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COMMITTEE ON INTERIOR
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The Honorable Nunzio J. Palladino Chairman k
U.S. Nuclear Regulatory Cosmtission i
1717 N Street, N.W.
Washington, D.C.
20555
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Dear Mr. Chairman j.i I am very concerned by the Nuclear Regulatory Commiission's q
apparent failure to identify mamarous errors in the license j
application of the Grand Golf Nuclear Station prior to issuing 3
g a low power license.
It is.my understanding that Grand Gulf, 1
the nation's largest nuclear-reactor, received a license despite j
the fact that (a) menerome license conditions and surveillance i
procedures were'in errer3 (b).the qualifications of operatore 1
were apparently falsified end mone of1the operating staff hace l
previously operated a sammessial reacters and, (c). the drywell 1
cooling syntam use imaangmaam1hy deelgend and constreeted, j
These matters are of poet importance and concern becanoe of their implications for both the agency and the_ licensee.
.i The probless at' Grand 4mit stroogly soggest that, the NRC greeted a license without a proper and detailed review.
For the'11eeeeee, 4
Mississippi Power and Light -(396L), corroboration of thsee concerns might create doubt about its ability to operate and
- anage Grand Gulf in a manner consistaat with NRC regulatices, and therefore, in a way udtich provides reasonable assurance.
that the public besith and estety can and will be protected.
Additionally, sieller doubts have been raised by the overwhelmingly critical January 1984 findings of NBC's Systematic Assessment of Licensee Performance (SALP) Board.
I as most troubled by the f act that the NBC has granted a ~
licanae to a plant for which apprcximately 200 technical specifi-cations and 600 ~ surveillance procedures were -in error. Apparently socie of the erroneous technical specifications were formulated for a different size and type contairment building than the one 7.,.----..,
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Ne hmr. arable Nunzio J.
Falladino March 13, 1984 Paq.. Two at Grand Gulf.
And, some of the errencous surveillance procedures were apparently submitted f or equipment that does not actually axist in the plant.
I am a*,c :tsbed L'.e t these errors were not discovered by the NRC pr.or to t!
- tesuance of a low power license.
Evidently, tho NRC 1-not ftli.'.lic9 its obligation to perform thorough cnd indepe.. dent rev:.
.n. of the technical information submitted by the nuclear i, tur r.
This situation is unacceptable and inexcusable.
The NRC's f ailure to scrutinize this application carefully lo especially troubling considering MP&L's lack of previous nuclear experience and that this was the first plant of its particular type to be licensed.
It is worth noting in this context that this was an unconteeted license.
I cannot help but think that such laxness would not have been possible if there hcd been intervenors and licensing boards reviewing the work of tha NRC staff and MP&L and that these errors would have likely been detected prior to licensing.
I am similarly concerned that despite the belated identifi-cation of these and other deficiencies, the NRC is continuing ito consideration of a full power license and has apparently given no thought to reconsidering the existing low power license.
To assist the Subecennittee in investigating these matters further, I would appreciate your response to the followinn
- 1. With respect to the errors identified in the technical specifications and surveillance procedures submitted to the NRC by MP&L, please indicates t
a.
the nature or types of errors; l
- b. the cause(s) of the errors;
- c. what, if any, analysis NRC has done to discover the possible root cause(s) of the errors and the results of any such analysis
- d. why the NRC did not discover these errors prior to issuing a licenser
- e. the safety significance of the errors (at both low power and normal operation)
- f. what actions the NRC staff took upon learning of those errors; and
- 9. when and by what process the Commission was informed of the errors.
The Honorable !;unzio J.
Palladino March 13, 1984 Page Three
- 2. Did Grand Gulf reach criticality and operate without performing required and appropriate surveillance testa?
If yes, indicates for what periods of time this occurred; a.
- b. whether this took place with the knowledge and/or approval or concurrance of any member of the NRC staff and if so, whom;
- c. what, if any, NRC regulations were violated; and
- d. the safety significance.
- 3. I have been informed that MP&L was examipted by the NRC from performing approximately 30 pre-operational tests.
If true, please indicate what was the technical basis for providing these exemptions.
- a. If these tests had been performed rather than exempted, would any of the technical specifications or surveillance procedure errors have been discovered prior to criticality?
- b. Who at NRC is responsible for granting these exemptions and was a "no significant hazards consideration" determination reade by the staff for some or all of these tests?
Provide a. list of all those that concurred in these decisions along with the Official Record Copy of the document (s) authorizing these exemptions.
- 4. List those members of the NRC staf f that cpproved or concurred in the approval of the erroneous techaical specifications and surveillance procedures subnitted by MP&L for Grand Gulf.
Specifically requested is the Official Record Copy of the document (s) indicating such approval or concurrence.
- 5. How many NRC personnel actually review technical specifications and surveillance procedures submitted by' applicants and licensees?
Please indicate the budget and staff power assigned to this task for each of the past five years.
Indicate also whether the NRC staff and commission believe the present funding, staffing and organization of this task is adequate.
- 6. It is my understanding that HP&L agreed to discontinue operations at Grand Gulf in October 1982 in accordance with an NRC Confirmation of Action Letter issued by NRC's Region II office.
Pleano explain:
The lionorable Nunzio J.
Palladino March 13, 1984 Page Four the reasons why the NRC staff asked a.
MP&L to discontinuo operations in October 1982;
- b. why the license was not revoked or suspended instead;
- c. when, why, and by whose authority MP&L was allowed to continue operations (please provide the Official Record Copy of the document authorizing the return to operations) and
- d. what errors have been discovered since MP&L has continued operations and why these errors were not discovered after the issuance of the Confismation of Action Letter and prior to continued operation.
- 7. Considering the serious problems identified with Trans-America Delaval diesel ganarators at Shoreham in the summer of 1983, what wee the technical basis for allowing Grand Gulf ice operate at low power in September 19837 Additionally, woe the cause of the September 4, 1983 diesel generator fire at Grand Gulf in any way related to the generie problems identified with Trans-i America Delaval diesel generators at Shoreham?
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- 8. In a March 9 1984 telephone coeversation with the staff of the subecum,ittee, Enrold Denton, Director of NRC's Office of Nuclear Doester Regulation, made remarks that my
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staff has related as follows:
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-- Grand Gulf is the "least built" plant ever to receive a low power license.
NRC issued the license because the applicant was in a hurry--
apparently because it wanted to get the plant in the rate base--and assured NRC that it could complete those things necessary for full power operation without any risk to the public after the plant was critical
-- NRC has not determined the safety significance of the inaccurate technical specifications and surveillance procedures for full power operations
-- the NRC staff did not Consider, and is not now considering, revoking or suspending the low power license because of the problems identified at Grand Gulfs and
-- the NRC staff believes that the training records of some of the operators at Grand Gulf were falsified.
l e.
The licr.orable Nunzio J.
Palladino Ma rc h 13, 1984 Page Five Please comment on the above characterizations of what are apparently the views of the NRC staff.
Additionally, please explain:
- a. why a license was issued to a plant that was essentially incomplete and state what, if any, analysis was done by the NRC staff to determine independently whether significant hazards were involved in low oower operation at Grand Gulf considering th.
fact;
- b. what the average amount of ttwe is between issuance of a low power license and a full power license;
- c. what the findings are of MRC's Office of Investigations inquiry into the possible falsification of operators' qualifications (please provide a copy of the OI report).
- 9. Given the large number of errors identified in the technical specifications and survaillance procedures, and considering the fact that reviews and subsequent re-reviews by the licensee, contractors and the NRC have all been inadequate, is the Commission going to require a 100 percent review of the FSAR, the SER and the technical specifications?
If not, please explain why.
Additionally, please indicate what, if any, errors have been identified in the FSAR or the SER and their significance.
- 10. The Commission's regulations at 10 CFR 50.100 state that a license may be revoked or suspended "for any material false statement in the application for a license or in the supplemental or other statement of fact required of the applicant", or, because of " conditions revealed...that would warrant the Commission to refuse to grant a license on an origins 1 application...."
- a. Does the Commission consider that the erroneous technical specifications and surveillance procedures submitted by MP&L for Grand Gulf constitute either a material false statement or a falso statement of fact?
- b. Does the Commission consider that the information submitted by MP&L concerning the qualifications of operators at Grand Gulf constitutes a material false statement?
- c. If the NRC staff and/or Commission had been aware of the errors in the technical specifi-cations and surveillance procedures at Grand Gulf prior to the approval of the low power license, would it have granted the license?
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- . g The Honorable Nunzio J.
Palladino March 13, 1984 Pa';e Six
- 11. In light of the errors discovered in the information submitted to ther NRC for the Grand Gulf low power license, what, if any, steps does the Commission plan l
l to take in order to establish that MP&L has the management integrity and management competence required to operate Grand Gulf.
Additionally, please specify what the Commission presently requires of MP&L before it will vote on the proposed full power license.
1 I would also like to request that the Subcommittee be provided with all internal staff memoranda on the scope, cause or significance of the errors in the technical apecifications and surveillance procedures.
Your response should also include the documents that I understand the staf f has generated in rest onse to Commissioner Gilinsky's interest in this case.
Further, I would like to request that your response to the concerns and questions stated in this letter be provided to the Subcomunittee within two weeks.
Thank you for your prompt attention to this matter.
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1 Sincerely, j
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EDWARD J.
EY Chairman, Sube fee on oversight and Investigations i
EJMirau
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