ML20055F361

Comments on Plant Performance Improvement Plan & Implementation Program.Requests That Representative of Citizens Organization Become Permanent Member of Util Offsite Safety Review Committee

ML20055F361
Person / Time
Site:	Calvert Cliffs
Issue date:	07/01/1990
From:	Birnie P MARYLAND SAFE ENERGY COALITION
To:	Boger B Office of Nuclear Reactor Regulation
References
NUDOCS 9007160338
Download: ML20055F361 (3)

Text

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a., Mcryland Safo EncrgpCsalition  !

P.O. Scx 902 Calumbia, M land 21044 13011343 0499 011381 2714 gg g _

July 1, 1990 Bruce ~A.'Boger, Assistant Director, Region I Reactors Division of Reactor Projects I/II Office of Nuclear Reactor Regulation '

'U..S. Nuclear Regulatory Commission Washington, D.C. 20555 I"lO R6 _

Dear Mr. Boger:

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SUBJECT:

COMMENTS O'N CALVERT CLIFFS' PERFORMANCE IMPROVEMENT PLAN After careful review of the Calvert Cl-iffs Performance Improvement Plan and its Implementation Program, Ewe want'to register some of our concerns with you.

Our top priority is Safety. In both documents we are glad to read that safety and quality are Baltimore Gas and Electric (BG&E)'s'most important goal, raore important'than production.'

The documents go into great detail about proposed ,

improveme6ts in management, operations, accountability, ,

verification, new training programs, better communication with other utility operations and other industry oversight groups. It is'hard.for an outsider to evaluate the proposed changes and Ldetermine whether they can be truely effectively implemented, or whether'they turn-out to be rhetoric. We wish to comment on a few areas.in'which we question the~ adequacy of the plans, or

.which we'did not find covered at all.

'1. Management Changes. We have read about the root causes of the problems at Calvert Cliffs (11 root causes, all'of which BG&E admits to be of management origin), and have read other documents

-that give some insight into the established crony system of, t management that was_so detached and uncommunicative with the operation of Calvert Cliffs. We question-whether there has been j enough'NEW mangement or leadership added', and whether enough of I the "old wood" has been' pruned. Are there'not. qualified people  !

available to replace those who have grown complacent? There was +

a rather thorough management " house cleaning" at all_ levels of the. Phi.ladelphia Electric Company and Peach Bottom Atomic Power 1 Station recently that reportedly has improved worker morale at  ;

Peach Bottom. '

2. Off-Site Safety Review Committee. We request that a representative of our citizens' organization become a permanent  ;

. member of the utility's Off-Site Safety Review Committee. If '

part of the objective of this committee is to " pay attention to the ' people-side' of issues", we could certainly provide a I responsible representative who is well informed and has good ideas.

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3. Circle Meetings. The " Circle" concept of improving team work..

1 communication, and trouble-shooting is very good. We question

. . whether only an annual meeting of the System Circle.would be adequate. It would seem that it should meet at least quarterly so tha't' problems could be identified and addressed more promptly.

.4. Whistle-Blower. Provisions. We found no provision-to' encourage la -anonymous alerts about unsafe conditions which workers may observe'but might be fearful to identify in person. This should' be a key provision for aay operation that has such safety risks involved.

5. Remaining Modificationa Required by TMI Review Committee. We note that BG&E has three incompleted modification requirements for both reactors resulting from NRC's assessment of safety inadequacies following .the TMI accident. All three seem to be rather important (Control' Room Design Review, Control Room Habitability, and Combustible Gas control), and we question the several years' delay in the implementation of modifications,.

6. Emissions Monitoring. We strongly advocate that upgraded emissions monitoring by the utility be implemented before Calvert Cliffs is returned to service. We-urge that real time monitoring operate at ALL reactor venting or effluent orifices. We also urge that real time monitoring be established at off-site locatlans. radially-from Calvert Cliffs, at 5 mile intervals, up to a.35 mile distance, with a-greater concentration of monitoring stations in the predominant down-wind locations.

7. Emissions Monitoring. We: urge BG&E to increase its funding to Maryland state agencies which monitor Calvert Cliffs' radioactive emissions to enable the state to conduct real time monitoring.

8. Emissions Monitoring. We request that BG&E' provide funding

'for additional emissions monitoring stations for citizens' independent monitoring.

9. Emissions Reports Available. We request.that a " hot line" phone be provided to answer citizen inquiries about the type and level of radioactive emmissions being released by Calvert Cliffs at the moment of the inquiry.

10., Emissions Reports Available. We request that annual written summaries of records of radiation emissions vented, information collected by BG&E's monitoring of air, water, soil, sediment, vegitation, milk and seafood...both at on-site and off-site locations...be available on request by the public.

11. Emergency Evacuation Information. We request that BG&E provide better information about emergency evacuation and health-l

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~ protectiie measures individuals should take in case of serious releases of radiation.

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12. Local & State Emergency Planning. We urge increased funding by BG&Efto County and State agencies responsible for emergency-procedures.

-l In conclusion, we must confess that nuclear power does not 1 s

-meet the common sense test.for generating electricity. It is -'

absurd that technical engineers could justify such a complicated and dangerous technology that threatens the human.genecpool, and a all li fe on earth, requires so many highly trained people to  !

operate it, so many layers of safety systems, and generates a i g ' toxic waste product that we haven't devised a technology to

. I isolate.

Respectfully yours.

Patricia Birnie, .

Co-Director 1 1

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-ce: George V. McGowan, Chairman of the Board, BG&E George C. Creel, V.P., Nuclear Energy, BG&E j 9

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