ML082380957
| ML082380957 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/22/2008 |
| From: | Darrell Roberts Division of Reactor Safety I |
| To: | Gundersen A - No Known Affiliation |
| References | |
| Download: ML082380957 (5) | |
Text
August 22, 2008 Mr. Arnie Gundersen 376 Appletree Pt. Rd.
Burlington, VT 05408
Dear Mr. Gundersen:
On July 18, 2008, following a briefing of the Vermont Public Oversight Panel (Panel1) by four members of the NRC staff, you handed me a set of documents primarily containing copies of transcripts of testimony submitted in a petition to the Vermont Public Service Board (PSB) in 2004. The PSB was conducting proceedings related to the issuance of a Certificate of Public Good for the Vermont Yankee Nuclear Power Station (Vermont Yankee). In 2004, Vermont Yankee was under review for an extended power uprate (EPU) license amendment. Your 2004 testimony, as documented in the transcripts you provided me, was primarily based on concerns you raised about the Vermont Yankee cooling towers.
On August 19, 2008, in a phone call between you, me and Ms. Louise Lund, Acting Deputy Director, Division of Reactor Safety in NRC Region I, you provided amplifying information not contained in the July 18, 2008, documentation. The purpose of this letter is to document my receipt, and the staffs review, of the information contained in the set of documents you provided on July 18.
The documents you handed me contained multiple copies of two transcripts of pre-filed direct testimony you gave as an expert witness for the New England Coalition (NEC), which NEC filed in petitions to the Vt. Public Service Board in June and July of 2004, during the PSBs proceedings related to a Certificate of Public Good for Vermont Yankee. Also included were copies of various supporting documents, which - based on marked-up cross-references between these documents and the testimony transcripts - appeared to also have been provided to the PSB at the time. The supporting documents included a preventative maintenance basis document for the VY Cooling Towers, and copies of various electronic mail (e-mail) between individuals (presumably employees and contractors hired by Vermont Yankee), which inferred the need for a structural analysis of the cooling towers to support the proposed EPU. Also included were excerpts of a Stone & Webster/Tower Performance, Inc. (TPI) report (referenced in the e-mails) suggesting that a structural analysis of the Class II (non-seismically qualified portion of the cooling towers) had not been done in response to modifications conducted in the mid-1980s, which added heavier fill material to the cooling towers. Additional e-mail and TPI report excerpts were cross-referenced to the testimony transcripts, which were connected with concerns you previously raised about EPU-related modifications to cooling tower fan motor 1 The Public Oversight Panel referred to in this letter was established by Vermont State Legislation S. 364, which was signed into law by Vermont Governor Jim Douglas on June 5, 2008. The legislation requires that the Vt. Department of Public Service perform a comprehensive reliability assessment of Vermont Yankee, in consultation with the Panel. On July 18, 2008, at the states request, NRC Region I Staff (Darrell Roberts, Eugene Cobey, Wayne Schmidt, and Marjorie McLaughlin) briefed the Panel on the NRCs Reactor Oversight Process, including recent ROP results, the use of risk assessment, and inspection and oversight of Vermont Yankee. Mr. Gundersen is the current Oversight Panel Chairman.
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capacity and the suitability of the cooling towers drift eliminators to withstand changes associated with the EPU.
In addition to the technical concerns described in the documents mentioned above, the pre-filed testimony transcript dated July 6, 2004, (page 5, question 6) described your concern related to a disturbing trend in the area of RECORDS RETENTION (sic) for safety related items, and the paragraphs that followed provided examples detailing your concerns.
Our records show that two of the main concerns described in the above documents were provided to the NRC in e-mail correspondence on July 8, 2004, from you to Mr. Rick Ennis, then licensing project manager for Vermont Yankee. After several e-mails were exchanged between you and members of NRC staff requesting clarification and additional information, the two concerns - that Vermont Yankee had knowingly operated with a safety system in an unanalyzed condition for the previous 18 years, and the existence of a disturbing trend in the area of records retention for safety-related items - were referred to the licensee for additional information and subsequently reviewed by NRC staff. Following this review, the staff informed you by letter dated October 21, 2004, that those concerns were not substantiated.
Additionally, the New England Coalition, for which you were an expert witness during the NRCs proceedings associated with the VY EPU license amendment review, filed contentions related to the cooling towers in its request for a hearing during the licensing process. One of these contentions was related to the material you provided me in July and was adjudicated by the Atomic Safety and Licensing Board in 2004 and 2005. During the NRCs review of the EPU amendment request, the staff confirmed that the safety-related portion of the cooling towers met applicable regulatory requirements and approved the EPU.
After returning to the Region I office on July 21, 2008, following my briefing of the Vt. Public Oversight Panel, I gave the information you provided to our technical staff for review. Based on its review of the documents, the staff did not identify any new concerns not previously reviewed by the NRC. In our telephone call on August 19, 2008, you provided additional context for some of the information contained in the documents you handed me, and raised new questions related to the cooling towers, which the staff is reviewing and will address through separate correspondence.
Finally, upon handing me the documents in July, you requested both verbally and in a note at the bottom of the first page of the documents that I provide them to the VY cooling tower assessment team. You mentioned that the documents were self-explanatory and that the team leader was expecting them. The NRC did have a Special Inspection Team (SIT) on site the week of July 13, 2008, following Entergys discovery of a leak caused by problems with the cooling tower distribution piping supports in the non-safety related portion of the cooling tower on July 11. I spoke with the team leader who indicated that he was not aware that the information you provided me was forthcoming. The SIT team leader was generally aware of the concerns in the documents you handed me in July, and the teams preliminary review determined that these issues were not related to the recent cooling tower leak.
The SIT concluded its onsite inspection activities on July 17, 2008, but has continued its in-office review of Entergy information this month. The results of the inspection are pending and will be documented in a publicly available NRC inspection report in October 2008. The partial collapse of one non-safety cell in August 2007 was the subject of NRC inspections documented
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in inspection reports 50-271/2007-04 and 50-271/2007-05, which are available on the NRC document management system (ADAMS). Those inspections revealed that Entergy had performed inadequate internal inspections of the structural members of the cooling tower to detect the deterioration of the wooden support beams. Our preliminary review indicates that the cause of the July 2008 cooling tower problem most likely resulted from a recent design change, and is unrelated to the root causes of the cooling tower cell failure experienced in August 2007.
We understand that the structural problems experienced with the non-safety related portions of the Vermont Yankee cooling towers have been a concern to citizens and elected officials living near the Vermont Yankee plant. We also understand that you are continuing to pursue these matters in your present role as Chairman of the Vermont Public Oversight Panel.
I trust my response was helpful. We intend to maintain our interface with the Vermont Department of Public Service as it proceeds with the reliability assessment. Please contact me at (610) 337-5128 if you have any further questions on this matter.
Sincerely,
/RA/
Darrell J. Roberts, Deputy Director Division of Reactor Safety
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in inspection reports 50-271/2007-04 and 50-271/2007-05, which are available on the NRC document management system (ADAMS). Those inspections revealed that Entergy had performed inadequate internal inspections of the structural members of the cooling tower to detect the deterioration of the wooden support beams. Our preliminary review indicates that the cause of the July 2008 cooling tower problem most likely resulted from a recent design change, and is unrelated to the root causes of the cooling tower cell failure experienced in August 2007.
We understand that the structural problems experienced with the non-safety related portions of the Vermont Yankee cooling towers have been a concern to citizens and elected officials living near the Vermont Yankee plant. We also understand that you are continuing to pursue these matters in your present role as Chairman of the Vermont Public Oversight Panel.
I trust my response was helpful. We intend to maintain our interface with the Vermont Department of Public Service as it proceeds with the reliability assessment. Please contact me at (610) 337-5128 if you have any further questions on this matter.
Sincerely,
/RA/
Darrell J. Roberts, Deputy Director Division of Reactor Safety SUNSI Review Complete: djr (Reviewer=s Initials)
DOCUMENT NAME: g:\\ORA\\Barkley\\Gundersen letter re vy cooling towers.doc ML#082380957 ADAMS Document Accession No.: ML After declaring this document AAn Official Agency Record@ it will be released to the Public.
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DATE 08/22/08 08/22 /08 08/22/08 08/22/08 08/22/08 OFFICIAL RECORD COPY
- See Previous Concurrence Page
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Distribtuion:
S. Collins, RA D. Roberts, DRS L. Doerflein, DRS, M. McLaughlin, ORA D. Jackson, DRP B. Norris, DRP E. Dacas, CA