ML20141F217

Commends NRC for tough-minded Stance Re B Kenyon Persistent Reassurances of Millstone Restart Readiness & Strongly Urges NRC Maintain Posture Until Public Has Concrete Reassurances of Readiness

ML20141F217
Person / Time
Site:	Beaver Valley, Millstone
Issue date:	04/30/1997
From:	Bailey L AFFILIATION NOT ASSIGNED
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML20141F179	List: ML20141F173 ML20141F200 ML20141F217
References
NUDOCS 9707020157
Download: ML20141F217 (4)

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Ms. Lois E. Bailey 51 Hanover-Versailles Rd.

Baltic, CT 06330 April 30, 1997 Dr. Shirley Ann Jackson c/o U.S. Nuclear' Regulatory Commission Washington, D.C. 20555 j

Dear Dr. Jackson:

! It has come to the attention of The Citizens' Regulatory i

! Commission of Waterford through recent articles in The Day  ;

that in spite of Bruce Kenyon's persistent reassurances ,

of Millstone ~ restart-readiness, you and other N.R.C. officials l

, have.found that N.U. still failing to provide convincing, '

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specific evidence of that readiness. We commend you for your l tough-minded stance and strongly urge you to maintain that posture until we, the public,can also have concrete reassurances of a readiness we feel they are far from achieving. N.U. has not only lied to the public but continues to withhold vital plant .

systems' condition information your organization must provide in '

its. stead. The N.R.C. has a duty to us to do so through your public reports and documents, which we expect to be timely, honest and complete in updating us on current Millstone operations, plant overhaul and restart planning.

, Dr. Jackson, I am enclosing a fifteen-point agenda developed' l by my organization we feel Northeast Utilities MUST accept l in order to demonstrate any semblance of readiness for restart.

Please study these criteria, a copy of which has been sent to Wayne Lanning, Jacques Durr and Philip McKee, and make them part of your organization's agenda in evaluating Millstone.

Though we approve of what has been reported in the press ,

as N.R.C's current tough-minded stance towards N.U., because you ]

refused last December to accept outside evaluation from qualified ,

experts outside the N.R.C. and the utility, because your agency l broke'it pledge of last Summer.NOT to approve the hiring by N.U.

of any consultant having done business with the utility within ,

the last' ten years by hiring Sargent and Lundy, who has done 1 over $500,000 worth of business with N.U., and, lastly, because you have approved the evaluation of only a small pe tage of .

designated safety- or risk-related systems -- u of )

eighty-some at Unit III -- we must persist in our criticism of and vigil over the policies and activities not only of N.U. but of your organization as well. You have historically not been open.with the public or remained alert, accurate, honest and thorough in regulating an industry whose form of

power-production carry with it risks of global consequence.

We insist, therefore, that you study thoroughly our proposal and agree to make it part of your own restart evaluation ~ criteria., Please acknowledge receipt of this  ;

letter and its proposal at your earliest possible convenience.

It is vital that, whatever the cost, those plants be kept off i line as long as there are~any unresolved safety, regulatory, plant l

systems-and ethical issues -- and there remain many. Your sole l 9707020157 970619 PDR ADOCK 05000245 H PJR a.

i priority must be to assure plant safety and safeguard the public trust. The satisfaction of financial or other demands relating merely to corporate prosperity or survival is not a priority of i any kind, given the tremendous risks of nuclear power generation for the surrounding populace.

Thank you for your kind attention. We look forward to hearing from you soon.

Sincerely yours, (fA (

cc: Mr. Jacques Durr masE'" O Chief of Inspections, Special Projects Office, NRR Mr. Wayne Lanning Deputy of Inspections, Special Projects. Office, NRR Mr. Philip McKee Deputy Director of Licensing

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.04/j9/1997 07:32 8608482020 ORBIT INc PAGE 01 Citizens Regulatory Commission 180 Great Neck Road Waterford, Connecticut 06385 860-444-0113 860-443-1608 Fax The Citizens Regulatory Commission recommendations to the public to be resolved prior to re-start of any Millstone plants I

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1. Documented proof of Northeast Utilities ( NU ) accotmtability to the public to prove that a corporate cultural change has occurred.

A. Removal of all management responsible for negative culture

2. Documented proof ofNuclear Regulatory Conunission ( NRC ) _

. accountability to the public to prove that a regulatory cultural change has occurred A. Replace all NRC Region 1 management responsible for lack of enforcement at Millstone and Connecticut Yankee (CY ) .

B. Replace all Millstone and CY NRC Resident Inspectors involved in the inadequate oversight.

3. Resolution of all Whistleblower nuclear concems. Documented proof that the Employee Concerns Program ( ECP ) at N'U is accomplishing it's stated goal. Documented proof that the Independent Oversight Team for Employee Concerns ( IOTEC ) has observed evidence that the Millstone ECP is accomplishing it's stated goal.

4. Resolution of all on-going investigations: Criminal, NRC, DEP, EFA, and l

NU internal.

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5. Complete resolution of all 10CFR 2.206 Petitions associated with Millstone and CY i.e. T. Ross, G. Galatis. C A.N./ NIRS A. Cizek prior to the restart of any Millstone Unit.

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ORBIT INC PAGE 02 g/2p 971.,07:32 l

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1 6) ; Require the NRC/NU to provide a Spent Fuel Pool risk assessment on all Millstone Units and CY as they" presently exist, prior to restart of any unit.

A.7 Llook at effects of future fuel storage with regard to the assessment. J B. The public should ascertain, whether in terms of risk assessment, ' dry ,'

cask storage is safer.

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' 7. Request from NU'a breakdown of all outage costs since October 1994 with'the intent of detennining the cost to be shouldered by the ratepayer.

Tbc public should not be burdened with costs due to imprudent NU -

management,

s. Demand public input and involvement in the planning and implementation .

l of CY decommissioning.

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! 9. Req 6 ire NU to take an oath that it will operate in accordance with established state'and federal ethical standards,

10. Change the Independent Corrective Action Verification Program (ICAVP) process to allow a truly independent team to oversee the restart process j utilizing some fonn of the CRC PROV proposal.

l- A. Require at least a 25% review of Risk / Safety Significant Systems by.

tlie ICAVP contractor.

B. Require at least a 10% review of Risk / Safety Significant Systems by ,

the NRC Oversight Team, i j

c. Require a similar ICAVP process of NRC oversight. ,

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11. Require a consistent pattern ofviolation-free inspection ~ report periods.

12. Require a consistent pattern of below industry average License Event l Reports ( LER ),

n Demonstrate to public that all required items established by the'NRC for j restart are met. j

! 14. Demonstrate to the public a viable plan for evacuation. The current plan  !

l lacks a credible indication that it can be accomplished.

l 15. Public should propose that Nuclear Energy Advisory Council (NEAC),

l Govi Rowland, and the Connecticut Legislature, study ways to reduce Connecticut's dependence upon nuclear energy through conservation,

! energy efficiency, and use of renewable sources of energy.

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