ML20138K952
| ML20138K952 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 02/01/1997 |
| From: | Del Core D AFFILIATION NOT ASSIGNED |
| To: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20138K941 | List: |
| References | |
| NUDOCS 9702190253 | |
| Download: ML20138K952 (5) | |
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j 024,03/1997 13:18 8608482020 ORBIT INC PAGE 01 l
i Dr. Shirley Ann Jackson Chairman i
U. S. Nuclear Regulatory Commission l
Waslington, D. C. 20555-0001 l
Donald W. Del Core, Sr.
i 4 DriscollDrive Uncasville, CT. 06382-1808 February 1,1997 FACSIMILE
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Dear Dr. Jackson:
I feel compelled to write this letter to you with the hope of convincing you that the regulatory activities of your agency are dimnal regarding it's oversight of the operation, maintenance, and licensing of the Millstone and Conn. Yankee plants.
' For you to tell Northeast Utilities executives that the Millstone plants " will be judged on what you do, not on what you've done.", is unacceptable to us in the public.
Accountability is exactly the problem! What Northeast Utilities has done is NOT abide by it's FSAR, Design and Licensing Basis, NRC Regulatory Guidelines. It has also ignored Technical Specifications,10CFR20,10CFR50, Millstone & Conn. Yankee procedures, and industry standards.
UNIT # 1 With regard to Unit #1, all of the issues raised by Mr. George Galatis, Attorney Ernest Hadley, and Anthony J. Ross have gone unanswered, buried in the bureaucratic wdderness called the Office ofInvestigations, the NRR, the NRC staff, and ofcourse, the Justice Department. We have grown accustomed to the terms, " Oh Justice has that, " or "OI is stilllooking into that.", or better yet, " the staffis still resiewing that ". All the while, Unit #1 continues to be outside ofit's FSAR, licensing, and the law. The NRC staffhas continued to allow them to conduct recovery operations, and restart schedules.
Day to day activities continue in spite of the overwhelming unresolved issues before your agency.; In addition, recent NRC Inspection Reports ( 50-245/%-06, and 50-245/96-08 )
i indicate no abatement to many of the very issues that placed them on the " Watch List ".
The report suggests rnore enforcement conferences are forthcoming. How can this be?
Many of your staff ( Region 1 managers, NRR, and NRC managers ) remain in place, as do manj Unit #1 managers and supenisors at Millstone, while many who raised safety mncerm are currently unemployed. YOU MUST SUSPEND THE OPERATING LICENSE AT UNIT # 1 UNTIL YOU AND THE COMMISSION GET THEIR ATTENTION, AND/ OR,WE THE PUBLIC SEE " MORE MEAT ON THE SKELETON OF THESE PLANS ", AND SOME ACCOUNTABILITY AT NU, AND THE NRC.
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i UNIT # 2 I
With regard to Unit # 2, two recent NRC Inspection Reports ( 50-336/ 96-06, and 1
50-336/96-08 validate that Unit # 2 is not ready for the recovery phase, or any restart l
plan. Again, NU continues to exhibit many,if not all. of the programmatic problems that got it put on the " Watch List. " Especially disturbing to me are the foBowing issues; Continuing violations ofNRC requirements, Continuing failure to fulfill commitments made to the NRC, Failure to demonstrate that the Corrective Action Program is i
improving, and management recent plans for entering Mode 6, for core-offload, using systems with known discrepancies that were contrary to the carrent operating license. Your staff claims the systems were " operable ", and " no violations of NRC requirements were identified." Based on information available la NRC document GL 91 18 that seems impossible. SOUNDS LIKE SHADES OF THE UNIT # 1/ -
GALATIS DEBOCKLE ALL OVEk AGAIN! DID YOU SAY PUBLIC TRUST????
I contacted Region 1 officials to find out which systems were affected, and what were the known discrepancies in those systems. First I was told the NRC staff no longer had the list of discrepancies and systems. Then I was told to see NU for the list. Then I was told to make a Freedom ofInformation Act request. I was also told that the NRC had no system for the public to audit the NRC inspection activities. I was also toki that the list was very voluminous, and the staff did not audit or verify aU ofit.
ITIS IMPORTANT TO POINT OUT HERE THAT NO LICENSE AMENDMENTS WERE ACCOMPLISHED.
THE OFFICIAL ALSO POINTED OUT THAT THE LICENSEE WAS OUTSIDE CURRENT OPERATINO LICENSE WHILE IN MODE 5. HAS A 10CFR50.54(f) LETTER BEEN SUBMITTED TO THE NRC STAFF ON THE SYSTEMS CURRENTLY IN USE BY MILLSTONE? MILLSTONE II SUBMITTED 45 LERSIN 1995, AND 41 LERSIN 1996. WERE ANY ASSOCIATED WITH MODE 6, OR CORE OFFLOAD? WAS THE LICENSEE USINO 10CFR50.59 PROCESS TO RESOLVE THE DISCREPANCIES WHICH WERE CONTRARY TO THEIR CURRENT LICENSE 7 WAS YOUR STAFF USING DESCRETIONARY ENFORCEMENT AGAIN7 DIDN'T YOU ISSUE A NOTICE TO THE NRC STAFF REGARDING MISUSE OF THE 10CFR50.59 PROCESS, AND DISCRETIONARY ENFOR' CEMENT?
After being turned down for the information on January 22,1997 by the ofBeial, I contacted your of5ce for help, got passed around from office to ofBee, and finally got to tellmy story to one ofyour aides. NO ONE HAS CONTACTED ME YET. HOW WAS THAT7' AN OPEN STRAIGHT FORWARD APPROACH IN DEALING WITH THE PUBLIC. OH YEAH, THE PUBLIC TRUST THING!!!! YOU MUST SUSPEND THE OPERATING LICENSE OF UNIT # 2 UNTIL YOU AND THE COMMISSION GET THEIR ATTENTION, AND WE THE PUDLIC SEE "
MORE MEAT ON THE SKELETON OF THESE PLANS," AND, SOME ACCOUNTABILITY AT NU, AND THE NRC. YOUR OWN STAFF REPORTED THE LICENSEE WAS OUTSIDE THEIR LICENSE, WHAT WILL
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IT TAKE TO SUSPEND THEIR LICENSE, A SERIOUS ACCIDENT 7 NOT j
j MUCH TRUST IS BEING BUILT HERE!!!!!
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i CONN YANKFR l
With regard to Conn. Yankee, It seems that the NRC staff was concerned about j
the conditions at the Conn. Yankee plant around the Apn1,1996 timeframe. The concerns were based on the findings at the Millstone plants, and the possibility that the same i
conditions could exist at CY. Northeast Utilities executives and CY management assured l
the NRC staff, and the public that no such problem existed at CY.
l In early July,1996, the NRC staff conducted an insgcdon ( 50-213/ EA 96-334,337,338,339, and 340) of CY to address the Design and Licensing Basis 3
l discrepancies, and to implement compensatory measures as needed to assure the continued l
operability of components to safe plant operation. Shortly after the inspection started, the NRC discovered several apparent violations ofNRC requirements, including a l
Contaimnent Air Recirculation ( CAR ) fan condition. Operability during a Design Basis Accidst was questioned. Other problems related to the Residual Heat Removal System, l
and the Emergency Core Coolirig Systems were also identified as apparent violations. CY and NU management decided to shut the plant down. Other issues were identified with Nuclear Instrumentation Sptem trip setpoints, and improperly tested containment i
i penetration piping and instrumentation. A total of 5 app: rent violations were assessed, including an enforcement conference. ( See also SpecialInspection Team Report 50-213/96-201, and Integrated Inspection Repon 50-213/96-06 for more )
)
Shortly thereafter, CY and NU management began publicly offering the possibility i
of CY Minwarly closing. This due to the projected costs to meet the license requirements with only 10 years left to recover costs, and the impendmg deregulation of i
electric rates. A financial review was started by the owners / directors of CY.
l During the Labor Day weekend a very serious accident was avened at CY. The near miss involved a loss of water inventory to the Reactor Vessel and Core. It was due to l
lack oflevel
- ctrumentation, numerous faulty leaking nitrogen valves, and a lack of u
l existing procedures, as well as a failure to follow procedures. Only the egnaMag of j
nitrogen pressure prevented the uncovering of fuel, pure luck!
Just recentlyl read, and was appalled at the significant deficiencies identified at CY in the oversight and control oflicensed activities associated with radiological controls, i
work planning, work control, and defueling practices on November 2,1996.
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The NRC Inspection Report ( $0-213/96-12 ) dated December 19,1996, identified eignW=nt problems related to basic RM='nantal radiological worker safety requirements.
It also identified shortcomings in the basic fundamental requirements of heahh physics 1
monitors, and supervision regarding current surveys, actual radiological conditions. and j
the protection of radiation workers.
A lack ofcommunications existed between workers and their supervisors j
regarding the job scope, and heath physics failed to recognue the need to commumcate i;
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with plant management, resulting in adverse shutdown risk conditions. As a resuh personnel were exposed to high concentrations of airbome radioactive material, resuhing l
in a substantial potential for exposures in excess of NRC limits. The levels of contamination around their nose and mouth were very high due to the lack of use of l
protective equipment. Intemal doses due to ingestion were significant.
As a resuh, some very important issues require resolution. Based on the violation i
ofsome very basic rudimentary radiation worker requirements, why wasn't all radiation work terminated at CY until all managers, supervisors, technicians, and workers were l
retrained regarding radiation safety, job scope, survey requirements, reports to managers, etc? If the utility didn't stop the work, why didn't the NRC require the work stoppage, j
and retraining? What does this say about the utility's ability to conduct upcoming decommissioning activities? Is the outflow of CY personnel creating too much of an experience gap? Will radiation workers coming to the sight as temporary workers be at i
i increased risk? Will the public be at increased risk as a result? Shouki a responsible l
contractor be brought in to oversee CY's activities? Should more NRC inspectors be assigned to oversee the activities? WHY WASN'T CY PUT ON THE WATCH LIST THIS PAST JANUARY,1997? IN VIEW OF THE INTENTIONAL l
WRONGDOING. ( Management at CY assuring the NRC and public allwas well j
at the plant) WHY WASN'T CY'S LICENSE REVOKED? WHY HASN'T CY'S i
LICENSE BEEN SUSPENDED FOR ALL THE INCOMPETENCE 7 WAS CY WITHIN IT'S CURRENT LICENSE REQUIREMENTS FOR ENTRY INTO
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MODE 6, OR FOR DEFUEL? WHY HASN'T YOUR STAFF REQUIRED CY TO j
MEET IT'S DESIGN AND LICENSE BASIS? HAS YOUR STAFF ALLOWED CY TO USE THE 10CFR50.59 PROCESS TO GET SYSTEMS WITH11N THE DESIGN AND FSAR? HAS THE FSAR BEEN UPDATED? IS YOUR STAFF i
ALLOWING DISCRETIONARY ENFORCEMENT AT CY? HAS THE NRC STAFF RECEIVED LICENSE AMENDMENTS FROM THE LICENSEE?
ICAVP i
i' The ICAVP process has been changed, twisted, and adapted to fit the current situation at Millstone. It is now unrecognizable as the oversight program that would insure independence as you promised in your August 6.1996 visit to the Waterford area.
i You and your staff have yet to come up with a solution to provide some assurance i
of adequate oversight, such as some sort ofICAVP for the NRC staff overseeing Millstone. Lets face it Dr. Jackson your actions, and those of your staff have not filled
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the public coffers with a feeling of trust and accountability. Based on the 10CFR 2.206 j
Partial Decision in the Galatis case, it appears you, and your staff are wielding a sympathetic gavel in your regulation ofNU, Millstone, and CY. The decision seemed to i
say"NU has been punished enough".
j Northeast Utilities, Millstone, and Conn. Yankee have demonstrated their j
unworthiness to hold a license to operate such a dangerous technology as a nuclear power j
plant. Looking back, the perception of Whistleblowers, public opinion, newspapers, TV reporters, magazines, radio stations, Office of the Inspector General, and, even your own staff ( MIRO ), have concluded a problem exists at these facilities. WE ALL CAN'T BE
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WRONG. IT'S TIME TO GET IT TOGETHER, MAKE THE NECESSARY CHANGES TO THE REST OF YOUR STAFF, FORCE NU TO MAKE CHANGES TO THE REST OF IT'S STAFF, AND MOVE AHEAD. PUBLIC SUPPORT AND TRUST WON'T OCCUR WITHOUT THE ACCOUNABILITY.
Sincere ';
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t nad.T.
ort,5r. "
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e/c: Sen. Joseph I. Liebennan i
Sen. Christopher Dodd Rep. Sam Gejdenson Ernest Hadley, Esq.
Sen. Edith Prague Sen. Melodie Peters Rep. Kevin Ryan Terry Concannon, NAEC Susan P. Luxton, CRC Mark Hollaway, NAEC Maura Casey, The Day Mike McIntre, Courant George Galatis Dave Lockbaum, UCS George Mulley, OlG