ML20147E321
| ML20147E321 | |
| Person / Time | |
|---|---|
| Site: | Crane, 05000000 |
| Issue date: | 01/06/1988 |
| From: | Matakas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 1-84-021, 1-84-21, NUDOCS 8801210079 | |
| Download: ML20147E321 (16) | |
Text
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\\p REPORT OF INTERVIEW
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Report Number:
1-84-021 Robert G. LAGRANGE was interviewed by the Reporting Investigator on February 6, 1985. LAGRANGE has been a Section Leader in the NRC's Equipment Qualifica-tion Branch, Office of Nuclear Reactor Regulation (NRR), since April 1982, and has been the Three Mile Island Nuclear Station, Unit 1 (THI-1) Equipment Qualification Reviewer since 1980.
The purpose of this interview was to discuss letters dated May 20, 1983 and February 10, 1984, from General Public Utilities Nuclear (GPUN), to the NRC's Office of Nuclear Reactor Regulation (NRR).
The subject of both letters was the Environmental Qualification of electric equipment at THI-1. During a related interview on December 6, 1984, LAGRANGE advised that both of the above mentioned GPUN submittals contained false statements.
LAGRANGE advised that in December 1982, the NRC transmitted a THI-1 Safety Evaluation Report (SER) for the Environmental Qualification of safety related electrical ecuipment to GPUN.
He said that augmenting the SER was a Technical Evaluation Report (T:R) which was prepared by the Franklin Restarch Center (FRC) under contract to the NRC. The FRC prepared its' report based on a review of Environmental Qualification documents supplied by the licensee i
(GPUN). LAGRANGE said that the FRC TER identified major qualification defi-ciencies to be resolved by the licensee.
He said that in both the May 20, 1983 and February 10, 1984 GPUN responses, GPUN indicated that TMI-1 elec-l trical equipment within the scope of 10 CFR 50.49 was environmentally qualified. LAGRANGE said that on March 20 and 21, 1964, he and a consultant (Max YOST from EG&G) conducted an audit of GPUN Environmental Qualification l
I files and found for each file audited, GPUN did not have the approprit.te documentation to qualify their equipment.
LAGRANGE explained that portions of "NUREG-0588" and "Division of Operating Reactor (DOR) Guidelines" set forth f
the requirerents the licensees had to fellow in order to environnentally l
qualify safety related electrical ecqipment to satisfy the requirements of 10 i
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2 CFR 50.49. He said the above NUREG and 00R Guidelines were transmitted to the l
licensees on January 14, 1980, as Attachments to IE Bullstin (IEB)79-01B.
LAGRANGE said that Section 8.0, Documentation, of the D0R Guidelines required the licensees to have complete and auditable records describing the qualifica-tion method in sufficient detail to verify that all of the guidelines had been satisfied and that a simple vendor certification of compliance would not be considered adequate. LAGRANGE said that contrary to Section 8.0, when he and the consultant audited GPUN equipment qualification files in March 1984, GPUN did not have complete and auditable records in their files to support the stater.wnts in their May 20, 1983 and February 10, 1984 letters that THI-1 equipment within the scope of 10 CFR 50.49 was cualified.
He said that during.
more recent e dits, he noted that the documents used to support qualificatiun were dated ;ft the February 10, 1984 letter.
LAGRANGE advised that the March 20-21, 1984 Audit findings were transmitted to the licensee in a letter dated April 25. 1984. He said that several of the findings were given to the licensee orally ind with handwritten notes on May 7-8, 1984.
LAGRANGE stated that the licensee responded to the Audit findings in a letter to the F C dayd May 31,1984 LAGRANGE said it was the equipment conponents ' identified in'the
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April 1, 1984 MC letter, which were clearly not environmentally qualified./
that, an his view, make GPON's assertiord f!n their May 20 and F< bruary 10 4
letters talse. He added that the majority of the cononents idet tified in the April ?5, 1984 NRC letter as being qualified, were oreviously identified as 4
unqualified in the December 10, 1982 IER/TER provided to the licensee.
In addition, LAGRANGE said that in October 1983, his Section nad a meeting with GPUN representatives F.G. MAUS, Supervisor, Environmental Qualification, Paul B0UCHEK, Environtental Qualification, and he believes, Roy HARDING, Licensing, to discuss the resolution of their December 1982 TER deficiercies. LAGRANGE said the individual deficiencies were discussed and it was apptrent that they (GPUN) did not have the deficir.ncies resolved and were not ready for the meeting. LAGRANGE said he met with GPUN EQ people again on March 8, i984 and L
once again discussed the resolution of TER deficiencies.
He said the meeting was taped and transcribed.
?e said the TER deficiencies discussed included those TER deficiencies identified as corrected in their May 31, 1984 lettar which was a response to deficiencies identified in the NRC March 20-21, 1964 l
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i audit that was documented in an April 25, 1984 letter to the licensee.
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LAGRANGE sa'id that during the March 20-21, 1984 audit, neither he nor the consultant were thinking in terms of false statements relative to the EQ docbmentationdeficienciesbeingnotedintheGPUNfiles. He said they just thought they were finding deficiencies that had to be resolved, Regarding the May 20, 1983 GPUN submittal, LAGRANGE said that the submittal s
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was in re.;ponse to 10 CFR 50.49 which required all licensees to identify the
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electrical equipment inportant to safety within the scope of Section 50.49(g) that is already qualified, and to subnit schedules for environmental quali-T fication for replacement of the remaining equipment that is important to safety as defined in 10 CFR 50.49(b).
LAGRANGE said that on the first page of k,I the May 20, 1983 submittal, the licensee stated that:
s ' j' "GPUN letter dated August 28, 1981 (LIL238) in response to IEC 79-01B lists all safety-related electrical equipment which is required to be and which is already qualified. The additional information we submitted in our %tters dated May 3, 1982 (5211-82-101) and May 16, 1983 (5211-83-076) (NUREG-0737 items),
support our conclusions that the components listed are qualified in
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accordance with D0R guidelines dated November 1979."
LAGRANGE stated that the above statenent was clearly a false statemut in that some of the components GP'JN listed as qualified, were not qualified.
- However, he said that every utility had to respond to the rule and that none of the utilities' responses were relied on or utilized by the.iRC ir; cny manner.
LAGRANGE saic that his EQ Section had decided sentime in the May to August 1983 time period to meet with the licensees and not rely on the responses. He said this decision was made prior to reviewing the responses and indicated that the May 20, 1983 GPUN response was not reviewed until after the March 1984 NRC audit.
LAGRANGE said that to his knowledge, GPUN was not confronted with any of the suspected false statements contained ir. the May 20, 1983 response.
LAGRANGE advised that GPUN's May 20 response did not have any impact on any NRC decision-making process nor could he state any special circumstances where the licensee wat on clear notice that the dRC had intended to rely on their May 20, 1903 response.
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4 LAGRANGE advised that after the NRC audit in March 1984, it was apparent to him that MAUS was not capable of handling the job. LAGRANGE opined that up until the March 1984 audit, it appeared that MAUS and 800 CHEK were the only GPUN individuals dealing with the Environmental Qualification issue and that there was little or no management involvement. LAGRANGE concluded that it was just L0o big of a job for two people and that MAUS did not know what docu-mentation was needed. LAGRANGE said that it was not until the exit meeting for the March 1984 audit that Dick WILSON, GPUN Vice President of Technical Functions, and other management officials showed up.
LAGRANGE said that other than the NRC exit meeting in March 1984, he was not aware of any circumstances where GPUN management officials had knowledge that environner.tal qualification deficiencies were not being corrected.
LAGRANGE advised that in May 1984, he attended a meeting with GPUN regarding environmental cualifications and Phil CLARK, President, GPUN, attended. He said at this time it was apparent that management was getting involved and it appeared to him that their environ-mental qualifications program was "turning around".
Pegarding GPUN's February 10, 1984 submittal, LAGRANGE previously identified the following alleged false statement:
"It is GPUN's position that THI-1 is currently in compliance with the environmental qualification rule 10 CFR 50.49 as applicable to TMI-1."
LAGRANGE stated that the rule 50.49 specifically states that one must have "auditable files" and GPUN did not have auditable files.
LAGRANGE said this was established through their March 1984 staff audit of GPUN files and several subsequent audits. LAGRANGE stated that when he received GPUN's February 10, 1984 submittal, he knew that he was not going to rely on the submittal because it was "too vague and did not address all the deficiencies in the TER."
He emphasized that by February 10, 1984, he had decided that he would no longer rely on any of GPUN's submittals (made up to that point) concerning their environmental qualification progran.
LAGPANGE advised that it was either he or SHEMANSKI who verbally inforned the GPU representatives at the October 1983 meeting to make the February 10 submittal addressing 1ER deficiencies in compliance with 50.49.
LAGRANGE believes it was related to GPU that the NRC wanted the submittal for a final
5 SER.
LAGRANGE advised that the submittal was not used for a final SER and he
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believed that an audit would have been conducted no matter what the submittal looked like, if for no other reason, than to address the UCS petition.
End of Results of Interview with Bob LAGRANGE dictated on various dates between February 11 and March 26, 1985.
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Reported By:
R. A. Mata(as, Investigator Office of Investigations Field Office, Region I
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Place:
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Date:
April 9, 1985 t
STATEMENT Ronald Joseph TOOLE, hereby make the following voluntary statenent to Mr. Richard A. MATAKAS, who has identified himself to me as an investigator with the U. S. Nuclear Regulatory Commission.
I provided Mr. MATAKAS with this information on April 4, '1985 with no threats having been made or promises having been extended to me.
As background information, I started with GPU in 1967 and in 1980, I became the Operations and Maintenance Director for Three Mile Island Nuclear Station, Unit 1.
I have held tnis position until the present time. My current work address is GPU Nuclear Corporation, P. O. Box 480, Route A41 South, Middletowr.,
Pennsylvania, 17057.
Mr. MATAKAS has shewn me a GPU Nuclear document deted February 10, 1984 (GPUN Control No. 5211-84-2038), which was subnitted to the NRC's Office of Nuclear Reactor Regulation and sigr.ed by me for Mr. Hank HUKILL, Director of iMI-1.
I do recognize the document and the signature is my signature.
Wher Mr. HUKILL is either out of town er offsite for some reason, I am authorized to sigt in his absence.
Since the cocument in question is an outgoing licensing corre-spondence, it requires Mr. HUKILL's signature.
I have reviewed the document on this date and other thsr. what the document says, I do not know for what purpose the response was being made. At this time, I do not specifically recall what consideration I gave before signing the document.
Typically, I would see if it was understandable, and if there was any site commitments.
Based on my background, I would look for its accuracy without going back over l
drawings, other related documents, or whatever.
I would also look at the review chain and in this case, I probably would have noted that Paul LEVINE, Site Engineering, had previously reviewed and acknowledged the contents of the l
document.
I normally review all correspondence that goes to Mr. MUKILL for I
his signaturc.
In this particular case, the document refers to the environ-(
mental qualification program at TMI-1 which is a Headquarters, Parsippany 'T' For n -97 696 f.y31
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gyy } f echnical Functions responsibility and Mr. LEVINE was the Site Engineer who
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was knowledgeable in this area, and who would have reviewed the package. This letter would have been written by Licensing in Parsippar.y New.ersey and sent to us for review.
As the Operations and Maintenance Director of THI-1, my Section's m ponsibility in the area of environmental qualifications would be to replace components identified by Technical Functions as being unqualified with qualified compo-nents and document the replacement. This would be done under the direction of Technical Functions out of Parsippany.
Neither I nor my direct subordinates have any input into the actual cualification of equipment.
Again, that is handled by Technical Functions ad we (my organization) are basically the implementing organization who does the actual changing or modification of components as directed by Technical Functions.
At Mr. MATAKAS's request, I have reviewed both the February 10, 1954 document (discussed above) and a related May 20, 1983 document (GPUN Contrcl No.
5211-83-157) and was not aware at the time I signed the February 10 document, nor was I aware at the time I reviewed the May 20, 1983 document, that either l
document contaired any false statenents. When I signed the February 10, 1984 dccunent, I believed that I knew there were things that remained te be done en some of the electrical ecuipnent compcnents important to safety which came under the purvien cf the environmental qualification progran.
Fcr instance, l
on page 2 of Attachment 2 (Item B, Asco Solenoid Valves), the statement is I
made that "Asco Solenoids will be replaced with qualified Asco Solenoids by June 1984 Therefore, Asco qualification test reports A0R67368 and AQS21676/TR apply."
In my mind, this refers a deficiencies that will be wed> b W
corrected in the future and this ~ r % understood by the NRC. Mr.
MATAKAS has pointed out to me that the Fei, uary 10, 1984 document literally states, "It is GPUN's position that TMI-l is currently in compliance witn the Prior environmental qualification rule 10 CFR 50.49 as applic6ble to TMI-1.'
to my discussion with Mr. MATAKAS on this date, I did not understand what was being referred to as the caterial false statencnt in the February 10, 1984 letter.
Prior to our discussion, I read the correspondence, as I did at the
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- e4 me I signed it, to nean that TMI would be in compliance with the environ-r mental qualification rule by March 31, 1985. With the benefit of my discussion with Mr. MATAXAS on this date, I now understand the concern and I can see by the words in the February 10, 1984 document what the concern it; however, that is not how I interpreted the document when I signed it in February 1984.
I didnotinterpretthestatenenttomeaghatallTERdef n{es g bg cc 'rected.
In retrospect, I can see (Mw how the letter wfs we idv'elone
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everything that needs to be done and that was not the case.
As I have previously stated, it is obvicus by reading the attachments to the February 10, 1984 letter that there was work that remained to be done concerning certain components within the scope of the environmental qualification program at TMI-1.
However, it was my understanding at the time I signed the letter, that we had identified and -:cmitted to complete cualification prior to March 31, 1985.
Prior to signing the February 10, 1984 document, I had net reviewed the December 1982 NRC SER/TER.
I wculd like to reiterate that when I signec th(
document in cuestion, I did not recognize any information in the document as being false information er information that was intended to deceive the NRC in any manner.
I have read over this three-page statemeet anc have discussed its cor. tents with Mr. MATAKAS on t9e date r6flected balew my signature.
I have had the opportunity to make all necessary corrections and additions and this statement is the truth to the best of my Pncwledge anc belief.
SIGNATURE:
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Subscribed and :wir-to before me this
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_ day of April, 1985, at
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Place: TMI-1 Date:
April 9, 1985 f
t STATEMENT I, Henry Durbin HUKILL, Jr., hereby make the following voluntary statement to Richard A. MATAKAS whc has identified himself to me as an Investigator with the U. S. Nuclear Regulatory Comission.
I provided this information to MATAKAS on April 4, 1985 with no threats having been made or promises having-been extended to me.
As background informaticn, I started my employment with GPU in June 1980 and I have been the Director of Three Mile Island, Unit 1, since September 1980.
My current work address is GPU Nuclear Corporation, P. O. Box 480, Route 441 South, Middletown, Pennsylvania, 17057.
Mr. MATAKAS has shown me two (2) GPU Nuclear documents addressed tc the NRC's Office of Nuclear Reactor Regulation that were prepared for my signature.
The first document is dated May 20, 1983 (GPUN Control No. 5211-83-157), and the second document is dated February 10, 1984 (GPUN Contrci No. 5211-84-2038).
I recognize my signature on the May 20, 1983 document and my Operations and Maintenance Director, Ronald TOOLE, apparently signed the February 10, 1984 cocument for me.
Mr. TOOLE is authorized to sign for me wher I ar either cut l
cf town or otherwhe unavailabb.
In this particular case, I e not recall why Mr. TOOLE signed the February 10, 1984 document.
The sub,iect of both documents is the environmental qualificatior of electrical equipment at the Three Mile Island Nuclear Station, Unit 6.
The primary responsibility for the area of environmental qualification at TMI-1 whiginebothdocuments were signed was with th chnical Functions E tir at Parsippar.y, New M
Jersey.
However,Aall tgoing licensing correspondence concerning TMI-1 is s
prepared for my signature as the Director of the Unit.
I do cet specifically y
recal' signine the May 20 docunent, and I do not specifically recail g y reviewing the February 10 document.
However, it is re policy to readnevery docunent that is prepared for my signa;'re from cover te ccver. Docunerts invciving such things as license operator certifications (which I ar deepi) invc hed in), I wculd gc over ir. mach greater detail the,1 I would a dccument fo2 M - H - H(*
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Ww 4e SuchastheMay 20. 1983 document, which would have been prepared under the direction of Technical Functions at GPUN Headquarters in Parsippany, New g
Jersey.
In the former case, I would go over the document in m g m gadetail 4 and would be more aware of the actual contents of the documentsas t:6 how statements were arrived at.
Concerning the May 20, 1983 letter, I would have read the document to see who reviewed it, who concurred with it, and de'.rmine if there was anything in the document that I did not agree with based on the knowledge that I had of the subject ratter.
To the best of my recollection, during the late 1983 and early 1984 time period, Jerry MAUS was more or less in charge of the environmental qualification program for TMI-1; however, I do not know if MAUS bad any input into either the May 20 or February 10 letters.
Prior to today's interview, Mr. Courtney SMYTH, the Site Licensing Manager, provided me with copies of the Mav 20, 1983 document in question and further provided me M various related review doc;ments.
Copies of the related documents are attached tc this Statement and are idantified as follows:
Twc correspondence project accountability check sheets (various detes) and two GPU Nuclear interoffice memoranda t'oth dated May 16, 1983. The i,4tials at the end of the May 20, 190 document inc:icates that it was prepared 'or my signa-ture by Mr. L. W. HARD NG, Licensing, and the attached corresponde ce project te th t D
R. J. CHISHOLM, M er, accountabigegc[4heetQn Electrical Oy:::n, and T. J. BROUGHTON,a Systems Engineering O' uta, all had input into the cantents of the May 20, 1983 document.
Regarding my review of the May 20, 1983 docunent, as for technical corter.t, I woulc have prcbably reviewed the correspondence project accountability check sheet and made sure that somacre from Plant Engineering had reviewed and approved the document prior to my signature.
In this caseprr espgdycgcgtp tg project check sheet indicates tha ir. C. HARTMAh T i s % him,
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reviewed and signed the document fo Tupervisor, Mr. J. J. COLI I do y
g g n g now specifically whc at GPUN Headouarters in oraippeny, New Jersey A j
4 reviewed the May 20, 1983 document.
Lite I have previously stated, t' "PUh Technical Functions, headed by R. F. WILSON, had the primary responso
.y for the environmental qualification prograr at THI-l during the time bv.h the May 20 and February 10 documents were drafted.
To the best of my recollection, Mr. Paul LEV 1NE, Plant Engineering, would have at the tine, beer the site individuai with tne responsibility for fcilowing the er.vironmental qualification program at the site level.
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.3-I persenally do not recall making comments on either submittal.
At the time that I signed the May 20 letter, I was not aware that the components referred te ander the heading Safety Related Electrical Equipment were not qualified in accordance with DDR guidelines dated November 1979 as stated in the document.
As a result of the AJdit in, I believe 1984, I became aware that the NRC w
electrical equipment components were not in compliance claimed that e e*T with the DOR guidelines.
I am also aware that subsequent GPUN internal aucits made the same determination.
Basically, my involvement in the THI-l anvironmental qualification progran has been through personal interaction an: other communications (staff meetings and other meetings) with Mr. Dick WILSON who heads the GPUN Technical Functions Sect 1or.
Up until either the NRC audit or the internal GPUN audits that I previously referred to, I was leao to believe that we were meeting the raqu:rements of NRL regulations recordi.9 the environmental qualification p* aram at TMI-1.
". MATAKA! oas shown me a GPUN interoffice memorandum dated June 25, 1961 the subject of which is Internal Audit 0-TMi-81-02 Technical Functions Home Officc Activities lor Compliance of IE Bulletin 79-01B.
I do not recall being aware o' the audit referred to in the abcVe mentioned intero?fice memurandum.
Like I have previously stated, etnagement involvement in the environmental uualification progear was a Technical f unctien's program.
I was aware that the plant would be invelved in the replacener.t of parts for those items d p r g d b,v thg g nreg ae for replacement after a certain lifetime,gThe enviro #nmental qullificatier. program has been very confusing and difficult to implement.
It is my understanding that it has been very hard to cert 'y certain parts with vendors whc are reluctant to do se or h:ve N but of business. These are some of the problems that have been related to me by the Technical functions Group.
Basically. I would like to reiterate tFat I read basically every correspendence which I sign.
Fo: tnose arens thtt I ac. personally responsibi, I personally get involved ir. the backup information pertaining te the document.
For other types of documents, especially these involving technical issues, I will read the document and it's relatef review sheets to ses if there is anything that I de not agree with anc will base my signature on the approva", list.
I wi'i have Mr. T00;E, my Plant Manager, review and approve every docunent befc e is
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2 comes to me for signature.
For very technical documents, 1 make sure that my i
Plant Engineering Director, Mr. COLITZ (or his representative), has reviewed i
and approved the document.
I also rely very heavily on Licensing for the accuracy of each document that I sign.
If I have a significant question or t
will request either concern on a g cg g e g g ained in a dgcu RON (tR f, et,Jn,ginee, ring gn{De_sion g p Mr. WILSON, ' v egir
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,, a ;;;r c' w t^. _ v. m. to cincuf with the conten'ts of f
the document before I sign it. All three of the abcve mentioned individuals are Senior Technical Functions people.
Concerning the May 20 document, I note on one of the correspondence project accountability check sheets that Mr.
CRONEBERGER approved the final letter on May 17, 1983.
have read over this four-page document on the date indicated below my signature and have had the opoortunity to make the necessary changes and corrections.
This statenent is the truth to the best of my kncwledge and belief.
D 52.GNATURE:
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day of April, 1985, at Subscribed and sworr to before me i is Afl - l
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