ML041620560
| ML041620560 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 06/10/2004 |
| From: | Lochbaum D Union of Concerned Scientists |
| To: | Blough A NRC Region 1 |
| Shared Package | |
| ML041620012 | List: |
| References | |
| Download: ML041620560 (3) | |
Text
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X-Mailer: Novell GroupWise Internet Agent 6.0.3 Date: Thu, 10 Jun 2004 09:48:24 -0400 From: "Dave Lochbaum" <dlochbaum@ucsusa.org>
To: <ARB@nrc.gov>
Cc: <DJH.kp1_po.KP_DO@nrc.gov>
Subject:
Re: UCS recommendations for Salem / Hope Creek Mime-Version: 1.0 Content-Type: text/plain; charset=US-ASCII Content-Transfer-Encoding: quoted-printable Content-Disposition: inline Hello Randy:
I have no objections to the e-mail being placed in ADAMs. Thanks for =
checking.=20 I have every expectation and confidence that Region I will consider the =
issues in our letter in determining what to do.
With respect to conditions worsening, there's little doubt about it. =
According to the Independent Assessment Team, the Corrective Action =
Closure Board found about an 80% passing rate on corrective actions closed =
in March 2004, meaning that 20% of the corrective actions were closed =
improperly.=20 Picture working on an assembly line where 100 items pass every working =
period. If 20 percent of those items are defective at the end of the line, =
then the longer the line operates, the more defective items are =
produced.=20 The corrective action program at Salem and Hope Creek is broken. The =
longer the reactors operate, the larger the pile of improperly closed =
corrective actions. Or, the worse things get.=20 So, there's no doubt that conditions at Salem and Hope Creek are worsening.=
I grant you that it's not as clear when the worsening conditions warrant =
shut down.
- Thanks, Dave Lochbaum
>>> "A. Randolph Blough" <ARB@nrc.gov> 06/10/04 09:33AM >>>
Dear Dave Lochbaum,
Thank you for providing the UCS views well in advance of next week's =
meeting. We will review the letter carefully. I will need to consult =
with other staff on whether or not your request, based on its content, =
must be treated under 10CFR2.206. However, regardless of that determinatio=
n, I assure you that I, along with other staff members, will consider your =
views in the very near term as we deliberate about our next steps with =
respect to Salem and Hope Creek.
Your email refers to worsening problems; as you may recall, I mentioned to =
you after the meeting in March that I did not share your view that the =
conditions are worsening. This is a question that I will continue to =
revisit frequently with the inspectors involved in these projects.=20 On an administrative matter, I believe I should place your incoming email =
to me into ADAMS, since it documents your wish that the UCS recommendations=
of 6/9/2004 not be labeled as a 2.206 request.
Would you have any objections to NRC placing your incoming email into =
ADAMS, publicly available?
Thank you again for your timely input.=20 Randy Blough
>>> "Dave Lochbaum" <dlochbaum@ucsusa.org> 06/09/04 08:31AM >>>
Hello Randy:
Attached is an electronic copy of a letter that's in the mail to you.=20 The letter contains our evaluation of the publicly available information =
about conditions at Salem and Hope Creek and our recommendations on what =
the NRC should do about the myriad and worsening problems.
Simply put, PSEG does not have a legal right to operate Salem and Hope =
Creek. NRC inspection reports and mid-cycle assessment letters over the =
past 18 months have chronicled programmatic breakdowns in PSEG's corrective=
action program. The recent independent assessments by Synergy, Utility =
Services Alliance, and the Independent Assessment Team reinforce NRC's =
findings.=20 Federal regulations - specifically, 10 CFR 50, Appendix B, Criterion XVI - =
require operating nuclear power plants to be supported by effective =
corrective action programs. When the NRC issued operating licenses to PSEG =
for Salem and Hope Creek, the licenses contained an explicit condition =
that the reactors be operated safely AND in compliance with federal =
regulations - not one or the other.
The NRC should order PSEG to shut down Salem and Hope Creek until the =
defective corrective action program is repaired and made functional.
If the NRC bows, again, to industry pressure and allows Salem and Hope =
Creek to operate outside the law, at least the NRC should do for safety =
what it recently did for security --- establish some desired end point and =
Order PSEG to get there by a specified date. The safety hazard at Salem =
and Hope Creek is far more credible and substantial than the security =
threat. The public must be protected from that safety hazard as it has =
been from the security hazard.
As you well know, PSEG has a long, long history of making promises it =
can't or won't keep. Just go back and review your files for the various =
promises made by PSEG in order to trick NRC into allowing them to restart =
the Salem units in the late 1990s. How many of those promises were kept? =
NRC must not accept any more promises and instead must Order PSEG to shape =
up its act.=20 Please note that while UCS strongly recommends NRC Order PSEG to fix the =
unacceptable performance at Salem and Hope Creek, we do not view these =
recommendations as a request under 10 CFR 2.206 for enforcement action and =
hope NRC will not construe the letter as such.
Thanks,=20 Dave Lochbaum Nuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW Suite 600 Washington, DC 20006-3962 (202) 223-6133 x113 (202) 223-6162 fax