ML20216H725
| ML20216H725 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/07/1998 |
| From: | Luxton S AFFILIATION NOT ASSIGNED |
| To: | Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20216H717 | List: |
| References | |
| NUDOCS 9803230154 | |
| Download: ML20216H725 (4) | |
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Citizens Regulatory Commission 1
Neighbors Asking Questions 7
180 Great Neck Road Waterford, Connecticut. 06385 l
Dr. Shirley Ann Jackson, Chairman U. S. Nuclear Regulatory Commission
[
Washington, D. C. 20555-0001 January 7,1998 FACSIMLE p
Dear Dr. Jackson:
l The Cdnnecticut citizen groups signing this letter have become deeply L
concerned with the handling of events at Millstone Unit # 3, and with what l
appears to be a " fast track " towards a favorable vote on restart at your upcoming. March 13,1998 meeting. In light of the matters described below, we respectfully request that the approval process be slowed, and the vote on the restart be postponed to a more realistic date, commensurate with their progress.
A review of the transcript of the Millstone Progress Update meeting before the Commission on December 12th,1997 reveals some disturbing information.
. In particular, the information dealing with the Configuration Management Progrdn ( CMP ) at Millstone Unit.# 3, and the Independent Corrective Action' Verification Program (ICAVP ).
The tQo areas of primary concern are; the Independent Corrective Action Verification Program ( ICAVP ) performed by Sargent & Lundy ( S&L ), and the sin'gle system, " Out of Scope " independent review performed by the Nucle &r Regulatory Commission ( NRC ) staff.-
- As a 3"' party oversight contractor, S & L conducted a review of four
" In-shope " Safety / Risk significant systems, selected by the NRC staff,'
and th'e Connecticut Nuclear Energy Advisory Council ( NEAC ).' The four systems were selected from a total of eighty-eight such systems at Millstone Unit # 3. Oversight of the four system review was conducted by the NRC l
statT, and select NEAC council members. The NRC conducted an 9803230154 980311 i
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independent review of one the four " In-scope " systems, to validate the review by S & L was adequate.
The 3'd' party review by S & L was started in late May,1997. Prior to the S &
L review, NU engineers conducted a very exhaustive period of review, and discovety. Their review began in the Fall of 1996, and ended just prior to the start of the S & L,3" party review. The NU review, and discovery period was intended to verify the adequacy of the Millstone Unit # 3, CMP. The CMP is necessary to ensure that Millstone Unit # 3 is operated, and maintai'ned in accordance with it's Final Safety Analysis Report ( FSAR ), the Updated Final Safety Analysis Report ( UFSAR ), it's license, and NRC regulations.
The review by S & L has initiated an enormous quantity of Deficiency g
Reports.( DR' s ), currently numbering approximately 712, the majority of which ( 605 ), or 85% have been validated by an S & L process.
Approximately one third ( 33% ) are safety related deficiencies. The process has been approved by your staff. A public report by S & L, dated December 2"d,1997, identified 729 DR's, approximately 500 of them were validated.
The report concluded some thirteen discrepancy categories. Six categories contained the most DR's, 670 of the 729 initiated, with " calculations "
having 275, of the 670 identified by the six categories.
The sheer numbers alone, provided by S & L, bring into question the validity of the Millstone Unit # 3 CMP. Additionally,. it brings into question the ability:of the Line Management, and Nuclear Oversight Department, regarding their review of the adequacy of the configuration program. The S &L Report certainly substantiates the need to increase the scope of the ICAVP. We saw no evidence of that suggestion, to the Commission, by your stafE at the update meeting.
The original definition of the purpose of the ICAVP, as provided by the NRC Special Projects Office, bears no resemblance to what has actually occurred.
S & L', according to the NRC, was supposed to act as an evaluator; grading the effectiveness of the NU Configuration Management Program. Instead, S
& L has operated in much the same_ fashion as other NU contract personnE
'distuverhrg problems, and working with NU to provide recommended IIEei.
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Tlitrinrcriticil drstinction iiiTvhat was proposed, and what has liappened "
That S & L finds it necessary to augment NU's technical staff, instead of 1
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-4 sticking to their original role of conftguration management evaluator, speaks volumes as to the failure of the NU Configuration Managemem Program.
At a public meeting in September,1997, the NRC staff conducting the " out of scope " ' system review, provided a rather telling report to NU officials regarding their findings. Those significant findings of Level 1," show stopper 1 ype " issues, have us concerned. Particularly bothersome, is the fact t
@ that little, if any, apparent action has been taken by t such a significant issue, was apparent at the Commission update meeting. We are astounded that the staff, was waiting for more information, by the Licensee, at an upcoming enforcement conference. We see the need again to increase the scope of the ICAVP, based solely on the minimal information we currently possess, from that. public meeting.
Based on the amount of time, and effon, NU spent on CMP discovery, prior to the itart of the ICAVP, we see no credible evidence to conclude that Millstone Unit # 3, has resolved the programmatic issue ofinadequate configuration management. We further maintain that they cannot adequately demonstrate the ability to comply with the requirements of 10 CFR 50.54
( f), w!ithout an adequate CMP. Likewise, they cannot meet the needs of the Restart Assessment Plan.
In closing Dr. Jackson, we have reviewed video tapes ofyour trip to Millstone Station last year. Again, we see no evidence that NU has satisfied even the most basic requirements you established in those two meetings.
We se'e no need to even begin to consider, the restart of Millstone Unit # 3.
Likewise, we believe that Unit # 3 is not in a position to move out of the current Mode 5 condition.
We sincerely hope that the internal reviews, and self-assessments, conducted by the:NRC staff, regarding your agency's past performance, have provided them the tools necessary to prevent a re-occurrence of the Millstone debacle.
Unfortunately, the changes, if any, are not readily apparent to us. We hope your oversight, and questioning, of this unacceptable situation will get your staff s attention. In the unlikely event of a Commission vote on a ' Unit # 3 start-up in March, we would expect a negative vote by you.
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LOClW Atsf
>v Susan Perry Luxton, for the Coalition members; Citizens Regulatory Commission Citizens Awareness Network p
Connecticut Citizens Action Group Peoples Action for Clean Energy Grassroots,Inc.
Don't Waste Connecticut ConnPIRG Concerned Citizcas of Montville Toxicsl Action Center Vecinos Unidos f
c/c: Mh. George Mulley, OIG Mr. Dave Lochbaum,- UCS Sen. Christopher Dodd Sen.l Joseph Lieberman Sen. Joseph Biden Rep. Sam Gejdenson Commissioner Greta J. Diaz L
Commissioner Nils J. Dicus l-Commissioner Edward McGaffigan, Jr.
l Committee on Commerce (llouse )
l Committee on Energy and Environment ( Senate )
Connecticut Office of Consumer Counsel -
Cdanecticut Nuclear Energy Advisoty Council ( NEAC )
l l
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