ML20216J229
| ML20216J229 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/20/1998 |
| From: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20216J211 | List: |
| References | |
| NUDOCS 9803230385 | |
| Download: ML20216J229 (4) | |
Text
.e
.e
.h
/
UNION OF CONCERNED SCIENTISTS January 20,1998 Chairm.m Shirley A. Jackson Commissioner Greta J. Dieus ConunissionerNils J. Diaz Commissioner Edward McGafligan, Jr.
Unitod States Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Chairman Jackson arxl Commissioners:
i We expressed our concems about the process being used by tie NRC staffin determining when it is safe for Millstone Unit 3 to restart in our letter dated January 6,1998. While we await >uur response to that letter, further events have deepened our c.mccrns. It appears to us that the process being used by the NRC staff will provide a restart recommendation wherever Northcast Utilities seeks it, irregardless of tie fmdings fnxn the independent i
corrvctive a: tion verification program (ICAVP) and NRC inspections. "Ihe purpose of this letter is to identify a bias we feel exists in the NRC staffs process and request that you consider that bias in your restart deliberations.
By letter dated January 6,1997, we asked Mr, Hubert J. Miller several questions about reactor safety margms at Millstone, Salem, arx! Maine Yankee. Mr. Samuel J. Collins responded on Mr. Miller's behalfin a letter dated February 27,1997. we had asked. "If these plants are not safe enough to operate today, does the NRC think that these plants were operatmg safely in the days and weeks prior to their being shut downT' Mr. Collins' replied:
i i
"Although the causes of the extended shutdowns for each of the Millstone, Salem, and Mame Yankee units existed before the shutdown of the facilitics, the NRC considers that the plants wuc upemting j
safely before they were shut down because of the protection afforded by the defense-in-depth philosophy.
Stated othenvise, although there are safety equipment deficiencies at cach of these fsteilities, the conservatism provided b>".he multiple levels of design and operating requirements masonably assured that there was no undue risk to public health and safety and the NRC did not find it necessary to ruluire the shutdown of the plants to protect public heakh and safety. However, the resulting reductions of the margia of safety led the stafTto conclude that correction of the problems is called for before restart of the plants."
'One could logically deduce from Mr. Collins' statenent that the NRC staff fwls as long as NU did not create any additional safety equipment problems since March 1996, then the plant that was safe enough to operate then must be saf; enough to restart now with "no undue risk to public heahh and safety." This is the bias we observe in the Wat..agton Oidce: 1616 P Street NW Suite 310. WasNogton DC 20036-1495 202-3324900. FAX: 202-3324906 Camtmdp headquarters: Two Brattle Squara Cambndge MA 02238-9105 617-547-5552. FAX; 617-8644405 Califome Oftce: 2397 Shattuck Avenue Suite 203. Berkeley CA 94704-1567 510 843-1872. FAX: 510-843-3785 900323O h % 3 0
t
.e i s
.7-sfa;g.
7 January 20,1998 Page 2 of2 NRC staffs tluniang - since they viewed Millstone Unit 3's operatum as safe before March 1996, how couki they possibly consuler its restart unsafe now?
Mr. Colhns's response uxbcated that the NRC staff consulenxi it r- - -- y for the problems at these plants to be cormeted before restart. Yet that simply is not happcsung at Millstone Unit 3. In dealms with nearly 150 findags per each of the four (4) safay systems reviewed duririg the ICAVP, the NRC staff, as expressed by Mr. Eugene Imbro in last month's public meetag in Waterford, has adopted the position that only the discovery of" safety sigsficant" problems wammt additional ia=~*'== Beanng in mind that none of the safety equipment deficiences wiuch prompted NU to close the plant are consulered by the NRC staff to prusent an undue risk to
. public health and safety, what kind of fmdmg would be deemed " safety sigm6 cant" by the staffnow?
We think this is a fair questaan for us to ask and the NRC staff to answer. In SECY-97-283 dated December 4, 1997, Mr. L. Joseph Callan infonned you of the status of the Millstone recovery effort. That status report stated the following: "On March 30,1996, the licensee shut down Mdistone Unit 3 aAer finding that contamment i
isolation valves for the auxiliary feedwater turbitedriven pump were inoperable because the valves did not meet NRC requirements "In other words, this safety system did not meet its licmsing/desen bases and was unable to perform its intended functen. 'the NRC's Office of the Inspector General issued an event evaluatum dated January 13,1998, "Public's Concerns with Millstone Independent Corrective Action Verification Program (ICAVP)," which reported that the NRC's = t-w criterion for a Level 1, or most significant, ICAVP finding involved a system not meeting its licensing / design bases and being unable toperform its intended 6-+ma Based on this criterion, it would seem that the specific problem wluch forced Millstone Unit 3 to shut down, if.
discovered now, would be classified as a Level 1 findmg. Yet, that F-e = posed "no.utulue risk to public heakh and safety" and would presumably not now be considered by the NRC staff to be " safety significant " So, what kind of finding would be deemed " safety significant" by the NRC staff?
We agree that many of the ICAVP findmgs have minimal safety significance using anyone's defuntion ofthe
. term. However, virtually every one of the fuxhngs represents a violation ofNU's quahtv assurance obligations under 10 CFR 50 Appendix B. A small handful of such violations could be tolerated, but nearly 150 problems.
per safety system, after a supposedly extensive readmess effort by N U, is tmly alanmng Dous the math at that failure rate, it represents 12,900 problems affecting the remanung 86 safety sptems which have not been irulependently exi ro..cd.
'Ihe ICAVP's findings clearly dme.haic that Millstone Unit 3 still has a lot ofproblems. The NRC staffwouki bejustified in iceu.r..c..sig the plant's restart ifit could produce an evaluaten showing that all:==ry safety margms were satisfied even with potentially 13,000 problems affecting all the safety systems. Given that the plant is designed, built, and maintamed to a single failure entenon and not a 13,000 mmor failure enterion, it seems that such an evaluation could not be successfully Muni,W. Consequently, the ICAVP's fuxhngs seem to dictate that further probksn correction is warranted at Millstone Unit 3 before it can be restarted Sincerely, h
hWin0 1
David A. !
==
, Nuclear Safety Engmeer
. a
i yr.~
ACTION 1
EDO Principal Correspondence Control l
FROM:
DUE: 01/26/98 EDO CONTROL: G980012 DOC DT: 01/06/98 i
FINAL REPLY:
D:vid.A. Lochbaum Uni n of Concerned Scientist TO:
Commission FOR SIGNATU DR CRC NO: 98-0009 Dd, 09.1L DESCt s/ &_f_ _ _ _ _ %ww ROUTING:
MI:'LSTON NIT 3 Callan Thadani Thompson Norry Blaha Burns DATE: 01/14/98 Miller, RI Lieberman, OE ASSIGNED TO:
CONTACT:
_ Collins SPECIAL INSTRUCTIONS OR REMARKS:
NRR ACTION: SPO: Travers NRR RECEIVED: January 14, 1998 NRR ROUTING: Collins /Miraglia S*** ""'* "
DUE T011 R DIRECTOR'S OFFIC Travers Roe j
l NRR Mailroom BY f
~
~n; y
j
(
l l
l i
I
)
m
,e OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER:
CRC-98-0009 LOGGING DATE: Jan-9 98' ACTION ~ OFFICE:
EDO' AUTHOR:
DAVID LOCHBAUM AFFILIATION:
DISTRICT OF COLUMBIA ADDRESSEE:
CHAIRMAN JACKSON AND COMMISSIONERS
' LETTER DATE:
Jan 6 98~
FILE CODE: IDR 5 MILLSTONE
SUBJECT:
MILLSTONE UNIT 3
- ACTION:-
Signature of Chairman DISTRIBUTION:
CHAIRMAN,.COMRS SPECIAL HANDLING: SECY TO ACK j
CONSTITUENT:
~ NOTES:
COMMISSION CORRESPONDENCE DATE DUE:
Jan 28 98 i
SIGNATURE
- DATE SIGNED:
AFFILIATION:
e i1 l
l l
1 l
EDO -- G980012