ML17334B688
| ML17334B688 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/12/1998 |
| From: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| To: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML17334A664 | List: |
| References | |
| 2.206, DD-99-03, DD-99-3, NUDOCS 9803030084 | |
| Download: ML17334B688 (8) | |
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UNlON OF CONCERNED SClKNTlSTS January 12, 1998 Mr.L.Joseph Callan Executive Director Sr Operations United States Nuclear Regulatory Comnussion Washington, DC 205554001
SUBJECT:
hDDENDUMTO PETITION PURSUANT TO 10 CFR 2206, DONhLD C. COOK MJCLEARPLANTS UNITS1mn Z DOCXZTNOS. SO-uS ANDSO316
Dear Mr. Callan:
The Union ofConcerned Scientists submits Gus addendum to thc petition pursuant to 10 CFR 2206 we submitted on October 9, 1997 regarding Donald C, Cook Units 1 and 2. This addendum was tepested by Ms. Elinor Adens:un ofyour stafF followingmy oral presentation this morning ofour sdcty concerns.
Enclosed is the prepared statcmcnt which I read during that presentation.
Sincerely, David A. Loch aum Nuclear Safety Engineer cc!
Chairman Shirley Ann Jackson
'nited States Nuclear Regulatory Conunission Washington, DC 205554001 Mr.A.B. Beach, Regional Administrator United States Nuclear Regulatory Commission 801 Warrenvillc Road Lisle, 1L 605324351 Honorable Spencer Abraham United States Scnatc Washington, DC 20510-2203 Honorable Carl Levin United States Senate Washington, DC 20510-2202 Honorable Fred Upton United States House ofReprcscntativcs Washington, DC 20515-2206 WesMngtonONce:
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~ CaeMdge MA 02238.9106
~ 0174474552 FAX: 61M044406 Ceifoele Othe: 2507 Shattuck Avenue Suke 2OS
~~ CA 04704.1567
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CONCERNED SClRNTlSTS This is a public meeting, not the public hearing that we requested when we submitted our 2.206 petition over three months ago. There have not been many public hearings held for 2.206 petitions. In fact, it is my understanding that Ihave attended every 2.206 public hearing ever held. One. That public hearing was held on the Millstone petition Gled by We.The People and Mr. George Galatis. Mr. Galatis was featured on the cover ofTIE in March 1996. The first, and only, public hearing for a 2.206 petition was held the followingmonth. Coincidence? Ihonestly doubt it. ButIwillgct into statistics and how they are used by the NRC later, You agreed to this meeting to so: ifI have "new" information about D C Cook Before I present my information, Iwillbriefly discuss some "old"information. You have heard this information before, but maybe not yet in 1998 the 2.206 petition process is seriously and fundamentally broken. It isn't bent, it's broke.
You revised the 2.206 process 3 or 4 years ago and think it is fixed. The process was indeed changed, but it is not fixed. The old 2.206 process was broken. The new 2.206 process is broken. It needs to be fixed, or eliminated.
I suspect that the NRC's difficultyin stemming declining perfonnance by its Hcensees offers a close parallel with the history ofthe 2.206 petition process, Your inspectors detect a performance problem at a plant. Its owner implements corrective actions. You conduct a followup inspection. Ifyou find that things are the same, you conectly assume that the problem has not.been fixed. Ifyou find that things are different, you assume that the problem has been fixed. However, things can be diFerent but still not fixed. That' your trouble with the 2.206 process and may have been thc trouble you had preventing performance declines during the early stages ofSalem and Millstone.
UCS submitted its 2.206 petition on October 9, 1997. We asked fortwo things; specific actions regarding D C Cook and a public hearing to present our concerns. To date, VCS has received onc piece ofpaper &om you concerning our petition - a letter dated December 9, 1997, acknowledging its receipt. Allofthe few telephone discussions we'e had regarding'the petition have been originated by me, But enough on the 2.206 process. Today's meeting is for UCS to convey its concerns regarding D C Cook to you. Normally, I distribute copies ofthe slides or handouts to accompany my oral remarks. Since Ithought, in good kith, that we would be granted a public hearing and assumed that I'd have at least 10 days to prepare For it, and since that did not happen, I am unable to provide any written documentation to you, There are six concerns that I would like to discuss with you today.
Januay l2, 199$
D C Cook Petition Meeting
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Myfiat coacera invo~ D C Cook's ice condenser contai The NRC Inspector General's office was informed last summer about alleged problems in the configuration and testing ofthe ice condenser at Watts Bar. Problems with the bay doors and components ofthc ice baskets were specifically identified. The allegations also suggested that many ofthe problems were generic and therefore affected the other ice condenser plants, including D C Cook Finally, it was alleged that the problems were known, but not properly reported, by the Watts Bar licensee, the D C Cook licensee, the Mcguire licensee, and even Westinghouse.
Irefer you to Mr. George Mulley in the IG's office for the technical issues. Idon't want to compromise IG's investigation, but these allegations exist and they may a6ect D C Cook. You recently issued an amendment to D C Cook's technical specifications involving the antount ofice in the ice condenser. The icc condenser licensing bases were changed, albeit to a limited extent. Itprovided another opportunity kr the licensee to identify and report any ice condenser problems. Idid not sec any such report. Arcthc Watts Bar ice condenser problems valid? Do they apply to D C Cook? Ican't answer that
- at this time. Can you?
Mysecond concern involves the licensee's 50.59 safety evaluation process. Fmm th' material I'e reviewed, it appeared that you felt the licensee's 50.59 safety evaluation process needed improvements, I understand that the licensee made changes to its process.
I am concerned that it is not evident that the licensee made any attempt to determine if safety evaluations prepared under the old process led to inappropriate conclusions. In other words, did the bad process cause bad products?
Before joining UCS in 1996, I was a consultant on a UFSAR vertical slice project for Salem Unit 2. Wc looked at ~v safety evaluation written for~v modification to the systems we examined. Prior to that assignment, Iwas a consultant on the power update project for Susquehanna.
Although that licensee did not have a suspect S0.59 process, the effect ofincreasing the plant's licensed power level might have invalidated the conclusions &om prior safety evaluations. Therefore, we reviewed the summary for every safety evaluation written. Prior to that assignment, I was a consultant on the Browns Ferry Restart Project. TVAdid have a configuration management problem. We reviewed
~ee safety evaluation written for ~ev modification to the systems we examined.
So, based on industry experience and common sense, I expected to sce at least some screening ofsafety evaluations written at D C Cook using the bad process. Has an assessment ofD C Cook's safety evaluations been performed? Ifnot, could "bad" safety evaluations prepared using the "bad" SO.S9 process mean that unidentified safety problems remain at D C Cook?
Januay t2, 1998 D C Cook Petition Meeting
Mythird concern invt engineering celcnhLtiont. Prom thc Serial I'e teviecred, it appears that the quality ofthe licensee's calculations was suspect. In Sct, the licensee's response to the confirmatoty action letter (CAL)dated December 2, 1997, stated that a root cause forits problems was that "Some analyses were found to oontain errors and incorrect assumptions." The licensee said a peer review process was used to spot check its calculations. According to the licensee's response, a total of 191 calculations were peer reviewed, Sounds like a broad review. But it's not, forthe followingreason.
171 calculations were reviewed to resolve the concerns you raised during the design inspection. The remaining 20 calculations covered the auxiliary feedwater, component cooling water, chemical volume and control, containment spray, essential service water, residual heat removal, and electrical distribution systems. 20 calculations for7 safety systems. That's an average offewer than 3 calculations reviewed per safety system. Even given this tiny sample, the licensee reported that "some administrative and minor technical concerns were identified."
Is the NRC satisfied that a review ofmerely 20 calculations is an adequate extent of condition assessment? Ifso, why?
Myfourth concern also involves engineering calculations, Between the time we
, submitted our petition and the time the licensee responded to the CAL,Ireceived allegations involving net positive suction head (NPSH) calculations performed forD C Cook. The individual making the allegations was at D C Cook and told me there were problems with more than one NPSH calculation. The alleged problems involved both "missing" and inaccurate calculations. I do not know which pumps were affected, but it should not be too difficultfor you to check. I am unable to check myself since these documents are not publicly avaihble, Do the safety-related pumps at D C Cook have adequate ASH as shown by quality calculations>
Januay 12. l998 9 C Cook Petition Meeting Page 3 of5
Myfifthconcern invo cs the credibilityofthe Hccnscc's response to your CAL.By letter dated February 6, 1997, the licensee submitted, under oath, its response to the NRC's 50.54(Q request dated October 9, 1996. Ithink it is Mrto state that the licensee, in that response, told you that there were no major problems with the two safety systems
- you examined in the subsequent design inspection. Each ofthese safety systems had been the subject ofa design bases document recently issued by the licensee. Essentially, the licensee gave both ofthese safety systems a dean billofhealth. Your subsequent design inspection clearly showed otherwise. Both units have been shut down for over three months to fixthc problems you identificd in the allegedly "clean" systems.
Since the shutdown, the licensee has expended considerable effort fixingthe many problems you identified. Numerous physical plant changes were necessary. However, the licensee has expended less effor examining whether the programmatic problems you found affected other systems as well. The licensee was unable to identic the problems in the two systems you examined during a thorough design bases documentation program. It appears that the licensee applied less effort, per system, on the recent extent ofcondition assessment than it applied during the design bases document process. Since the hrger effort fitiled, can you be sure that the smaller effort succeeded?
Mysixth concern involves the NRC's own inspection process. You came in, looked at two safety systems, and found enough problems to force both units to shut down. The licensee maintains that these problems were confined to these two systems and everything else is well. Sound familiar? In 1996, you examined 4 systems at Maine Yankee and documented over 70 pages ofproblems. That licensee claimed the problems were limited tojust those systems. Last year, you examined 2 systems at Vermont Yankee and found a serious problem affecting 1 systein and lesser problems affecting thc other. That licensee claimed the problems were limited to just those systems. Ifthese licensees are correct, then you arc the best regulator on the planet, You consistently find the needles in the haystacks. You find the only significant system problems that exist at the plants.
Were these licensees correct? Idon't know. More importantly, you don't know either.
You'e never expanded the scope for system sampling inspections. Ifyou had examined another system or two, then you'd really know whether you found the only problems or not.
You make sure that the licensees fixthe problems you find in the few systems. That obviously. needs to be done. But much more needs to be done, Thc true purpose ofthe your inspection ofsample systems is~ to ensure the operability ofthese few systems.
Your inspections are intended to assess the licensee's programs and controls for maintaining all safety systems. Your findings tell you something about the material condition ofthe plant, but they also provide you information on the licensee's general safety management ability. Theoretically, you should not find anything during an inspection. Thus, any finding actually represents two problems a nonconforming condition as well as a failure ofthc licensee's Quality Assurance (QA) process. Too often, you allow licensees to simply fixhalfofthe problem the nonconforming January )2, 1998 D C Cook Petition Meeting Piige 4 of5
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condition. For example, when you Gnd a broken widget, you make sure that the licensee changes the widget. You also need to find out why the licensee did not identify the broken widget and ifthey have any other broken widgets. The licensee's programtnatic failures must be fixed. Otherwise, problems in other systems willremain undetected and future problems may be introduced.
What wouM ittake foryou to expand the sample size9 This should not be a rhetorical question. You should develop and issue clearly defined criteria on when you willrequire additional system assessments based on findings &omyour system inspections.
These are my concerns.
Ithink UCS asked forvery reasonable actions in our petition. The significant problems you found raise valid questions about the other safety systems at 9 C Cook To date, Ido not think those questions have been adequately answered. It is clearly the licensee's burden to answer these questions.'t is your burden not to permit D C Cook to restart until these questions are answered and the answers indicate the plant willbe operated safely.
To be perfectly candid, I never expected our petition to be granted. The NRC's record is such that a public petition has very )ittle chance ofbeing granted. MyRllback position is to monitor daily event reports, LERs, and inspection reports after the phnts rest ut. When I see a signi6cant problem reported that might have been identified and corrected be&re restart had the NRC granted our petition, you can be sure I'llet you know.
Januaty 12, 1998 D C Cook Petition Meeting Page 5 ofS