ML20035F581
| ML20035F581 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/12/1993 |
| From: | Culver N SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13885 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9304220051 | |
| Download: ML20035F581 (5) | |
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. ;Lnij}D U5NrA SAN LUIS ODISPD MOTHERS FOR PEACE 33 Nm 15 P3 :51 before the ATOMIC SAFETY AND LICENSING BOARD
, q,p. M
- a In the matter of b6i ' N '-
t Pacific Gas and Electric Co Docket No. SO $75-OLA-2 D
Diablo Canyon Nuclect Power Plant SD-323-OLA-2 Unit Nos. I and 2 ASLBP No. 92-SSS-03-OLA-2 Facility Operating Licenses No. DPR-80 and DPR-82 April 12, 1993 Intervenor Son Luis Obispo Mothers for Peace Third Late-Filed Contention In accordonce with 10 CFR 2.714Cc]C13, this document supplements the Son Luis Obispo Mothers for Pecce Supplement to Petition to Intervene.
The San Luis Obispo Mothers for Pecce C"SLOMFF"] has been granted a hearing and petition for leave to intervene in the proceeding involving the propcsed amendment of the operating licenses for the Dicblo Canyon Nuclect Power Plant ("DCNPP"), Units 1 and 2.
Preheoring Conference Order CRuling upon Intervention Petition cnd Authorizing Hecring]CJonuary 21, 1993).
This omendment would extend the life of those licenses by more than 13 yects for Unit 1 and almost 15 years for Unit 2.
For the reasons set forth below, the SLOMFP is submitting the Ecllowing to supplement its original Supplement to Petition to Intervene.
XII.
The San Luis Obispo Mothers for. Peace contends thot deficiencies exist at the DCNPP with the environmental qualification of safety-related and non-sofety-related electrical cables COkonite cables or other cables with bonded jockets).
Furthermore, deficiencies exist in the adequacy of maintenance and surveillance practices at DCNPP to verify that the octual operating environment of these cables are bounded by the environmental parameters used to qualify the equipment.
Because these deficiencies make 9304220051 930412
%g PDR ADOCK 05000275 0
the plant more vulnerable to o severe occident, Pacific Gas and Electric Company's C"PG&E"3 license omendment request must be denied.
i SLCMFP believes that there may be some overlap in content with Contention I CMaintenance and Surveillonce].
But SLOMFP foresees that there moy be some aspects of this specific problem that may not be covered under Contention I.
1 Bosis:
Several cable failures have occurred at DCNPP:
On February 5, 1993, on electrical fire occurred at DCNPP in Unit 1 cable spreading room os o result of on electrical ground in the No. 11 Circulating Water Pump.
Event F 25029 CFebruary 6, 19933.
PG&E pulled a length of Unit 1, 12kV circulating water pump cable and found that opproximately 200 feet of the total 440 feet of cable showed signs of degrcdotion.
The vendor COkonite) indicated that "the degradotion is unprecedented and has not been seen by the industry previously."
Region U l
l Morning Report CFebruary 17, 19933.
There have been three cccasions since 1989 in which the Auxilicry Salt Water CASW3 system 4.15 kV safety-related cable has failed, apparently due to submergence.
The first failure of this type of cable was in October 1989 on OSU pp 2-2.
The second failure was in May of 1992 on the Bus 19E feeder.
The mcst recent of these failures took place in November of 1992 on ASU i-2 feeder cable.
The Onsito Screty Review Group COSRG3 expressed concerns regarding the repertobility of these failures and lock of documentation for the acceptobility of potentially degraded cable.
All three insulation failures cccurred in the vicinity of the first circuit pull box cutside the turbine building.
CSRG concludes that "the cable hos 2
i i
I been degraded due to repected submergence over the post 20 years."
CSRG CNovember 1592 Ncnthly Repcrt] Enclosure 1, ct 2.
Additionclly, the NRC has issued on information notice and cierted all holders of operating licenses or construction permits for nuclear power reactors of the qualification test results which indicate that Okonite cable with bcnded Hypolon jockets may be susceptible to fcilure.
Furthermore, other bonded-jocket cables may be susceptible to the some type of failures.
NRC Infccmotion Notice 92-81:
Potentic1 Deficiency of Electrical Ccbles with Sonded Hypolon Jackets CDecember 11, 1992).
Other internal NRC documents demonstr '.e NRC concern regarding failures of Okonite electrical cables with bcnded Jcckets:
13 In on NRC Memcrondum for Commissioners Rcgers, Curtiss, Remick cnd de Planque from Jcmes Tcylor dated December 10, 1992, the Commission was notified of the potentici deficiency in the environmental qualificction of these types of cables.
It reviewed test results and identified the variety of cables experiencing fcilures.
Also enclosed was a "Tcsk Action Plan Outline for Sonded-Jacket Cchles" CDecember 29, 19923.
23 In c letter to U1111cm Rosin of NUMARC frcm Willicm Russell, Office of Nuclecr Recctor Regulation CNRR] dated December 22, 1992, the NRC notified NUMARC cf the deficiency in the envircnmental qualification cf electrical ccbles with bonded jockets and inquired about their interest in being the fccc1 point for industry in resolving this issue.
It noted that "much of the Scndic test dato that are the basis for the IN and the NRC concerns have not yet been published."
33 Ashok Thadoni sent c Memorandum to Steven Ucrgo, Jcck Roe and Williom Travers (c11 from NRR] cn January 27, 1993.
In this memcrandum, 3
Mr. Thedoni informed the recipients of the recent develcpments regarding failures of Okonite and other bonded-jocket electrical cables.
He further cdvised them that their assistance in formulating the Generic Letter may be required.
Justification for Late-Filed Contention j
13 SLOMFP bcs good cause to file Contention XII at this time because the information has only recently been made ovcilable to SLOMFP.
Robert Pollced, o nuclear engineer at the Union of Concerned Scientists, recently received a set of internc1 NRC documents [the Region U Morning Report of Februcry 17, 1993 and 1 through 3 noted above].
He received these documents anonymously.
He forwarded this information to SLOMFP on March 25, 19S3.
SLOMFP received the OSRG meeting notes from PG&E discovery response to document requests at the site visit on March 16, 1993.
The importance of the OSRG information regarding the three ASW cable failures wcs not oppcrent until SLOMFP received the interno1 NRC documents.
SLOMFP has since moved for leave to file cdditianol discovery regarding Okonite cables with bonded jockets and filed written interrogotories and requests for the production of documents to both PG&E and the NRC CApril 2, 19932.
Additionally, SLOMFP consultants from MHB Technicci Associates, Greg Minor and Steven Shally, reported their concerns regarding the cable degrodotion at DCNPP to Dr. Ashok Thodoni of NRR.
SLOMFP served their letter to the Licensing Board on April 2, 1993.
SLOMFP has proceeded as quickly as possible to evolucte the information and to assemble enough evidence in support of Contention XII to satisfy the Commission's standard for admissibility of the contention.
1 4
23 No other forum exists by which SLCHFP can be hecrd by on importial judge end have its interests protected.
33 SLCMFP's po-ticipation in the litigation of this contention will lead to the development of a sound record.
SLOMFP has obtcined technical cssistance in prepcring its cose on this issue cnd expects to be able to provide expert testimony on the significant risks posed by the degraded cable and its impact on the proposed operating license extension.
43 There is no other party to this cose which con represent SLOMFP's j
interests.
S3 Admission of this contention at this time con be expected to j
broaden and delcy this proceeding.
However, any such delay would not.be the fault of SLCMFP.
Moreover, tiie litigation of this issue would not prevent or delcy the operation of DCNPP.
l 53 Environmental qualification is on extremely important issue with tremendous safety significance.
Respectfully Submitted,
)
blJUDAs
i Noney Cu ver, President Son Luis Obispo Mothers for Peace l
P.O. Box 169 i
Pismo Becch, CA S3498 5
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