished by June 30, 1984.
Thank you for your consideration in this matter.
Yours very truly, Y
R. M. Parsons-Project General Manager Shearon Harris Nuclear Power Plant J
RMP/sh Attachment cc: Mr. G. Ma.well (NRC-SHNPP)
Mr. R. Prevatte (NRC-SHNPP)
Mr. V. Stella (NRC) e e
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CAROLINA POWER & LIGHT COMPANY-SHEARON EARRIS NUCLEAR POWER PLANT i
UNITS 1 AND 2 i-i INTERIM REPORT SHNPP MAIN REACTOR TRIP BREAKERS 4 ITEM 130
- MAY 24, 1983
! REPORTABLE UNDER 10CFR50.55(e)
REPORTABLE UNDER 10CFR21
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SL'BJECT : SHNPP Units 1 and 2 Main Reactor Trip Breakers, Westinghouse Model DS-416 purchased under NSSS contract with Westinghouse NY-435002, Shop order 386.
ITEM: Misoperation of the undervoltage attachments.
SL'PPLIED BY: Westinghouse Electric Corporation Switchgear Division.
NATURE OF DEFICIENCY: A design discrepancy exists concerning a retaining ring on the undervoltage attachment pivot shaf ts.
Specifically, a design change increased the width of a retaining ring, while the groove in which the retaining ring seats, was not changed. This allows improper seating of the retaining ring. The result is that the retaining ring may detach itself from the pivot shaft with the potential for misoperation of the undsrvoltage attachment.
DATE PROBLEM OCCURRED: on April 12, 1983, Westinghouse informed CP&L (CQL-7343) of a potential problem concerning minimum gap clearances on the same item. On April 21, 1983, Westinghouse informed CP&L (CQL-7360) of a potential problem concerning a retaining ring design discrepancy on the undervoltage attachment.
DATE PROBLEM REPORTED: On April 18, 1983,- CP&L (Mr. N. J. Chiangi) notified the NRC (Mr. C. Hehl) that this item was potentially reportable. On April 27, 1983, CP&L (Mr. N. J.
Chiangi) notified the NRC (Mr. A. Hardin) that this item was reportable under 10CFR50.55(e) and 10CFR21. ]
SCOPE OF PROBLEM: This deficiency involves two Unit 1 and two Unit 2 Reactor Trip Breakers and two Unit 1 and two Unit 2 Reactor Trip Bypass Breakers.
SAFETY DIPLICATIONS : The potential for misoperation of the undervoltage attachment could create a condition wherein the reactor trip breakers might not open on automatic demand from the reactor protection system. This could prevent a safe shutdown of the reactor unless prompt operator action is taken to " manually" trip the reactor.
REASONS DEFICIENCY REPORTABLE: This item is reportable because the deficiency reported may affect the ability of safety rel:ted equipment to perform its intended function.
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CORRECTIVE ACTION: 1. Westinghouse has. committed to replacing the undervoltage attachments which: includes a replacement pivot shaf t with wider grooves. to accommodate the new retaining ring. Westing-house is developing new procedures for the installation and proper alignment and interface of this attachment.with the breaker trip .
shaft.
PREVENTATIVE-ACTION: 1. ' Westinghouse has revised manufacturing drawings and quality control procedures to assure that critical design dimensions are maintained during manufacture.
- 2. To prevent trip breaker failure as a result of any undervoltage attachment malfunction, CP&L is reviewing industry information as a
. precursor to initiating a design ~ change for the automatic du-l trip operation by activating-both the undervoltage attachment and the shunt coil attachment on receipt of an automatic undervoltage signal from the reactor protection system.
FINAL REPORT: CP&L expects to complete the corrective action plan and submit a final report by June 30, 1984. .
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