ML20039G116
| ML20039G116 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/08/1982 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8201150301 | |
| Download: ML20039G116 (15) | |
Text
_ _ 4 January 8, 1982 UNITED STATES OF AMERICA u bb '
NUCLEAR REGULATORY COMMISSION
'82 JM ll R2 :13 Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, et al. ) 50-441
)
(Perry Nuclear Power Plant, ) c) c)
Units 1 and 2 ) ) & 4 9 UCElL'EO p '\
APPLICANTS' ANSWER TO SUNFLOWER ALLIANCE MOTION FOR LEAVE TO $
g 8 /Sg FILE ADDITIONAL CONTENTION A /
o 9 .A In a motion dated December 18, 1981, Sunflower Alliance, et al. ( " Sun flowe r " ) seeks leave to file a additional conten-tion. The proposed contention states:
That the Applicant undertake to assure that the Perry Nuclear Power Plants control systems be upgraded, perhaps by making them redundant, so that no single failure in the system will cripple the control system.
Applicants oppose admission of Sunflower's proposed contention.
It should be rejected as untimely. It should also be rejected for failing to meet the basis and specificity requirements of the Commission's regulations.
I. Sunflower Has Not Justified Admission Of Its Untimely Contention ,
Sunflower admits that its contention is untimely. Brief, ,
- p. 2. As a resul't, the contention can only be admitted based i
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( 8201150301 820108 68 I PDR ADOCK 05000440 G pon
. upon a consideration'of the criteria specified in 10 CFR S 2.714 for late filings. The relevant case law has been summarized in prior filings l and need not be repeated here. It is clear that Sunflower has not adequately justified admission of the contention.
The most important factor in determining whether the contention should be admitted is intervenor's showing of good cause for the delay. Sunflower's showing is totally inadequate. Sunflower states that the issue of control systems' safety and reliability "has only recently been discovered", Brief p. 2, and refers to unidentified recent i
i media reports, Brief, pp.1, 3. Sunflower fails to identify.
i when these revelations took place, whether the information in the recent media reports was something new, and whether the information has any bearing on the Perry plants. The most specific allegation provided by Sunflower is that the concern about control systems comes "(al s a result of a recent failure at the Rancho Seco Nuclear Power Plant in Clay Station, California". Brief, p. 1. Sunflower dcss not specify what this "recent failure" was er when it occurred.
1 " Applicants' Answer to Ohio Citizens for Responsible Energy Motion for Leave tc File its Contention 15", dated December 7, 1981; " Applicants' Answer to Ohio Citizens for Responsible Energy Motion for Leave to File its Contention 16",
dated December 7, 1981; " Response of NRC Staff to Motions of Ohio Citizens for Responsible Energy for Leave to File Contentions 15 and 16", dated December 11, 1981.
~
Applicants' research has found what appears to be the source of Sunflower's contention. The attached article from the December 6, 1981, New York Times uses language identical to that in Sunflower's filing.2 The article identifies the "recent failure at the Rancho Seco Nuclear Power Plant" as a rapid shutdown of the reactor which occurred when a dropped i
light balb caused short circuits in the control systems.
However, that episode took place in March 1978, almost four years ago, and cannot conceivably be classified as new informa-tion. Even if Sunflower were to be excused for not being aware that this event has been common knowledge in the technical community for some time,3 it cannot escape responsibility for information which appeared in the same sources that it now relies upon. For example, the New York Times two years ago 2 The December 1981 New York Times article also discusses the possibility of a radiation embrittled reactor pressure vessel failing due to sudden thermal shock. This issue affects pressurized water reactors, not boiling water reactors such as Perry. See NRC Press Release 81-133, "NRC Staff Seeks Additional Information on Pressure Vessel Thermal Shock" (April 26, 1981);
SECY-81-286 " Pressurized Thermal Shock" (May 4, 1981); NRC Staff Generic Letter 81-19, " Thermal Shock to Reactor Pressure Vessels" (April 20, 1981); Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit 1), Partial Initial Decision, vol. 1, pp. 123-24 (December 14, 1981).
3 See, e.g., NURZG-0667, Transient Response of Babcock &
Wilcox - Designed Reactors", Table B.2 (May 1980); SECY 286, " Pressurized Thermal Shock" (May 4, 1981); NRC Board Notifica' tion BN-81-06, " Thermal Shock to PWR Reactor Pressure Vessels" (May 8, 1981); Office of Nuclear Reactor Regulation, Generic Letter 81-28, " Steam Generation Overfill" (July 31, 1981). As is clear from the titles of these documents, the Rancho Seco occurrence is relevant to Babcock & Wilcox/ pres-surized water reactors.
discussed the Rancho Seco event in an article reporting a control system failure at the Crystal River facility, like Rancho Secc a Babcock & Wilcox reactor.4 Reliance upon an event which occurred four years ago as good cause for a late contention seems at the least far-fetched. An intervenor should not be permitted to select only the most recent newspaper report of an episode which happened years age and argue that it has somehow shown good cause.
Sunflower's Brief claims that the issue of safety and reliability of control systems "has only been recently disco-vered", that to its knowledge "there was no concern about the safety and reliability of the control systems in March of 1981", and that "to the best of the knowledge of your Intervenor, the issue has never been litigated." Brief, p. 3.
The safety and reliability of control systems is not a new issue. In fact, a whole chapter of Applicants' Final Safety Analysis Report, more than 300 pages, is devoted to these systems. FSAR, chapter 7. The Staff's Standard Review Plan also includes detailed requirements for control systems.
NUREG-0800, chapter 7. Nor is it accurate to state that the issue has never been litigated. In fact, the control system for the Rancho Seco facility itself has been litigated.5 The 4 A copy of this article, dated February 28, 1980, is attached.
5 Sacremento Municipal Utility District (Rancho Seco Nuclear Generating Station), LEP-81-12, 13 NRC 557, 568-573 (May 15,
i 1 .
1
- same control system was also the subject of litigation with I
respect to Three Mile Island, Unit 1, like Rancho Seco also a Babcock & Wilcox plant.6 As a generic matter, the NRC is examining the safety I
implications of control systems. (As shown in Part II below,
! the mere existence of a generic issue is not enough to support admission of a contention.) In its August 12, 1980 letter to then Chairman Ahearne, the Advisory Committee on Reactor Safeguards suggested that control system reliability be considered an " Unresolved Safety Issue". In December, 1980 the Staff adopted Task A-47 as an " Unresolved Safety Issue". Task A-47 calls for the development of generic criteria to be used I for plant-specific control systems reviews. See NUREG-0606,
" Unresolved Safety Issues Summary", Vol. 3 No. 1 (February 13,
- 1981). NRC discussed the issue in its report to Congress in March 1981 as well as in its 1980 Annual Report. The 4
(continued) 1981); see also Sacr,enento Municipal Utility District (Rancho Seco Nuclear Generating Station), ALAB-655, 14 NRC (October 7, 1981).
! 6 Metropolitan Edison Co. (Three Mile Island Nuclear Stati9n, Unit No. 1), Partial Initial Decision vol. 1, pp. 107-e 124. (December 14, 1981). The TMI decision also included a lengthy discussion of the more general issue of systems i interaction. Id., pp. 198-216.
1 7 NUREG-0705, "Special Report to Congress: Identification of New Unresolved Safety Issues Relating to Nuclear Power Plants", pp. 11, A-9-ll (March 1981).
! 8 U.S. Nuclear Regulatory Commission, 1980 Annual Report, i p. 45 (March 1981).
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Advisory Committee on Reactor Safeguards discussed the issue at a number of public meetings during early 1981.9 While it may be true that Sunflower has only recently learned about control systems, there is no basis for concluding that the control systems issue is new. Other intervenors have litigated control system issues ac long as two years ago.10 As noted above, the Rancho Seco episode of March 1978 had been in the newspapers well before the December 6, 1981 article apparently relied upon by Sunflower. An intervenor cannot blithely sit back and ignore information which has been both widely known and readily available untilca newspaper article happens to catch its eye.
Any other result would read the good cause requirement out of the regulations.
Nor has Sunflower made an adequate showing on the other t
balancing factors of 10 CFR S 2.714, particularly where its showing of good cause is so weak. As for other means to protect Sunflower's interest, the Staff's on-going generic 9 See 46 Fed. Reg. 1379 (January 6, 1981); 46 Fed. Reg. 7456, 7457 (January 23, 1981); 46 Fed. Reg. 10030 (January 30, 1981); 46 Fed. Reg. 12171 (February 12, 1981); 46 Fed. Reg. 13436 (February 20, 1981); 46 Fed. Reg. 13612 (February 23, 1981); 46 Fed. Reg. 16009 (March 10, 1981); 46 Fed. Reg. 19123, 19124 (March 27, 1981); 46 Fed. Reg. 20337, 20338 (April 3, 1981); 46 Fed. Reg. 22839, 22840 (April 21, 1981); 46 Fed. Reg. 24334 (April 30, 1981). The meetings took place on January 23, February 6, February 24-25, March 25, April 11 and May 7, 1981.
10 The evidentiary hearings in Rancho Seco took place between February and May 1980. See LBP-81-12, 13 NRC at 566. The TMI hearings on control system issues took place in December 1980.
Y - -
investigation is aimed at the overall concern which Sunflower appears to be addressing. And, as the Commission has observed,
" parties sre always free to bring to the attention of the Commission any matter within its jurisdiction." Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), CLI-81-5, 13 NRC 361, 364 (1981). As to the third factor, assistance in developing a sound record, Sunflower has pointed to no particular knowledge or expertise relevsnt to the proposed contention. In fact, Sunflower's acknowledgement that its concern about control systems has only come about as a result of recent media reports belies any substantial familiar-ity with the subject matter. The fourth factor, representation of Sunflower's interest by other parties, favors admission of the contention but is far outweighed by the inadequate showing on the other factors. The final factor also cuts against Sunflower; any new contention necessarily brosdens the issues.
Whether or not it would delay the proceeding is speculative.
On balance, Applicants submit that Sunflower has failed to make an adequate showing to justify admission of its untimely contention.
i II. The Proposed Contention Fails To Meet The Basis and Specificity Requirements of Section 2.714 The-Commission's Rules of Practice require that a conten-tion, to be admissible, must include a stetement of its basis set forth with reasonable specificity. The Licensing Board has provided an extended discussion of these requirements. Special Prehearing Conference Memorandum and Order, LBP-81-24, 14 NRC 175, 181-184 (July 28, 1981). Sunflower's proposed contention fails to meet these standards.
It must first be pointed out that the FSAR contains a long and detailed discussion of control systems. FSAR, Chapter 7.
These three hundred plus pages analyze the Perry control systems, including their compliance with applicable General Design Criteria, IEEE Standards, and NRC Regulatory Guides.
Sunflower's contention and the accompanying brief totally ignore this information. Instead, they focus on "a recent
[ sic] failure" at Rancho Seco, a pressurized water reactor manufactured by Babcock & Wilcox, which bears no apparent resemblance to the Perry facility or its control systems.
Sunflower has shown no awareness of the Perry facility design, the relevance of the Rancho Seco episode to Perry, or any specific problems with the Perry control systems. The Licensing Board and the other parties are lef t to speculate on the relationship between the 1978 Rancho Seco event and this proceeding. In short, no nexus has been established.
The Appeal Board has explicitly addressed the admissibi-lity of contentions in these circumstances. In , Gulf States Utilities Co. (River Bend Station, Units 1 ).nd 2), ALAB-444, 6 NRC 760 (1977), the State of Louisiana attempted to litigate a number of generic issues in the proceeding.11 The Licensing 11 Although the State was a 10 CFR S2.715(c) participant rather than a 10 CFR S2.714 party, and its issues not technically con-Board rejected the State's attempt, holding that no nexus had been shown between the generic issues and the 'harticular facility. The Appeal Board agreed.
Given the generalized nature of the studies identified in the TSAR [ Technical Safety Activities Report] and the status of regulatory guides, it was not erroneous for the Licensing Board to have imposed its nexus requirement. Unlike in [ sic] the case of the SER, where the relationship to the facility is perforce established by its introduction into evidence in connection with the application, there is no necessary connection between the safety of a facility and any particular TSAR item or regulatory guide. Some connecting link must therefore be supplied.
The mere identification of a generic technical matter which is under further study by the staf f ( such as a TSAR item or Task Action Plan) does not fulfill this obligation, even if the matter has some patent relationship to the category of reactor under review. For as we have seen, the generic study may have little bearing on safety -- e.g., where it concerns the methodology of the staff's review. To establish the requisite nexus between the permit or license application and a TSAR item (or Task Action Plan), it must generally appear both (1) that the underta-ken or contemplated project has safety significance insofar as the reactor under review is concerned; and (2) that the
, fashion in which the application deals with
! the matter in question is unsatisfactory, i
that because of the failure to consider a I particular item there has been an insuffi-l cient assessment of a specified type of risk for the reactor, or that the
( short-term solution offered in application l
(continued) tentions, the Appeal Board applied the same tests as if the party and contention rules applied. 6 NRC at 768, 772.
i
to a problem under staff study is inadequate. To bring newly issued regula-tory guides into play, .if would have - to shown, e.g., that the means adopted by the applicant (as reflected in the application) for satisfying a regulatory requirement are either not efficacious or significantly less satisfactory than those recommended in the guide.
6 NRC at 767 (footnote omitted) . Absent such a showing of nexus, the proposed contention must be rejected.
The nexus requirement is particularly appr opriate here.
Sunflower relies on a failure in Babcock & Wilcox pressurized water reactor, not the General Electric boiling water reactors used at Perry. The Babcock & Wilcox design also uses a particular type of control system (the " Integrated Control System") peculiar to Babcock & Wilcox reactors. Considering the substantial amount of information available to Sunflower, something more than a generalized reference to an unrelated incident at an unrelated facility is required. Nor can Sunflower take credit for the unsubstantiated, unsupported claim that "a failure in the control systems of the Perry l
l Nuclear Power Plant could easily trigger an accident of the proportion of Three-Mile Island", Brief, p.2. Sunflower has simply provided no basis for the contention.
12 See Sacremento Municipal Utility District (Rancho Seco Nu-clear Generating Station, LBP-81-12, supra; Metropolitan Edison i Co. (Three Mile Island Nuclear Station, Unit No. 1), Partial Initial Decision, supra.
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III. Conclusion Sunflower has not presented adequate reasons to justify admission of its untimely contention. Nor has it meet the tests established for contentions generally. Part of the problem may be Sunflower's apparent misconception of the role of the Licensing Board. Sunflower believes that it is a mandatory requirement that the Atomic Safety and Licensing Board specifi-cally find that the Perry Nuclear Power Plant can be operated in such a manner so as not to endanger the public health.
Brief, p. 4. Sunflower also cites to 10 CFR S 50.57(a)(3) for the proposition that the Licensing Board must make a finding on the overall safety of the facility before it can grant an operating license. Brief, p.2. At the operating license stage, the responsibility of the Licensing Board is, of course, to decide matters in controversy and those issues raised sua sponte. 10 CFR S 2.760a; 10 CFR S 2.104(c). The responsi-bility to make the findings required by S 50.57(a) is the Commission's. Within this regulatory framework, Sunflower must do more than cite to a four-year old event at an unrelated facility to warrant admission of a new contention at this stage of the proceedings.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWERIDGE By: / f Ja 5. $11 berg [
Co seljfor Applicants 18 M Street, N.W.
Dated: January 8, 1982 Wasnington, D.C. 20036 (202) 822-1000
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THB NBW YORK TIMES,. SUNDAY, DBCBMBER 6,1981 f- ,
Nuclear Accident Raises Doubt on Safe :y Marginski l ByMATDIEW J.WAI.D termperature falls while the pressure is equipment, pumps and valvesin critical the commission's research on the prot >
An accident that began when a techn!-
high? parts of the plant. While " safety rys- ability of a low temperature-high pres-In a recent meeting with the Nuclear tems" must meet stringent require- sue accident.
clan dropped a light bulb has raised Regulatory Commission, one member nents to withstand fire, eenhquake, D commission staff now says it be-serious questions in the minds of nuclear of the commission's Adviso Commit- electric power failure and other chal. lleves that the probability of a high-experts about their ability to estimate tee on Reactor Safe rds, yer Eend- lenges, control systems do not, because presst m and low. temperature combing.*.*
accurately the likelihood of a disastmus er, said that the an er point might it is assumed that if they fall, the safety tion % not so great that corrective action fatture in many of the nation's nuclear havealread beenrea ed, although he systems willtake over. Is warmnted now but, according to a gg merr.orandu Oct. 30 to the commis-debted it. e estimated that "two or SomeImbt ValidHyofIHetinctlee stoners, it *,m ofmay be aquimd for some tis ue are two factors that in combi. thne vessels' wem especially pmne to nation couId more eastIy lead to a disas- cracking because of metallurgical Some engineers now believe, how- plantswithina ear."
ter than,elther factor alone. ne are en- characteristics and design. "Unless you ever, that the distinction is meaning- As the ccmm stoners have sought as-gineers uncertainty about the greet ement less, because a failure of the control sys- surances about the margin of safety, nu-which working reactors have been made have looked at the g system,'ahe ," Ido tems, such as ss. ire,*, at Rancho Seco clear experts have been hazy about the brittle by years of neutrnn radiatl ,
not think we are able to say for certain and at hree Mile Island, could lead to a dangers. For example, at a joint meet.
and their waring confidence in the a - that they cannot be in trouble. I think serious accident.
Ing in October of the Nuclear Regula-ity of reactor control and safety systems r1y intuition says that they are not in According to Demetrios Basdekas, a toryCommlWon and the AdvisoryComs torespond to a fallurein the system, trouble." . safety engineer at the Nuclear Regula- mittee on Reactor Safeguards, Nunzio
- The engineers have long known that tory Commission, the safety systems do J. Pallaatno, the chairman of the com. -
radiation from the reactor core over ReactorShut Down Abruptly not create an " umbrella" of inttction mission pressed members of the advi '
years causes steel to become brittle. All ne discusalon was over the plant. "It turns out that the um- advice thst we '
steel is brittle when it is cold enough (30 abrupt halting of the krombted anc Seco nu-bybrella sory cor* mittee for "an[confusencs the has a lot of holes," he said. The have a certain degree o that degrees below retu Fahrenheit for ordi- clear plant in Clay Station Calif., when conrol and safety systums, he said, have we are right, even on the oldest plants' - '
nary stmetural steel, for example). a worker dropped a light Intib inside a a tendency to "sw.melve, cascade fail
- foraperiodof time." u Over the years, as the steel of which control panel and the bulb itself caused ures," because they are interconrected. Dispute From Operator reactor pressure vessels are made ab- short circuits in the control systems, nat is how a small disruption brought scrbs neutron radiation, the tempera- which made the reactor shut down fast. down so many systems at Rancho Seco, At the other end of the argument are ,
the licensees. Northeast Utilities, for e s. .
ture at which it turns brittle (the refer. In f act, it shut down so f ast that, had the hesaid.
ence temperature) rises, reactor been older, it is likely that the With a brittla reactor vessel, or in a ample, has test data for its Connecticut .:
pressure would have cracked the walls, newer plant, an earthquake or fire while Yankee plant, in Haddam Neck, Conn., .:
Rateincludedin Design ne result could have been loss of cool- the plant is running, he said, could cause slawing that the reference temperaturo -
In building reactors, the predicted ant, which would have allowed the fuel the control systems to "go haywire," is 130 degrees, and will reach 150 de-grees at the and of its !!fe. The unnmis. -
rate of embrittlement is included in the to heat up and melt into an uncontrolla- pumping water too fart or too slow, ston udng a diff6 rent test, widch North <
calculations. But estimateg of the ble mass ' draining parts of the system that must amount of radiation have risen recently, ne full consequences of a meltdown be kept covered, or filling steam pipes east Util,tles says is too conservative,"
found the reference tempenturo to be .
and engineers have learned that the use are little known, because there has w*.thwater. causing a rui ture. 230 degrees aiready. 8.
of traces of nickel and copper in the never been one. But it is considered by Major Effort May Be Needed Staff memtwsof theNuclearRegula- .
welds has made them more susceptible engineers the worst thing that can 30 to radiation attack. De safety factors wrong. All reactor systems are designed Some other engineers are beginning to tory Commissson acknowledge that the ,
computed into the steel have been called to prevent a meltdown, not to deal with agree with Mr. Baadeus that a major right c xdition could cause a vessel to into question as uncertainty has grown one. effort may be r utred tobpgrade con- crack, but question their likllhood. "If .
about the temperature at which brittle- Beyond the brittleneas problem, the trol systems, ps making them re- you postulate more severe overcooling.
ness setsin. Incident raises the issue of a whole class dundant so that no single failure would events, you can get to a point, corre ..
As long as the reactor is hot enough, of systems whose vulnerability to short cripple a system. "no ladustry, along sponding with lor proMbility, where operating normally at 550 degrees Fahr- circuits and fires and earthquakes may with the commisalon, is learning that you can predict failure." said Mr.
enheit under pressure of 2,200 pounds a bea safetyhazard. there is a lot more safety significance to Woods.
squaru tnch, there is little cause for con- he systems are called ** control sys- nonanfety systems than we thought,"
ccm, experts believe. But what if the tems," and they include monitoring said Roy Woods, who is in charge of the 'DO NOT FCMGET THE NEEDIE5TI m ',
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In i.he Matter of )
)
THE CLEVELAND ELECTRIC ) Docket Nos.53-440 ILLUMINATING COMPANY _et _al, ) 50-441 (Perry Nuclear Pcwer Plant, )
Units 1 and 2) ')
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing
" Applicants' Answer To Sunflower Alliance Motion For Leave To File Additional Contention", were served by deposit in the U.S. Mall, First Class, postage prepaid, this 8th day of January 1982, to all those on the e.ttached Service List.
< A [ 4
. Ja' . ffilberg Dated: January 8, 1982
)
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
THE CLEVELAND ELECTRIC , Docket Nos. 5'0-440 ILLUMINATING COMPANY _Et A1.)
50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) ).
SERVICE LIST Pator B. Bloch, Chairman Robert. Alexander-
~
Atomic Safety and Licensing Board OCRE Interim Representative U.S. Nuclear Regulatory Commission 2030 Portsmouth Street (2 Washington, D.C. 20555 Houston, Texas 77098 Dr. Jerry R. Kline Daniel D. Wilt, Esquire -
Atomic Safety and Licensing Board Wegman, Hessler & Vanderburg U.S. Nuclear Regulatory Commission Suite 102 .
. Washington, D.C. 20555 7301 Ch1ppewa Road .
Brecksville, Ohio 44141 ..
Mr. Frederick J. Shon .-
C Atomic Safety and Licensing Board Terry Lodge, Esquire :
- U.S. Nuclear Regulatory Commission 915 Spitzer Building Washington, D.C. 20555 Toledo, Ohio 43604 Atomic Safety and Licensing Mr. Tod'J. Kenney Board Panel 228 South College, Apt. A-U.S. Nuclear Regulatory Commission Bowling Green, Ohio 43402 Washington, D.C. 20555 Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Panel Lake County Administration Center U;S. Nuclear Regulatory Commission 105 Center Street Washington, D.C. 20555 Painesville, Chio 44077 Docketing and Service Section Office of the Secretary John G. Cardinal, Esquire U.S. Nuclear Regulatory Commission Prosecuting Attorney .
Washington, D.C. 20555 Ashtabula County Courthouse Jefferson, Ohio 44047
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James H. Thessin, Escuire -
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission --
Washington, D.C. 20555 .
.