Wednesday, September 10, 2008

TMI Relicensing: Letter to NRC (Piccola/DePasquale)

August 18, 2008 Chairman Dale E. Klein Commissioner Gregory B. Jaczko Commissioner Peter B. Lyons United States Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Re: Findings and Responses of the NRC Office of the Inspector General Report on the License Renewal Program Dear Chairman Klein and Commissioners Jaczko and Lyons: As you know, the federal relicensing system that has historically ensured nuclear plants are safe to operate for an extended period beyond their original license of 40 years has come under sharp criticism. The Nuclear Regulatory Commission’s (NRC) Office of Inspector General (OIG) Audit of the NRC’s Renewal Program (OIG-07-A-15) found certain safety evaluations lacked critical documentation. Essentially, the Division of Licensing Renewal (DLR) lacks a complete report quality assurance process to ensure documentation of the staff’s aging management program review methodology and substantive support for staff conclusions. (1) Currently, Pennsylvania has three nuclear stations involved in the relicensing process: Beaver Valley Nuclear Generating Station (Shippingport), the Susquehanna Steam Electric Station (Berwick), and the Three Mile Island Nuclear Generating Station (Londonderry Township). According to the Massachusetts Executive Office of Energy and Environmental Affairs, “ is theoretically possible that NRC does an adequate job in reviewing the issues associated with the continued safety of aging nuclear plants, but its own documentation of the review process suggests strongly to the contrary.” (2) We too have some concern about the OIG’s findings which were outlined in its September 2007 report. In the 13 relicensing cases it examined, the office found littleevidence that NRC staff had confirmed the integrity of aging safety systems they approved. For example, 98 percent of 458 passages in audit, inspection and safety evaluation reports failed to adequately document or support NRC conclusions. Problems fell into two categories: ‘red’ cases, where no specific support was found, and ‘yellow’ cases, where support was often provided by the companies whose plants were being relicensed. In those latter cases, the report found that NRC safety evaluation language was often ‘identical or nearly identical’ to the information that the companies had provided in the license renewal application. (3) The Letter raises questions as to whether the NRC actually verified the materials submitted by the licensees, and whether errors may have escaped detection and correction. In addition, there is a concern that even when the NRC was able to verify information, this practice may set the stage for future errors. Under NRC regulations (specifically 10 CFR 50.59) licensees can make future changes without prior NRC review and approval to anything that NRC hasn't relied upon in past regulatory decisions. We are aware that similar concerns have been expressed by representatives from California, Connecticut, Massachusetts, and New York. And, we are encouraged by your efforts to repair the problems outlined in the Assistant Inspector for General Audits’ Memorandum to Luis A. Reyes, Executive Director of Operations, U.S. NRC on January 7, 2008. As elected officials near Three Mile Island, we are interested in the overall safety review of this facility and any site specific issues that have been identified with it. Thank you for your prompt consideration in this most important matter. We look forward to hearing from you. Sincerely, JEFFREY E. PICCOLA (15th Senatorial District) EUGENE A. DePASQUALE (95th Legislative District) ___ 1 OIG-07-A-15, September, 2007, p.11. 2 Letter to the Commissioners of the NRC from the Executive Offices on Energy and Environmental Affairs and the Office of Public Safety and Security, Commonwealth of Massachusetts, February 15, 2008. 3 This regulation is available online at: HYPERLINK ""

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