NRC Public Meeting on Petition to Suspend Millstone 1 License

[CLAUDE A. FLORY <FLORYCA@GWSMTP.NU.COM>]

THESE OBSERVATIONS AND OPINIONS ARE MINE AND NOT NORTHEAST UTILITIES'

The NRC conducted it's first ever public meeting to solicit public comments on
a petition, a petition to suspend the license of Millstone Unit One.  The
petition was filed by George Galatis and 'We The People, Inc.'  Mr. Galatis,
who was a recent cover boy on Time magazine, works for Northeast Utilities
(NU), owners of Millstone 1.  The petitioners are basing their request for
license suspension not on technical grounds but on allegations of wilful and
deliberate violations of license requirements.  They claimed that NU has
intentionally violated license requirements to save money and has lied to the
NRC.  They also claim that the NRC has colluded with NU (and the nuclear power
industry) by allowing NU to ignore license requirements, specifically by
routinely off loading the whole core into the spent fuel pool during outages
(more later).  

It was a mostly civil meeting with the petitioners and NU presenting their
cases followed by about 50 public commentators at three minutes each.  Mr.
Hadley, lawyer for We The People, opened with a one hour plus soliloquy (look
up the definition).  He made some reference to a Sherlock Holmes classic about
not hearing the dogs howl at night, with Mr. Galatis attempting a dramatic
line.  Evidently the dogs of NRC were not howling when horse thieves were
removing horses from the barn.  He read a litany of NU's practice of off
loading too much core too early.  And he hammered away at NU's alleged wilful
misconduct and dishonesty.  NU presentation was less than an hour by three
persons, even including one lawyer.  One audience member held up a sign with
the words 'Blah, Blah, Blah' at the beginning of NU's presentation (cute!).  

Public comments were about half and half, for and agin.  Of the 'agin' folks it
was roughly two-thirds to one-third, activist versus local, honestly concerned
citizens.  One activist was dressed as a ghoul; of course his photo was front
page the next morning.  This drama act was followed by a comic who simply
stated, "The earth is flat, pigs fly, and nuclear power is safe."  But it was
the local citizens who concerned me the most.  They read every incident report
as a near accident.  One lady referred to the recent 'accident' at Palo Verde
and the simultaneous fire (also called an 'accident') in the control room.  To
her it proved that unrelated, simultaneous incidents are probable.  She
envisions at Millstone a scenario similar to that which the industry uses in
emergency preparededness exercises (see recent radsafe thread).  The 'for' folk
were mostly NU employees or contractors including a labor union boss who flatly
stated that the Millstone site is the safest labor site in Connecticut.  He was
laughed at!  A community leader from New Hampshire related how Ted Fiegenbaum
at Seabrook had established trust with the local community leaders by his
willingness to openly communicate.  Mr. Fiegenbaum is now the CNO (Chief
Nuclear Officer) for NU.  

At the heart of these allegations is the full core off-load into the spent fuel
pool (as detailed in the Time magazine article).  It is not prohibited by the
license but the safety report (FSAR) called it an abnormal procedure before the
report was recently revised.  During the first two outages full core off-load
were performed because of abnormal conditions including chlorine intrusion. 
Outages three and four were partial core off-loads.  Operating experiences
(observed fuel pool temperatures for example) and analyses showed, by outage
five, that full core off-loads were at least as safe for the public as partial
off-loads, were safer for the workers, and saved money.  Full core off-loads
are practiced routinely by the industry.  NU mistake was that they did not
update the FSAR.  It was viewed as an 'historical document.'  There is still an
open question about timing, the FSAR said full core off-load would occur no
sooner than 250 hours after shutdown and partial core off-loads no sooner than
150 hours; NU off-loaded as early as 65 hours and typically at 120-150 hours
for full core off-loads.

I have two observations:
1) There is some parallel to the recent flap on human radiation experiments. 
Changing industry practices, poorly understood standards and regulations, and
public misconceptions are the ingredients for a major public relations debacle.
2) The public cannot trust something they don't understand.  They don't
understand the margin of safety built into nuclear power plants by conservative
designs and calculations.  They don't understand that the working relationship
between the NRC and the nuclear power industry is regulator to licensee, not a
peer relationship.  They don't understand the robustness of a nuclear power
plant, a robustness built in by the complexity of systems and procedures
required by both a common sense for safety and by regulations.  They don't
understand that you shouldn't believe anything you read (they do believe the
half from the activists and don't believe the half from industry and
government).  But they do understand that you believe only half of what you
hear (the activists' half).  

THESE OBSERVATIONS AND OPINIONS ARE MINE AND NOT NORTHEAST UTILITIES'   

Claude Flory, CHP
Senior Scientist
Northeast Utilities
floryca@nu.com  (work)
76531.1107@compuserve.com (home)