ML20133E465

Amend to Citizens Awareness Network & Nirs Petition for Enforcement Per 10CFR2.206 to Revoke Northeast Utilities OL for Connecticut Nuclear Power Stations Due to Chronic, Systemic Mismanagement....*

ML20133E465
Person / Time
Site:	Millstone, Haddam Neck  File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/23/1996
From:	Block J CITIZENS AWARENESS NETWORK, NUCLEAR INFORMATION & RESOURCE SERVICE
To:	NRC COMMISSION (OCM), NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20133E446	List: ML20133E442 ML20133E465
References
2.206, NUDOCS 9701130046
Download: ML20133E465 (4)

Text

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CITIZENS AWARENESS NETWORK Box 83 Shelbume Falls, MA 01370 T/ F: 413-339-8768 N uclear Information and Resource S enice 142416th Street, NW, Washingtgggqq{p 202-328-0002 USHRC l

December 23, gg ,

o l OFFICE i F SE PIMY Chairman Jackson and the Commissioners of the DOCKE Ti" euW I United States Nuclear Regulatory Commission,and the M ^'

l Executive Director of Operations for the U.S. Nuclear Regulatory Commission Washington, DC 20555 AMENDMENT TO CAN's and NIRS's PETITION FOR ENFORCEMENT, PURSUANT TO 10 CFR 2.206, TO REVOKE NORTIIEAST UTILITIES' OPERATING LICENSES FOR TIIE CONNECTICUT NUCLEAR POWER STATIONS DUE TO CIIRONIC, S YS TEMIC MIS MANAGEMENT RES ULTING IN SIGNIFICANT VIOLATIONS OF NRC SAFETY REGULATIONS, AND TO INVESTIGATE TIIE NRC STA FF'S RESPONSIBILITY FOR NOT DEALING WITil TIIIS PROBLEM FOR OVER A DECADE L

SUMMARY

RATIONALE FOR REOUESTED ACTIONS in the interest of public health and safety, Citizens Awareness Network (CAN) and Nuclear Information and Resource Service (N1RS), hereby amend their November 25,1996, petition the United States Nuclear Regulatory Commission (NRC), pursuant to 10CFR Q 2.206, to suspend or revoke Northeast Utilities'(NU) licenses to operate the Connecticut Yankee nuclear power stations due to violations of 10 CFR 50 Appendix B, and to prohibit NU from decommissioning any ofits reactors until it has complied with the conditions specified in the main body of the original petition.

1 9701130046 961223 PDR ADOCK 05000213 0 PDR

Amendment to C4N's andNIRS's 10 CFR f 2.206 9 Pettrion toRevole NU's LJcensesfor oss Connecticut Reactors andinvestigate Ncghgent NRCStoJJOversight.

LL REOUESTED ENFORCEMENT ACTIONS A. Petitioners request that the NRC take the following actions to enforce its regulations against Northeast Utilities:

1. As part of the 2.206 process, we request that you provide us with copies of CY's nitrogen calculations, and conduct an i I

independent review to see if these calculations meet the requirements of10CFR50 Appendix B. If they do not, this is just one more serious reason to concluded that CY still lacks the managerialwherewithal to safely conduct the decommissioning of 1 the CYnuclear power station or continued operation of any of the Connecticut reactors. For this reason, we request that NU's operating licenses forits Connecticut reactors be revoked, and NU  ;

not be permitted to commence decommissioning until its has  !

complied with the conditions outlined in the main body of the original petition. Moreover, the Commission should inquire into j the NRC staff's failure to discern this situation, and continuing i failure to enforce the terms and conditions of NU's license and NRC regulations.

IIL RATIONALES FOR REOUESTEDACflONS A. Nature of Problem

1. At the November, 1996, enforcement conference, Connecticut Yankee informed the NRC that it had calculated the amount of nitrogen that entered the reactor coolant system and the amount of water that was displaced. Petitioners allege that NU only had draft calculations to support this statement, and that these calculations were neither finalized nor subjected to independent review to see if these calculations met the requirements of 10 CFR 50 Appendix B. These failures violate the terms and conditions of NU's operating license and NRC regulations. Additionally, the NRC's failure to discern this problem is yet another instance of continuing failure to enforce regulations against this licensee.

Amendment to C4N's andNIRS's 10 CFR f 2.206 3 Perotton to Revole NU's Licensesfor its Connecticut Reactors andInvestigate Neghgens NRC Staff oversight.

i B. Possible Violation of Regulations

! 1. We believe that the calculations were never reviewed or approved as required by 10CFRpart 50and Appendix B.. The NRC regulations require that safety-related calculations be prepared by a qualified individual and reviewed by an independent qualified individual. Additionally, NRC staff failed to discern, and NU and its employees failed to disclose, that only draft calculations were J

used, and there was no independent verification of the engineering calculations concerning the nitrogen bubble problem.

l, C Reason for Requested Action

1. CYhas a history of not doing the required reviews. They may have some kind of draft calculations. Although it is certainly 2

possible that the answers from any such draft calculations may in fact be correct and valid, the purpose forthe requisite reviews is to ensure correctness. This is simply an application of the single failure criterion to human performance. Additionally, if the l allegation contained herein is correct, it is yet another example of

~t he NRC's failure to adequately monitor NU's license and demand conformity with its terms. The bottom line is that ifthe allegation is correct, the licensee's failure to adhere to the requirement of 10 i CFRPart 50and Appendix B,and the NRC's failure to enforce this portion of the regulations, creates a potential catastrophe for

, workers at Cor.cecticut Yankee, persons living in the vicinity of the facility,and the natural environment in proximityto CY.

VL CONCLUSION For the forgoing reasons, petitioners ask the United States Nuclear Regulatory l Commission to grant this amendment by providing the requested information and immediately commencing: (1) an investigation of the need for immediate enforcement I

action against Northeast Utilities for violation of 10 CFR Part 50 and Appendix B, and l

j i

Amendment to CAN's and NIRS's 10 CFR f 2.206 4 Perttion toRevole NU's licensesfor its Connecticut 1:cactors andinvestigate Negligent NRCStaff Oversight.

(2)an investigation of the role of the NRC directorate management and staff (NRR),and l Region I management ar.d staff in permitting NU to operate its Connecticut nuclear j i

power stations out of regulatory compliance with 10 CFRPart 50 and Appendix B.

l DATED: This 23th day of December,1996 l

Respectfully submitted:

l DEBORAH KATZ, President,CAN PAUL GUNTER, Reactor Watchdog Project, NIRS ROSEMARY BASSILAKIS, Researcher for CAN BY: M*

l Jonathan M. Block, Esq.

Attomey for CAN and NIRS Main Street P.O. Box 566 Putney,VT05346-0566 )

l I

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cc: Deborah Katz Paul Gunter Rosemary Bassilakis l Daniel R. MacDonald, Petition Supervisor Emile Julian, Esq., Docketing and Service l

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