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Category:E-Mail
MONTHYEARML22335A2802022-11-0404 November 2022 11-4-2022 Email Transmitting Draft Questions Pertaining to Pilgrim ISFSI Exemption Request ML22270A0422022-09-26026 September 2022 Acknowledgement Email for Holtec'S Request for Reporting Exemption with Regards to the Pilgrim ISFSI Annual Radioactive Effluent Release Report (Docket No. 05000293) ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22007A2602021-12-0606 December 2021 E-mail from P. O'Brien, Holtec, to A. Snyder, NRC, on Pilgrim Effluent Discharge ML21287A6192021-10-14014 October 2021 E-mail from S. Phillips, MEMA, to A. Snyder, NRC, Pilgrim Nuclear Power Station, Commonwealth of Massachusetts Consultation Response to Amendment Review for Emergency Preparedness ML21266A2512021-09-23023 September 2021 Consultation with Commonwealth of Massachusetts Regarding Proposed Amendment Application for Emergency Plan and Emergency Action Levels ML21266A2772021-09-23023 September 2021 HDI Clarification of Exemption Requested from 10 CFR 20, Appendix G, Section Iii.E ML21267A0012021-09-23023 September 2021 E-mail from A. Snyder, NRC, to A. Sterdis, Holtec, - Pilgrim Nuclear Power Station - Request for Exemption from 10 CFR 20, Appendix G, Section Iii.E Acceptance Review ML21257A3832021-09-15015 September 2021 E-mail from A. Snyder, NRC, to A. Sterdis, Holtec, - Pilgrim Nuclear Power Station - Follow-on Request Re Request for Additional Information 2 Pilgrim - License Amendment Request Independent Spent Fuel Storage Installation Only Emergency Pl ML21211A5912021-07-22022 July 2021 Consultation Response from Commonwealth of Massachusetts Regarding Proposed Pilgrim ISFSI Only Technical Specifications ML21211A5162021-07-22022 July 2021 Consultation Response from Commonwealth of Massachusetts Regarding Proposed Pilgrim ISFSI Only Physical Security Plan ML21200A2352021-07-13013 July 2021 Consultation Request to Commonwealth of Massachusetts Regarding Proposed Pilgrim ISFSI Only Technical Specifications ML21200A1522021-07-13013 July 2021 Consultation Request to Commonwealth of Massachusetts Regarding Proposed Pilgrim Isfi Only Physical Security Plan ML21176A1842021-06-25025 June 2021 Email from HDI Regarding Pilgrim Nuclear Power Station Training ML21180A0582021-06-17017 June 2021 Email from Region I Regarding Pilgrim Nuclear Power Station Inspection - EA-13-132 ML21097A0402021-04-0606 April 2021 E-Mail Consult with Commonwealth of Mass Re - Amendment Application - Physical Security Plan for the Pilgrim Nuclear Power Station L-20-092, Email Pilgrim Nuclear Power Station-Exemption from Annual Force-On-Force Exercise Requirements of 10 CFR Part 73, Appendix B,2020-12-10010 December 2020 Email Pilgrim Nuclear Power Station-Exemption from Annual Force-On-Force Exercise Requirements of 10 CFR Part 73, Appendix B, L-20-096, Supplemental Information to Support Physical Security Plan Revision and License Amendment Request to Incorporate Alternate Measures - Holtec Email Dated December 10, 20102020-12-10010 December 2020 Supplemental Information to Support Physical Security Plan Revision and License Amendment Request to Incorporate Alternate Measures - Holtec Email Dated December 10, 2010 ML20328A2982020-11-16016 November 2020 Response from Commonwealth of Massachusetts on No Significant Hazard for Pilgrim ISFSI Amendment to Address ISFSI II Dated November 16, 2020 ML20297A2372020-10-22022 October 2020 Request for Additional Information - HDI Fleet Decommissioning Quality Assurance Program ML20266G4032020-09-22022 September 2020 Acceptance Review Email - Request for Approval of HDI Fleet Decommissioning Quality Assurance Program, Revision 0 ML20163A6802020-06-11011 June 2020 Confirmation of the Scope of the Requested Regulatory Relief for Pilgrim Security Qualifications ML20280A1912020-04-17017 April 2020 Request for Additional Information- Clarifying Information for Pilgrim ISFSI Physical Security Amendment Application ML20269A3542020-03-0505 March 2020 CFR 26.717 Reports 2019 Transmittal Email ML19336A0302019-11-27027 November 2019 OEDO-15-00479 - Re 2.206 Petition Regarding Pilgrim Nuclear Power Station'S Current Licensing Basis for Flooding ML19336A0332019-11-26026 November 2019 OEDO-15-00479 - E-mail to Petitioner - 2.206 Petition Regarding Pilgrim Nuclear Power Station'S Current Licensing Basis for Flooding (CAC No. MF6460; EPID L-2015-CRS-0002)- Issuance of Final Director'S Decision ML19331A1952019-11-21021 November 2019 NRR E-mail Capture - (External_Sender) Pilgrim Nuclear Power Station - Commonwealth Consultation Response - Amendment Regarding Site Emergency Plan and Emergency Action Level Scheme ML19331A1732019-11-12012 November 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station -Consult with Commonwealth - Amendment Regarding Cyber Security Plan ML19331A1642019-11-0505 November 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station -Consult with Commonwealth - Amendment Regarding Site Emergency Plan and Emergency Action Level Scheme ML19331A1792019-11-0505 November 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - EA and Fonsi for Pilgrim Emergency Planning Exemption CY-19-007, LTR-19-0441 Henrietta Cosentino, E-mail SECY-19-0078 Request by Entergy Nuclear Operations Inc. for Exemptions from Certain Emergency Planning Requirements for the Pilgrim Nuclear Power Station2019-11-0404 November 2019 LTR-19-0441 Henrietta Cosentino, E-mail SECY-19-0078 Request by Entergy Nuclear Operations Inc. for Exemptions from Certain Emergency Planning Requirements for the Pilgrim Nuclear Power Station ML19275H1962019-09-24024 September 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - Consult with Commonwealth - Amendment Regarding Permanently Defueled Technical Specifications (PDTS) ML19239A0372019-08-26026 August 2019 E-mail from Entergy Dated August 26, 2019, Notification of Pilgrim License Transfer ML19239A0262019-08-23023 August 2019 LTR-19-0330 Janet Azarovitz, E-mail a Plea for More Time and Reasonable Discussion Including the Citizens of the Commonwealth in the Sale of the Pilgrim Nuclear Power Station ML19234A2072019-08-20020 August 2019 LTR-19-0328 Lawrence Delafield, President, Six Ponds Improv Assoc., Plymouth, Ma, Ltr Requests NRC to Postpone Consideration of Transferring the Licenses for the Pilgrim Nuclear Power Until the NRC Has Answered Concerns by Pilgrim Watch, Se ML19232A4032019-08-20020 August 2019 LTR-19-0322 Diane Turco, Director, Cape Downwinders, Massachusetts, Letter/E-mail Requests Suspension of the Pilgrim License Transfer from Entergy to Holtec Until the Adjudicatory Hearing Is Held and Raised Contentions Are Resolved ML19308A9942019-08-19019 August 2019 Entergy Nuclear Operations, Inc. Confirmatory Order Rescission Supplemental Information ML19226A3912019-08-14014 August 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - EA and Fonsi for Pilgrim Decommissioning Trust Fund Exemption (Holtec) ML19226A3962019-08-14014 August 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station -Consult with Commonwealth - Conforming Amendment in Support of Pilgrim License Transfer Application ML19226A1212019-08-13013 August 2019 OEDO-15-00479-2.206 Petition Regarding Pilgrim Nuclear Power Station'S Current Licensing Basis for Flooding - Status (CAC No. MF6460; EPID L-2015-CRS-0002) ML19227A1032019-08-0707 August 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - Draft Wording for Potential Condition of License Transfer Order ML19207B3662019-07-26026 July 2019 NRR E-mail Capture - Pilgrim - RAI Direct and Indirect Transfer of Lic.; Conforming Lic. Amend.; Req. for Exemption 10 CFR 50.82(A)(8)(I)(A) for Holtec Decom. International, Llc ML19176A3452019-06-25025 June 2019 2.206 Petition Regarding Pilgrim Nuclear Power Station'S Current Licensing Basis for Flooding - Information (OEDO-15-00479) (CAC No. MF6460; EPID L-2015-CRS-0002) ML19154A0652019-06-0303 June 2019 NRR E-mail Capture - Pilgrim - Permanent Cessation of Power Operations ML19154A5242019-06-0303 June 2019 NRR E-mail Capture - RAI - Pilgrim Post-Decommissioning Technical Specifications (PDTS) License Amendment Request (LAR) ML19161A2122019-05-20020 May 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - Acceptance of License Amendment Request to Remove Cyber Security Plan Requirements ML19123A0332019-05-0101 May 2019 NRR E-mail Capture - Logbook Entry: 05/01/2019 Endangered Species Report Regarding a Confirmed Sighting of North Atlantic Right Whale(S) (Balaena Glacialis) ML19122A4912019-04-29029 April 2019 NRR E-mail Capture - Logbook Entry: 04/29/2019 Regarding the Confirmed Sighting of Ten North Atlantic Right Whales (Balaena Glacialis) ML19108A2372019-04-18018 April 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - Acceptance of Requested Licensing Action, Proposed Exemptions from 10 CFR 50.54(w)(1) - On-Site Property Damage Insurance ML19108A2362019-04-18018 April 2019 NRR E-mail Capture - Pilgrim Nuclear Power Station - Acceptance of Requested Licensing Action, Proposed Exemptions from 10 CFR 140.11(a)(4) - Primary and Secondary Liability Insurance 2022-09-26
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Anthony T. Gody, Jr. Director Division of Reactor Safety, Region II U.S. Nuclear Regulatory Commission James A. Isom, Senior Reactor Operations Engineer Reactor Inspections Branch, DIRS, NRR U.S. Nuclear Regulatory Commission Via Email: Tony.Gody@nrc.gov; James.Isom@nrc.gov November 27, 2017 Pilgrim Watch (PW) and The Town of Duxbury Nuclear Advisory Committee (DNAC) Object to Industry Self- Assessments Pilgrim Watch is a non-serves the public interest on issues regarding the Pilgrim Nuclear Power Station specifically, and nuclear power in general. The organization is located at 148 Washington Street, Duxbury, Massachusetts, 02332. Its membership extends throughout the Commonwealth. The Board of Selectmen appoint the Town of Duxbury Nuclear Advisory Committee to advise the town on radiological emergency response and all other matters pertaining to the potential impact on the town from the Pilgrim Nuclear Power Station, located near Duxbury. PW and DNAC object to the proposal to replace NRC engineering assessments with industry self-assessments that the industry then would mail to NRC. Independent assessment is our only hope that safety will not be further compromised resulting from: aging nuclear reactor components; in maintenance and replacement of parts; workers intimidated by management from reporting problems; ineffective management; and other factors. Despite Also, public transparency will be lost ess. Pilgrim - an example why NRC assessment is required Pilgrim provides the perfect example why NRC nuclear safety inspections are necessary and why industry self-assessments would be dangerous. Pilgrim cannot be counted on to conduct any complete or accurate self-assessment. The and consistently failed to follow established procedures, to report problems, or to take corrective actions even when the NRC tells it to do so. Pilgrim, like other reactors in market economies, is losing money because it cannot compete in gas and wind. At the same time Pilgrim is 47 years old and requires considerable maintenance. But, because Pilgrim is losing money, Entergy has been unwilling to invest in the reactor at the 2 resulted in getting Pilgrim into deeper trouble. Finally, NRC dropped Pilgrim into the lowest safety category, Category 4. It took multiple NRC inspections for the NRC to discover and document Entergywould have self-assessed and reported the reasons that Pilgrim is, and belongs to be, in the lowest safety category.? We give very small odds that any Entergy self-assessment would look for, let alone report, anything that might require it to spend any significant amount of money. Energy decided to shut the reactor for good by June 1, 2019 or sooner because Pilgrim is losing money, and has repeatedly asked the NRC to -ordered safety improvements. We simply cannot understand how the NRC would conclude that changing from NRC inspections to industry assessment does not place citizens at significantly greater risk.. This is true not just for reactors like Pilgrim that are already in low safety categories. The liklihood of any rector honestly reporting its problems and risking being placed in a lower category is slim-to-nonexistent if industry is allowed to self-assess itself. Welcome to nuclear Lake Wobegon, where every reactor is a star. The danger of turning over inspections from NRC to Entergy is clear from reading a leaked Preliminary Inpection Report (December 2016)Jackson. . This report included a long list of flaws at the plant none of which Entergy had bothered to report - that NRC inspectors observed during only the initial week of the inspection. In the report, Donald Jackson, said that: "The plant seems overwhelmed just trying to run the station." Who seriously believes Entergy would make that comment? The list of unreported Pilgrim failures that the NRC found and specified in the email were: failure of plant workers to follow established industry procedures, broken equipment that never gets properly fixed, lack of required expertise among plant experts, failure of some staff to understand their roles and responsibilities, and a team of employees who appear to be struggling with keeping the nuclear plant running been hastily developed and implemented, and some have been circumvented as they were deemed too hard to complete. We are observing current indications of a safety culture problem that a bunch of talking probably won't fix." Recurring problems with the emergency diesel generators at the plant highlight "poor engineering expertise, no communication with the shift manager and poor corrective action."
3 Subsequent quarterly NRC inspection reports show continued pattern of ignoring maintenance on items that NRC to compromise essential safety systems in a radiological emergency. (See, for example, Pilgrim Nuclear Power Station Integrated Inspection Report 05000293/2017003) Once again, the evidence that the NRC seems clear - if Entergy were to write its own reports, it would ignore inspecting and reporting on those same items. Workers Intimidated: We are aware that Pilgrim workers, knowing that there are components that needed maintenance or replacement, did not report the problems to management because they understood management was unwilling to make the investment - better keep quiet, especially if the worker hoped to be offered a job at another site aftnot be subject to this type of pressure. Bias: NRC inspectors, unlike industry, do not have a stake in the game and are not blinded by tradition - the way the site has always operated works and nothing will go wrong. Workers also live in silos and do not see the big picture that an outside inspector can. Transparency: performance at operating reactors and describes the tests and the grading processes behind the results. The public meetings, reports and press articles generate political pressure that are valuable in placing pressure on the industry and NRC to take corrective action. This would be lost if industry simply provided NRC written reports of its assessments. Few members of the public scour Adams so public input and pressure would diminish. Diminished Safety- Accident Precursors Show the need for Increased NRC Inspection, not Self-Assessment. Accident Precursors: The NRC defines an accident sequence precursor (ASP) stulated Industry claims the reactor safety record has continuously improved so that NRC inspection is not needed. But ficant unless there was an accident, and . The record is particularly poor for BWRs such as Pilgrim. As said in Figure 8 (below) of the report, occurrence rate of precursors at BWRs exhibits a statistically significant increasing trend (p-value = 0.001) over the past twenty years;and, Pilgrim has the most (23) precursors associated with a single unit NPP, including four over the past 5 years. (Report, p 21) 4 Conclusion Nobody would recommend letting students evaluate their SATs, GREs, LSATs or MCATs -although the worst that could happen if they did would be admitting unqualified students. But, the worst that could happen letting licensees self-evaluate is a catastrophe a TMI, Chernobyl or Fukushima. It is time for NRC to recognize this, especially as reactors age and many operating on the cheap as merchant plants. No, we do not want Entergy in charge of its own engineering inspections; and fail to understand how the NRC could rationally expect the operator of a failing both structurally and economically - bligations. Thank you for your consideration. Mary Lampert Pilgrim Watch, director 148 Washington Street Duxbury, MA 02332 Tel. 781-934-0389/Email: mary.lampert@comcast.net Rebecca Chin Town of Duxbury Nuclear Advisory Committee, co-chair 31 Deerpath Trail, North Duxbury, MA 02332 Tel. 781-837-0009/Email: rebeccajchin@hotmail.com