ML20216J255
| ML20216J255 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/06/1998 |
| 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 9803230392 | |
| Download: ML20216J255 (2) | |
Text
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UNION OF
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CONCERNED 1
SCIENTISTS January 6,1998 Chauman Shirley A. Jacksm Commissioner Greta J. Dieus CommissionerNils J. Diaz Commissioner Edward McGaffigan, Jr.
3 United States Nuclear Regulatory Comnission
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Dear Chainnan Jackson and Commissimers:
%e Nuclear Regulatory Comnussion is deterwururg when Millstone Unit 3 can be restarted by its licensee, Nonheast Utilities. uc Union ofConcemed Scientists is troubled that this process lacks clearly defined criteria, making it vulnerable to subjectivity. Millstone's history ofpoor segulatory performance is well documented in TRE magazine, in numerous NRC inspection reports, and in a Govemment Ac-nting Office report released in May 1997. The GAO report, requested by Senators Biden and Lieberman, also docunx:nts the NRC's complicity in that history. Prudmt regulatory practice and the Atomic Energy Act dictate that the Commission gauge the facility's material condition and NU's admmistrative programs against tangible, objective criteria before allowing the plant to restart. System assessments mcently performed at Millstone Unit 3 by an indemvinnt contractor and by the NRC staffidentified an unerpect~ny large number of problems. UCS recommends that the NRC require additional system assessments at Millstone Unit 3 before setting a restart date. Altematively, the NRC staff could formally issue the objective standards used to detemune if additional assessments are necessary He NRC issued Northeast Utilities a full power operating license for its Millstone Unit 3 facility on January 31, 1986. nat license was granted in accordance with the Atomic Energy Act of 1954 as amended following the NRC's detemunation that the facility's design and construction satisfied applicable federal regulations and that there was reasonable assurance that the facility's operation would satisfy federal regulations.
NU shut down Millstone Unit 3 on March 30,1996 so as to resolve equipment and pigr.reetic problems. On April 4,1996, the NRC issued a 10 CFR 50.54(f) letter which m:1uired NU to submit information on cormctive actions to its configuration numgenx:nt program prior to restutmg the unit. On August 14,1996, the NRC I
issued a confirmatory order which required NU to implement an Irxlependent Corrective Action Verification Progmm, On Dwiver 10,1997, the NRC imposed a record $2.1 million civil penalty on NU for over five dozerniolations of federal regulations. Some of these siolations involved faults in the original design of Millstone Unit 3 while other violations covered operation of the facility outside fedemi safety regulations. nus, hindsight suggests that the NRC should not have granted NU a full power operatmg license for Millstone Unit 3 since neither of the two criteria from the Atomic Energy Act were satisfied.
l Washington Omce: 1816 P Street NW Suite 310. Washington DC 20036-1405 202432 0000. FAX: 202432 0005 Cambrxige Headquarters: Two Brattle Square. Cambndge MA 02238-9105 617-547-5552. FAX 617-064-9405 Caufornia Ofree: 2397 Shattuck Avenue Suite 203. Berkeley CA 94704-1567 514843-1872. FAX: 510843-3785 9803230392 980311 e
PDR ADOCK 05000423 H
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January 6,1998 Pgc 2 af 2 The NRC stasis cuently cr.h e g wlusher Millstone Unit 3 can be safely nutarted. UCS is concerned that -
objective standards are not being used by the NRC stasin makmg this detennemhan Speedically, the NRC stas has not defined the nnnridiasm for expandmg the scope of the systan assesammes pedbnned by the Independent Cornetive Action Verificenne Projem (ICAVP) contractor and by the NRC stasitself. 'Ihe ICAVP contractor '
exanuned ibur systems and the NRC stafflooked at two syWans includag one already examined by the
- 1CAVP's contrador. Dunng a pubhc mentag on Decanber 17,1997, Mr. Eugene Imbro of the NRC's Special Projects Office stated that the number offindags from the system assessments were i -Wy high. *Ihese l findags comrred 38g NU certdied these systans to be within their deman and hoenseg bases. Apparently, NU's syman nndmeas process lacked robusames.
It has not yet been established that any one of several hundred findmgs yould haw prevented a safe system from functioning properly. But such a findmg should not be requued for the NRC staff to seriously consider l
m.ng the scope of the systan assessments at Millstone Unit 3. Roomt events at Mdistone would seem to
~I mandate that adchtional system assessmmes be conducted Accordmg to both NU and the NRC, Millarane Unit 3 was gg shut down in March 1996 because it was unsafe - it was shut down iw=use the larac number of j
unneolved issues undermined the plant's safety margins. 'Ihat same situation exists today at Millstone Unit 3. No single findmg from the syman assessmets may constitute a clear and present danger to the public. But the sheer volume ofproblems identdied at the facihty 38g nearly two years afinemove corredive arvinns warrants closer exammation. If nethmg else, the la:Ec number of findags unplies that NU's configuration managemmit process, the very progam covand by the NRC stafD 50.54(f) letter of April 4,1996, is less than adequate. Allowmg the facdity to restart with an irW* configuration managemmt program would be inappropnate.
UCS i-..w.ds that the NRC staffiequire the ICAVP contrador to assess at least two additional systems and that the NRC staff assess at least one additional system. As an attemative, the NRC staff should issue the objective standards it is using to deemune that furtier inquines were not required. Anythmg has can only 'enrn the NRC well deserved cnticism that it is nardiaing the laisser faire regulatory practices that contributed to the Millstone tneedy.
Sincerely, j
QAkkh "P:
i
' David A. I ~ kh-m Nuclear Safety r=p=
oc:
SenatorJoseph Bulm SenatorJosephIA.. -.
Mr. L. Joseph Callan Dr.WilliamTravers