ML20056H553

Discusses Proposed Changes in Regulatory Requirements by NRC & Outlines Position Re Degredation of Marginal Safety Requirements at Brunswick 1 & 2

ML20056H553
Person / Time
Site:	Brunswick
Issue date:	05/11/1993
From:	Shackelford R AFFILIATION NOT ASSIGNED
To:	Dey M NRC
Shared Package
ML20056H548	List: ML20056H547 ML20056H553
References
CCS, NUDOCS 9309100059
Download: ML20056H553 (4)

Text

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TO: DR. MON! DEY-US NUCLEAR REGULATORY COMMISSION FROM: RON SHACKELFORD 341-11 SOUTH COLLEGE ROAD, SUITE 100 -

WILMINGTON, NC 28403  !

1-919-452-5200 MAY 11, 1993 DEAR DR. DEY:

THANK YOU FOR YOUR TIME ON THE PHONE THIS MORNING AND YOUR WILLINGNESS TO LISTEN AS I REDUCED FAIRLY COMPLEX ISSUES TO

" LAYMAN'S TERMS".

i AS I SAID, I AM CONCERNED ABOUT PROPOSTD CHANGES IN REGULA10RY REQUIREMENTS UNDER CURRENT CONSIDERATION BY THE NRC. HAVING MISSED THE WORKSHOP ON APRIL 27 & 28 I WOULD LIKE TO BRIEFLY OUTLINE MY POSITION'ON THE8E ISSUES, BOTH IN TERMS OF DEGREDATION OF MARGINAL-SAFETY REQUIREMENTS AT BRUNSWICK 1 & 2 AND, MORE IMPORTANTLY, THE POSSIDLC ECONOMIC IMPLICATIONS OF CP&L'8 CONTINUED OPERATION OF THE TWO AGING REACTOR $.

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FIRST, BASED ON INFORMATION AT HAND, IT SCEMS THE.NRC IS ON THE VERGE OF ERODING A LONO-STANDING PHILOSOPHY OF DEFENSE-IN-DEPTH AND  !

REDUNDANCY OF SAFETY SYSTEMS FOR OPERATING NUCLEAR PLANTS. MY JUSTIFICATION FOR THIS BELIEF IS BASED ON PROPOSALS CURRENTLY UNDER i CONSIDERATION TO REDUCE OR ELIMINATE LEAK RATE TESTING, WEAKEN FIRE )

l PROTECTION RATINGS BY ELIMINATING 3-HOUR FIRE BARRIER REOUIREMENTS

( AND RELATED 1-HOUR REPORTING PROCECURES), REDUCTION OF REGULATORY  !

REQUIRE 5ENTS FOR COMBUSTIBLE GAS CONTROLS, AND REDUCTION OF PLANT SECURITY REQUIREMENTS. -

i WN ALL OF THESE ISSUES n ,5MMECIFICALLY APPLIED TO BRUNSWICK 1 & 2 j

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LE AVE ~ME~~ QUITE CONCERNED AS AN AREA RE81 BENT AND RATEPAYER.

ALTHOUGH SUCH ACTION MIGHT PROVIDE CP&L REQULATCRY RELIEF; I FAIL TO SEE HOW SUCH ACTION CAN BE JUSTIFIED WHEN IN SALP REMARKS LAST YEAR, NRO STATED ...ThE CP&L ORGANIZATION IS NOT EFFECTIVE IN IDENTIFYING PROBLEMS VIA SELF-ASSESSMENT NOR IS IT PROACTIVE IN CORRECTING INTERNALLY IDENTIFIED PROBLEMS. THE CONTINUING REPETITIVE PRO 8LEMS EXPERIENCED WITH WORK CONTROL AND PROCEDURAL ADHERENCE ARE INDICATIVE OF THIS."  ! ALSO NOTE THAT WHEN THE NRC PLACED BRUNSWICK 1 & 2 ON ITS " WATCH LIST" (JULY 1992), IT STATED "A5 AN ASING STATION, BRUNSWICK HAS HORE EQUIPMENT FAILURES (THAN NEWER FACILITIE8] AND THE MORE FAILURES THEY HAVE, THE MORE l l

REACTIVE THE [ BRUNSWICK) STAFF BECOMES. THE REACTIVE THINGS KEEP j COMING. 80 THE DEFERRED LIST KEEPS GROWING AND THEY NEVER GET i

FIXED...THE PLANT TENDS TO DECLINE FA8TER THAN THEY KEEP UP WITH IT."

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l CP&L INTENDS TO SPEND ALMOST A QUATITER BILLION DOLLARS IN ANNOUNCED PLANS TO REPAIR BRUNSWICK 1 & 2 OVER THE NEXT FIVE YEARS AND, HOPEFULLY. GET A HANDLE ON THEIR MAINTENANCE BACKLOG. IN STUDYING SUCH PLANE AT OTHER FACILITIES. I AM CONVINCED THAT COST OVERRUNS ARE THE RULE RATHER THAN hHE EXCEPTION. ULTIM4TELY, I FEEL THAT AS MANY AS 25 AGING REACTORS WILL FACE EARLY DECOMu!SSIONING IN THE NEXT DECADE, AS RATEPAYERS REBEL AGAINST STAGGERING MAINTENANCE l COSTS. BRUNSWICK 1 & 2 SEEM DESTINED TO BE AMONG THOSE MOTHBALLED.

WHEN I CONSIDER THE ADDED CERTAINTY 0F DECOMMISSIONING COST OVERRUNS, ! OUESTION ESTIMATES OF CP&L'S SHARE OF SUCH EXPENSES r

l (BRUNSWICK 1- 8176.7 MILLION AND BRUNSWICK 2- $162.4 MILLION).  !

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EXPERIENCE AT YANKEE R0WE, RANCHO SECO, SHOREHAM, AND FORT ET . -

l VRAIN SUPPORT THE NOTION THAT ACTUAL COSTS MAY BE MORE TNAN DOUBLE THOSE PLANNED. ,

DR. DEY,. THE NRC'S CHANGES CURRENTLY UNDER CONSIDERATION WILL DO LITTLE MORE THAN INCREASE POTENTIAL RISKS TO THE PUBLIC, BOTH IN RELATION TO SAFETY AND ECONOMIC LIABILITY.* SY RELAXING CURRENT STANDARDS, 1 AM CONVINCED THAT YOU WILL DO LITTLE MORE THAN OELAY j THE INEVITABLE. WOULD LIKE THE OPPORTUNITY TO DISCUSS THIS MATTER WITH YOU OR APPROPRIATE REGULATORY 0FFICI ALS IN PERSON, PREFERABLY AT A PUBLIC HEARING IN WILMINGTON (OR, IF NECESSARY, IN 9

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ff MEANWHILE, WASHINGTON) BEFORE ANY FINAL DETERMINATION 18 MADE.

PLEASE PROVIDE ME WITH THE APRIL 27 & 28 HANDOUTS YOU PROMISED TH MORNING, ALONG WITH A COPY OF THE 11#24/92 rEDERAL REGISTER RELATIVE To THESE MATTERS, I UNDER, STAND ANOTHER MEETING OF INDUSTRY OFFICIALS IS SCHEDULED FOR THIS TH,URSDAY IN WASHINGTON AND THAT THE PUBLIC COMMENT PERIOD 18 TO EXP!RE AT THAY TIME.

THIS COMMUNICAT10N TO APPROPRIATE THEREFORE, PLEASE FO,RWARD PLEASE FEEL FREE CHANNELS S0 IT CAN BE INCLUDED AS PUBLIO COMMENT ONCE TO CALL OR WRITE AT ANY TIME IF I CAN BE OF ASSISTANCE.

AGAIN, THANKS FOR YOUR HELP IN THIC MATTER. ,

SINCERELY, ,

RON SHACKELFORD THE COASTAL ALLIANCE FOR A SAFE ENVIRONMENT ,

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