ML060750103
| ML060750103 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/15/2006 |
| From: | Joseph Sebrosky NRC/NMSS/SFPO |
| To: | Epstein E - No Known Affiliation |
| References | |
| Download: ML060750103 (10) | |
Text
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 01/10 Wed, Mar,15, 2006 8:10 AM From: Joseph Sebrosky <JMS3@nrc.gov>
To: <Ericepstein@comcast.net>
Date: Wednesday, March,15, 2006 7:51 AM
Subject:
Re: Proposed Spent Fuel Exemption for the My a
number is 301-415-9555.
Joe
>>> Eric Epstein <ericepsteinecomcast.net> 03/15/06 8:00 AM >>>
now about a fax? What's your fax number?
> Mr. Epstein,
> Thanks for the email that you sent me.
Unfortunately, sore of the formatting
> was changed inadvertently.
For example, the footnotes appear to have been
> misaligned. If possible, can you send me the MS word file or other
- wordproceesing document file or pdf file that you used to create the notes.
> This will allow me to docket a "clean" copy of your notes.
> Please call ne at 301-415-1132 if you have any questions.
> Sincerely,
> (ae Sebrosky2
>t>4ftzSoj ect Manager
> Spent Foel Project Office
> 301-415-1132
>>>> Eric Epstein <ericepeteinecomcast.net> 03/14/06 3:25 PM >>>
> Teleconference with the NRC
> March 14, 2006
> Re: Proposed Spent Fuel Exemption for the
> Susquehanna Nuclear Generating Station
> Conuents of Eric. J. Epstein*
> Thanks for the opportunity to offer input and share my concerns on
> PPL's
> spent fuel cask exemption request.
> On April 16, 2003 at the Nuclear Regulatory Commission's (NRC) annual
> RIC
> workshop in Rockville, Bryce Shriver from PPL gave a presentation on Safety
> Management: An Integrated Approach. Among the key areas he touched upon
- were "work Management," 'Operational Decision Making,- -Design and
- Licensing Basis Control," and "Business Planning and Budgeting-. He
- emphasized
> that PPL' processes together with their "Independent Oversight" and
- "Culturea
- would produce "Safety Performance."
7
> This approach seemed to make sense as PPL prepared for relicensing and power
> uprates:
Pane 1 of 4
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 02/10 Teleconference with the NRC March 14, 2006 Re: Proposed Spent Fuel Exemption for the Susquehanna Nuclear Generating Station Comments of Eric. J. Epstein*
Thanks for the opportunity to offer input and share my concerns on PPL's spent fuel cask exemption request.
On April i6, 2003 at the Nuclear Regulatory Commission's (NRC) annual RIC workshop in Rockville, Bryce Shriver from PPL gave a presentation on Safety Management: An Integrated Approach. Among the key areas he touched upon were 'Work Management," 'Operational Decision Making," "Design and Licensing Basis Control," and "Business Planning and Budgeting". He emphasized that PPL's processes together with their "Independent Oversight" and "Culture" would produce "Safety Performance."
This approach seemed to make sense as PPL prepared for relicensing and power uprates:
- The Company has contracted with GE Energy to prepare for additional uprates, i.e., Susquehanna 2 (1994) and Susquehanna 1 (1995) had 4.5%
bumps. The 200 MWe uprates are scheduled to be implemented in phases during several refueling outages.
- Susquehanna Steam Electric Station, Units i and 2 are currently preparing for a license extension applications estimated to be somewhere from July-September 2006.
What went wrong?
Mr. Epstein is the Chairman of Three Mile Island Alert, Inc., is a safe-energy organization based in Harrisburg, Pennsylvania andffounded in 1977. TM1 4 monitors Peach Bottom, Susquehanna, and Three Mile Island nuclear generating stations.
1
83/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 03/10 It appears PPL has poorly managed human and, technical resources to complete competing projects.
Background:
PPL submitted a request for an exemption that would enable the plant to begin loading Framatome gxg-2 spent fuel into the Nuhoms 6iBT storage system. The Company is not presently authorized to store the fuel.
Statement of concern: This 'precedent" (1) would bypasses normal review and approval processes for cask loading and penalize plants like Peach Bottom that have followed the NRC's procedures and protocol.
In my opinion, granting the exemption would weaken the NRC's regulatory protocol of firm, fair and consistent oversight.
Background:
Normally, the NRC reviews exemption requests for changes the staff has already reviewed as part of an amendment to a cask certificate of compliance (COC). Such exemptions allow the utility to begin cask-loading before NRC completes its rulemaking process to formalize the amendment is complete.
Statement of concern: However, Transnuclear has not yet submitted the amendment request to make the change PPL needs. Any exemption would force the NRC to prematurely approve the cask to relieve a self-imposed economic hardship. There is a reason the Agency prides itself on a rigorous oversight process.
1 Please note that PPL opposed the merger of Come Ed and PECO based on one principal - "precedent.'
PENNSYLVANIA PUBLIC UTILITY COMMISSION, A-oo1lo55oFo14, OPINION AND ORDER, "Thus, PPL states that the Recommended Decision failed to address the distinction between the use of the settlement as "binding precedent" and its admissibility as evidence in future proceedings..."
2
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 04/10
Background:
PPL claims the exemption is necessary because the plant will lose full-core offload capability in December, 2006 when it receives and begins to stage new fuel for Unit 2's 2007 refueling outage. Susquehanna had originally scheduled cask-loading to begin in October, 2006.
However, because of recent fuel channel performance problems at Unit i, PPL expects Unit 2 will have to undergo a mid-cycle maintenance outage to inspect and replace any bowed fuel channels. That would limit space available in the pool, requiring the plant to accelerate its loading plans.
Statement of concern: An exemption would reward poor planning (2) of a utility that owns and operates one plant vs. AmerGen and Exelon that own and operate three plants in the state. (3)
Reactor Limerick 1 Limerick 2 Oyster Creek Peach Bottom 2 Peach Bottom 3 Salem 1 Salem 2 Three Mile Islai Station Limerick Oyster Creek Peach Bottom Core Size 764 764 56o 764 764 183 193 177 Cask Technolanu Lose Full Core Off hoad C-aabilm 2006 2006 LOST 2000 2001 2012 2018 NA Deployment Iate c>>n Summer 2010 TBD July, 2010 None June, 2000 Raytheon Dhu BD NU.HOMS 52B (4)
Trans-Nuclear TN-68 2
Poor resource planning by a Company headed by a systems manager, i.e.,
William F. Hecht, warrants an independent NRC evaluation, e.g., Augmented Inspection Team.
3 PENNSYLVANIA PUBLIC UTILITY COMMISSION, PECO's Response to Eric Epstein's Informal 1-8.
4 Holtec has been chosen by AmerGen to provide dry cask services at Oyster Creek.
3
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 05/10 I am asking the NRC deny the exemption and preserve a fair and level regulatory playing field.
4
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 06/10 Safety Management An Integrated Approach Session W8 Bryce L. Shriver PPL Susquehanna, lic Regulatory Information Conference Washington, DC April 16, 2003 ppi '
I SAFETY MANAGEMENT ppi \\
1
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 0 7/10 roces KEY AREAS
- Work Management
- Corrective Action
- Operational Decision Making
- Design & Licensing Basis Control
- Regulatory Programs
- Business Planning & Budgeting
- Staffing & Staff Development
- Management Incentive Programs Processes KEY QUESTIONS l
- Safety "Built-Into" the Process?
- Critical Steps & Interfaces Highlighted?
- Strong Industry-Based Self-Assessments?
- Robust Use of Corrective Action Process?
- Active Leadership Involvement?
- Active Workforce Support?
- Disciplined Approach to Change?
2
03/15/2006 11:01 7175415487 THE UPS STORE 2204 PAGE 08/10 Culture
[ DEFINITION I
l Workforce\\
Values & Beliefs/
I Leadership Values & Beliefs Ppi.p..
5 I LEADERSH
- Openness - Seeking Facts & Implications?
- Long-Term View of Plant Performance?
- Bias for Action?
- Active Knowledge & Participation?
- Positive, Principle-Based Accountability?
- Inclusive - Bargaining Unit, Staff?
- Respect for Independent Oversight?
PIe Commitment to Personal Improvement?
3
03/15/2006 11:01 I
7175415487
/THE UPS STORE 2204 PAGE 09/10 Cu tur WORKFORCEl
- Active Involvement in Key Processes?
- Understand Human Performance & Risk?
- Active in Improvement Initiatives?
- Seek & Apply Operating Experience?
X Respect for Other Work Groups, NRC, Management?
- Positive, Energetic, Eager to Learn?
4 Contract Employee - Involvement & Standards?
ppl,,
7
\\ nependent Oversigh r Integrated Oversight I
- NRC
- Corporate Executives & Directors
- Off-Site Safety Committee
- Plant Safety Committee
- Quality & Oversight Organization
^ Workforce S
PPI /J 4
03/15/2006 11:01 I
7175415487 THE UPS STORE 2204 PAGE 10/10
\\ l Questionsl Independent Oversight
^ Clear Charter, Processes & Interfaces?
- Rotational Staffing for Career Development?
- Independent?
^ Performance Focus?
- Current Industry & Regulatory Perspective?
- Senior Management Support?
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