ML051330090

e-mail to Nancy Burton Millstone'S Degrading Conditions

ML051330090
Person / Time
Site:	Millstone
Issue date:	03/30/2005
From:	Emch R NRC/NRR/DRIP/RLEP
To:	Burton N - No Known Affiliation
References
NUREG-1437
Download: ML051330090 (6)

Text

Richard Emch - Re: Millstone's Degrading Conditions - age D1 From: Richard Emch To: NancyBurtonEsq ?aol.com Date: 3/30/05 12:49PM

Subject:

Re: Millstone's Degrading Conditions Ms. Burton:

As I indicated to you in the email message dated March 28, 2005, the comment period for the draft Supplemental Environmental Impact Statement for License Renewal of Millstone Power Station, Units 2 and 3 (NUREG-1437, Supplement 22) ended on March 2, 2005. As indicated in the Federal Register notice dated December 9, 2004, and at the public meeting on January 11, 2005, we accepted comments for consideration received after the deadline to the extent practicable. We have accepted your comments dated March 16, 21, and 22, 2005; however, in light of our overall review schedule, it became no longer practicable to accept comments for consideration on March 23. 2005, three weeks after the noticed comment deadline. The time period for acceptance of comments on NUREG-1437, Supplement 22, is closed.

Rich Emch

>>> <NancyBurtonEsq @aol.com> 03/30/05 12:06PM >>>

CONNECTICUT COALITION AGAINST MILLSTONE www.mothballmillstone.orq (http://www.mothballmillstone.orp)

March 30, 2005

Dear Mr. Emch:

Please include the letter which appears below and which we have submitted to The New London Day for publication, in the record of your proceedings involving the Millstone Environmental Impact Statement for Millstone relicensing.

Thank you for your assistance.

Sincerely, Nancy Burton Tel. 203-938-3952 CONNECTICUT COALITION AGAINST MILLSTONE www.mothballmillstone.orq (http://www.mothballmillstone.orq)

March 30, 2005 To The Editors:

We must give The New London Day a 'thumbs-down" for keeping the community in the dark about degrading conditions at the Millstone Nuclear Power Station which endanger the public.

Did we attend the same meeting as your reporter who wrote the article entitled "NRC Gives Millstone a Thumbs Up for Safety" (March 30, 2005)?

At a meeting on March 29, the Connecticut Coalition Against Millstone shared the scathing reviews the U.S. Nuclear Regulatory Commission has given of Millstone's performance during the year 2004.

Space limitations require us to cite only a few specific examples below.

Please go to our website, www.mothballmillstone.oro (http://www.mothballmillstone.ora) for an expose of Dominion's safety breaches committed during the year 2004

• A spent nuclear fuel rod broke at Unit 2 on August 5 while operators were

Richard Emch - Re: Millstone's Degrading Conditions Page 2l inspecting fuel assembly failures. The lethal rod fragmented and it took a week for Dominion to recover all the pieces.

• During a draindown of the vital reactor coolant system at Unit 3, the worker assigned to monitoring the refuel pool level left his assignment before completion and the critical draindown occurred in his absence for 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

Operators were left to rely on the remote camera indication of the refuel pool level - and they read it incorrectly. The NRC correctly called this safety breach "more than minor" because it "affected the likelihood of causing a loss of reactor water inventory to the point that shutdown cooling could be lost."

• Millstone Unit 3 suffered repetitive failures of leakage tests for vital water systems. Over a span of eight years - including three years of Dominion operations - the same known failure mechanism resulted in a 50 per cent failure rate for critical check valves.

• Unit 2's reactor trip breaker failed to shut remotely. This is alarming, given Unit 2's unusual propensity to suffer unexpected and dangerous spontaneous "trips" or shutdowns.

• Unit 2 suffered four reactor "trips" during the inspection period due to equipment failures or personnel error.

• Dominion allowed Millstone's "high-range" radiation monitor - key to measuring radiation doses to the public - to become seriously degraded.

• On April 4, while Dominion was preparing to remove the reactor vessel head at Unit 3, an overhead crane malfunctioned, causing significant damage to a critical lifting rig and damaging personnel safety equipment.

• On April 14, workers discovered that a fuel assembly "had moved several inches upon coming out of the core and would not travel into the mast without causing an overload condition."

• Unit 2 used materials from an unqualified vendor.

• At Unit 2, a reactor trip breaker failed to shut.

• The Unit 2 spent fuel pool ventilation system was allowed to become degraded.

• Inspectors discovered a critical modification was made to the Unit 2 spent fuel pool water level indicator without documentation.

• At Unit 2, a loss of shutdown cooling occurred, resulting in an uncontrolled reactor coolant system temperature increase of 14 degrees Fahrenheit.

• Dominion repeatedly violated Technical Specifications (its formal licensing conditions) throughout 2004. These "Tech Specs" are legal requirements the public has a right to expect will be carried out and enforced.

• NRC inspectors discovered boric-acid buildup on the Unit 3 reactor vessel head worse than what was reported by Dominion.

• Dominion violated its Technical Specifications when an electrical system failure required it to stop reactivity additions to the Unit 3 nuclear reactor; contrarily, operators increased reactivity and heat buildup.

• The emergency diesel generator was allowed to develop a "through-wall" leak at Unit 2.

• The emergency building filtration system at Unit 2 was allowed to degrade.

• A thermal performance test of a vital system at Unit 3 was terminated prior to completion.

• Inspectors discovered that modifications to Unit 2's charging system were not supported by calculations or test data.

• Dominion's failure to properly employ engineering controls led to serious radiation exposures to two workers who handled contaminated air filters at Unit 2 on September 29.

• Unit 2 suffered "excessive leakage" in the radioactive cooling system because of a pump failure.

• The Unit 2 intake structures suffered degrading conditions on November 5,

Richard Emch - Re: Millstone's Degrading Conditions _ _ Page3 potentially jeopardizing the critical reactor cooling system, due to high winds and high seas.

In their inspection reports of 2004, NRC's inspectors concluded that Dominion has failed to address degraded conditions at Millstone. NRC inspectors gave these examples:

1. Operators did not recognize the significance of several steam generator code "safeties" that had lifted subsequent to reactor trips at Unit 2;

2. Operators did not recognize that a failure of a vital inverter made the electrical train credited, as required by the Technical Specifications, inoperable at Unit 3;

3. Operators did not understand the potential significance of air found in the discharge piping of the RHR (residual heat removal) system at Unit 3 and their evaluation was not technically supported;

4. Operators did not adequately consider the effects of small oil leaks on high head safety injection pumps at Unit 3;

5. Operators and engineers at Unit 2 determined compensatory cooling measures installed in a direct current switchgear room at Unit 2 would ensure the availability of the switchgear, while existing technical evaluation stated just the opposite.

NRC inspectors concluded that during the year 2004, they "found a lack of rigor by Dominion related to both the understanding of the effects of degraded conditions and the technical bases used to evaluate degraded conditions

... resulting in violations [of Millstone's licensing requirements]."

The blistering NRC inspection reports demonstrate that Dominion is routinely operating Millstone in violation of its legal requirements and endangering the public on a daily basis.

Astonishingly, when the NRC inspectors presented their review of Millstone's 2004 performance history on March 29 at a public meeting, they stated that Dominion's good performance during 2004 warranted reduced NRC inspections.

The NRC's conduct is disturbing, especially in light of the following:

On December 31, 2004, the NRC completed a special inspection of Dominion

's fire protection system. The NRC inspectors randomly chose six areas to inspect at Unit 2. One was the turbine building. The NRC reported: "No findings of significance were identified."

On January 14, 2005, just two weeks later, a fire broke out in the Unit 2 turbine building. That fire caused an unprecedented all-site evacuation by non-emergency personnel. That fire also disabled Millstone site security: as a result of the January 14 fire, Dominion lost control over its perimeter fence and lost its ability to exclude intruders and keep track of personnel movement within the nuclear plant.

Dominion operated Millstone in the year 2004 as though no one was watching.

When the NRC inspectors announced they will reduce their inspections at Millstone during the next year because of Dominion's "good performance" in 2004, the NRC was really telling Dominion it has carte blanche to disregard its licensing requirements

Pacie 411 Richard Emch - Re: Millstonq's~

- Degrading Conditions Millstone's Degrading qqpqLfitqor _ tPage 4 4 Does the NRC think no one is watching?

Sincerely, Nancy Burton Nancy Burton is a founder of the Connecticut Coalition Against Millstone.

CC: Andrew Kugler; Ann Hodgdon; Brooke Poole; Diane Screnci; Francis Cameron; Neil Sheehan; Pao-Tsin Kuo

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Re: Millstone's Degrading Conditions Creation Date: 3/30/05 i2:49PM From: Richard Emch Created By: RLE@nrc.gov Recipients Action Date & Time aol.com Transferred 03/30/05 12:50PM NancyBurtonEsq (NancyBurtonEsq@aol.com) nrc.gov kpl-po.KPDO Delivered 03/30/05 12:49PM DPS CC (Diane Screnci) Opened 03/30/05 12:49PM NAS CC (Neil Sheehan) Opened 03/30/05 01:11PM nrc.gov owf4.po.OWFNDO Delivered 03/30/05 12:49PM AJK1 CC (Andrew Kugler) Opened 04/04/05 04:46PM PTK CC (Pao-Tsin Kuo) Opened 03/30/05 05:08PM nrc.gov owf5_po.OWFN_DO Delivered 03/30/05 12:49PM APH CC (Ann Hodgdon) Opened 03/30/05 05:07PM BDP CC (Brooke Poole) Opened 03/30/05 03:27PM FXC CC (Francis Cameron) Opened 03/30/05 01:21PM Post Office Delivered Route aol.com kpl-po.KPDO 03/30/05 12:49PM nrc.gov owf4_po.OWFN_DO 03/30/05 12:49PM nrc.gov owf5_po.OWFN_DO 03/30/05 12:49PM nrc.gov Files Size Date & Time MESSAGE 18058 03/30/05 12:49PM Options Auto Delete: No Expiration Date: None Notify Recipients: Yes Priority: Standard Reply Requested: No Return Notification: None

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