ML020870195
| ML020870195 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/07/2002 |
| From: | Burton N Connecticut Coalition Against Millstone, Long Island Coalition Against Millstone |
| To: | Atomic Safety and Licensing Board Panel |
| Byrdsong A | |
| References | |
| +adjud/rulemjr200506, 50-423-LA-3, ASLBP 00-771-01-LA-R, RAS 4127 LER 01-007-00 | |
| Download: ML020870195 (10) | |
Text
f-IR s ,',ia7 REIamEDoORRESPotamm DOCKETED USNRC March 20, 2002 (11:25AM)
OFFICE OF SECRETARY UNITED STATES OF AMERICA RULEMAKINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICATIONS STAFF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:. Docket No. 50-423-LA-3 Dominion Nuclear Connecticut, Inc. ASLBP No. 00-771-01-LA-R (Millstone Nuclear Power Station, Unit No. 3) ' MARCH 7, 2002 CONNECTICUT COALITION AGAINST MILLSTONE AND LONG ISLAND COALITION AGAINST MILLSTONE'S RESPONSE TO DOMINION NUCLEAR CONNECTICUT'S FIRST SET OF INTERROGATORIES AND DOCUMENT REQUEST INTHE REOPENED PROCEEDING In accordance with the schedule established in the Atomic Safety and Licensing Board ("Licensing Board") Memorandum and Order (Telephone Conference Call, 3/28/02) issued on March 6, 2002, Connecticut Coalition Against Millstone and Long Island Coalition Against Millstone (collectively, "Intervenors") respond herewith to Dominion Nuclear Connecticut, Inc.'s First Set of Interrogatories and Document Request dated January 25, 2002.
Interrogatories Interrogatory 1: Identify each person who supplied information for responding to these interrogatories. Specifically note the interrogatories for which each such person supplied information.
Response: Not applicable. See Responses infra.
(
Interrogatory 2: Identify each person whom Intervenors expect to provide sworn affidavits or declarations in connection with the written filing for-this Subpart K proceeding, and each person who would testify in any subsequent evidentiary hearing. For each person identified, describe that person's professional affiliation, address, area of professional expertise, qualifications and eM~/4/ ese cy. 4035 s5ec V/.0-oa
I-educational and scientific experience. Also, describe the general subject matter on which each such identified person is expected to provide sworn affidavits or testimony in this proceeding.
Response: David A. Lochbaum, nuclear safety engineer with the Union of Concerned Scientists, 16 P Street NW, Washington DC, who has been previously disclosed as an expert witness for the Intervenors proceedings, may provide a sworn affidavit or declaration in these in connection with the written filing for the Subpart K proceeding and he may present testimony in a subsequent evidentiary hearing. If presented, the subject matter would generally address the issue of administrative controls in spent fuel pools and more specifically the loss of administrative controls at Millstone Unit 1.
The Intervenors reserve the right to present other witnesses.
Interrogatory 3: Identify each document that Intervenors reference, cite or otherwise rely on in the written filing expect to submit, in this Subpart K proceeding.
Response: The Intervenors intend to submit, reference, upon interalia documents and materials previously cite or otherwise rely released by the Licensee, the NRC Staff, the Office of Investigation, the Office of the Inspector General in these and related proceedings; and documents and disclosed by the Intervenors; and the following document, materials previously subject to reservation of the right to submit, reference, cite or otherwise rely on other documents as appropriate:
Licensee Event Report 2001-007-00 Interrogatory 4: Identify and give a description of any specific relief, remedy, corrective actions, order, or other action that Intervenors connection with the reopened Contention 4 in this Subpartwill request in K proceeding and state the basis for such request.
Response: The Intervenors will request an adjudicatory Contention 4 to resolve disputed issues of law and hearing on reopened fact, as to be more particularly set forth in their Detailed Written Summary, and theywill relief as is appropriate including orders sustaining their thereafter seek such challenge to the license amendment application at issue.
Interrogatory 5: Identify and describe each procedure or other administrative control whoseMillstone Unit I fuel pool non-compliance or inadequacy Intervenors assert resulted in or contributed to the loss or misplacement of the
I.
two fuel rods reported Imi ssing by Ucensee Event Rep'ot 2000-02-00 (filed on January 11, 2001). This response should identify:
(a) the specific provision of each procedure or administrative control with which the Licensee did not comply, or which was inadequate to protect the public health and safety; and (b) the acts of the Ucensee that would have constituted compliance, or such terms of the procedure or administrative control that would have sufficiently protected.public health and safety.
Response: The Intervenors object to this Interrogatory. The information sought is beyond the proper scope of discovery as directed against the Intervenors. The Licensee has ackhowledged that its failure to adhere to its own administrative controls caused it to lose accountability of the spent fuel rods, which controls remain inadequate in that the fuel rods remain unaccounted for.
Interrogatory 6: Identify and describe each Millstone Unit 3 spent fuel pool procedure or other administrative control that Intervenors assert is question by any Unit I inadequacy or non-compliance identified in brought into response to Interrogatory 5, either in terms of:
(a) the adequacy of the Unit 3 procedure or administrative control itself; (b) the ability or willingness of the current Licensee to implement such procedures or administrative controls to protect public health and safety.
Response: The Intervenors object to this Interrogatory. The information sought is beyond the proper scope of discovery as directed against the Intervenors, Interrogatory 7: For each Millstone Unit I and Unit 3 spent fuel pool procedure or administrative control identified in response to the preceding two interrogatories, identify and describe, in specific detail, each commonality in the substance, purpose or execution of such procedures or administrative controls, as between Unit I and Unit 3, that Intervenors assert renders the Unit 3
procedure or administrative control susceptible to inadequacy or non-compliance.
Response: See objections to Interrogatories 5 and 6.
Interrogatory 8: List all reasons that Intervenors will assert to support conclusion that Dominion Nuclear Connecticut will not or cannot comply a Millstone Unit 3 administrative controls that support the license amendment with.the issue in this Subpart K proceeding to prevent a criticality accident in at the Unit 3 spent fuel pool.
9-o Response: The InteiVenors object to this Interrogat*ry. The Interrogatory improperly calls upon the Intervenors to speculate as to future specific acts of wilful misconduct and/or negligence on the part of Dominion Nuclear Connecticut, Inc.
Interrogatory 9: State whether Intervenors will assert that loss of one or individual fuel rods (removed from a fuel assembly) would lead to a nuclearmore criticality accident in the Millstone Unit 3 spent fuel pool. If so, state the basis for this position and list all reasons that will be given in the written filing in this Subpart K. proceeding. Specifically identify how many fuel rods would need to be lost to cause a criticality accident.
Response: The Intervenors -object to this Interrogatory because it is nonsensical.
Document Request The Intervenors provide herewith the following document identified in response to Interrogatory 3:
Licensee Event Report 2001-007-00 Respectfully submitted, CONNECTICUT COALITION AGAINST MILLSTONE LONG ISLAND COALITION AGAINST MILLSTONE By:
Re = Ridge CT 06876 Tel. 203-938-3952 It
MAR-04-2002 14:00 P. 02/06
- ' . Domlnio~r
- Dominionirofty mallwne Nudw S,+on c.io Canntcdcut, U&
Rcp10~ Road DEC 17 200' Docket No. 50-336 RB18533 10 CFR 50.73(a)(2)(i)
U.S. Nuclear Regulatory Commission Attention: Docuroent Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 iUcensee Event Report 2001-007-00 Movement of HeWav Loads Not Addressed In Procedure This letter forwards Ucensee Event Report (LER) 2001-007-00, which related to. a condition that was discovered at Millstone Nuclear Power Station, Unit No. 2, on October 22, 2001. This LER Is being submitted pursuant to 10 CFR 50.73(a)(2)(hl) and 10 CFR 50.73(a)(2)(v).
There are no regulatory commitments contained within this letter.
Should you have any questions regarding this submittal, please contact Mr. David W. Dodson at (860) 447-1791, extension 2346.
Very truly yours, DOMINION NUCLEAR CONNECTICUT, INC.
Master Process Owner - Operate the Asset Attachment (1): LER 2001-007-00 cc: H.J. Miller, Region 1 Administrator J. T. Harrison, NRC Project Manager, Millstone Unit No. 2 NRC Senior Resident Inspector, Milstone Unit No. 2
-7 7 . -' " ".. .;04-202. 14:00 P. 03/06 Doet No. M-336 Attachment I Millstone Nuclear Power Station, Unit No. 2 LER 2001-007-00
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EN T ..... - WORT A.... OM-ER FAIUTES INVOLV DAY YE YEA S fAL REV NO DAY YA FAC-LMY NAME COcKET NUMBER R NO.05000 21 2001 -007 -00 1 7 2001 FA*.*.TY NAME DOCKT NUMBeR OPERAING" 1 - nhiS REPOIRTr eI.IiMT PUnRSuAITTO THE REtIEMENTR OF 10 :t an ) 1_)
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- .* A 50.73(SX2)Xy)(D) InNRC Form 366A 20.2=20()(2V) - 60.73(a)(24)(4) __M073(aX)Mvi 20.2203()(2)MI M073(a)(2X)M(A) d 07(XXvIB f NAMF- -LUCENBEE CONTACT FOR THIS LE 02 OEN~
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David W. Dodson, Team Lead - Compliance *860-447-1791 COMPLETE ONE UNE FOR EACH ,OMPONEMT FAILURE DE IBED INTHIS REPORT'=
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cm~om" ,o m.- umr* compo_. mmu SUPPLEMlENTAL REPORT EXPECTED (141 XET OM DY YA
'YES ItYas, complete EXPECTESUBMISSON IDATE. I X IN NOMSSO ABSTRACT ('Unmt to 1400 apace-,Le,. approxmately 1 lugle;paoad typewdtten kmXlE)
It has been Identified that no safe load path exists for lifts of new fuel shipping containers and spent resin casks at Millstone Unit No. 2 In the area of the cask washdown pit and the associated lifting device is not single failure proof. Safety related commodities are located both Inthe pipe trench below the cask pit floor and on the west wall of the railroad access bay. Load flfts on the order of 24 feet are required to bring material Into and out of the spent fuel pool area via this boad path. Previously it was Identified that a 50 ton reactor coolant pump motor was stored In the cask washdown pit and that the drop of this motor would result In failure of the floor and potential damage to safety related components Inthe pipe trench.
The root cause for the failure to Identify heavy load path IsInadequate work practices In the Millstone engineering department Inthe area of programs.
Remedial corrective actions taken to date Include marking the loca*ton of the pipe trench on the railroad access bay floor and removal of the reactor coolant pump motor from the cask washdown pit using a NUREG-061 2 compliant lift. Additional corrective actions are being addressed in accordance with the Millstone Corrective Action Program.
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- J "trfR-*04-2002 14:02 P.,5,,6
- NFIC FORM 366A U.&. NUCLEAR REaULATOR CMmmSION UCENSEE EVENT REPORT (LER)
FAILM NMEg). - - LER UMBER MI PAGE(M Millstone Nuclear Power Station - Unit 2 05000336 Y GECtJe~ m REVISION 23 OF 3 NUMB:R, 2001 -007- 00 NARRATNE AVmo~w sp wa I n qiw Lftda addftoWa; kbs et AMCom5554) (17)
- 1. Event Descriotion On October22, 2001, with the plant in mode one at one hundred percent power, Itwas discovered that heavy loads have been historically moved at Millstone Unit No. 2 without appropriate procedural guidance. In order to support plant operation and refueling activItes, various Items need to be fifted and transported to locations within the power block and yard. These lifts and movements am controlled by procedures which take into consideration safety related structures, systems, components, and fuel which may be adversely effected by a load drop. Historically this Issue has been addressed via the guidance provided In NUREG.0612, *Control of Heavy Loads at Nuclear Power Plants.' Commitments were established for procedural controls, conduct of operations-for cranes, and safe load paths.
The Millstone Unit No. 2 Spent Fuel Pool Area, 38'-8" elevation of the Auxilla*y Building [NF], as well as the cask washdown pit, Is addressed by procedure MP 2712B11, 'Control of Heavy Loa*s.' The procedure shows the Spent Fuel Pool as a restricted area for Ifts, with a safe load path adjacent to the pool Historically, loads such as new fuel, spent resin casks, and other Items have been lifted from the railroad access bay at the 14-6W elevation, to and from the 38'-6 elevation, over d safety related pipe trench. Most recently, a spare reactor coolant pumpMP] motor
[MO] was lifted into the cask washdown pit. However, these loads have been lifted over the safety related pipe trench using a crane [CRN] that Is not %singlefailure proof' as described In NUREG-0612.
The safety related pipe trench lies below the cask washdown pit and the railroad access bay floor. The trench contains conduit [CND], cable raceways rrRLY] and safety related piping, including redundant refueling water storage tank [EM (RWST) suction headers and redundant emergency diesel Service Water ["IB] headers. The drop.
of a heavy load In the area of the cask washdown pit could cause failure of the floor slab resulting in damage to the safety related pipe trench. In addition, the end wall of the railroad access bay supports various safety related Items that could be damaged while performing heavy load Ifts In the area.
The cask crane Is not "sIngle failure proofm as described In NUREG-0612. -The crane Is a conventional 100 ton beam crane. The factor of safety requirements for rigging, presented In NUREG-0$12, can be extended to the hook and other load bearing components where the stress distributions do not change as the load is being either lifted or transported horizontally, however, It cannot be extended to the other partu such as the cable, sheaves, etc. where the stress distribution does change while the load is being lifted/transported. Thus a failure of one of these parts must be considered even though the probability of such a failum Is very low. If one of these parts does fall, the load will not necessarily fall straight down. Ifa sheave were to fall or ifthe cable somehow rides up over the edge of a sheave, and then fails, the block will tilt prior to releasing the load. The center of gravity of the load will move to remain directly beneath the location of the support force. This support force location will be constantly changing as the cable unloads. Hence, an Initial angle andQr aslight tendency to tumble cannot be precluded.
Should a load drop have occurred, the floor of the cask pit could have failed and the resulting Impact to the safety related structures below the floor may have resulted In a loss of safety function for the RWST and Service Water system. The ablirty to safely shutdown the plant under these circumstances would have been a significant chaflenge and Is not an analyzed condition for the facility.
On the basis of the above, this condition Is considered to be reportable under 10 CFR 50.73(a)(2)(ii) as an unanalyzed condition which could significantly degrade plant safety, and 60.73.(a)(2)(v% as a condition that could have prevented the fulfillment of the safety function.
- 2. Cause The root cause for the failure to Identify heavy load paths Is Inadequate engineering work practices Inthe Millstone engineering department In the area of programs.
NRO FORM Sma (1.21),
VA "UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.
In the Matter of: Docket No. 60-423-LA-3 Dominion Nuclear Connecticut, Inc. ASLBP No. 00-771-01-LA-R (Millstone Nuclear Power Station, Unit No. 3) MARCH 7,2002 CERTIFICATE OF SERVICE I hereby certify that a copy of "Connecticut Coalition Against Island Coalition Against Millstone's Response to Dominion Millstone and Long Nuclear Connecticut's First Set of Interrogatories and Document Request in the Reopened Proceeding" was served upon the following on March 7, 2002 via U.S.
postage pre-paid Additional e-mail service was made Mail, first class, on March 7, 2002 as indicated below.
Charles Bechhoefer, Chairman Dr. Richard Cole Administrative Judge Atomic Safety and Licensing Board Administrative Judge Board Atomic Safety and Licensing U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington DC 20555-0001 Washington DC 20555-0001 (e-mail: &,*RM.&.*) (e-mail: rfcl@nrc.gov)
Dr. Charles N. Kelber Administrative Judge Office of the Secretary U.S. Nuclear Regulatory, Commission Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington DC 20555 Attn: Rulemakings and Adjudications Washington DC 20555-0001 Staff (e-mail: nk@Agrgov)
(original + two copies)
(e-mail: HEA McNGCTrCRov)
Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Adjudicatory File Atomic Safety and Licensing Board
,a Washington DC 20555 U.S. Nuclear Regulatory Commission Washington DC 20555 David A. Repka, Esq.
Winston & Strom Ann P. Hodgdon, Esq.
1400 L Street NW Office of the General Counsel Washington DC 20005-3502 U.S. NuclearRegulatory Commission (e-mail: drewh*.winstoncom) Washington DC20555 (e-mail: IP rm.com)
Diane Curran, Esq.
Harmon, Curran, Spielberg &
Eisenberg, LLP 1726 M Street NW Suite 600 Washington DC 20036 (e-mail: dun -harmoncuroacom)
Nancy 6tn, -Esq.
147,_*~ Highway Red ti Ridge CT 06876 Tel. 203-938-3952 C"