ML18038A302
| ML18038A302 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/21/1990 |
| From: | Carr K NRC COMMISSION (OCM) |
| To: | Pooler R ATLANTIC STATES LEGAL FOUNDATION, INC. |
| Shared Package | |
| ML18038A303 | List: |
| References | |
| NUDOCS 9006270090 | |
| Download: ML18038A302 (22) | |
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ee CHAIRMAN UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 June 21, 1990 Rosemary S. Pooler, Esquire Vice President for Legal Affairs Atlantic States Legal Foundation, Inc.
658 West Onondaga Street
- Syracuse, New York 13204-3356
Dear Ms. Pooler:
Distribution:
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- TM1urley, FMirag1 ia JPartlow CSMyre SVarga BBoger RCapra CVogan RMartin DCrutchfield FGillespie WRussell BClayton WKane JScinto TMartin I am responding to your May 14, 1990 letter to the Commission in which you expressed a number of concerns regarding the Nine Mile Point Nuclear Station Unit No. I (NMP-1).
The Nuclear Regulatory Commission (NRC) staff's detailed comments addressing your specific questions and concerns are provided in the Enclosure.
The NRC has not yet made a decision regarding the startup of NMP-1.
While the NRC staff believes that the results to date indicate no significant impediments to restart, the staff awaits the completion of ongoing final preparatory actions by the licensee.
Restart will not occur until NRC is satisfied that the licensee can safely proceed with startup and can operate the plant safely.
With respect to your general concern that the NRC might authorize the restart of Nine Mile Point Unit I before the licensee has completed action on require-ments addressed in generic letters and bulletins, you should be aware that at any particular point in time there will be a number of generic letters and bulletins that have been issued for which all requested actions have not yet been fully implemented.
This is because the staff, on an ongoing basis, continues to issue generic letters and bulletins based on the results of operating experience or results developed from either the NRC's assessments or from information from the nuclear power industry.
These letters and bulletins contain information on diverse subjects, and, thus, result in widely varying solutions and schedules for action depending on the issue.
None of the generic letters or bulletins currently outstanding at NMP-1 deals with issues that must be resolved prior to startup.
The major programmatic issues that do have to be completed prior to the NRC authorizing restart are outlined in the NRC staff's Confirmatory Action Letter No. 88-17 of July 24, 1988.
These issues concern management ineffectiveness in recognizing and remedying problems such as maintenance of operator licenses, inservice inspection deficiencies, and other issues as referred to in the letter.
The licensee has provided information concerning how these problems are being corrected in various documents, the most important of which are its Restart Action Plan and its Restart Readiness Report.
The NRC staff has Originated:
NRR:Martin 9006270090 900621 PDR COI'IMS NRCC CORRESPONDENCE PDC
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reviewed these documents and the licensee's corrective actions and reported its findings in various inspection reports, including the report of the Integrated Assessment Team of November 8, 1989.
A follow-up report is currently being prepared.
These reports and other related documents contain the NRC staff's conclusions with respect to each issue which must be resolved prior to restart.
The NRC staff is, now completing final evaluations necessary to an NRC decision on NMP-1 restart.
Sincerely, Kenneth M. Carr
Enclosure:
1.
NRC Staff Response
NRC STAFF RESPONSE TO SPECIFIC QUESTIONS AND CONCERNS RAISED BY ATLANTIC STATES LEGAL FOUNDATION, INC.
ENCLOSURE I.
INTEGRITY OF THE TORUS guestion 1.
"For what percentage of the torus wall have thickness measurements been made?"
Answer:
guestion 2.
Answer:
guestion 3.
The Nine Mile Point Unit 1 torus is made up of 20 sections referred to as "bays."
In August 1989, NMPC performed an extensive inspection program that included over 2600 wall thickness measurements covering the bottom, central portion of all 20 bays.
The areas inspected are the most highly stressed and are the most limiting with regard to wall thickness.
In
- addition, NRC performed wall thickness measurements in other parts of the torus (above,
- below, and at the water line), visual examinations, and surface replications.
These inspections showed that the form and rate of corrosion did not vary sig-nificantly in different areas of the torus.
Thus, the most critical area of the torus wall was inspected in all 20 bays.
"What were the results?"
At the thinnest point, the thickness of the torus wall near the bottom center of the bay had a value of 0.452 inches in bay 17.
This value was 0.005 inches greater than the 0.447-inch minimum wall thickness required for that location.
No areas thinner than the code-required minimum wall thickness were identified.
"Has the NRC or will the NRC require Niagara Mohawk to measure the thickness of the entire torus before permitting the plant to restart?
If not, why not?"
Answer:
As indicated in the response to question number 1, the NMPC inspection program included all of the most critical areas of the torus.
Thus, the scope of the NMPC inspection was con-sidered adequate to determine the acceptability of the torus for plant restart.
- However, because of uncertainties in the rate of future corrosion, the licensee has committed to the NRC to perform wall thickness measurements at least every 6 months.
In accordance with this commitment, in February 1990, the licensee performed thickness measurements in 4 bays including bay 17, which has the least margin in thickness of all 20 bays.
These measurements did not indicate a significant change from the August 1989 measurements.
The NRC will continue to monitor closely the results of these inspections.
uestion 4.
"What is the minimum required wall thickness?"
Answer:
uestion 5.
There is not a single value of minimum wall thickness for the torus shell.
- Rather, the required minimum wall thickness varies throughout the shell depending on the calculated stresses.
- However, as indicated in the response to question number I, the location with the highest calculated
- stresses, and therefore the maximum required minimum wall thickness, is at the bottom,
, central location in each bay.
The required minimum wall thickness at that location is 0.447 inches.
However, in accordance with the criteria of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
some localized areas with thickness less than 0.447 inches could be acceptable.
"What is the standard or basis for saying that that is the minimum required torus wall thickness given that the torus at Nine Mile Point Unit I (and at Oyster Creek) wereunlike all other Mark I containments originally designed only to withstand a lower pressure than the drywell?
In all subsequent Mark I containments the torus and drywell have the same design pressure and thus have thicker torus walls than Nine Mile Point Unit 1."
Answer:
Mark I containment structures were designed and fabricated in accordance with the ASME Code, and plants with Mark I containments were licensed on that basis.
The ASME Code specifies the design methods and factors of safety to establish a minimum wall thickness that will ensure reliable operation for the postulated design loads.
All plants have torus wall thicknesses exceeding the minimum acceptable thickness specified in the ASME Code.
- However, as you are aware, the actual wall thickness is not the same for all Mark I containments.
Nine Mile Point Unit 1 and Oyster Creek, which were the first Mark I containments constructed, have nominal torus wall thicknesses of 0.460 inches and 0.385 inches, respectively.
The other 21 Mark I contain-ments in the United States have nominal wall thickness between 0.53 inches and 0.63 inches, with the exception of the three Browns Ferry Units that have wall thicknesses of 0.75 inches and Brunswick Units 1 and 2 that have concrete containments with steel liners.
Although factors such as structural design features, material selection, and fabrication techniques may have been involved, the main reason for the variation in wall thickness appears to be one of practicality in performing required containment pressure tests.
The Mark I containment is composed of two main
- sections, the drywell and the torus suppression
- chamber, which are connected by large vent pipes.
Based on design accident
conditions, the drywell requires a higher design pressure than the torus.
At Nine Mile Point Unit 1 and Oyster Creek, hardware is installed to separate the torus from the drywell during required tests of the drywell at its higher design pressure.
In subsequent
- plants, the designers decided it would be more practical to design the torus for the same pressure as the drywell, thus facilitating the required pressure test.
This decision resulted in thicker torus walls.
"Niagara Mohawk contends in a March, 1990 Economic Analysis of Continued Operation of the Nine Mile Point Unit 1 Nuclear Station prepared for the New York Public Service Commission, page S-4, that it will cost "less than
$ 15 million to correct" the torus.
What is the purpose of postponing this repair given the relatively low cost of such repair compared to the already great incurred cost of the present prolonged outage and the potential risk to the health and safety of the public of post-ponement?"
Based on the NRC staff's review, the torus at, Nine Mile Point Unit 1 satisfies existing safety requirements and therefore does not pose any undue risk to the public health and safety.
As long as applicable safety requirements are satisfied, questions regarding financial decisions made by the utilities are beyond the purview of the NRC.
- 4 II.
THE INTEGRITY AND COMPETENCE OF MANAGEMENT Concern:
~Res onse:
"a spill of radioactive water was concealed by Niagara Mohawk from the NRC and, of course, the public for eleven years.
The same management which elected to illegally keep secret important regulatory information is still in 'charge.'"
The NRC understands that this refers to the use, since 1981, of the, subbasement of the Radwaste Processing Building as a liquid waste retention facility.
An NRC inspection team addressed this issue in August 1989, and a Notice of Violation was issued to the licensee.
on February 23, 1990.
The team concluded that management did not perform required reviews and failed to recognize the significance of the flooded contaminated subbasement, but did not conclude that management tried to keep the event secret.
Extensive changes in management personnel have also been made during the past several years.
Specifically, these changes include but are not limited to the three top levels of on-site management, including the Executive Vice President-Nuclear Operations, the General Superintendent, and the Station Superintendent.
The major management changes made during the shutdown and since the violation initially occurred were signifi-cant factors in the staff's decision not to issue a civil penalty for this violation.
Concern:
"Management inability to guarantee performance standards and quality control has been a continuous theme of the NRC's complaints about Nine Mile Point 1."
~Res onse:
During the past 2 years, the licensee has implemented extensive management
- changes, has established new standards of performance, has developed and implemented virtually all of the items in their Restart Action Plan, and has developed a Nuclear Improvement Plan.
The NRC staff's extensive evaluation of these issues is documented in inspection reports as noted in the response to Part I.
The following summary in the SALP report succinctly states the NRC staff's view of the licensee's current level of performance:
There was an apparent turning point in Niagara Mohawk's approach to assuring quality.
The Restart Action Plan was responsible for the better problem identification, more critical problem evaluation and self-assessment, and the establishment of programs and standards to promote and sustain good performance.
The approach appeared to have enabled the improved results noted in the engineering and surveillance areas and the generally improving direction in most other areas.
However, the performance in several areas remained at minimally acceptable
- levels, and the challenge for Niagara Mohawk management remains to utilize this better approach to produce improved results on a consistent basis in all aspects of plant operations.
I Concern: "Specifically, can the Commission be sure that the health and safety of the public can be assured given the most recent SALP report which continues to document operator failure."
~Res onse:
The most recent Systematic Assessment of Licensee Performance (SALP) report of May 7, 1990, provides an assessment in the Plant Operations section for NMP-I which notes both areas of improvement and examples of events that reflected poor performance.
The report noted that "More effective management, particularly oversight of daily opera-tions, appeared to be needed to raise overall operations department performance."
However, the assessment did not find that the examples of poor performance events were of sufficient magnitude to call into question the fundamental ability of the operations staff to operate the plant safely.
Concern:
The NRC is under pressure by the licensee to permit restart.
~Res onse:
The NRC wi'll not permit the Nine Mile Point Unit L station to pro-ceed with startup until there is reasonable assurance that the licensee can do so in a competent, controlled, and safe manner that will ensure protection of the public health and safety.
When a
restart is allowed, the NRC staff plans to monitor very carefully the licensee's
- startup, including performing focused reviews at several stages in the program.
In addition, the NRC staff will continue to keep the facility in the category of plants requiring close monitoring until such time as sustained acceptable performance during operation is demonstrated.
The staff has not identified any issue for which an evidentiary hearing would be required prior to an NRC determination regarding restart.
It should be noted that the staff previously provided opportunity for public comment on the licensee's plan for restart in a public meeting held August 23, 1989, in
- Oswego, New York.
Rosemary S. Pooler, Esquire Vice President for Legal Affairs Atlantic States Lhgal Foundation, Inc.
658 West Onondaga rect
- Syracuse, New York 3204-3356
Dear Hs. Pooler:
I am responding to your Ma 14, 1990 letter to the Nuclear Regulatory Commission regarding the Nine Mile Poi t Nuclear Station Unit No. 1.
The NRC staff has responded to your concerns as stated in the enclosure to this letter.
I trust that this information w) 1 be useful to you.
Sincerely,
Enclosures:
1.
NRC Staff Response 2.
NRC Responses to Public Comments on Restart Action Plan, dated December 6, 1989 Kenneth H. Carr Distribution:0-22O/i ig NRC/Local PDR w/incoming EDO 80005471 EDO Rdg THur 1 ey/FHirag 1 ia JPartlow PDI Rdg w/incoming
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Rosemary S. Pooler, Esquire Vice Presiden for Legal Affairs Atlantic Legal oundation 658 West Onondaga Street
- Syracuse, New York 13204-3356
Dear Ms. Pooler:
I am responding to y r May 14, 1990 letter to the Nuclear Regulatory Commission regarding the Nin Mile Point Nuclear Station Unit No. 1.
The NRC staff has responded to your co cerns as stated in the enclosure to this letter.
I trust that this informati n will be useful to you.
Sincerely,
Enclosures:
1.
NRC Staff Response 2.
NRC Responses to Public Comments on Restar t Action Plan, dated December 06, 1989 Kenneth M. Carr RACapra CVogan REMartin DCrutchfield FGillespie WRussell OGC PGA/CA SECY Beverly Clayton Tech Editor PDI-1 gg~
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FROM:
DUE: 05/31/90 EDO CONTROL: 0005471 DOC DT: 05/14/90 FINAL REPLY:
ROSEMARY S.
POOLER ATLANTIC STATES LEGAL FOUNDATION, INC.
TO:
COMMISSIONERS FOR SIGNATURE OF:
GRN CRC NO: 90-0525 DATE: 05/16/90 ASSIGNED TO'RR CONTACT:
HURLEY SPECIAL INSTRUCTIONS OR REMARKS:
RESPONSE
TO BE CLEARED WITH THE COMMISSION PRIOR TO DISPATCH.
DESC:
REQUEST ANSWERS TO QUESTIONS RE NINE MILE POINT 1
ROUTING:
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MAY'6, 1990 ACTION:
DRPR:VARGA NRR ROUTING: v'MURLEY/MIRAGLIA UPARTLOW y CRUTCHFIELD uCiILLESPIE USSELL SMYRE A-C-T-I-O-)
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ACTION OFFICE:
CRC-90-0525 EDO LOGGING DATE: May 15 90 AUTHOR AFFILIATION:
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