ML20202E646
| ML20202E646 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/03/1997 |
| From: | Katz D CITIZENS AWARENESS NETWORK |
| To: | Collins S NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20202E614 | List: |
| References | |
| CON-#497-18613 2.206, 50-271-97-201, NUDOCS 9712080102 | |
| Download: ML20202E646 (2) | |
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CITJZENS AWARENEst NETWORK From: Debbia Katz 1.413.339.4374 11/3/97 13 07:24 Page 2 of 3 Aant;hy the Aw:rrt Winnin0 Cheyenne Ritwara e.
I MA: Box a3 Shelburne Polls, MA c187o/ so Davenport Rd Roese, MA P/F 418 849 5741/8745 f*Ta Ad Olcl furar,lke innd, Wrirldem,("T fudtA P/p Aen.. tat.atti V1;C/Olox 544 Putney,VT oss44 F/F;8o2 3e7 2644/2447 NH: 7 Moodew Lane, ExeSof, NH C3813 P/F 6o8 772-3439 NY:13 Chories St. NYC 190141:212 475 3974 Cnmu Awasas Nm-November 3,1997 Samuel Collino, Director Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washiristun, DC 20555 Docket No. 50 271
Dear Mr. Colllins,
We have received NRC's partial response to CAN's December 6,1996 2.206 petition for enforcement concerning Vermont Yankee. The Partial Director's Decision does not address many of the concems raised in our petition. In this petition under conclusions, we requested.
- 1. Since the number of long standing VY deficier.cies acknowledged in its LERs-1Q jj ytaa! raise serious questions about the adequacy of VT's safety analyses, VY and the NRC should immediately review all of safety analyses conducted since startup of VY with particular ottontion to their role in providing a comploto and up to dato FSAR.
Subsequent LERs have uncovered long standing unreviewed cr incompletely revie.ved design basis pivbivm> urrJ lect of compliance with the FSAR. Since the subritivvion of the December C,1996 petition, CAN and Unkx1 of Concerned Scientists submitted allegations to the NRC on subsequent VY LERs and inspection reports with questionable adequacy and availability of desgn basis yttormation, for their lack of thoroughness m addressing adverse conditions, lack of " defense in depth", and be!cw incustry standard analysis. VY routinely minimizes the problems with their design basis problems, FSAR deficiencies, and analyses as having little importance because the probability of an accident is small and other safety backup systems will compensate for the shortcomings of the safety related system under review, notwithstanding there are no certifications that the other safety rotated backup systems are operable. (CT Yankee operated without adequate backup systems for 28 years). Similar justifications and inadequate root cause analyses were experienced at Millstone Units and CT Yankee where the licensee tried to characterize the deficient FSAR as "merely paperwork".
VY ca.'!*d its lack of compliance at the last Vermont State Nuclear Panel meeting in Septembct,1997 no "popor work". Yot Rogion i NRC ctaff havo reforrod to the FSAR oo a
'living document" without which the health and safety of the workers and the pubEc can not be guarantood.
THE EXPERIMENTIS OVER Web site: www.nukebusters.org E Moll: coneshaysnet.com l
l 9712080102 971128 l
PDR ADOCK 03000271
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~e At that exit meeting, concems were raised by NRC staff as a result of the NRC design l
Inspection conducted at W (Inspection Report 97 201 dated August 27,1997). NRC staff stated that they 'did not want any more smoke and mirrors bm VT Yankee
- in addition the l
team ' concluded that it was unlikely ( W personnel) would have uncovered some of the Issues identified in this report." The inspection found serious design errors, somw of which had never been adequately addressed by the licensee or the NRC stafn The licensee could continue operation of W only by reducing. power. CAN believes that inspection Report 97 201 confirms and aggravates these concems. Therefore we continue to request that NRC require-2.
W correct serious deficiencies in its desigr' change control process. It thould immediately commence a review of its design control process (including a historical review of its design control documentation to vertfy the accuracy of this document when compared with the actual, physical configuration of W).
- 3. W perform a global ' extent of condition" evaluation to determine how many modifications have been inadequately tested since startup. In addition eny and all untested systems or systems that have not been tested for 10 years at W should be teated immediatoty.
- 4. W Init'.te a training program to review and emphastre the underlying safety purposes of the Technica! bpecifications, the FSAR, design bases, and NRC regulations in relation to routine operation, emergency preparedness, and implementation of NRC's ' defense in depth" philosophy.
- 5. W staff train workers on the proper use of ' single failure" criterion.
In addition, CAN is concemed with systemic mismanagement et W. We request that:
- 1. an NRC team in conjunction with an outside contractor conduct a review of a second system, the ventilation. system.
- 2. NRC with an outside contractor and W conduct a review of all back up safety systems to assu' '5e adequacy of these systems in order to protect worker and public haalth and safet
- 3. Giver lack of thorough.ess by the fican,ee and significant flaws in the FSAR and design asis cvaluatlan, Can questions Region I staffs competence to effectively overses reactors under its authortty. We therefore request that the archive of NRC's oversight failures at W be added to the inspector General's investigation of complichy and systematic failure to enforce NRC regulations by NRC sta3 in Region I and Project Directorstes..
The Director's partial Decislor, addresses none of these conoems, rather the decision limits conoems primarity to the specific LERs submitted with the petition. Our conoems go beyond the speciflo LERs submitted and include W's FSAR, the Technical Spoolfleetion, design control, and rettsining. We therefore again request that the Director respond to our 2.206 Petition for Enforcement in the particulars stated above.
Sincerely, i
Deborah Katz l
Ni&weitiam Awswu.wak l
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