ML20217B909
| ML20217B909 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/12/1997 |
| From: | Miraglia F NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217B886 | List: |
| References | |
| 2.206, DD-97-21, NUDOCS 9709300391 | |
| Download: ML20217B909 (4) | |
Text
__ _ _ _ _ _ _ _ _
3 7590-01-P UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHEAST UTILITIES MILLSTONE NUCLEAR POWER STATION. UNITS 1. 2. AND 3 DOCKET NOS. 50-245. 50-336. AND 50-423 HADDAM NECK PLANT DOCKET NO. 50-213 ISSUANCE OF PARTIAL DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that the Director, Office of Nuclear Reactor Regulation, has issued a Partial Director's Decision with regard to a Petition dated November 25, 1996, as amended on December 23, 1996, filed by Ms. Deborah Katz and Mr. Paul Gunter on behalf of the Citizens Awareness Network (CAN) and the Nuclear Information and Resource Service (NIRS), hereafter referred to as
" Petitioners." The Petition pertains to the Millstone Nuclear Power Station, Units 1, 2, and 3, and the Haddam Neck Plant.
The Petitioners requested that the NRC: (1) immediately suspend or f
revoke Northeast Utilities' (NU's or Licensee's) licenses to operate its nuclear facilities in Connecticut; (2) investigate possible Licensee material misrepresentations to the NRC; (3) continue the shutdown of the Licensee's facilities until the Department of Justice complctes its investigation and the results are reviewed by the NRC; (4) continue the shutdown until the NRC evaluates and approves the Licensee's remedial actions; (5) continue listing the Licensee's facilities on the NRC's " Watch List" should any facility resume operation; (6) bar any predecommissioning or decommissioning activity at any of the Licensee's nuclear facilities in Connecticut until the Licensee and the NRC take certain identified steps to assure that such activities can be safely conducted; (7) initiate an investigation into how the NRC allowed the asserted 9709300391 PDR 970912 C ADOCK 05000245 PDR ,
c illegal situation at the Licensee's nuclear facilities in Connecticut to exist and-continue for more than a: decade; and (8) immediately investigate of the' .)
r need for enforcement action for alleged violation of 10 CFR Part 50, Appendix B, with respect to nitrogen calculations.
The bases for the assertions are Licensee and NRC-inspection findings l and Licensee documents referred to in the Petition and a VHS videotape,. I Exhibit A, which accompanied the Petition. The videotape records an August 29, 1996, Citizens Regulatory Commission televised interview of a former Millstone Station employee expressing his views on Licensee management.
-Areas identified-in the Petition include inadequate surveillance testing, operation outside the design basis, inadequate radiological controls, failed corrective action processes,;and degraded material condition. The Petition asserts that this information demonstrates that there are inadequate quality assurance programs at the Licensee's nuclear facilities in Connecticut, that the Licensee has made material false statements regarding its Millstone units, and that safe decommissioning of the Haddam Neck facility is not possible because of the deficiencies in the design and licensing bases of.the facility.
The Director of the Office of Nuclear Reactor Regulation has partially granted the Petition. The reasons for this partial grant are explained in the l " Partial. Director's Decision- Pursuant to 10 CFR 2.206" (DD-97-21 ),the complete text of which follows this notice and is available for public inspection at the Commission's Public Document Room, the Gelman Building, 2120 LE Street, NW., Washington, DC, at the local public document rooms located at the Learning Resources Center, Three Rivers Community-Technical College, New London Turnpike, Norwich, Connecticut, and at the temporary local public document room located at the Waterford Library, ATTN: Vince Juliano, 49 Rope
i Ferry Road, Waterford, Connecticut, for Millstone Units 1, 2, and 3; and at the Russell Library, 123 Broad Street, Middletown, Connecticut, for the Haddam Neck Plant.
A copy of the Partial Director's Decision will be filed with the Secretary of the Comission for the Comission's review in accordance with 10 CFR 2.206(c) of the Comission's regulations. As provided for by this regulation, the Decision will constitute the final action of the Comission (for Requests 1, 2, 5, 6, and 8) 25 days after the date of issuance unless the Commission, on its own motion, institutes a review of the Decision in that l
time.
Dated at Rockville, Maryland, this 12th day of September
- FOR THE NUCLEAR REGULATORY COMMISSION Frank MMiraN Jr., Daputy Director Office of Nuclear Reactor Regulation 6
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EDO CONTROL: G960919 DOC DT: 11/25/96 FINAL REPLY:
Deborch Booth Katz Citiz ns Awareness Network .
TO:
Emile Julian, DSB FOR SIGNATURE OF : ** GRN **
CRC NO: 96-1189 DESC ROUTING:
2.206 PETITION ON CONNECTICUT YANKEE, MILLSTONE Taylor UNITS 1, 2, AND 3 M11hoan l
Thompson Blaha Miraglia, NRR NNiller, RI DATE: 12/06/96 Lieberman, OE ASSIGNED TO: CONTACT:
OGC Cyr SPECIAL INSTRUCTIONS OR REMARKS:
ACTION 4tRR RECEIVED: DECEMBER 16, 1996 KRR ACTION: GEGRAESS, DEE TO NRR D:RICICR'S OFFICE (RRROUTING: MIRAGLIA .
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, . N uclear Information and Resource S enice 142416th Sucet, NW, Washmgton, D C. 20036 202 328-0002 .
November 25,1996 ,1' V
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Mr. James Taylor, N'
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Executive Director ofOperations 1).S. Nuclear Regulatory Commission Washington, DC 20555 L
PETITION FOR ENFORCEMENT, PURSUANT TO 10 CFR { 2.206, TO REVOKE NORTiiEAST UTILITIES' OPERATING LICENSES FOR Tile CONNECTICUT NUCLEAR POWER STATIONS DUE TO CllRONIC, SYSTEMIC MISMANAGEMENT RES ULTING IN SIGNIFICANT VIOLATIONS OF NRC SAFETY REGULATIONS, AND TO INVESTIGATE '
TIIE NRC STAFF'S RESPONSIBILITY FOR NOT DEALING WITII Tills PROBLEM FOR OVER A DECADE L _
SUMMARY
RATIONALE FOR REOUESTED ACTIONS l
In the interest of public health and safety, Citizens Awareness Network (CAN) and Nuclear Information and Resource Service (NIRS), petition the United States Nuclear Regulatory Commission (NRC), pursuant to 10 CFR { 2.206, to suspend or revoke Northeast Utilities' (NU) licenses to operat2 the Millstone Units 1,2,3, and Connectict:t Yan'.ee nuclear power stations due to over a decade of chronic, systemic mismanagement and violations of NRC regulations that have jeopardized occupational and public health and safety.'
'NU conducted an "in house" audit of the causes of the problems detailed in this petition. See Northeast Utilities System, Event Response Team Report (ACR 7007) (NRC Acc. No.
9603150021) (February 22, 1996). Until NU issued the report, the NRC took no definitive action to resolve the problems detailed thuein, despite the blatant safety violations openly taking place on a daily basis for over 10 years!
0 1
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e i
}* CAN's and NIRS's 10 CIR l 2 206 l't tton Is y
\ ,
Rewie NU's Licenses for tas Connecticut Reactors andinssstogare Neglogent NRC5sqlf Ossrsight.
IL REOUESTED ENFORCEMENT ACTIONS A. Petitioners request that the NRC take the following actions to enforce its regulations against Northeast Utilities:
h Petitioners request that the NRC immediately suspend or revoke
,g Northeast Utilities' license to operate the Connecticut Yor.kee atid y Millstone nuclear reactors due to chronic, negligent management of the reactors which, for over a decade, has endangered and b)qi l e .
continues to endanger occupational and public health r.nd safety V and the environment due to resultant and cumulative major safety l problems and violations of NRCregulations.
e 2; Petitioners request that the NRCinvestigate the possibility that NU made material misrepresentations to the NRC concerning engineering calculations and other information or actions relied upon to assure the adequacy of safety systems at Connecticut O4 'h Yankee and Millstone reactors, said possible material m.' shtements due to a lack of rigor and thoroughness, or as a i
result ofprovidii.3 ntentionally misleadinginformation.
- i'
~
In the event that an investigation determines that Northeast Utilities deliberately provided insufficient and/or false or misleading infonnation to the NRC, petitioners request that the NRC revoke Northeast Utilities' operating licenses for the Connecticut Yankee and Millstone Unit 1,2 and 3 reactors. If the NRC chooses not to revoke the Northeast IJtilities' licenses, the Petitioners specifically request that the reactors remain offline until a United States s
DQe artment of ustice independent inves,tigationis_ s complete and
$ the NRC reviews conclusionLand . recommendations contained O- theWf6ryt'enifal}onsequences to the licensec and its agents under NR~Cregulations?
5'C i
s.p ;-
8 The Department of Justice report will likely produce information essential to the NRC's evaluation of NU's management problems. Such information should have a direct efTect upon any NRC decision concemingNU's future operation of nuclearreactors in Connecticut.
CAN's nedNin5's 10 CfR l 2 206 P: tion Is 3 9q newar NU's IJtenses pr its Connectitwl nract:ts
, , andinnsrigest Nrghgent NRCSs40wrsight.
- 4. In the event that the NRC chooses not to revoke Northeast Utilities' license to operate Connecticut Yankee and the Millstone Unit 1,2, and 3 reactors and allows the reactors to retum to d# operation, petitioners request that the reactors remain on the NRC yY g watch list" to oversee reactor operations until such time as NU gyd management demons: rates to the NRC's satisfaction that:
- a. NU is able to fulfillNRC regulatory requirements;
- b. NU has met all prior commitments conceming the repair, modification, maintenance, and documentation of the nuclear power stations; k
/# j c. NU has retrained all staff in the applicatiois and
\
xy/
l interpretation of NRC's regulations; and
~
hq) ~NU has removed from any positions of responsibility for g' operation and/or management of the reactors any and all
. j persons whom the Department of Justice, NRC, or other
- t. ,
govemment investigators and/or civil or criminal yaf.f prosecutions find to have made material misrepresentations C '
e .i.o
. to the NRCduring the past decade of mismana8ement.
- 5. The Petitioners request that, at a minimum, the NRC keep Connecticut Yankee and the Millstone Units 1,2, and 3 nuclear reactors offline until the NU's chronic mismanagement has been analyzed, remedial management programs put into effect, and the NRC has evaluated and approved the effectiveness of the h licensee's actions. At a minimum,this should entail:
eo a. A thorough analysis of root causes for deficiencies in NU's igt FSARs,. documentation for licensing and design basis, safety analyses, engineering, quality assurance, ALARA programs, and other necessary or required documentation;
.b. screation of kte, accurh updated FSAR-mere y?" reform" is imp 6s i when the basic document is h inadequate and inaccurate;
_. ___d
,e '
e
- CAN's nedNIRS's 10 CfM l 2206 Pr: tion ea4
- newer NU's thwn. sos for its Connecticut React:rs
,. end Imstigest Neghgent NRC Soo)J Oven tsht.
- c. Re-evaluation of any of NU's activities initiated under (or which NU should have initiated under) 10 CFR { 50.59 in
, i order to confirm the validity of such activities, particularly to P determine the extent to which the updated FSAR does not match "as built" reactor configurations. This requires more than a mere paper audit, and necessitates a component by-component and system by system check of the actual physical plant against the existing documentation, and the creation of correct documentation where it is lacking and/or inadequate; ,
Q -
f I nstitution
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N y/.f./ and documentation of an effective ALARA i' gview for all operational and non operational activities N'[k '@\ ~
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.ded\r> y to radiation; 5 gWhich expose or potentially expose workers and/or the
_ public
'/ s r1 N Thorough documentation of the root causes ofNU's chronic W// @$
j and systemic mismanagement-including docum
" /y" M (f7/' S)h the NRC Region I inspection program's staff and management failures over the past decade to detect and deal with this problem; f
- f. That NU demonstrates, over a substantial period of time to the satisfaction of the NRC, NU's commitment to respect NRCregulatory requirements and consistently put them into pmetice;
- g. NU retrains all personnel involved in day to-day operations so that they are thoroughly conversant with NRC regulations;
- h. Updating and documentation of Plant Design Changes Requests to 4y include allchanges to the reactor's design,and that these design changes g %p are verified by the NRC staff, with close-outs of PDCRs receiving the o highest priority;
CAN's andNIRS's 10 CfM i 2.206 Pr: tion a2 e e. Renar NU's licenses for in Connectinnt Re: curs $
, , andbowstigent Nrghgent NRCSnelf Owrsight.
B.
Petitioners request that, in the event that NU decides to shut down any or all of the nuclear power reactors at issue herein with the intent to commence the decommissioning process, the NRC oues not permit any decommissioning or pre-decommissioning activity to take place until such 1 timeas:
o.
Q l All of the documentation mentioned above is available to the NRC
- h. and on-site at the reactors; A-g / 2. All personnel involved in the decommissioning process have been (r retrained (or trained)in the use and interpretation of the applicable NRC regulations contained in Title 10 of the Code of Federal l , Regulations; 3 The NRC appropriately evaluates, replaces personnel, and
.f f restructures the NRC Region I inspection program, its management and the supervising NRC directorate to eliminate the regulatory anarchy that plagued the Connecticut nuclear reactors during the past ten years; e NRC makes certain that NU does not employ any persons in
% management or operations who made materialmisrepresentations to O the NRC about the status of operations, repairs, modifications, or maintenance of NU's Connecticut reactors, hN Petitioners request that the NRC commences an investigation into how it allowed the illegal situation at NU's Connecticut reactors to exist and
/,),7 g/Commission orders its staff (directors of the responsible dir p/
(' managers, Region 1 management and staff) to answer the following questions, and hold these persons accountable for their answers and actions regarding the past 10 years at NU's Connecticut nuclear power reactors:
r '
- l. What documents did Region I inspectors, their supervisors, and NRCdirectorate oversight review during ten years of NU's out of-compliance operation?
- CAN's and N S's 10 CfR l 2 206 Moton Is
- . f
, Reunbr Mtrs Llewnses)6r nos Ctanectinor Meectzrs
, and knenngest Neghgent NRC5nnff Owrsight.
@ If NU provided doctunents that somehow deceived the Region !
inspectors, how does the information in these documents relate to the actual everyday workings and activities conducted during the otherwise undocumented decade of operations at the Millstones and Connecticut Yankee?
- 03. How did Region I inspectors, their supervisors, and NRC directorate oversight find that NU was conducting operations in a way that keeps worker and public exposures to radiation As law As Reasonably Achievable (ALARA) when NU was not adequately documenting either its licensing bases or the basis of reactor operations?
t 4. Knowing, as Region I inspectors must have known, of excessive workerexposures- for example,due to a long standing problem with leaking pipes as documented by an NU worker in the video tape provided with this petition Exhibit 'A'-how did the Region I inspectors certify that operations at the ' Millstones and Connecticut Yankee were being conducted ALARA7 'How did their -
supervisors, and those in the NRC directorate,~~inake the same certifications?
Sh During the undocumented decade, how did Region I inspectors, their supervisors, and NRC directorate oversight manage to track NU's activities at the Millstones and Connecticut Yankee under 10 CFR { 50.597
- 6. To what extents have NRC Region I inspectors, their supervisors, and NRC directorate oversight allowed the same type of problems to develop at other nuclear power reactors in New England (i.e.,
Maine Yankee, Pilgrim, Seabrook, Vermont Yankee, and Yankee Rowe)?
- 7. Is there any connection between licensees employing Yankee
} Atomic Electric Company's consulting and engineering services and the existence ofserious problems with documentation and lack 0 ofcomP liance withlicensing and design bases at any New England area nuclear power stations or those in other parts of the country?
+'
, CAN's andNIRS's to CfM $ 2 206 Prxtion a2 y e'
Renar Ntrs Ustnusfor ses Connecticut Renet:rs
, nedinnstrgest Negitgent NRC Stof Onesight.
EL RATIONAIER FOR REOUEhTgnACTIONS For the past decade, NU mismanagement of the Millstone and Connecticut Yankee nuclear power stations has compromised the health and safety of workers and the public by subjecting them to increased risks of radiation exposure and the uncertainties of actual exposures on a daily basis, as well as subjecting them to an increased risk of death and illness during and following a major nuclear accident.
During that period of time, NU has operated the Connecticut nuclear power stations in flagrant disregard of fundamental NRCregulations designed to assure that workers and the public are adequately protected from such risks. NU violated NRC regulations, despite a continuing responsibility to assure the safety of the most vulnerable members of the public (i.e., citizens living near the reactors, within the effluent pathways, and all those within a fifty mileradius of the reactors), protect NU workers, and safeguard its
- own assets (as a fiduciary obligation to its shareholders).
Over and over, during the decade of mismanagement, NU promised NRC Region I inspectors, their supervisors, and NRC directorate oversight that it would fulfill its obligationt under NRC's regulations. NU's unfulfilled commitments- in writing, orally, and even under oath--include, but are not limited to, promises that NU would: (1) correct mistakes in reports and procedures, (2) correct mechanical and engineering deficiencies, (3) repair or replace equipment, (4) maintain and/or upgrade safety systems,(5) conduct
t i
- CAN's andNIRS's )0 CFR l 2 206 ft:ston Ia g
,\ nrsehr NU's IJewners for its Connecekst Renesses and Jewssigene Nagingent NRC Segowrotsht.
engineering and documentation evaluations under 10 CFR { 50.59 to justify tests, modifications, experiments,or changes made to any portion of the Connecticut reactors, 1
and (6) maintain complete and proper documentation on the required safety systems of i I
the reactor, its general operation, and technical specifications. These acts and l
omissions are, at a minimum, violations of 10CFR { 50.4,f 50.5,( 50.59and { 50.71.
Safe operation of a reactor necessitates that a licensee (such as NU) maintain a properly documented and completely updated Final Safety Analysis Report (FSAR),
and routinely conduct fullengineering and documentation reviews, pursuant to 10 CFR
{ 50.590n proposed changes, tests, or experiments conducted in the course of any and all operations. See, e.g.,10 CFR f 50.4, { 50.59,6 50.71. The implications of failing to f
l meet such basic requirements are staggering.
The effectiveness ofmultiple back up safety systems which the NRC requires of licensees under the" defense in depth" program approach, and basic assumptions relied upon in every probabilistic risk assessment-(PRA) utilized to predict the degree of assurance provided by such safety systems, are swept away likea house of cards when a licensee (such as NU) operates without adequate documentation. This is more than mere paper shuffling. Ifit were just a matter of giving NU a bit more time to gather papers, the Commission could let NRC Region I take the usual casual approach.
t t .
, C4N's med NIRS's 10 CfR l 2.206 fx::en Is e% . Renar NU's LJewnses for its Connectkwt Re:ctors 9
, ned innsngear Negitgent NRC Sonf Owrsight.
However, the Region I casual approach to auditing operations at NU facilities permitted NU over a decade of operating and profiting from its Connecticut nuclear power stations without adequate evidence that operations met NRCregulations. A lack of documentation directly translates into a continuous elevated risk of radiation exposure to NU workers and the public, an unknown and yet to be determined aucunt ofincreased radiation exposure to workers, and a continuing risk that a combination of operator error and safety system failure willresult in a majornuclear accident.
NU's Event Response team told NU,as the NRCnow knows, that during the past decade NU did not maintain the required documentation at the Millstone Unit I nuclear station. The NRChas since learned of the same shoddy practices at the other Millstone reactors and Connecticut Yankee (Haddam Neck). This is a large part of the reason why petitioners have requested the NRCto take immediateaction to halt alloperations at the Millstone facilities until the required documentation is on file. NU's Event Response team told NU that:
Most of the engineers and mananers contacted durina Ithe Event Response Team analysis 1 (individuals who should be well-versed in desian control reauirements) have not read Title 10of the Code of Federal Reaulations INRC Reaulationsl. Reaulatory Guides. or ANSI Standard certinent to desian contal. There is a meneral lack of understanding and gpr3ciation of the relationship and implications between 10 dFR 50 design basis (50.2Llicensing basis, industry codes. and NU's administrative _ programs controlling configuration and design for reactor ope _ rations).
CAN's andNIRS's 10 CfR U206 Pe: tion Is }g
- Renar NU's IJansesfor tos Connecticut Meectors
, * ' andJewstonese Neghgens NRCSee.Wontsteht.
Event Response Team, Executhy Summary at 11 (emphasis added). The Event Response team report also states that:
i internal correspondence and events involvina the desiar basis (e.g.
NOVs,DERs,LERs] from 1985throuah 1996 show a cattern of information i commuelested to NU mx;;;. This information consistently identified weaknesses and risks associated with the UFSAR [ updated FSAR)and desian basis.
l l
/d. at 2 (emphasis added). This means that NU management had concrete particularized knowledge of serious on going violations of NRC regulations. The Event Response Team Report further states that:
NU management made_ commitments on the docket to correct thesp deReiencies. The actions [of NU managementl were inegoctive, partially implementedt or not done.
- 14. (Emphasis added). This means that althouah NU mannaement had concrete.
narticularized knowledae of serious on-noina safety violations of NRC reaulations, it either acted ineffectively or did nothina at all. Therefore, it is axiomatic that when NU management knowingly led the NRC to believe that NU was taking effective action to come into compliance, or wu in compliance with NRC safety regulations, NU was making material misrepresentations to the NRC, misrepresentations directly related to the safe management, maintenance, inspection, repair and operation of the Connecticut Yankeeand Millstone facilities under the terms and conditions of NRC's license to NU to operate these nuclear power stations. Over and above allthe underlying violations 4 ^
t
- CAN's nedMIRS's 10 CFR l 2.206 Pr:lton Is
Renkt NU's IJunses for its Connecticsot Re:ctsrs
, andinnsrigent Nrghgent NRCSnef Owrsight.
of other portions of 10 CFR part 50 leading up to them, in and of themselves, such material misrepresentations violate NRC regulation 10 CFR 650.5 (deliberate misconduct), 650.54 (conditions of license), 650.55a(s)(1)(requirement to meet codes i
- and standards), and 650.7)(c)(requirement to update FSAR and maintain 650.59 i
documentation). Although NU merely intended that the Event Response Team Report would identify problems at Millstone Unit 1,the Report stated that: The long term pattern of decisions and actions [at Millstone Unit 1] has generic implications for Connecticut Yankee and Millstone Units 2 and 3. A samde_of_jntemal_and enctnal assessments _and_ design _ events (e.g, LERs)for _ Units 2_and_3_and_ Connecticut Yankee m supports the_ potential forgeneric implications. Id.at 8(emphasis added). The Report goes on to state that the Team needed more data Rom each of the NU licensed facilities mentioned in order to determine the " full extent of the implications." Id. Thus, NU's own investigative team, without even having a complete picture of the extent to which the problems at Millstone Unit I apply to other NU operated nuclear reactors, recommended that NU should " conduct a verification effoit similarto the Millstone Unit 1 effort for Millstone Units 2 and 3 and Connecticut Yankee."Id. at 9. Beyond the efforts that the NRC has already taken to try to deal with the problems described in NU's in-house report, the Commission needs to direct its independent panel to examineeach of the NOVs, DERs, and LERs over the past decade
C4N's andNIRS's 10 CIR f 2.206 Pr: tion es Rewar NU's !Jcenses)>r its Connecticut Roncerrs
}}
, ' andinnstegent Negiogent NRCSeaf Owestsht.
to determine the actual physical status and documentation for all of the problems (and any of the changes, modifications, tests) at all of the Millstones and Connecticut I Yankee, as well as the rest of the New England reactors--certainly any in which NU has an interest, as well as those ~ serviced by NU's primary engineering contractors and consultants- and probably allof the nuclear power stations inspected by Region 1.8 This petition calls upon the Commission to face reactor licensee violations more pervasive and serious than any previously confronting the NRC. Not only do the decade long, serious, chronic, systemic mismanagement problems at the Millstone and Connecticut -Yankee nuclear power stations require action against NU, but the Commission must confront its own chronic, systemic failure to enforce its regulations. Specifically, the blatant, abject failure of regulatory oversight by the NRC NRR directorate rtmagement and stafT, NRC Region 1 management, staff, inspectors, and other NRC administrators, management, and staffin failing to assure NU's compliance with NRCregulations. 8 Petitioners believe,as does the NRC, that NU's Connecticut problems may have infected other nuclear power reactors in New England. See S. Varga, Director NRC Division of Reactor
] projects, Letter to 0. Cheney (NRC Acc. No. %10090036)(October 7,1996). It is not : lear to what extent the company side pro'lems c are strictly the responsibility of NU, or should be 3
shared by any and all of the various consultants and contractors utilized by NU such as Stone
/,
O'1 l and Webster Engineeringand Yankee Atomic Electric Company. Likewise, the NRC needs to
- ack ordi or the naciar pow = atias une
- inspection resime or NRC Region i, as well as those persons at headquarters to whom RegionI reports, because RegionI allowed NU to get away with dangerous, flagrant violations of NRC regulations for over 10 years!
CAN's nedMIRS's 10 CfR $ 2206 h: tion os
*s
- Mrwar NU's Lkwnses for los Connecticut Reactsrs }3
, and huseigene Negiogent NRCSmWOnesight. * \
in the event that the NRC determines that the root causes of Northeast Utilities' chronic, systemic mismanagement ofits Connecticut nuclear reactors has jeopardized public health and safety, petitioners have requested the revocation or suspension of l Northeast Utilities' licenses to operate these facilities until such time as the NRC l Commissioners have reviewed and approved the recommendation of an independent s panel appointed by the Commission that unequivocally recommends re licensing or liAing the suspension. In the event that the NRCdetermines that its staff (NRR, Region I, and any other NRC personnel involved) has systematically failed to enforce regulations, not carried out inspections which assured the completion of documentation, repairs, upgrades, maintenance, ALARA reviews and procedures, and any activities which licensees promised to accomplish pursuant to regulation or best practices, petitioners have requested that all such personnel be permanently removed from any positions involving oversight authority in reviewing, directing, supervising or carrying-out the NRC's regulatory requirements, ne bottom line on the failures of NU and NRC inspections described in this petition and the video Exhibit attached hereto is that these failures culm,inate in NU's Connecticut nuclear power stations having inconsistent and inaccurate Final Safety Analysis Reports.
..-..m_.... , . . , - - . . . .' '
n.. CAN's andNIRS's 10 CfR f 2 206 Pontion is Rewer NU's IJtenetsfor its Connecticut React:rs y , and innsagent Negitgent NRC Ssef Owestght. O
'Ihe updated FSAR is the essential document for safe reactor operations. The FSAR demonstrates licensee compliance with NRC regulatory requirements by
/
documenting allchanges to a reactor from constmetion through operations and for the f
, ,Aj duration of the license. Along with the Technical Specifications, the FSAR provides a working blueprint against which a licensee may compare the day to-day condition of the facility. This allows the licensee to be relatively certain that the reactor is operating safely, and efficiently plan for continued safe operation. By documenting modifications and repairs to a reactor, the FSAR allows a licensee to determine the need for additional design modifications and plan for necessary repairs and maintenance. In this way, the i
FSAR provides managers and engineers with a guide to determine how to retrain the work force. By encapsulating the history of physical modifications, repairs, and maintenance, the FSAR also protects workers from unnecessary exposure to radiation. l
} lt does this by providing a guide for licensees during the planning and reviewing process necessary to implement the NRC's mandatory ALARA standards in 10 CFR part 50and Appendix 1.
Because the FSAR is the blueprint which documents the history of changes to a reactor and its operation, consistent, timely updating is absolutely essential.
.- cars a,exanss totra nm ham on
, neu xv s omersje us cau.urna,e nonom }$
, a.dlowwgeer Nostraret NRCsegunestght.
The updated FSAR allows the licensee to maintain knowledge of the current condition of reactor operations, make information accessible to reactor staff, and allows staff to effectively handle both routine operations and abnormal events. In the absence of an updated and accurate FSAR, nuclear power station i managers, engineers, staff, employees and contractors lack information on how the reactor systems and components operate together. Changes occurring in the reactor design become difficult, if not impossible, to determine, and require case specific inustigation based upon inherently unreliable sources: individual, anecdotal memory. l Likewise, absent an adequate, updated FSAR, discovering the impacts of design changes upon other systems requires such time consuming, case specific investigation. Under emergency conditions, it would be impossible for operators, engineers, and staff to immediately access the exact cause of a problem or understand the conditions they would find when attempting to make emergency repairs. A time-consuming, case-specific investigative process confronts staff precisely at the moment of crisis, when timeis of the essence to avoid catastrophe. A deficient FSAR prevents a licensee from adequately training and retraining workers. By having different_and conflicting updates of the FSAR,, workers may respond to the wrong condition or at a wrong location, leading to confusion and conflict in addressing both standard operation and abnormal occurrences. To the
C4N's edNIRS's 10 C*R $ 2.206 ?:: tion es
.s .
Rewar MU's LksentsJiw tos Connectkus Reactors }$
. and Jmsuuseer Nrghgret NRC Ss40ntsight.
extent that the deficient FSAR forces workers to rely on inherently unreliable anecdotal knowledge, such conflicts multiply as different managers, engineers, and operators recall different versions of what was done, where, how, and by whom. In an emergency situation, under these conditions, coordinated efforts by personnel are excisodingly difficultifno*t impossible. Clearly,the anecdotal, case by-case scenario for problem solving increases the likelihood of unnecessary worker exposure to radiation. Personnel cannot practice a
" lessons learned" approach to problems under such conditions. The possibility of personnel conducting ALARA analyses is completely compromised under such conditions. Absence of an updated FSAR forces workers to constantly reinvent the wheel whenever problem situations confront them in areas ofradioactive contamination.
This directly translates into workers routinely exposed to higher doses of radiation than they would incur under proper ALARA practices. Fina"ly, and most significantly, absence of a properly updated FSAR forces the nuclear power station operators and other staff to function in a constant reactive or
" crisis" mo$e. The result is personnel exercising poor judgment, suffering from excess stress, and making inferior decisions. This translates into higher employee absenteeisrn, higher turn over, and lost experience. In this way, the demands placed upon operators and staff by the necessity of maintaining a high level of scrutiny of
- CAN's andNOS's 10 CfR U206 Perttion to }y
\ Rewar NU s Linnses for its Connecticut Reactors , and innstigate Nrghgent NRCSsof Owrstght.
worn and out dated components and systems in an aging reactor are compound by the problems created when attempting to conduct operations with a deficient FSAR. Ultimately, under such conditions, engineers will find it more and more difficult to i effectively calculate and set conservative limits on already deteriorating systems. This way, the process of deterioration willaccelerate, eventually spiraling out of control. Workers' and the public's besith and safety are in constant jeopardy when the NRC allows licensees to operate nuclear reactors without an updatedFSAR. Absent ar opdated, accurate FSAR, NRCinspectors have no wayto determine that a i reactor is in compliance with regulations and technical specifications. For these reasons, and in order to avoid the anarchic situations described above, the l l NRCmakes a licensee's commitments to maintain an accurate and updated FSAR (and other necessary documentation) binding, legal requirements unt',er NRC regulations: Each person licensed to operate a nuclear power reactor pursuant to the provisions of Sec. 50.21 or Sec. 50.22 of this part shall update periodically, as provided in saragraphs (c) (3) and (4) of this section, the final safety analysis report (FSAM ongmally submitted as part of the application for the operating license, to assure t1at the information included in the FSAR contains the latest material developed. This submittal shall contain all the changes necessary 1o reflect information and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the oriainal FSAR or, as appropriate. the last updated FSAR. The updated FSAR shall )e revised to include the effects of: all changes made in the facility or procedures as described in the FSAR: all safety evaluations performed by the licensee either in su sport of rec uested license amendments or in support of conclusions that changes cid not involve an unreviewed safety auestion; and all analyses of new safety issues performed by or on behalf of the licensee at Commission rec uest. The updated information shall be appropriately located within the FSAR. (1) The licensee shall submit revisions containing updated information to the Commission, as specified in Sec. 50.4, on a replacement page basis that is accompanied by a list which identifies the current pages of the FSAR following page replacement.
.g C4N's and NIRS's 10 CFR $ 2206 Prition Is }g Rewar NU's Licenses for sus Connecriat Reactors
, andimstigase Nrghtent NRCStallonesight. l (2) The submittal shall include (i) a cenification by a duly authorized officer of the licensee that either the information accurately, presents changes made since the previous submittal, necessary to reflect information and analyses submitted to the Commission or pre changeswere made; pared and (ii an p)ursuant identification to Cornmission of changes requirement, made under-the provisions or that no such of Sec. 50.59 but not greviousIV submitted to the Commission.
~($ A reviiTo~n7t1e originalFSAR contEnTng those onginalpages that are still applicable plus new replacement pages shall be filed within 24 months of either ju y 22,1980, or the date of issuance of the operating license, whichever is later, and shall brina the FSAR up to date as of a maximumof 6 months prior to the dateo -filing t ie revision.
(4) Subsequent revisions shall be fN no less frecuently than annually and shall reflect allchanges up to a maximum:b months prior to the date of filing. 10CFR { 50.7!(e)(emphasis added). The rule makes patently clear the NRC's concern (and requiremen9) that licensees have both updated FSAR and (50.59 analyses on hand.
- Without an updated FSAR in place, NRC staff had (and have) no basis for determlalag whether NU was in compliance with its technical specifications and NRC safety regulations.
( Thus, to the extent that NU failed to provide, and NRC staff failed to demand, an up-to-date and accurate FSAR for the Millstones and Connecticut Yankee, the NRC staff permitted NU to operate the reactors out of compliance with technical specifications and in violation of crucial NRCsafety regulations. Recent NRC action has taken some initiative in attempting to isolate NRC Region I from a continuing role overseeing inspections of NU's nuclear facilities in Connecticut. While this is a beginning, it is hardly comforting to members of CAN and NIRS living throughout New England, where NRC Region I has supposedly been
i {' s' e CAN's edNias's 10 Cnt $ 2 2e6 Pr: tion is Rower NU's betnses for ses Connecticut Reectors
}9 ,, and Jnwssigner Negitgent NRC Snef Owestght.
inspecting other nuclear power stations. What assurance, if any, is there that NRC Region I has been vigilant outside Connecticut when it has so totally failed to do its job l theref The Commission needs to conduct an audit of all NRC Region I inspections knd NRCheadquarters oversight of these inspections during the past decade to see if there are the same type of negligent inspection practices throughout NRC Region I as those documented in Connecticut and Maine 5 Moreover, to date, the licensee's responses T s 'See S. Varga, Letter to G. Cheney, supra, note 3.
*See NRC, independent Safety Assessment ofMaine Yankee Atomic Power Company at 1, 74 (October 7,1996). Both the ISA and Office of the Inspector General found, in separate investigations, that NRC and its Region I inspection program were deficient in regulatory oversight of Maine Yankee for more than a decade. In its conclusions to the ISA report, the Team recommended that the NRC inspection program should be reviewed in the following areas:
the licensee-implemented testing programs for safety systems relative to its scope, rigor, and analyses of results the periodic review of licensee developed Technical Specification interpretations to assure consistency with the intent of the approved TechnicalSpecifications f assessment of the adequacy of the plant design-basis including a review of the disposition of significant findings from previous licensee efforts such as design-basis documentation or design-basis reconstitution programs M at 74. The striking similarities between the length and depth of the NRC's Maine Yankee problems and solutions, and the problems at the Connecticut nuclear reactors are a bit too close to pass off as mere coincidences. Clearly, the NRC needs to undertake some major housecleaning in order to assure that it is adequately protecting workers at NRC Region I reactor sites and the citizens livingin reactor communities. Naturally, if the problems with NRR and NRC Region I are due to mismanagement, economic pressure, and other problems endemic to NRC programs,
t
~
CAN's nedNiaS's 10 CF.1 $ D06 f*:strion Is newar NU's !Jernses fr>r its Connecticut Reecotrs y e andinnsvognor Nrghteet NRCSonff Owesight. have been insufficient. DERs, inspection reports, and other documents--as petitioners illustrate below--show an increasing number of serious problems emerging at an alarmingrate. This means that NU has failed to address the root causes of the problems at the Millstones and Connecticut Yankee, and is merely attempting a cosmetic fx. To do the job right, the NRC must initiate a full scale independent analysis of all reactor systems at NU's Connecticut facilities. Even ifNU decides to permanently close one of these nuclear reactors- as likely it willdo with Connecticut Yankee-without such a massive audit and re-documentation, it would be unsafe to attempt to disassemble any portion of a nuclear power station. This is because an updated FSAR provides a blueprint for safe decommissioning. The same applies to the licensee having complete, accurate, and up-to-date 10 CFR {50.59 l documentation. Absent these documents, there are no " specs" for a nuclear power station. No meaningful ALARA analysis and review can take place. Thus, decommissioning workers could easily receive extremelyserious radiation exposures by enterir.g highly contaminated areas of the plant, attempting to remove the wrong 1 component, or attempting to undertake decontamination activities in a highly contaminated section of the facility. Furthermore, and fundamentally, without the the problems " uncovered" at the Connecticut and Maine nuclear power stations probably exist at most of the nuclear power stations under NRC regulatory authority.
** ? CAN's andNIRS's 10 CFR l 7206 Pe:tton oegl
- nrwar NU's lJcensesfer its Connectwut Reactors
,, andinwanneer Neghsent knCSeqWOwrst~ht. proper documentation. L .ers have no way of knowina how the nuclear power station was out tonether. so they ca..aot possibly take it apart safely. The NRC must detennine the root causes of such chronic, systemic mismanagement, because the recognized deficiencies presage potential widespread mismanagement compromising safe reactor operation. This applies with no less force to i l the same deficiencies in NRC regulatory oversight. The lack of documentation, I inaccuracies in existing documents, and other serious lapses have occurred over i decades, making it difficult to verify system compliance-whether one looks at the individual nuclear reactors at issue here, or the NRC Region I inspection program as a whole. The NRCordered a Connecticut Yankee shutdown because NU was operating the reactor outside technica'. specifications. The NRC's shutdown decision followed a series of NRC inspections and reportable event occurrences [ documented in DERs] at the reactor. Among other safety problems, the inspections uncovered serious weaknesses and inaccuracies in NU's documentation for operating Connecticut Yankee, particularly NU's failure to maintain an accurate and completely updated Final Safety Analysis Report [FSAR). Thr. same problem existed at Millstone Unit 1l where NU's own in house evaluation team found that management and engineering personnel were
- .I ) ;'
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- Renar NU's Licensesfor its Connecticwo Renctors y
i ,
, end Jewstugeot Negitgent NRCSnef Owrstght.
i not familiarwith the NRC safety regulations contained in Title 100f the Code of Federal
- Regulations. .
1 The NU evaluation team also reported that Millstone Unit 1 management carelessly or knowingly neglected to follow-through on mandatory commitments to the NRC staff to assure that particular repairs, modifications, and documentation of changes to the reactor were actually taking place. The same NU evaluation team raised ) serious questions about mismanagement of Millstone Units 2, 3, and Connecticut Yankee.
- IV. CHRONIC.SYSTEMICPROBLEMS AT NU'S CONNECTICUTREACTORS 1 Petitioners contend that NU's Connecticut nuclear power reactors do not exhibit substantial improvement, despite NU's recent efforts to get them back on line.
Management and operation at NU's Connecticut reactors continue to be dangerous, S , substandard, and generally outside NRC's regulations, as the examples cited herein illustrate. Petitioners believe that NU's admitted decade-long failure to maintain an updated FSAR for each reactor facility epitomizes the seriousness of the current state of i affairs at the Connecticut reactors. 3 Petitioners have assembled but a few of the incredibly numerous inspection reports, internal review documents, and licensee event reports for each of NU's 4 Connecticut reactors. These documents raise seri:ns concerns about the management i
~
- C4N's nedNIRS's 10 CfM $ Z206 Prxtiem Is Arnar NU's LJeweses for Its Connecekut Reactors y
o endinnstigent Neghgent NRCSanfowrsight. and operation of Connecticut Yankee and the Millstone Units 1,11, & 111 nuclear power stations. In a letter to T. Feigenbaum, Chief Nuclear Officer for NU, William Russell, then NRC Director of Nuclear Reactor Regulation stated: i Ibg gam identified a number 2f sinnificant deficiencies ja lhg enaineerina calculations and AnalnlE 131121 EEan 12 EDIEtt the adecuacy 2f 1hi desian gf)[g gute,m3 at ];]3ddam Eg;h [ Connecticut Yankee). In nemt i gaan, design-bas 4 calculations and analyses were not sufficient to confirm that the safety system functional requirements would be met. Some of these errors were long standing, while others were recently introduceJ.... Deficiencies 31 dentified i in thg calculations ADA BBR]D11 supportina the station batteries, the emergency diesel nenerators..., containment air recirculation ... system, service water ... gg[g,rg, ggd in jjlg combination of systems and components needed to sunogrt the emeraency coolina svFlem ... transfer from the injection phase to sump recirculation. These deficiencies revealed __significant weaknesses in the defense.in-dipth Drinciples that the NRC_ relies on to ensure nuclear power plant gperatiorLdoes not jeopardize the health and_ safety of the public. The team concluded that weaknesses _in your configuration meagement Rt cess andMack of technigal rinor, thoroughness. an_d attention to detail in thq_dtsign_pto_ggts,_cither r contributeito or direqtly_cssed q the identified grron. In addition, desian control measures aush as supervisory rgvism, independent desian reviews add reviews by oversiaht ggg" gggg did B21 identifV 1hng deficiencies. Inspection Report 50 213/96 201(emphasis added). The team identified several errors in the updated Final Safety Analyses Report (UFSAR) which reflected ' programmatic weakness in the process for maintaining the accuracy and consistency of the
'~
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CAN's andNIRS's 10 CIR l 2 206 Petition es Renae NU's Linnsesfor its Connecticut Reactors y e mdiensrugase Nashgent NRCSoof 0westght. information in the UFSAR. The team also found instances where NU's managers did not meet commitments to the NRC: The team found several instances involving the failure to identify,
- e. valuatem and_ correct conditions adversejo_ quality and some instanectin which f janned_cortective_ actions were_not prompflyjnitiated. In gome instances the delays in initiating planned corrective actions were j gjgnificant beca.use the actions included _the evaluation of the_ potential l generic imp]i_ cations of these_ issues _ for oti l er plant systems and gqgipment.
Id. (Emphasis added). The inspection report goes on to note that the February 22, 1996, Event Response Team Report found process issues at Connecticut Yankee' similarto those identified at Millstone 1: [Qhe_ team _four.d that_ calculations _did not exist to suppor_t some of the design. bases and _the administrative control _ programs atJaddam.yock [Connectic_ut Yankee] had not maintained an accurate. UFSAR....
'These problems were not new to either NU or the NRC. See generally, J. F. Opeka, NU, Letter to T. Martin, NRC RegionI(NRC Accession No. 9407130157) at 1,2 (July 5,1994). Duringthe first halfor 1994, John F. Opeka, Executive Vice President, C.wnecticut Yankee Atomic Power Company (CYAP), had been exchanging letters with Thomas Martin, then Regional Administrator for NRC RegionI, attempting to explain prior inaccurate statements conceming servicewater system problems.1d. These statements included: (1) reference to an " engineering evaluation"which Mr. Opeka subsequently admitted was really only a few "related informal discussions" and one engineer's statement that he would provide the welding department with any pipe needingreplacement,(2) reference to testing of a weld when it was only subject to
" visual" inspection, and (3) reference to all degraded welds being solely in the first nine feet of piping, when, in fact,"all 22 welds inspected (at that time) were degraded to some extent."Id. In Mr. Opeka's opinion these utter mischaractenzations were merely overstatments or "not accurate" or "could have been more clear." /d Incredibly, it took two inspection reports and three letters before the NRC finally received this " clarification" from Mr. Opeka.
* * ' . ,' CAN's and MIRS's 40 CfR $ 2 XM Part* ton to Renar NU's Dewesfor tas Connecutcut Reactors 3$
e, and husetgent Nrghgent NRCSodowrsight. [L]icensee management oversight did not identify and address the patterns of corrective action program implementation problems.... 'a gral lack of und.trstanding and appreciation for the relationship httwsen 10 CFR_50 drsign bases. licensina bases. indgstry eqdes,Jnd N_lfs administrative programs existgj.'
- 14. (emphasis added). Discussing Connecticut Yankee, NRC's Director of Division of Reactor Projects told NU that:
*!he discovery by design engineering that the service water piping supplying cooling water to the CAR fans would not remain functional under accident conditions was g ggE12h pf g hgg fg which th dyign basis for_ the plagt_had _ not been thoroughly reviewed _ or understood.
R. Cooper II, NRC, letter to T. Feigenbaum, NU (September 12,1996)(emphasis added). Other design basis issues discussed in the report included the reliance on high containment back pressure to assure reliable performance of the residual heat removal (RHR) system under postulated accident conditions and the adequacy of the containment sump screens to limit debris from entering the safety systems. These - issues adversely impact the operability of emergency core cooling systems, thus undermining " defense in depth" against a core melt-down and the ensuing catastrophic release ofradioactivity into the environment. The report identified these ultimate safety concerns as but two " apparent" violations of technical specifications.
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- C4N's andNIRS's 10 CFR $).206 Pettinen to y I
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- e* and1=wsassar #eghgent #RCSadowerstger. ,
I i i ! ) A. landeensteSurveillance Testion'
- MP1 DER 30821(08/01/96) involving inadequate NPSH for the RHR pump during the long term cooling phase of an accident. The intent of the surveillance testing program i l for safety related equipment is to assure that these components will fulfill their required ;
i functions in an emergency. This DERdemonstrates that the MPl surveillance testing ! program was deficient. MP2 DER 311%(10/22/96) involving non conservative reactor trip setpoints. The : purpose of the surveillance testing program for safety r~ lated instruments is to assure . I that these components will perform as assumed in accident analyses. This DER demonstrates that the MP2 surveillance testing program was deficient and the plant { safety analyses wereinvalid. i 1 MP2 DER 30393(05Ml/96) involving a 32"x 9" hole (roughly the size of a large doggie door) in the auxiliarybuilding wall near the spent fuel pool. This deficiency, reported as j having existed for some time, demonstrates a significant deficiency in the surveillance
- - testing program. Ignoring the fact that one might reasonably be expected to notice a
! gaping 32"x9" hole, the auxiliary building is intended to be a radiologically controlled ! area and as such is subject to periodic testing. The auxiliarybuilding is, or should have ! been,- pressure tested to confirm that all releases are controlled and filtered as - , i necessary. Such testing, had NU conducted it properly, should have detected problems j reflective of a gaping hole. t I MP3 31052(09/24/96) involving nuclear instrumentation high power reactor trip testing ! not conforming to design and licensing bases assumptions. The intent of the - ! surveillance testing program for safety related instruments is to assure that these ! components wiliperform as assumed in accident analyses. This DER demonstrates that
- the MP3 surveillance testing program was deficient and the plant safety analyses were invalid, r
l .
'In the following subsections, MP1,2,3 refer to the Millstone reactors, CY refers to the L
Connecticut Yankee (Haddam Neck) reactor. ' DER' refers to licensee Daily Event Reports to the NRC. t
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e B. Omeratian Outside Desima Bases MP1 DER 30821(08/01/96) involving inadequate NPSH for the RHR pump during the long term cooling phase of an accident. This deficiency, apparently existing for years, meant that the reactor core would not have maintained adequate cooling following an accident. Since the RHR pumps also provide suppression pool cooling (containment cooling), this deficiency could also cause containment failure following an accident. MP2 DER 31167(10/16/96) involving flooding of the emergency diesel generator rooms through a common, connected floor drain line. This deficiency, apparently existing since the plant initially started up, represents a potemial failure mechanism for all of the emergency diesel generators. Many other licensees, during the course of their l Appendix R fire protection evaluations or in response to the Surry pipe rupture event in 1984, identified common floor drain line vulnerabilities such as reported in this DER. This DERdemonstrates that the operational experience review program, mandated by the NRC following the TMI accident, is inadequate at Millstone. MP2 DER 31085(10/03/96) involving improper setting of the steam generator safety reliefvalves. This deficiency, apparently existing since the plant initially started up and made worse by the steam generator replacements, represents the potential for over pressurizing the steam generators, thereby invalidating the assumptions that a single tube rupture would not propagate. This DERdemonstrates, among other things, that Millstone's design modification process is deficient because NU replaced the steam generators without detecting the existing problem or recognizing that the new steam generators would make the problem worse. MP2 DER 30350(04/23/96) involving a single failure that could render the enclosure building ventilation system inoperable. Plant safety analyses assume that one of the two redundant ventilation paths functions to filter containment releases. This deficiency, apparently existing for considerable time, challenges that assumption. MP3 DER 31081(10s02/96) involving a spent fuel pool design problem that could cause loss ofspent fuel pool cooling after a seismic event. The NRC issued NRC Information
-- Notice No. 93-81 in October 1993 alerting licensees to potential loss of spent fuel pcol cooling following design bases events. This DER demonstrates that Millstone's operatior,al experience review program, mandated by the NRC following the TMl accident, is inadequate.
% { CAN's andNIRS's 10 CFR f 2206 Pr:sbon togg s.
Rende NU's LJcwnsesfor les Connecticut Reactors l e andinnstogeor Negligent NRCStef owrsight. MP3 DER 31062(09/26/96) involving potential failure of 21 safety related air operated valves on loss of power causing diversion of safety injection flow and possible pump run out. NRCBulletin 38 xxspecifically requires licensees te review the performance of safety related components for loss of instrument air. This DER demonstrates that Millstone's response to this NRC bulletin is less than adequate. l ' MP3 DER 31008(09/16/96) involving failure of the safety related charging system if instrument air is lost. The charging system perfont.? the essential function of core cocling following an accident. NRC Bulletin 88-xxspecifically requires licensees to reviev; the performance of safety related components for loss of instrument air. This DERdemonstrates that Millstone's response to this NRCbulletin is less than adequate. MP3 DER 30976(09/06/96) involving failure of 37 solenoid valves upon failure of non. safety related airpressure regulators. The DERstates that the solenoid valves effect many safety systems including the charging system and both the high and low pressure safety injection systems. NRC Bulletin 88 xxspecifically requires licensees to review the performance of safety related components for loss of instrument air. This DER demonstrates that Millstone's response to this NRCbulletin is less than adequate. C. Destraded MaterialCondition CY DER 30945 (08/31/96) involving a pin hole leak in the RHR heat exchanger inlet isolation valve. Following a design basis loss of coolant accident, the RHR piping containing this isolation valve extends the reactor coolant pressure boundary outside primary conteinment. This identified integrity loss provides a pathway for radioactive material to bypass primary containment in the event of an accident. MP3 DER 30897(08/20/96) involving fouling of the containment re-circulation system heat exchangers by debrie. The DER states that the fouling was thought to have occur.ed the previous month when system flow was increased to maximum. Ti2is DER demonstrates the potential failure of all components cooled by service water if the strainers and other protective measures have not been adequately designed to withstand maximumservice water flow,as this DER apparently indicates. ,This potential may also apply to MPI and MP2.
, t
- ?*;,* % l CAN's ad NIRS's 10 CFR $ 2.2&S Perttien 39 to Resdr NU's Lkenses for its Connectkut Reactors a
and Imssetgeor Negligent NRC Suf Onrstght. D. Problems Conticular at Connecticut Yankee Afler Shund' o CY DER 31126(10A)9/96,10Al/96) involving a 30 inch longitudinal crack on the water 1 supply line to the spent fuel pool heat exchanger and a bad weld on a 6-inch service water retum line from the spent fuel pool heat exchanger. The purpcse of the supply lineis described in this way: The spent fuel pit cooling system removes residual heat from the spent fuel stored in the pit. The spent fuel pit pumps draw water from the pit, circulate it through a heat exchanger and retum it to the pit..There are two spent fuel pool heat exchangers, a shell and tube type and a plate type. The plate heat exchanger has a greater heat removal capacity than the shell and tube heat exchanger. Section 9.1.3.2of the Connecticut Yankee Updated Final Safety Analysis. This DER raises the concem that the material condition of the system used to cool the irradiated fuel in the Connecticut Yankee (Haddam Neck) spent fuel pool may have degraded to the point that it is less likely to withstand the loadings imposed by a seismic event. In fact, the identified problems indicate that the material condition of the piping may have degraded to the point where it may be vulnerable to rupture under normal thermal and dead weight loadings. NRCInspection Report 50 213/96-201 stated that the NRC's special investigation team into problems at Connecticut Yankee (Haddara Neck) found deficiencies which.
" revealed weaknesses (in systems] that the NRC relies on to ensure nuclear power plant operation does not jeopardize the health and safety of the public."Id. The team concluded that " weaknesses in your configuration management processes and a lack of technical rigor, thoroughness, and attention to detail in the design process, either contributed to or directly caused the iden+ified errors."Id.
This inspection report in wnjunction with recent de-staffing activities at Connecticut Yankee (Haddam Neck) raises the concem that appropriate safety margins may not exist or be maietained at the facility. NU's managers did not correct the weaknesses in the configuration management processes and the inattention to detail during the design process prior to the Configuration Management Project team disbanding. Consequently, there may not be a solid technical foundation to support prudent decisionmaking at this facility, particularly as both the NRC and NU continue to reallocate resources to the Millstone and Seabrook reactors.
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- a CAN's andNIRS*s 10 CRt $ 2.206 Petition is Rewar NU's Deensesfor sts Connecticut Reactors y ,
s',. I andinesttgote Negligent NRC Stof Ontsight. e, - E, Inadeanate Onality Assarance Programs Collectively,the documcats summarizedabove provide persuasive evidence that the Quelity Assurance programs at NU's Connecticut reactors are significantly flawed. NRCregulations at 10CFRpart 50, Appendix B, require NU to have Quality Assurance programs that assure maintenance of the original design bases and safety margins. These QA requirements include provisions for testing, auditing, configuration management, and design control. NU must develop an " effective" QA program.
" Effective"means meeting the NRC's Appendix B requirements.
F. Material False Statements The NRCissued 50.54(f) letters to NU in the spring of 1996,cencerning all three Millstone nuclear power stations. NU maintained that the Millstone nuclear power stations met all applicable design and licensing bases requirements. The DERs cited above demonstrate that such statements were false at the time NU made them, and in some cases, have been false since the initial start-ups of the Millstone reactors. The same concerns apply to Connecticut Yankee. G Decommissionian And Desina/Licensima Basis Defleiencies The new NRC decommissioning rules will allow Connecticut Yankee (Haddam Neck)to conduct all ofits majordecommissioning activity under 10 CFR Q50.59. To
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t ,, n andinnstigest Neghtent NRCSnef Onesight. safely conduct activities under 650.59, the licensee must have its design and licensing bases in order. At a minimum,this means having an updated: FSAR, and updated, accurate Technical Specification for any of the nuclear power stations which NU may decide to decommission. The problem is that Connecticut Yankee's design and licensing bases are so defective that no one can really perform a valid (50.59 safety analysis. During the better part of1996, staff and management at Connecticut Yankee were in the process of l rebaselining the design and licensing bases in order to provide reasonable assurance to the NRCthat it was safe to permit the reactor to restart. Despite the licensee's feverish activity, the NRC's special Inspection Report of July 31,1996, documented extremely serious deficiencies in the areas ofdesign and licensing bases. Thus, NU had not even come close to resolving these problems when it announced the shutdown of Connecticut Yankee and began drastic reductions in staffing levels at the reactor. The point is that if the NRC decided that NU lacked sufficient knowledge of the licensing and design bases forstaff and management at Connecticut Yankee to be able to safely restart the reactor, NU plainly does not have sufficient information to conduct decommissioning under 10 CFR 650.59 as the new rules allow. The same problem would, of course, apply were NU to attempt to shutdown and begin decommissioning at any of the other Connecticut reacto:s. Wherever deficiencies in the licensing and
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4 design basis exist, safe decommissioning under $50.59is not possible without adequate licensing and design bases. V. ABOUTTHEPEITHONERS Citizens Awareness Network (CAN)is a non-profit, public interest group with members located near the Yankee Rowe reactor in Massachusetts, the Vermont Yankee reactor in Wrnon, Vermont, the Connecticut Yankee and Millstone reactors in Connecticut, and the Seabrook reactor in New Hampshire. CAN is concerned with the entire nuclear fuel cycle from mining uranium, through operating nuclear power reactors, to establishing sites for disposal or radioactive waste. CAN represents citizens in many communities that experience the economic, environmental, and health impacts of the uranium fuel cycle. Since 1991,CAN has participated in a variety of NRC proceedings, including NRChearings on reactor embrittlement and decommissioning, nalemakings, workshops, and adjudicatory hearings. Neelear Information and Researce Service (NIRS) is a nonprofit membership organization dedicated to providing information and assistance to people concerned about the effects of nuclear power, radioactive waste, and renewable energy
' alternatives to nuclear power. NIRS membership is world-wide, including Connecticut residents whose health and safety are a priority of this petition. Since 1978, from its headquarters -in Washington, DC, NIRS has, among other activities, participated in nuclear regulatory affairs, including rulemakings, enforcement actions, and administrative and judicial adjudications on the regulation and licensing of particular nuclear power stations.
e p: CAN's adNIRS's 10 CfR $ 2.206 P:ttrion Is 33 Rewar NU's Liansesfor its Connecticut React:rs
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1 VL CONCLUSION For the forgoing reasons, petitioners ask the United States Nuclear Regulatory Commission to grant this petition by immediately commencing:(1) enforcement action, as detailed above, against Northeast Utilities, and (2) an investigation, as detailed above, of the role of the NRC directorate management and staff (NRR), and Region I management and staff in permitting NU to operate its Connecticut nuclear power stations out ofregulatory compliance for over a decade. 1 DATED: This 25th day ofNovember,1996 Respectfully submitted: Deborah Katz,Presi'e'nt d g m WbSw Paul Gunter, het(ctor Watchdog Project Citizens Awareness Network NuclearInformation and Resource Service P.O. Box 83 142416th Street, NW 4th floor Shelburne Falls, MA 01370 Washington, D.C. 20036 413-339-8768 202-328 0002 hvSt.'Mtvw Y E.A b _ Rosemary Bassikkis, Researcher *O Citizens Awareness Network 54Old Turnpike Road Haddam,CT06438 860 345-8431 1
Crpnns AwmMESS NETwam_v P.O. Box 83. Shelbume Fallt MA 01370 0083 T/F 413-339-8768 9' . November 25,1996 Emile Julian,Esq. Docketing & Service Branch United States Nuclear Regulatory Commission Washington, D.C. 20555 RE: 10 CFR 2.206 Petition on Connecticut Yankee, Millstone Units 1,2, and 3. Dear Mr. Bell Enclosed please find the original and six copies of Citizens Awareness Network's and i Nuclear Information and Resource Service's 10 CFR f 2.206 petition with two copies l of a video tape marked ' Exhibit A' for service upon: The Commission:
- Dr. Shirley A. Jackson, Chairman, USNRC e Dr. Nils J. Diaz, Commissioner e Ms. Greta Dieus, Commissioner
- Mr. Edward McGafUgan, Jr., Commissioner
. Mr.Kenneth Rogers, Commissioner Executive Director for Operations:
- Mr. James Taylor, EDO, USNRC Thank you for your kind attention to this matter.
Sincerely, l} Deborah Booth Katz,pesident - Citizens Awareness ytwork Enc.] i f) p 'i V
)
' UNffED STATES I, .# NUCLEAR RE2ULATORY COMMISS60N 8 wasemetow,oc. nom.am January 23, 1997 i
k**** Deborah Katz, President . Citizens Awareness Network P.O. Box 83 1 i Shelburne Falls, MA 03170 l i Paul Gunter, Reactor Watchdog Project Nuclear leformation.and Resource. Service 142416th Street, W., 4th Floor Washington, DC 20034
Dear Ms. Katz and Mr. Gunter:
This letter is to acknowledge receipt of a Petition pursuant to Title 10 of the code of Federal Reculat' ans (10 CFR) Section 1.206 dated November 25, 1996, and an amendment to the Petition dated December 23, 1996, submitted by you on behalf of Citizens Awareness Network FCAN) and the Nuclear Information and Resource Service (NIRS) (Petitioners . % Petition was submitted to the Commissioners of the U. S. Nuclear Regula) tory Commission (NRC) and to the NRC Executive Director for Operations. Tie Petition requested that the NRC take actions regarding the nuclear facilities that Northeast Utilities (W or Licensee) operates in Connecticut. The Petition has been forwarded to my office for the preparation of a response. Petitioners allege that W has, over the past decade, mismanaged its nuclear facilities in Connecticut and eperated them in flagrant disregard of NRC regulations; that W has failed to fulfill its commitments to the NRC; that W management had concrete particularized knowledge of serious on-going violations of NRC regulations culminating in material misrepresentations to the NRC; that regulatory oversight by the NRC to assure W's compliance with NRC regulations Itas been a blatant and abject failure; that W is in violation of 10 CFR Part 50, Appendix B; and that these failures have culminated in inconsistent and inaccurate Final Safety Analysis Reports at W's nuclear facilities, in Connecticut, thereby posing a significant safety concern for either continued plant operation or decommissioning. The bases for these assertions are W and NRC inspection findings and W documents referred to in the Petition and the amendment, and a VHS videotape. Exhibit A, which accompanied the Petition. The videotape records an August 29 1996, Citizens Regulatory Commission televised interview of a former Millstone Station employee expressing his views on W sanagement.
, operation Areas outsideidentified the designinbasis, the Petiticaand degraded includematerial surveillance testing'he Petition condition.
asserts that this information demonstrates that there are inadequate quality assurance programs at W's nuclear facilities in Connecticut, that W has made material false statements regarding its Millstone units and that safe decommissioning of the Haddam Neck facility, which the Petitioners refer to as Connecticut Yankee, is not possible given the defective nature of the design and licensing basis for this facility. In addition, in the amendment,
-D4i wC 3 ,
e / t) 5 Deborah'Katz and Paul Sunter . Petitioners assert that certain nitrogen calculations performed by W for the facility may not comply with 10 CFR Part 50, Appendix B, and the NRC has failed to identify tits problem. The videotape interview included the fomer esployee's views relating to W's poor management in allowing: degradation of the material condition of the plant poor potential radiation exposure to employees;radwaste practices and harassment, resulting intimid W on andin subsequent illegal termination of employees raising safety concsrns. The NRC has had the videotape transcribed and placed in the Commission't Public Document Room at 2120 L Street, N.W., Washington, DC 20037, and also placed in the local public dorment roces at Rivers Community-Technical College,(594 New London Turnpike, Norwich, CT11 t 06360,(2 Waterford), CT 06385, and (3) the Russell Library,123 Broad Street,the Wa Niddletown, CT 06457. Petitioners request the following actions: immediate susoension or revocation of E 's licenses to operate its nuclear facilities in Connecticut; investigation of possible W material misrepresentations to the NRC; continued ' shutdown of the W facilities until the Department of Justice completes its investigation and the results are reviewed b evaluates and approves W remedial actions;continued y the NRClisting and until tte NRC of the W facilities on tto NRC ' watch list' should W resume ooeration; barring any predecommissioning or decommissioning activity at any W nuclear faci ,ity in Connecticut until W and the NRC take certain identified steps to assure that - such activities can be safely conducted; and initiation by the NRC of an investigation into how it allowed the asserted illegal situation at W's nuclear decade. facilities in Connecticut to exist and cont'nue for more than a In addition, in the amendment, Petitioners request copies of Haddam Neck's nitrogen calculations and an immediate investigation of the need for enforcement action for alleged violation of 10 CFR Part 50, Appendix B. The basis for Petitionars' request that the NRC immediately suspend or revoke the licenses to operate the Haddas Neck and N111 stone facilities is the alleged chronic, negligent management of the nuclear facilities for more than a decade. The Licensee shut down the Haddam Neck plant on July 22, 1996, as required by the facility Technical Specifications, >ecause of concerns that the service water piping from the fan that recirculates containment air may exceed design loads during certain accident conditions. The Licensee determined that these concerns and other hardware and programmatic concerns identified before and during this forced outage should be resolved before W would restart.the . plant. However, on October 9,1996, the joint owners of the Haddam Neck plant stated that an economic analysis of operations, expenses, and the cost of replacement power indicated that a pomanent shutdown of the plant seemed likely. On hcomber 4,1996, the joint owners voted to decommission Haddam Neck instead of restarting the plant. I g .
, /E E
f[ Deborah Katz and Paul Gunter On November 4,1995, the Licensee shut down Millstone Unit I for a scheduled refueling outage. Subsequently, potential violations regarding past refueling practices and operation of the spent fuel pool that were inconsistent with the unit's design basis. The NRC sent a letter to the Licensee on December 13, 1995, requiring that, before the restart of Millstone Unit 1, NU inform the
, of the actions taken to ensure that NRC, pursuant in the future to 10 it would CFR that oparate Section faci 50.54(f)lity according to the terms and conditions of the plant's operating license, the Comm'ssion's regulations, and the plant's updated Final Safety Analysis Report (UFSAR).
In January 1996, the NRC designated the three Millstone units Category 2 plants on the NRC's watch list. Plants in this category have weaknesses that warrant increased NRC attention until the Licensee demonstrates a period of improved perfomance. On February 20, 1996, the Licensee shut down Millstone Unit 2, as required by the unit's Technical Specifications, due to the high pressure safety injection system being declared inoperable. On March 30, 1996, the Licensee shut down Millstone Unit 3 after it found that some containment isolation valves did not meet NRC requirements. In response to a Licensee root-cause analysis of the inaccuracies in the l Millstone Unit 1 UFSAR that identified the potential for the presence of similar configuration-management conditions at Millstone Units 2 and 3, and design configuration issues identified at these units, the NRC sent 10 CFR 50.54(f) letters to the Licensee on March 7 and April 4, 1996. These letters required that the Licensee inform the NRC of the corrective actions taken regarding design configuration issues at Millstone Units 2 and 3 before the restart of each unit. In June 1996, the NRC designated the units at Millstone as Category 3 plants on the NRC's watch list. Plants in this category have significant weaknesses that warrant maintaining them in a shutdown condition until the Licensee can demonstrate to the NRC that it has both established and implemented adequate programs to ensure substantial improvement. Plants in this category require Commission approval before operations can be resumed. On August 14, 1996, the NRC issued a confimatory order directing the Licensee to contract with a third party to implement an Independent Corrective Action Verification Program (ICAVP) to verify the adequacy of its efforts to reestablish the design bases and design controls for the Millstone units. The ICAVP is intended to provide additional assurance, before the restart of a Millstone unit, that the Licensee has identified and corrected existing problems in the design and configuration control processes for that unit. On October 24, 1996, the NRC issued an order directing that, before the restart of any Millstone unit, the Licensee develop and submit to the NRC a comprehensive plar, for reviewing and dispositioning safety issues raised by its employees and ensuring that employees can raise safety concerns without fear of retaliation. The order also directs the Licensee to retain an independent third party to oversee implementation of its comprehensive plan.
o I ( Deborah Katz and Paul Gunter ! The staff's approach to oversight of the W facilities is to ensure that the Licensee will carry out a comprehensive and broad-scope program to identify and correct its weaknesses. In a June 20, 1996, letter to the NRC, the Licensee described its Configuration Management Plan (CMP), which is its principal program to provide reasonable assurance that weaknesses at the Millstone units haye men effectively corrected. The CMP includes efforts to understand the licensing and design-basis issues that led to NRC issuance of the 10 CFR 50.54 The Licensee desc(f) letters and actions to prevent recurrence of those issues. ribed its CMP objective to document and meet each units' licensing and design-basis requirements, and its intention to ensure that adequate programs and processes exist to maintain control of these requirements. A CMP is also in progress at the Haddam Neck Plant. Thus, the significance and number of issues identified at the Millstone units and at Haddam Neck have resulted in the shutdown of all four units. As discussed above, the Haddam Neck facility will not resume operation. By letter dated December 5, 1996, the Licensee for Haddam Neck certified, in accordance with NRC regulations, that it had detemined to permanently cease operations at the Haddam Neck facility and that the fuel had been pemanently removed from the reactor. In addition, I see no need to immediately suspend or revoke the operating licenses for the three Millstone units as these units are currently stut down and are undertaking major efforts in response to NRC orders. Furthermore, the Commission must approve the restart of any of the Millstone units. The basis for the Petitioners request for an immediate detemination of the need for enforcement action for violation of 10 CFR Part 50, Appendix 8, is alleged deficient calculations perfomed by W for the Haddam Neck facility. An event at the Haddam Neck facility resulted in the introduction of a nitrogen gas bubble in the reactor vessel. The Licensee performed calculations to estimate the water level to assess whether the reactor fuel had been uncovered during the event, which presumably are the " nitrogen calculations
- to which the Petitioners refer. The NRC conducted an Augmented Inspection Team 80,. dated October (AIT) review of this event. Inspection Report No. 50-213/96-30, 1996, provides the results of the AIT review. Although the AIT concluded that the event was safety significant, it further concluded that there were no actual consequences. A copy of the AIT report is enclosed that details other actions taken by the Licensee to determine the water level in the reactor vessel including special tests. Subsequent to the AIT report, a predecisional enforcement conference was held in Waterford, Connecticut, on December 4,1996,. which addressed several issues including W's response to this event. I see no basis for an immediate investigation of the need for enforcement action for violation of 10 CFR Part 50, Appendix 8. relating to a11 edged deficient calculations performed by W in response to the event since the reactor vessel has been defueled and the Haddam Neck facility will not resume operation. Consequently, accuracy of the calculations has no present safety impact.
' 4 Deborah Katz and Paul Gunter January 23, 1997 Y. ,
I
- With regard to your request to prohibit NU from decosmissioning any of its reactors in Connecticut, 10 CFR 50.82, " Application for termination of license,' requires that a Licensee submits a post-shutdown decommissionin activities report (PSDAR) to the NRC and a copy to the affected state (s) gprior to or within 2 years following pensanent cessation'of operations. The report must include among other things activitiesalongwithaschedue,fortheirimplementation.a description of the planned decommiss The joint owners of the Haddam Neck plant have not submitted a PSDAR to the Commission. All activities being performed at the Haddam Neck plant are required to comply with its current license.
As the Petition and amendment requests an investigation of NRC oversight activities at NU facilities in Connecticut over the last decade, copies of the Petition, amendment, and videotape have been sent to the NRC's Office of the Inspector General. In accordance with 10 CFR Section 2.206, the NRC will take action with regard to the issues raised in the Petition within a reasonable time. For your i information, I have enclosed a copy of the Notice that is being filed with the Office of the Federal Register for publication. I have also enclosed for your infonsation a cop petition process.y of Ms.the videotape Deborah Katz,transcription and ahas President of CAN, passhlet on the public seen added to the service lists for the Millstone and Haddam Neck facilities to assure that the Petitioners receive all relevant NRC correspondence. i Sincerely OrYsinaleisneaW Prank J. utraslia Frank J. Miraglia, Jr., Acting Director Office of Nuclear Reactor Regulation Docket Nos. 50-245, 50-336, 50-423 and 50-213 DISTRIBLTTION
Enclosures:
see next page
- 1. Federal Register Notice
- 2. Inspection Report No. 50-213/96-80
- 3. Video Transcription
- 4. Pamphlet on the Petition Process cc w/encis: Rosemary Bassilakis, Researcher Citizens Awareness Network 54 Old Turnpike Road Haddam, Connecticut 06438 DOCUMENT NAME:
Licensee and Service List w/o enc 1: 4 G:\MC
- see previous concurrence w .
m - D.ONA.LD.\. PET.206w r .c. 0FFICE SPD-L:PM ] El SPD-L:LAttl r.cr.o SPD-4tW/ l TECH ED* OGC/ /L///U NAME DMcDona1 V L I L8erry W "
,,d"(/ RSanders Rfkf/s DATE 01 97'
]g 97 '
g g/ g 0FFICE SP0:D NR8 NAME WTr!*Ws diiirii ;-ia DATE 01/5 & 97 4 01? fig 7 01/ /97
"' 01/ /97 01/ /97 0FFICIAL RECORD COPY
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. 9
i e i Deborah'Katz and Paul Gunter / With regard to your request to prohibit NU from decommissioning any of its reactors in Connecticut,10 CFR 50.82, ' Application for termination of license," requires activities report that a Licensee submits a post-shutdown decommissioning to or within 2 year (s following permanent cessationThe must include ofreport operations.PSDAR) activitiesalongw<thascheduefortheirlaplementation.amog other thinps, a descript The joint owners of the Haddam Neck plant have net submitted a PSDAR to the Commission.All with its current license. activities being performed at the Haddam Neck plant are require As the Petition and amendment requests ahi investigation of NRC oversight activities at NU facilities in Connecticut over the last de::ade, copies of the Petition, Inspector amendment, General. and videotape have been sent to the NRC's Office of the i to the issues raised in the Petition within a reasonable For your time.In accord l information, I have enclosed a copy of the Notice that is being filed with the Office of the Federal Register for publication. I have also enclosed for your information a cop petition process.y of the videotape transcription and a pan >hlet on the public Ms. Deborah Katz, President of CAN, has seen added to the Petitioners receive all relevant NRC correspondence. service lists for the M Sincereiy, 4ak. L. l]t Frank J. @ ragl a d ., A d ng Director Office of Nuclear Reactor Regulation
Enclosures:
- 1. federe? Aegister Notice
- 1. Inspection Report No. 50-213/96-80
- 3. Video Transcription
- 4. Pamphlet on the Petition Process cc w/encis: Rosemary Bassilakis, Researcher Citizens Awareness Network 54 Old Turnpike Road Haddam, Connecticut 06438 - - -
Licensee and Service List
-}}