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NRR E-mail Capture - (External_Sender) NRC Response to Pilgrim Watch'S Email Dated April 5, 2017, Regarding Pilgrim Relief Request Nos. PNPS-ISI-004 and PNPS-ISI-005
	ML17108A576
Person / Time
Site:	Pilgrim
Issue date:	04/18/2017
From:	Lampert M; Pilgrim Watch
To:	John Lamb; Special Projects and Process Branch
References
	Download: ML17108A576 (9)
	v • d • e

NRR-PMDAPEm Resource From: Mary Lampert <mary.lampert@comcast.net>

Sent: Tuesday, April 18, 2017 10:02 AM To: Lamb, John Cc: Dean, Bill; Evans, Michele; Dorman, Dan; Ross-Lee, MaryJane; Benner, Eric; Brock, Kathryn; Broaddus, Doug; Brown, Eva; Lubinski, John; Coyne, Kevin; Alley, David; Cumblidge, Stephen; Burritt, Arthur; Cline, Leonard; Carfang, Erin; Vazquez, Justin; Pinson, Brandon; Lew, David; Wall, Scott; Scott, Michael; Screnci, Diane; Sheehan, Neil; Tifft, Doug; Weil, Jenny; Dacus, Eugene; Burkhardt, Janet; Jackson, Donald; Watson, Bruce; Parrott, Jack; Carter, Ted; Kulp, Jeffrey; Gerzhoy, Gene (Markey); Dave Lochbaum; Seth Schofield (AGO); Josh Cutler; Rep James Cantwell; Rep Thomas Calter; Rep.

Mathew Muratore; weavenel@gmail.com; 'Becky Chin'; 'Graeme Groombridge'; 'James lampert'; 'marischka dopp'; 'Nancy Nowak'; 'Pat Gagnon'

Subject:

[External_Sender] RE: RE: NRC Response to Pilgrim Watch's Email Dated April 5, 2017, Regarding Pilgrim Relief Request Nos. PNPS-ISI-004 and PNPS-ISI-005

Dear Mr. Lamb:

Thank you for your description of NRC departments.

Regarding NRCs oversight of Pilgrim, I refer you to an older GAO document, GAO/RCED-97-145 NRCs Oversight of Nuclear Power Plants.

It remains relevant today.

Page 2 --- "Determining the safety of plants is difficult because NRC does not precisely define safety."

NRC claims to be a safety regulator, yet literally and figuratively doesn't even know the meaning of the word safety.

And, For some plants, NRC has not taken aggressive enforcement action to force the licensees to fix their long-standing safety problems on a timely basis.

The report goes on the say, for example, that:

NRCs regulations and other guidance do not provide either the licensees or the public with the specific definitions and conditions that define the safety of a plant 1

NRC is also concerned that as nuclear plant owners pursue cost-cutting strategies to meet future competition, safety priorities may be jeopardized

NRC Is Not Effectively Overseeing the Plants That Have Problems o Our review of three facilities with a history of poor performance shows that NRC has not gotten licensees to fix safety problems at these plants in a timely manner.

Identifying and correcting safety deficiencies are among the licensees most important safety responsibilities and a major focus of NRCs inspection program. Yet NRC allows licensees repeated opportunities to correct their safety problems, often waiting for a significant problem or series of events to occur at a plant before taking tough enforcement action

NRC Is Not Getting Licensees to Fix Deficiencies in a Timely Manner o In addition, since NRC does not precisely define safety, perceptions of safety levels and risk are subjective and are not always consistent from inspector to inspector.

Several current and former NRC inspectors told us that they cannot easily distinguish a safe plant from an unsafe one and that the guidance on when to shut down a plant does not cover all situations

Relying on Plant Managers to Fix Problems Is Not Always Effective

NRC Enforcement Actions Are Too Late to Be Effective

Conclusions-There are a number of instances in which NRC has neither taken aggressive enforcement action nor held nuclear plant licensees accountable for correcting their problems on a timely basis. NRCs practice of giving licensees extensive time to fix their problems allows nuclear plants to continue to operate and the problems to grow worse Yesterdays NRC announcement that it was relieving Entergy from requiring Pilgrim to implement three of the Post Fukushima Orders that modified Pilgrims license. They related to severe accident capable vents, flooding 2

and seismic NRCs relaxation of these orders demonstrated to the public once again that NRC cares only about the licensees financial safety and not public safety. We can only hope that our luck does not run out.

Mary Lampert- Pilgrim Watch/Town of Duxbury Nuclear Advisory Committee From: Lamb, John [1]

Sent: Tuesday, April 18, 2017 6:15 AM To: Mary Lampert Cc: Dean, Bill ; Evans, Michele ; Dorman, Dan ; Ross-Lee, MaryJane ; Benner, Eric ; Brock, Kathryn ;

Broaddus, Doug ; Brown, Eva ; Lubinski, John ; Coyne, Kevin ; Alley, David ; Cumblidge, Stephen ; Burritt, Arthur ; Cline, Leonard ; Carfang, Erin ; Vazquez, Justin ; Pinson, Brandon ; Lew, David ; Wall, Scott ; Scott, Michael ; Screnci, Diane ; Sheehan, Neil ; Tifft, Doug ; Weil, Jenny ; Dacus, Eugene ; Burkhardt, Janet ;

Jackson, Donald ; Watson, Bruce ; Parrott, Jack ; Carter, Ted ; Kulp, Jeffrey

Subject:

RE: RE: NRC Response to Pilgrim Watch's Email Dated April 5, 2017, Regarding Pilgrim Relief Request Nos. PNPS-ISI-004 and PNPS-ISI-005

Dear Ms. Lampert:

This is to acknowledge receipt of your email, dated April 12, 2017, to the U.S. Nuclear Regulatory Commission (NRC) regarding Pilgrim Nuclear Power Station (Pilgrim).

The NRC Office of Nuclear Reactor Regulation (NRR) is responsible for accomplishing key components of the NRC's nuclear reactor safety mission. As such, NRR conducts a broad range of regulatory activities in the four primary program areas of rulemaking, licensing, oversight, and incident response for Pilgrim to protect the public health, safety, and the environment. NRR works with the regions and other offices to accomplish its mission and contribute to the agency mission.

The Japan Lessons-Learned Division (JLD) supports NRR's mission by managing the NRC's actions related to the lessons learned from the Japanese nuclear accident at Fukushima Dai-ichi. JLD plans, develops, and implements the actions found necessary to enhance the safety of Pilgrim. JLD develops Commission policy papers, conducts public meetings, and follows international events related to the Fukushima Dai-ichi accident.

Region 1 Division of Reactor Projects (DRP) plans, directs and coordinates the Reactor Oversight Process (ROP), including inspection activities and related project management functions, at Pilgrim. Region 1 DRP recruits, supervises and trains staff, including resident inspectors. They perform Pilgrim assessments, which includes leading resident baseline, problem identification and resolution and supplemental inspections, as well as allegation follow-up and implementation of the Enforcement Policy. Region 1 DRP supports the Agency Action Review Meetings, and conducts public Annual Assessment Meetings at Pilgrim. Region 1 DRP provides initial response to Pilgrim events and emergencies. They develop generic correspondence and provide feedback on ROP implementation. Region 1 DRP coordinates inspection activities with the Division of Reactor Safety, NRR, and the Office of Nuclear Security and Incident Response. Region 1 DRP acts as liaison with the Division of Operating Reactor Licensing counterpart in NRR. Region 1 DRP coordinates Commission visits to Pilgrim and responds to Federal, State and Local government and public inquiries.

The Office of Nuclear Material Safety and Safeguards (NMSS) Division of Decommissioning, Uranium Recovery, and Waste Programs (DUWP) manages the NRC's program for the regulation of decommissioning, low-level waste (LLW) and uranium recovery in close coordination with other Federal agencies, States, and Native American Tribal Governments, licensees and the public. NMSS DUWP oversees decommissioning and cleanup of contaminated sites, safe management and disposal of LLW, and uranium recovery activities.

Manages complex decommissioning activities and conducts safety reviews and inspections related to decommissioning. NMSS DUWP provides project management for power reactors, undergoing decommissioning and terminates licenses when decommissioning is complete. NMSS DUWP reviews reactor 3

financial assurance plans for decommissioning and issues licenses and license amendments related to sites undergoing decommissioning.

Your email has been distributed within the NRC for appropriate consideration.

Sincerely, John G. Lamb, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation From: Mary Lampert [2]

Sent: Wednesday, April 12, 2017 9:53 AM To: Lamb, John <John.Lamb@nrc.gov>

Cc: Dean, Bill <Bill.Dean@nrc.gov>; Evans, Michele <Michele.Evans@nrc.gov>; Dorman, Dan

<Dan.Dorman@nrc.gov>; Ross-Lee, MaryJane <MaryJane.Ross-Lee@nrc.gov>; Benner, Eric

<Eric.Benner@nrc.gov>; Brock, Kathryn <Kathryn.Brock@nrc.gov>; Broaddus, Doug

<Doug.Broaddus@nrc.gov>; Brown, Eva <Eva.Brown@nrc.gov>; Lubinski, John <John.Lubinski@nrc.gov>;

Coyne, Kevin <Kevin.Coyne@nrc.gov>; Alley, David <David.Alley@nrc.gov>; Cumblidge, Stephen

<Stephen.Cumblidge@nrc.gov>; Burritt, Arthur <Arthur.Burritt@nrc.gov>; Cline, Leonard

<Leonard.Cline@nrc.gov>; Carfang, Erin <Erin.Carfang@nrc.gov>; Vazquez, Justin

<Justin.Vazquez@nrc.gov>; Pinson, Brandon <Brandon.Pinson@nrc.gov>; Lew, David

<David.Lew@nrc.gov>; Wall, Scott <Scott.Wall@nrc.gov>; Scott, Michael <Michael.Scott@nrc.gov>; Screnci, Diane <Diane.Screnci@nrc.gov>; Sheehan, Neil <Neil.Sheehan@nrc.gov>; Tifft, Doug <Doug.Tifft@nrc.gov>;

Weil, Jenny <Jenny.Weil@nrc.gov>; Dacus, Eugene <Eugene.Dacus@nrc.gov>; Burkhardt, Janet

<Janet.Burkhardt@nrc.gov>; Jackson, Donald <Donald.Jackson@nrc.gov>; Watson, Bruce

<Bruce.Watson@nrc.gov>; Parrott, Jack <Jack.Parrott@nrc.gov>; Carter, Ted <Ted.Carter@nrc.gov>; Kulp, Jeffrey <Jeffrey.Kulp@nrc.gov>

Subject:

[External_Sender] RE: NRC Response to Pilgrim Watch's Email Dated April 5, 2017, Regarding Pilgrim Relief Request Nos. PNPS-ISI-004 and PNPS-ISI-005 Hello:

Thank you for your prompt reply.

I understand that the ASME protocol was enhanced to provide higher quality data than previously required-that would provide increased safety.

However, despite the fact that Pilgrim is old, Entergy was not required to meet those standards.

Although you end by saying that the health and safety of the public is of paramount importance to the NRC.

To us, if that were true, the ASME protocol that provides higher quality data would be required.

Out of curiosity, does NRC have a definition of safety and if so please provide.

Thank you and happy holiday.

Mary the 2005-2015 inspection (a) did not inspect all of the welds (how many were not?), and (b) the most recent inspection that was done (on how many welds is not clear) used the old ASME procedures.

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From: Lamb, John [3]

Sent: Tuesday, April 11, 2017 10:43 AM To: mary.lampert@comcast.net Cc: Dean, Bill <Bill.Dean@nrc.gov>; Evans, Michele <Michele.Evans@nrc.gov>; Dorman, Dan