ML20059F710
| ML20059F710 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/14/1990 |
| From: | Nader R, Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML20059F677 | List: |
| References | |
| NUDOCS 9009110328 | |
| Download: ML20059F710 (29) | |
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UNITED STATES OF AMERICA '
U.S. HOUSE OF REPRESENTATIVES ,
i COMMITTEE ON INTERIOR AND INSULAR AFFAIRS SUBCOMMITTEE ON GENERAL OVERSIGHT AND INVESTIGATIONS t
r HEARING ON'THE LICENSING PROCEDURES-OF THEL U.S. NUCLEAR REGULATORY COMMISSION FOR THE SEABROOK NUCLEAR POWER PLANT Testimony of Ralph Nader l and Robert D. Pollard Nuclear Safety Engineer Union of Concerned Scientists L
Washington, D.C.
.s March 14, 1990 9009110328 900831 PDR ADOCK 05000.443 p FDC p.
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SUMMARY
OF TESTIMONY i
Reports written by the Institute of Nuclear Power OperatiLos (INPO), and others written jointly by INPO and the Public Service j Company of New Hampshire (PSNH), are pertinent to the questions 1 raised about the safety of the Seabrook nuclear power plant. We
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have reviewed INPO documents that are dated between October 1983 l and December 26, 1989. The INPO reports describe a wide variety of serious safety deficiencies identified by INPO at the Seabrook nuclear power plant and the plans by the PSNH to initiate corrective actions. In numerous instances, the schedules for completing the corrective actions extend well past March 1, 1990, i the date on which the U.S. Nuclear _ Regulatory Commission decided to issue a f'ull-power operating license for Seabrook.
The subjects of the safety deficiencies identified by INPO in late 1989 include the following: inadequate training of maintenance personnel and radioactive waste technicians; the continuing failure of plant personnel to follow proceduras; the permanent installation of equipment not shown on plant drawings or included in plant procedures; the lack of staffing for the -
solid radioactive waste handling group; the lack of an-effective check valve preventive maintenance program, despite numerous check valve failures; and a design review of check valves which
- is not scheduled to be completed until April 1991.
The contents of the INPO evaluations compel a conclusion that the NRC had--and continues to have--no valid technical basis for permitting the Seabrook nuclear power plant to operate. At the very least, given ths Administration's position on nuclear power, the Seabrook plant should not be permitted to operate unless and until the PSNH completes its planned corrective actions end the NRC reviews those actions and determines that the safety dLficiencies have been corrected. Furthermore, all INPO documents related to the Seabrook plant should be disclosed to permit the parties to the Seabrook licensing proceeding to evaluate the veracity of sworn testimony presented by the NRC and !
PSNH witnesses to the NRC licensing boards. I i >
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Introduction Thank you for the invitation to appear before the l Subcommittee to address the licensing procedures used by the U.S.
l Nuclear Regv3 Etery Commission (NRC) in issuing a full-power operating li' d yW for the Seabrook nuclear power plant.
Reports written by the Institute of Nuclear Power Operations 1 (INPO), and others written jointly by INPO and the Public Service
- Company of New Hampshire (PSNH), are pertinent to the questions ~
t raised about the safety of the Seabrook nuclear power plant. The INPO documents we have reviewed are dated between October 1983 and December 26, 1969. They include INPO trip reports provided
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to PSNH, evaluations of tha Seabrook Station, construction project evaluations, and evaluations of PSNH, New Hampshire Yankee Division corporate support and monitoring of the Seabrook Station. The latter three types of documents include PSNH's responses to INPO's findings and recommendations.
We have concentrated our review on the more recent INPO t documents. Quotations in this testimony from INPO reports are from documents dated March 1988, September 1989, and December 26, I 1989.
Further identifir.ation of these three documents is !
provided later.
Description of INPO and Its Relationship With the NRC '
The Instituts for Nuclear Power Operations was created in the aftermath of the Three Mile Island accident that began on March 28, 1979.
According to an article in the January 2, 1989 edf aon of Inside N.R.C., INPO: __
"has a $50-million operating budget paid by utilities, conducts periodic inspections of operating nuclear plants, plants under organizations. *** construction, and corporate ;
It manages an accreditation of utility and technical personnel. forIt Operations, training programs maintenance, also analyzes abnormal events that occur during construction, testing, and operation of plants, and it disseminates that information, the lessons-learned, to its members."
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Testimony of March 14, 1990 I
Ralph Nader & {
Page '
Robert D. Pollard According to the INPO documents, "INPO's goal is to assist member utilities in achieving the highest standards of excellence in nuclear plant operation. The recommendations in each area are i based on best practices,'rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory performance." (emphasis added.) !
In October 1988, the NRC and INPO signed a revised
" Memorandum of Agreemer.t" (MOA), which modified a 1985 MOA.
This MOA was signed for the NRC by Victor Stello, Jr., then the NRC's Executive Director for Operations. As part of the f
Subcommittee's investigation of the NRC licensing procedures, we i recommend a thorough review of the current MOA between INPO and the NRC. In our view, the MOA effectively transfers the NRC's regulatory responsibilities to INPO, despite assertions to the contrary in the MOA.
Some of the MOA provisions relevant to the types of the INPO ,
appraisal and evaluation reports discussed in this testimony are as.follews:
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"NRC desires to recognize INPO evaluation activities to the extent that these activities are effective in helping meet NRC's responsibilities as well as lessen the burden imposed '
on the industry by duplicative appraisal activities."
o "NRC requires access to selected INPO documente and '
information as well as the opportunity to give credit for INPO activities and to thereby avoid unnecessary duplication."
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"INPO expects its member utilities to make operating plant evaluation reports available to the NRC for review or reading.
Further, INPO will make final evaluatior. reports l
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j Testimony of P.alph Nader & March 14, 1990 l Page -3 =-
Robert D. Pollard !
available to the NRC for review or reading by appropriate NRC management personnel at the INPO offices in Atlanta." ,
i "NRC review of INPO evaluation activities'ill w be I coordinated by the NRC Office of the Executive Director for !
Operations.
Since INPO has its own system for obtaining -
member corrective action, NRC's role in pursuing correction of 1NPO ovaluation findings will primarily involve only 1 those potentially significant safety problems for which NRC has no other reasonable alternative in meeting its legislated responsibilities. Any other NRC follow-up ;
enforcement action would be in accordance with.. . . the established Commission enforcement policy for licensee '
identified non-compliances to those non-compliances i
dentified by utilities as a result of INPO evaluations."
INPO documents which reflect unsafe conditions at Seabrook also serve to highlight the public's ongoing lack of access to -
L virtually all of INPO's vital records. Ironically, in addition
" to furnishing its safety evaluations to the NRC, INPO makes them available to every nuclear utility, as well as virtually all '
i ~ industry consultants and contractors. However, INPO has L
vehemently objected to the release of the reports to the public
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(including members of Congress) who must actually live in the- "
shadow of nuclear power plants because, in the words of an internal-INPO memorandum, "public and/or political pressure may be brought to bear on the NRC to follow-up on INPO evaluations j
for the purpose of regulatory action." The result'is that the d
INPO reports are routinely made available to everyone that is concerned in any way with the construction and operation of
- nuclear plants in the United States--with the exception of the .i American public.
Since INPO is funded by utility dollars which come from consumer dollars, consumers are paying for this intolerable secrecy.
l Testimony of Ralph Nader & March 14, 1990 Robert D. Pollard Page j Even more alarming than INPO's position on public access is '
the fact that the NRC has allowed INPO to dictate the Commission's own non-disclosure policies. Since 1984, the NRC
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has been battling in federal court to prevent a public-interest greap--Public Citizen's Critical Mass Energy Project--from obtaining access, under the Freedom of Information Act, to INPO ,
safety reports that are in the Commission's possession. While conceding that it heavily relies on the INPO reports in i establishing and pursuing its regulatory activities, and also
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that the INPO reports frequently contain more safety-related information than NRC records, the Commission has nonetheless ,
maintained that the public has no right of access to the reports.
simply because INPO has objected to their disclosure. ,
The NRC's disdain for the public's right to know about INPO's findings is especially outrageous since the Commission has t insisted on turning many of its regulatory functions over to INPO.
For example, rather than promulgate its own requirements l
L for the training and qualifications of nt;1 ear power plant personnel, as Congress required in 1982, the Ceecission has simply rubber-stamped INPO's training program, The Commission did the same with regard to fitness for duty requirements. In essence, the Commission has allowed INPO to take over many of the Commission's own vital regulatory functions, yet, at the same time, it is allowing INPO to ignoro essential elements of public accountability and access--which the Commission would have had to afford if it had not ceded. control to an industry group.
The public is, therefore, getting the short end of the stick P
in two different. ways -- first, because a self-interested industry group rather than a federal agency is entrusted with regulating the safety of nuclear power plants and, second, because the industry group is permitted to conduct its quasi-governmental functions in complete secrecy. In essence, if the
'NRC is willing to simply hand over its statutory respons1*bilities
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- Testimony of Ralph Nader & March 14, 1990 I
.. Robert D. Pollard Page l t
s to the nuclear industry, it should at least be prevented from '
surrendering the public's right to know at the same time.
Analveis of IMPO Documents i
- Document No. 1 i The following quotations are from a document consisting of a ,
one-page letter from W. R.
Kindley, Director, Corporate Support Division, INPO, to George S. Thomas, Vice President, Nuclear-
?roduction, New Hampshire Yankee Division, PSNH, dated February 8, ,
1988, enclosing a seven-page " Trip Report - Special Assistance Visit to Seabrook Station," dated February 8, 1988, with a one-page attachment listing personnel contacted.
t The PSNH had itequested INPO "to participate in an audit of the Seabrook L;.orgency Preparedness and Public Aff airs Divisions." One of the INPO emergency preparedness evaluators had previously observed a drill of the Seabrook Emergency Operations Facility during an evaluated exercise in December 1987. This INPO " trip report" document discusses and makes ,
several "significant recommendations
- regarding the organization of the Seabrook emergency preparedness program, the Emergency Plan and the emergency plan implementing procedures, the emergency preparedness training program, and the emergency public information program.
The following are among the problems affecting emergency >
_ preparedness at Seabrook which were noted by INPO:
l Under " Organization," INPO stated that: "Several New Hampshire Yankee personnel-interviewed did not know their. complete assigned e duties and responsibilities and indicated they had not ever seen their position descriptions;" and "There is no document, form, or system in. place that describes all the duties and responsibilities of the Radiological Assessment Manager."
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- Tcatim:ny of March 14, 1990 i
Ralph Nader & l Page , Robert D. Pollard )
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Under " Emergency Plan and emergency plan implementing procedures," INPO noted that: "The emergency plan in some instances is not consistent with the emergency plan implementing procedures and/or business as it is being conducted;" and -
" Revisions to on-site procedures are being accomplished through the use of an unauthorized change control program, administered =
by the emergency preparedness group outside of the approved \
process. * *
- Interviews and document reviews indicated that
'short cuts' are being used to speed up even this process and user impacts are not being considered. No documentation exists >
for this unauthorized process." ,
Under " Training," INPO noted that: " Emergency preparedness i training programs do not currently comply with the requirements specified by procedure. * *
- Emergency p 9paredness training instructors are not being qualif14d or selected in accordance ~
with the criteria specified in (a procedure containing well-defined criteria for selecting and training emergency preparedness training instructors)." i t
The INPO document does not contain any responses by PSNH.
t Given these deficiencies in the Seabrook emergency preparedness program, there is reason to question the validity of the NRC and FEMA evaluations of_ emergency drills conducted prior to this INPO report and prior to PSNH correcting the 1 deficiencies, assuming (without any basis) that they have been corrected.
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- Document 2 The following quotations are from a document coni.isting of a 45-page INPO report, " Evaluation of Seabrook Station," dated September 1989, including a one-page Appendix I and a twelve-page Appendix II, " Additional Supporting Details."
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- TOctim:ny of Ralph Nader &- March 14, 1990 '
, Robert D. Pollard Page t During the weeks of September 11 and 18, 1989, INPO L l conducted an evaluation of Seabrook. Low power testing was
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completed in' June 1989 and the plant was shutdown for modification work during this evaluation. 1 INPO made findings and recommendations, which PSNH responded
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in the areas of organization and administration, operating j experience review, technical support, operations, maintenance, radiological T?otection and chemistry. The following are examples of the areas that INPO characterized as "the most 1
significant areas in need of improvement:"
INPO Finding:
" Monitoring of plant activities and programs and supervisors h is often ineffective in' identifying needed improvements." One '
example: " Senior station managers were unaware that vendor I manuals are used to conduct station activities contrary to station policy.
Interviews with instrument and control technicians indicated that vendor manuals are routinely used to '
g troubleshoot and repair process equipment. Vendor manuals do not receive the equivalency of station operating review committee L
L approval, and a program is not in place to keep the manuals up to date."
PSNH Response:
" Station management's expectations of supervisors and mancgers regarding their presence in station work areas will be restated and reemphasized." The remainder of the PSNH response did not specifically address the use of vendor' manuals in place of approved procedures.
INPO Finding:
"The station has experienced a number of recurring events due to inadequate identification and investigation of in-house operational events."
l One of six examples cited by INPO was the
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Testimony of Ralph Nader & March 14, 1990 Robert D. Pollard Page following: "Between August 6 and September 9, 1989, water was inadvertently drained from the refueling water storage tank or the condensate storage tank on three occasions. The first event was due to a valve being open that was thought to be danger-tagged shut.
The second event was due to not performing a required valve lineup. The third event occurred while restoring eight valves that were discovered to be previously mispositioned."
It should be noted that the refueling water storage tank and the cos.f=nsate storage tank are important safety equipment because they *re the soutcos of water for plant safety systems, such as the emergsacy core cooling systems and the emergency.
feedwater syotem, that are needed in the event of an accident. I PSNH Response:
"The station information report (SIR) procedure will be revised 1 or a new reporting method will be developed to ensure that in-house operating events, such as those noted, will be i investigated thoroughly and completed in a timely manner. ***
This procedure will be updated and implemented by February 1990 " !
INPO Finding: !
"Some events have occurred at the (Seabrook) station that could have been prevented by improved application of industry operating experience.
Implementation of corrective actions to prevent #
occurrence of events described in significant operating I experience reports (SOER) is frequently not effective or timely." ,
INPO cited three examples, involving multiple failures of safety ;
equipment at Seabrook, which were the subject of SOERs issued before the failures occurred at Seabrook.
" Corrective actions taken in response to 118 SOER recommendations were reviewed 'during the evaluatic's. Of these, 25 station responses were determined to be f.ot satisfactory due to either 1
- Testimony of March 14, 1990 Ralph Nader &
. Robert D. Pollard Page insufficient progress being made, or the actions taken not being-implemented completely or effectively."
" Review of significant event reports (SER) is frequently not complete or timely as indicated by the following: a. Five SERs, one 1987 and four 1988, were closed out without being reviewed for applicability and appropriate corrective actions; b. Five 1988 SERs have not received initial screening for applicability."
PSNH Response:
"The New Hampshire Yankee industry operating experience review program will be improved and strengthened to ensure effectiveness and timeliness in the implementation of lessons learned from industry operating experience. A schedule has been developed for the review and implementation of outstanding SOERs and SERs. The backlog of open SOERs will be reviewed and corrective actions determined by October 1990." (emphasis added.)
INPO Finding:
"Many plant changes do not receive appropriate technical review and are not incorporated into plant drawings and procedures. The lack of adequate design review and documentation has resulted in plant events and reportable conditions." INPO cited four examples, including the following:
" Excluding temporary modifications required to support the power ascension test program, there are 64 outstanding temporary modifications with some installed more than four years ago.
Fifty-two of'these 64 require a design' engineering decision to be made permanent or to cancel. Twenty-one are being worked or are scheduled to be completed by 1990: however, 10 are not scheduled
.for completion until 1991 or later, and 21 have no dates currently established." (emphasis added.)
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- Testimony of March 14, 1990 Ralph Nader &
- Page Robert D. Pollard PSNH Response:
"An assessment of the current scope of tho temporary modification program will be performed by March 1990. Ao part of this assessment, existing controls will be enhanced to further ensure plant configuration control. * *
- In addition, previously installed temporary modifications that have been mads ria o suu r will be reviewed to ensure that maintenance p.scedure'. s on technical information are accurate. This effort wil. be completed by June 1900." (emphasis added.)
INPO Finding:
" Preventative maintenance measures have not been established to identify check valve performance problems or degradation in some important systems. Recent check valve problems, including a case of seat leakage that resulted in the residual heat removal system suction piping overpressurization and two stuck open volume control tank nitrogen supply check valves, demonstrate the need for such measures."
The chock valve failures and other problems experienced at Seabrook cited by INPO involve many vital safety systems, 3:cluding the following: residual heat removal (which is part of the emergency core cooling system); emergency feedwater; emergency tiesel generator starting and cooling systems. INPO also noted that " Test and inspection requirements have not been specified for 64 of the 220 valves listed in the check valve monitoring program."
INPO also found that the existing check valve monitoring program at Seabrook does not contain " quantitative acceptance criteria" which industry experience has shown is necessary.
Furthermore, the " limited testing" of check valves at Seabrook-
"may not identify degraded internal conditions such as worn hinge pins, loose or missing non-pressure retaining parts or erosion of internal parts."
- Testimony of March 14, 1990 Ralph Nader &
Page , ' Robert D. Pollard PSNH Response:
The response by PSNH includes the following statements.
'"A review of the current check valve design and monitoring program will be conducted and completed by October 1990. This effort will include * *
- a design review of check valves for applicability with respect to EPRI Report NP-3479 and INPO SOER 86-3. * *
- Preventative maintenance on selected check valves will be performed prior to completion of the first refueling outage." (emphasis added.]
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This particular subject deserves additional discussion to illustrate its safety significance. A check valve is, simply, a valve which is designed to permit fluid flow in one direction and is supposed-to close and prevent flow in the opposite direction if system pressure downstream of the valve is greater than the pressure upstream.
One common use of check valves is to prevent over-pressurization of low-pressure systems connected to the high-pressure reactor coolant system. Failure or significant leakage of check valves installed in this " interface" between high-pressure and low-pressure systems can result in what the NRC terms an interfacing systems loss-of-coolant accident. This is t an extremely serious and fast-moving accident involving destruction of the emergency core cooling system, core meltdown, and radiation doses in the 100-rem range to the public in about i an hour.
Thomas Murley, a high-level NRC 6fficial, has described the !
j serious nature of such an aucident.
"This sequence is-important in my judgement because it bypasses the containment and it bypasses emergency preparedness. It effectively bypasses two levels of our defense-in-depth safety philosophy _under the worst circumstances.
that you have a break out inThe theworst RHR circumstances residual heat (are) removal)-system which then causes you(to not only lose j
I Testimony of Ralph Nader & March 14, 1990 Robert D. Pollard Page coolant but to lose all your safety injection (i.e.,
emergency core cooling) capability, and which ultimately then leads to core damage and core meltdown to an open containment.
"That goes straight to the atruosphere and it can happen ia a short time.
The worst time celculations that I've seen can lead to core uncove-age'in a half hour, core damage in 45 minutes, and off-site doses in the 100 rem range in an hour or bour-and-a-half. So its the importance of that seqvance that caused me to consider. taking another look at it. I have no evidence that the probability is higher than what is said in the PRAs (probabilistic risk assessments), (but) I'm starting to see these precursors, so rather than take the PRA results at face value, I'm going to be a little skeptical, just because of this sequence and its consequences."
Inside N.R.C., April 10, 1989.
Of course, existing probabilistAc risk assessments (PRAs) rely, in part, on the assumption of an adequate check valve maintenance program. As INPO noted, the program at Seabrook is inadequate and has already resulted in overpressurization of the RHR system due to check valve leakage.
~INPO Finding:
" Unapproved vendor technical manuals are being used to perform various maintenance activities. In addition,-sorr.e of the manuals lack sufficient technical direction for the conduct of maintenance activities."
PSNH Response:
"The New' Hampshire Yankee program for vendor manuals is presently
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being revised and strengthened'. Part of this revision will define which vendor manuals will be available for use, how they can be used and what review process must be completed. Full implementation of this program is scheduled for December 1990."
(emphasis added.)
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we Ralph Mader E. March 14, 1990 RobertED. Pollard Page ,
INPO Finding:
"The station' equipment tagging and isolation procedureyneeds.
improvement to ensure protection for personnel and equipment." l
'INPO cited three problems, some involving safety systems,-where I the Seabrook procedures are not adequate to prevent personnel injury or equipment damage. !
l PSNH Response!
i "The review of the current (tagging) procedure with suggested: '
modifications will tus completed by June 1990. The sLBsequent-procedur6 revisions and_ training will be completed by September ;
1990." (emphasis added-]
INPO' Finding:- !
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"The material condition of some plant equipment and' piping'is i, degrEded due7to corrosion. In addition, many equipment
. deficiencies are not identified in the work control system." I o
_INPOLcited six examples'of problems including the following.
m "Nearly.50 percent (18 of 38) of a sample'of equipment ideficiencies checked:were not in.the work control system.
Examples include the following:-excessive boric acid crystal i Eb111dupr on core? spray and residual heat removal system valves .-.
Both systems cited by INPO are vital plant safety-sh.
'SNH Response: 1 g, otation management will stress the importance of routine k'l 1% porting of problems using-the work request system." The a * ,
W, remainder'of:the response describen. changes to the existing p -
Seabrook-p'rogram-which will be co'Apleted by January 1990 and a new prograu to complement the existing program which will be corupleted by September 1990.
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. * ' Document 3.
The following-quotations are from a document consicting of a *
,, one:-page letter from-Zach T. Pate, President, INPO, to John C.
LDuffett, President & CEO, PSNH, dated Decemcar 26, 1989, !
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. Testimony'of. 4 1 Ralph Neder"GE March 14, 1990 i A- . Robert D.-Pollard. Page -
J enclosing a-17 page report on "INP0's evaluation of Public Service' Company of New~ Hampshire, New Hampshiro Yankee ~ Division's corporat eupport and' monitoring of Seabrook Station from October 2 through 6, 1989."
. i INPO Finding:
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" Consistent direction needs to be provided to.the Ne't Hampshire
' Yankee organization to facilitate the nuclear station's ]
l transition from the support role it held during construction, to-that of the principal department requiring support during power 3
'g s operation."
Among the areas cited by INPO. as re quiring !
" additional corporate emphasis or resolution for the station to enmplete preparations for power operations" was the following: I The solid radioactive: waste handling group has not been
' staffed."
In addition, " Maintenance training was recently 4
. cancelled due to insufficient resources-in the maintenance department to complete'both the scheduled work and training..-* *
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- -Senior plant and. corporate management' vere not aware of these ,
decisions or the impact on the maintenance. department's readiness '
for power operations."
PSNH-Responso: ,
Many of-the actions taken by PSNH, such as" reinforcing and O
.further defining-responsibilities and ateffing.the radioactive waste handling group were scheduled to be completed by December
-1989. -However, ongoing reviews to identify and, if necessary, to reassign activities'are not scheduled to be= completed until June 1990,"and any identified responsibility reassignments will be implemented by September ~1990." (emphhs'is added.]
p INPO Finding:
' Timely action has not been. taken by the corporate organization to address and resolve some-important problem areas'that could
? ' affect station operation. In several cases, these problems were c
Lpreviously identified from within the organization, but gc ,
' corrective action was not adequately implemented." .
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Ralph'Nader-& March 14, 1990.
Robert D;; Pollard Page -
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-One of the three lengthy examples of "significant problem areas" cited.by INPO was the following: " Procedure adherence problems were repeatedly identified in.the executive summaries of
-semi-annual quality assurance trend reports since 1987. However, management action to address.this. problem was not initiated until early .1989, and was not effective in preventing an event in. June.
1989 that was, in part, attributed to non-adherence to a test
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INPO also noted that "despite the check valve failures at >
Seabrook and (previous INPO correspondence emphasizing the I
. significance of check' valve failures], an effective check valve ;
maintenance program is not yet in place. Additionally, a design j
, review of check valves is not scheduled to be completed unti1~
-April 1991."-(emphasis added.] j
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I PSNH Response:
Most of the actions discussed in the'PSNH response were scheduled i'
to be completed by February 1990. However, PSNH stated: "A task team has been established to eddress vendor manual issues, and a ]
compsw mnsive check valve design and monitoring program is under ]
devei.opment.. Corrective actions associated'with these issues i
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wi,1 be fully implemented by penamber 1090, and petober 1990, a i
.respectively." (emphasis added.]
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- ~INPO Finding:
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" Corporate.and station managars and supervisors are often not I held accountable for timely completion of assigned actions or
'improvements to.the station," Examples cited by INPO included ;
3 the-following:."Approximately.one-quarte
- of 1,250 items on the b^
H integrated commitment tracking system are past due; Based on a '
recent status report, 29 of 47 corporate goals (62_ percent) will not'be achieved in 1989;-48 percent of the annual appraisals for b,
xexempt, personnel in the station staff are overdue; e number of.
p' !1ssues: identified in this and the recent station evaluation are 1
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I Testimony of
. Ralph Nader & March 14, 1990
- . , Page Robert D.-Pollard i
similar to those identified in 1986 and 1987 INPO corporate and '
station visite."
PSNH Response:
The PSNH response consists primarily of nebulous efforts such as 4 ('
instituting a " Core Values and Work Ethic Program" to strengthen
' attention to detail,. accountability, and management expectations, ,
all of which were scheduled to be completed by December 1989.
E One PSNH action that may be effective in correcting one problem is that " completion cf performance appraisals will be assured by ,
requiring that performance appraisals be-a prerequisite to annual
-wage and salary actions." }
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.INPO Finding:
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" Insufficient management attention has been given to the- -
development and implementation of a radioactive waste handling:
E program.
As a result, although generation of radioactive-waste has begun and'the plant expects to begin power ascension in the U
near futuro, key segments of the radioactive waste program at not,in place. Examples include the following; i.
"a. Responsfbilities for the processing ~i j are unclear.
radioactivt waste.
The corporate radiological protection organization L
1' l is; assigned responsibility for radioactive waste shipments by p procedure.
I However, based on an interface' agreement approved in '
July 11989, the principal health physicist considers.this responsibility to have been shifted to the station maintenance l
, utilities-manager. The utilities manager considers the interface !
L Eagreement~to be contingent upon staffing the utilities /
u radioactive. waste organization (staffing positions not yet I approved) and has not accepted radioactive material processing and shipment responsibilities. As a result, neither group is l ' modifying procedures to accomplish the- shif t in responsibilities. 1 l
' "b.
Reorganization and staffing to create the proposed 1 l
. utilities / radioactive waste organization is incomplete. As a G
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, +Tottimany cf Ralph Nader & March 14, 1990 l Robert D. Pollard Page . ,,
result, progrenc is not being.made in training and'procadure revisions, and develcpment of long-term plans for interim radioactive waste storage pending resolution of final waste disposal options has been delayed."
b, "c.'The radioactive waste minimization committee has not met- "
h in over two years, and has not' addressed existing station p
o practices that contribute to unnecessary generation of radioactive waste. Management oversight has not been effective in identifying and correcting this problem.
"d. Plans and milestones have not I communicated for the tampcrary storage of radioactive waste .r tc callability-of
'fa011'ities for long-term storage. Despite'the long-lead. times 1.nvolv3J.for'someftemporary facilities, plans have not been implemented.- Various managers in the plant and corporate
-organizations havencommunicated.~different plans for interim st orage of radioactive waste ranging from flatbed trailers parked
, !i'.fth'e protected areas to a new storage building."- $
PSNH Response:'
t g,
"A comprehensive radioactive waste program will~be developed by ;
January 1990. The-program will clearly define the responsibilities, res,ources, and procedures necessary-to handle
- expected volumed'of radioactive waste. Steps are being-taken to j
fill: radioactive waste technician positions. - ~ Temporary storage : j
'of soli,d low level waste will'be in place by April'1990. A-i: g training program for radioactive waste technicians has been established;and will'be fully implemented in the first quarter of t
v ,
<1990." (emphasis added.)
~
Conclusion L
1 1These' findings'by-the nuclear power industry's own Institute 4
of' Nuclear Power Operations argue that anything short of correcting the: grave safety deficiencies constitutes grounds for m s ,
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- TO3timany of _
March 14,-1990- j Rainh NaderL&' _ '?cge' Robert D.-Pollard criminal negligence in the-operation, supervision and regulation
-of=the Seabrook nuclear plant. Any harm proceeding from-any uncorrected safety problems should justify a criminal indictment
, for. willful and. knowing violations.
A full congressional investigation is needed with all pertinent officials and analysts from the Pub 11c' Service Company '
of New Hampshire, the Institute of Nuclear Power Operations and ,
the-U.S. Nuclear Regulatory Commission ordered to respond-to-congressional questioning. No further movement toward power operation should-be_permitte'd by the NRC which shoult immediately- '
g modify, suspend,-or ravoke the operating license for the Seabrook plant pending completion of such an investigation.
The life ofLthe. land and its people are at stske.
- i Thank you.
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,- SEABROOK SERVICE UST 4 HARMON,' CURRAN & -TOUSI.EY '
b .
Atomic Saferv ar.c Licensing Robert A. Backus. Esq.
U - Alan S. RosenthaL Chairman Michael Santosuosso. Chairman Appeal Bosrd Panel - Backus, Meyer & Solomon 7 Atomic Seferv and ucensing Boa'd of Selectmen U.S. Nuclear Replatory Commission 111 lamell Street Appeal Board K Jewell Stmet RFD e 2 Washington.D.C 20535 .Vanchester NH 03105
' US NRC Sovih Harepton,NH 03s42 j Washington. D.C 20$55 - Atomic Safety and Licensing
'Mitai A. Young, Esq. Judith H. Minner Esq.
Board Panel Edwin J. Reis. Esq. Silverglate, Geriner, et at W ; Thomas 5 Moore US Nuelur Replatory Commission Ofnee of the General Counsel 88 Broad Street Atomic Saferv and ucensing' Washington.D.C 20555 U.S. Nucisar Regulatory Coenman . Boston,MA 02110 1 Appeal Board ' .
Washington,DC 20$35 ,
'q. U S. NRC ~
- Docketing and Service Branch i
, Washinyon.D.C 20$35 -
' US Nuclear Regunatory Commesson - H. Joseph Flynn, Esq.
- By hand Washington.D.C 20$$$ Ofnee of Geners! Counsel " By telefax 6 >
MKuseth M. Carr FEMA i
U1 N.iclear regulatory Commesion Jane Doughty 500 C Street S.W.
)
Wuhincon. D.C 20555 SAPL Washington, D.C 20472 q" ,
$ Masket Simet j
- i. *homas M. soeris i Ponsmouth. . H 03801 George Dana B'abee. Esq.
- Commissioner Geoffrey M. Huntington. Esq. ;
US Nuclear Regvlatore "ommasion John Traficonte. Enouire Office of the Attorney General *
' Washington, D C 20535 Assatant Attorney General State House Anne.t
~ l A.hbunon Place.19th Floor Concord.hH 03301
' James R. C.inas Boston, MA C2108 i
~ Commisioner -
Richard A. Hampe. Esq.
- U S. Nuclear Reptatory Commasion Senator Gordon J. Humpnrey Hampe and McNicholas Washington. D.C 20$55 1 Easic Square. See 507
- ] i.
' 35 Pleasant Street Concord.NH 03301- Concord.hH 03301
'Forrest J/kemick '
=r
= Commassoner - - Alfred V. Sergent. Chairman Gary W. Holmu, Esq.
U1 Nuclur Regulatory Commision Board of Selectmen Holmes & Ellis Washington.DC 20535 Town of Sahsbury, MA 01950 47 Winnacunnent Road
. Hampton,NH 03842
'Kenneth C Rogers J Rep. Sunnne Breinth Commissioner Town of Hampton Fat i
,-' William Armstrong '
U1 Nuclear Replatory Commission Dnnkwater Road lJ
. Washington. D.C 20$55 -
Civil Defense Director Hampson Falls NH 0244 10 Front Street Exeter,I,H 03833 Howard AlWilber Stanley W. Kriowiu Atomic Safety and Ucensing . Board of Selectmen l, .. Appeal Board Mrs. Anne E. Goodman P.O. Box 710 - .>
Board of Selectmen l_ UiNRC North Hampton.hH 03826 e
13-15 New Market Road .
(l . Washmston. D.C 20$35 l-
.=
'Durham.hH 03842 Allen bmpert
. Ivtn W. Smith, Chairman -
Civil Detense Director R. Scott Hill-Whitton L" ';" E Atornic Safety and Licensing Board Town of ' Brentowood Lagouhs, Clark. Hill-Whilton a J U1 Nuclear Regulatory Commission Eneter,NH 03833 - and McGuire -
- Washington.D.C 20$$$
79 State Street Paul McEachem, Es4 Newburyport,MA 01950 R Dr. Richard F. Cole Shaines & McEachern Aeomic Safety and Licensing Board P.O. Box 360 Diana Sidebotham
- US Nuclear Reptatory Commission - Maplewood Avenue t Washington, D.C 20535 RFD # 2 Box 1260 . '
Portsmouth.NH 03801 Putney, VT 05346 "M ' Kenneth A. McCollom ' Sandre Gavutis Richard Donovan Atomic Safety and Ucensing Board RFD 1, Bor 1154 ;
. U1 Nuclear Replatory Commission East Kensington,NH 03827 i
- Washington, D.C 20555 = Mt J.W. McCormack (POCH)
%ston,MA 02109 Phillip Ahrens, Esq.
Robert R. Pieree. Esq. Anissant Attomey General Senator Gordon J. Humphrey 4
-- Atomic Safety and ucensing Board State House, Station #6 US Senate
' UA Nuclear Replatory Commission Augusta,ME 04113
!: heington,D.C. 20510 Washington, D.C 20535 (Atta. Tom Burack)
" Thomas G. Dignan. Esq.
R.K. Cad 11. Esq. ' Ashod N. Aminan.Esq.
Ropes & Grey 145 South Main Street i
One late rnational Place P.O. Box 38 j Doston. MA 02110,.r.24 .t Dradford.MA 01115
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' asked to-concur-on all-staff correspondence .-
, 4 Jack R. Goldberg _
Deputy Assistant General Counsel! .
' for~ Enforcement Office of the General! Counsel i
Enclosures:
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- 1. s 2; Draf t = Letter of. Ackowledgement
- 3. Draft federal Register Notice ;;
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^ Jack R. Goldberg Deputy Assistant General Counsel ' !'
for. Enforcement bifice of the General Counsel
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Jack R. Goldberg-Deputy Assistant General Counsel ._
for Enforcement Office of the General Counsel q
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FOR THE NUCLEAR REGULATORY COMMISSION-Original signed bf Thomasg,MarleY
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Thomas E. Murley, Director Office of Nuclear Reactor Regulation 4
Dates at Rockville Maryland
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Thomas E. Murley, Director Of' ice of Nuclear Reactor Regulation Dated at Rockville, Maryland .{
this, day of , 1990
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, Sincerely, ,
l l Thomas E. Murley, Director-Office of Nuclear Reactor Regulation
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i 6 UNION OF m-CONCERNED '
SCIENTISTS "I
,, 9 i
ROBERT D. POLLARD
+
Robert D.: Pollard, 50, is Senior Nuclear Safety Enginoer for. the thion of Concerned Scientists, a non-profit group of scientistst and other professionals - a supported by omtributions frm citizens natiorwide. ~
i 3
Robert Pollard's fomal education in nuclear design began in May,1959, dan ha' was-' y selected to' serve as an' electronics technician in the U.S. Navy nuclear power program. ' ' After completing the required training, he became an instructor n- i respcnsible for teaching naval personnel both the theoretical,and practical aspects of operations, maintenance and repair of nuclear propulsicn plants. Frcm j February 1964 to Apd11965, he served as senior reactor operator, supervising the 4 reactor ocntrol divisicn of the U.S.S._ Sargo, a nuclear-powered submarine. t L After his _hcnorable discharge in 1965, Robert Pollard attended Syracuse University, where he graduated with a Bachelor of Science degree magna cum laude in electrical engineering in June 1969.
l 1 p , In July 1969, Robert Pollard was hired by the Atmic Energy 0:mnissicn (AEC), and . O L ccotinued as a technics 1= expert with the AEC and 'its swmaav the Nuclear 1 Regulatory Ctmnission (NRC) until- February 1976. After joining.the AEC, he; -[
t studied advanced electrical and nuclear engineering at the Graduate School:of.the
- -University of New Mexico in Albaquerque. He ethaaquently advanced to the ,
positions of reactor engineer and project manager with the AEC/NRC. >
[ '
L ; As a reactor engineer, Robert Pollard was primarily respcmsible for performing
{i ,
detailed technical reviews analyzing and evaluating the-adequacy of the design of
, reactor protection systems, omtrol systems and emergency electrical power systems t
in' W.M raclear facilities. In Se A i.-r 1974, ha'was prmated to project j; ." manager, respmsible;for plarning and mordinating the design and satoty reviews of applicaticns for licenses to s, Lect anc4 operate seven camercial nuclear power plants.
D While with NRC, Mr. Pollard also served as the agency's representative standards in standard-settng and safety guides, and as agroups, si participating in the developent of
.mw of IEEE camittees.
u He resigned frun the NRC and began working for UCS in February 1976. In'als work
[* ' >
for UCS, Mr. Pollard has continued to use his expertise in nuclear safeti
'in the U.S. and overseas. analysis. He has testified as an expert witness in NRC an Mr. Pollard conceived and provided the technical analysis, for a petition filed by UCS with the NRC that resulted in the 1980 ~
j h
acbption of industry-wide safety standards for nuclear plant cmpcnents. He has traveled extensively throughout the country s
\-
off3cials on issues related to nuclear. power.peakits to citizens 'and government
.V l;
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a ', _ y. ~. .,1ste _ P Street, NW Suite 310 Washington, DC-20034.16@S DS84039 20BA N -
- ~-