ML20044B725

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Partially Withheld Commission Paper Informing of Denial of Request for Enforcement Action for Facilities
ML20044B725
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 07/17/1980
From: Malsch M
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
Shared Package
ML19290F683 List:
References
FOIA-92-436 SECY-A-80-103, NUDOCS 9303030245
Download: ML20044B725 (44)
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Text

{{#Wiki_filter:- UNIVED STAT ES 1 NUCLEAR R E GULATO RY COMMITS 10N ADJUDICATORY ITEM m.30_,03 COMMISSIONER ACTION For: The Commissioners Frem: Martin G. Malsch Deputy General Counsel ~

Subject:

D.TRECTOR'S DENIAL OF. 2.206 RELIEF" (VIRGINIA ELECTRIC PCWER CO. ), DD-80-23 F a cili ;.ie s : SPrry Power Station, Units 1 and 2; Ncrth Anna Station, Units and 2. Furrose: To inform the Commission of the denial of a reguest for enforcement action which, I \\. Review Time Expires: July 30, 1980 Discussion: In a series of five letters to. the Cccmission, Mrs. June Allen on behalf of the North Anna Environmental Coalition, asked the NRC ' to take a number of actions in regard to thei nuclear power plants at the Surry and North Anna sites based on her expressed safety concerns. Among other things, Mrs. Allen asked that each of the four.VEPCO nuclear plants either be shut down or stay out of service until certald, remedial actions had been ,: j, :, I taken. She also asked that the licensing ..." h,:,;rtuF: d'ati! i.a..- -r INI'M moritorium on the Sequoyah operating ["f'. c' license be continued. Mrs. Allen's concerns focused in particular on steam ~~ fg ~j, y generator tube integrity, the design of em _ _ _- the demineralizers, turbine cracks, and seismic questions. Each -of Mrs. Allen 's concerns and specific requests is detailed in the Director's denial and we see no need to reiterate them here. T'19 57

Contact:

Marian Moe, OGC x43215 e. 9303030245 921125 M. PDR FOIA di -MF GILINSK92-436 PDR ENNNM4WWW .g. t .2, /

m l i e i The Commissioners 2 i I t i on June 20, 1980, the Director denied the requests,.which we for purposes of review,re treated together - and refused to shut down or keep down any of the reactors specified in Mrs. Allen's letters. 'the Director's reply addressed each of Mrs. Allen's individual concerns and adequately explained the Director's reasons for denying her requests f $X. S ~ OPE has reviewed the Director's Denial and considers it technically accurate and complete. Recorrendat n: l l ~ Martin G. Malsch _ Deputy General Counsel -5 Attachments: 1. Director's Denial, DD-80 2. Ltrs from June Allen to the Commission dtd Feb. 18, Feb. 22, Feb. 28, April 25 i and May 25, 1980 Comissioners'. coments should be provided directly to the Office of the Secretary by c.o.b. Thursday, July 31, 1980. Comission Staff Office comments, if any, should be submitted to the r Comissioners NLT July 24,1980, with an information copy-to the Office of the Secretary. If the paper is.of sych a nature that it reouires additional time for analytical review and coment, the Comissioners and' the Secretariat should be apprised of when coments ray he eyperted. i 1/ Consolidated Edison of New York (Indian Point), CLI i 8, 2 NRC 173, 175 (1975). i Distribution ' Comissioners - = Comission Offices Secretariat s +

f., Docket File (4) HBerkow. DISTRIBUTION: 7 9 - MStine 6 NRC PDR WRussell. JDiCamillo ~. Local PDR Dross I&E (3) TERA (4) RDeYoung DSwanson, OELD NSIC RMattson HShapar, OELD Dockets Nos. 50-230/281 EDO Rdg. VNoonan JS'cinto, OELD 50-338/339 NRR Rdg. RAClark Gray File (4) ORBf3 Rdg. LEngle Green Ticket File ORBf3 PKreutzer Mrs. June Allen WDircks President,- N AEC KCorn' ell XCampe 412 Owens Drive TRehm DNeighbors Huntsville, Alabama '35S01 HRDenton SECY 80-0398-43)), EGCase MGroff

Dear Mrs. Allen:

VStello ~ GErtter (EDO-08479) DEisenhut MJambor By letters. dated Fe'bruary 18, February 22, February 28; April 25, and Itay 25,1980, you requested on behalf of the North Anna. Environmental. Coalition (NAEC) that the Comission take sarious actions concerning the Surry and North Anna Pe.ver Stations. As noted in the letter sent to you by Mr.' Thomas Gibben dated June 2, 1980, these letters were fonfarded to the Director,' Ruclear Reactor '{ Replation, to be treated as a petition under 10 CFR {2.200 of the Comission's regulations. Upon review of ycur requests and other relevant information, I have determined not to take the requested actio~ns. The reascns for this. i decision are fully discussco in the enclesed "Cirector's Decision I, Under 10 CFR s2.206." Also enclosed is a copy of a Federal Rer;ister t Nctice regarding this decision that is being filed witn the Office of the Federal Recister for publication. A copy of this decision will be placed in the Comiss' ion's Public Docu: rent Room at 1717 H Street, N. W., Washington, D. C. 20555, and at the local Public Document Roonis for the Surry Pcwer Station located ~ at Swem Library, College of William and Mary, Williansburg, Virginia 23185 anu for.the North Anna Pouer Statien located at the Deard of Supervisor's Office, Lcuisa County Courthouse, Louisa, Virginia 23093 - and at the Alderran Library, l'.anuscripts Department, University of Virginia, Charlottesville, Virginia 22901. A copy of this document ~ will also be. filed with the Secretary of the Comission foi-Comission. review in accorda'nce with 10 CFR 92.206(c) of the Comission's regulations. Sincerely,.

  • See previous yellow for concurrences Harold R. Denton, Director Offi e of Nuclear f:eactor.'tegulation LEngle* - RAClark* - TNovak* - VNoonan* - DSwqn

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DISTRIBUTION: ',i ~ JUN 2 0 620 ' ~ ~~ Docket File (4) DEisenhut' PKreutzer ' ' ~ -NRC PDR w/ine. RPurplo KCampe -L PDR w/inc. TMovak DNeighbors TERA (4)w/inc. Glaines OELD Deckets Nos. 50-280/2S1 NSIC RTedesco CMiles 50-338/339 EDO RDG J01shinski diGroff iiRR RDG HBerkow 'GErtter (EDO-c475 Prs. June Allen ORSf3 RDG WRussell Schilk, SECY (5)o President Herth Anna Environ:nental WDircks Dross CStephens, SECY" Coalitien ~ XCornell RDeYoung LSickwitt, GC** 412 Owens Drive TRehm RMattson JMurray, RD** l HDenton VNoonan ARosenthal, ASLAR Huntsville, Alabam 35501 ECase RClark -MStine VStello LEngle JDiCamillo -

Dear Mrs. Allen:

I&E(3)- Sy letters dated February 18, February 22 February 28, April 25 and DSwanson,0$ you requested on behalf of the Ncrth Anna Environmntal MShapar, OEL May 25,1980, Coalition (NAEC) that the Cem.ission take urious actions concerning JScinto, DEh the Surry and North Anna Pcwer Stations. .-Gray File (4 GreenTickej As noted in the letter sent to ycu by Mr. Tnomas Gibbon dated June 2, FileCESq 19S0, these letters were forsarded to the Director, Nuclear Reactor Regulation, to be treated as a petition under 10 CFR 52.205 of the l Ccmissicn's regulat' ens. l 1 l Upon revies of your requests and other relevant infonr.stien. I have j The reascns for this deter =ined not to take the requested actions. j decisien are fully discussed in the enclosed " Director's Decision l Also encTesed is a ccpy of a Federal Register Under 10 CFR {2.205." Notice regarding this decisien that is being filed witn tne IJffice of the Federal Register fcr publication. A copy of this de' cision will be placed in the Comission's Public ~ Dccu. ent Rcom at 1717 H Street, N. W., Washington, D. C. -20555, an'd at the local Public Document Rec =s for the Surry Pcwer Statien located l at Sucm Library, College of Willia = and Mary, Williacsburg, Virginia 23185 and fcr the North Anna Power Station locate # at the Board of Supervisor's Office, Louisa County Courthouse, Louisa, Virginia 23093I q' j % and at the Alderman Library, Manuscripts Departcent, University of 4 22901. A copy of this documen N Virginia, Charlottesville, Virginiawill also be filed with the Secretary of the Socymo review in accordance with 10 CFR 2.206(c) of the Comission's y uwe 3 M 2 Wh regulations. che :r ite h-Sincerely, hoc tt 1 k*v .gg.td t1. j g g,o Dg.t:3. ; Parold R. Denton, Director Office of Huclear Reactcr Re'platicn VNoonan* - .Engle* - RAClark* - TNovak* - DSwanson* *See previous yellow for, concurrences.

Enclosures:

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' cc: ' Mr. J. H. Ferguson Ellyn R. Weiss, Esquire Executive Vice President - Power Sheldon, Harmon, Roisman and Weiss Vircinia Electric and Pcwer Company 1725 I Street, N.W., Suite 505 P. d. Box 26666 Washington, D. C. 20005 Richmond, Virginia 23251 ...;I- .7 ~.. 2 7 ~~ Mr'. James C. Dunstance Mr. W. L. Stesart, Manager State Corporation Comission P. O. Box 315 Corraonwealth of Virginia i Surry, Virginia 23883 Blandon Building Richmond, Virginia 23209 Swem Library College of William and Mary ~.. Mr. Michael S. Kidd, Resident Inspector Williamsburg, Virginia 23185 ;--- U. S. Nuclear Regulatory Comission P. O. Box 128 e-Dona 16J. Burke, Resident Inspector Spotsylvania, Virginia 22553 Surry Power Station U. S. Nuclear Regulatory Comission Mr. W. R. Cartwright, Station Manager Post Office Box 959 _P._0._ Box 402 Williamsburg. Virginia 231Sb...... Mineral, Virginia 23117 ~ i Mr. Sherlock Holres, Chairran Director, Technical Assessment Division Board of Supervisors of Surry County ~ Office of Radiation Programs (AW-459) Surry County Courthouse, Virginia 23683 U.S. Environmental Protection Agency Crystal Mall !2 Attcrney General Arlington, Virginia 20460 1.:1. East Froad Street R i.- do nd, 'V i rgi ni a 23219 U. S. Environmental Protection Agency Region III Office Mr. James R. Wittine. ATTN: EIS COORDINATOR Conenwealth of Virginia Curtis Building i State Corpcration Comission - . 26th and Walnut Streets Post Office Box 1197 ~ Richmond, Virginia 23209 Philadelphia, Pennsylvania 19105 Alderran Library Mr. Anthony Gambardella r Man: scripts Dnpartment Office M the Attorney General. ---- , University of Virginia 11 Soutn 12th Street - Room 308 Charlcttesville, Virginia 22901 Richmond, Virginia 23219 Mr. Edward Kube Richard M. Foster, Esquire Board of Supervisors i 1230 A Pearl Street - 1.ouisa County Courthouse ~~ Denver, Colorado 80203 - P. O. Box 27 Michael W. Maupin, Esquire -Louisa, Virginia 23093 Hunton, Williams, Gay and Gibson Comonwealth of Virginia P. O. Box 1535 Council on the Environment Richmond, Virginia 23212 903 Nir,th Street Office Building Richmond, Virginia 23129 Mr. James Torson i 501 Leroy Mr. Paul W. Purdom Socorro, New Mexico 87801 Environmental Studies Institute Drexel University Mrs. Margaret Dietrich 32nd and Chestnut Streets Route 2, Bcx 568 Philadelphia, Pennsylvania 19104 Gordonsville, Virginia 22042 Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Comission n c M nnt nn

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DD-SO-23 i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Dockets Nos. 50-280 ) 50-281 VIRGINIA ELECTRIC AND P0h'ER COM?ANY ) 50-338 (Surry Power Station Units 1 and 2; ) 50-339 North Anna Station, Units 1 and 2) ) (10 CFR 2.206) DIRECTOR'S DECISION UNDER 10 CFR 2.206 In letters dated February 18, February 22, February 28, April 25 and May 25, 1980, Mrs. June Allen, on behalf of the North Anna Environmental Cealition (NAEC), requested the Nuclear Regulatory Comm.ission (NRC) take the following actions with regard to the Surry and North Anna Power Stations: 1. Shut down North Anna !1 for turbine inspection, installation of steam generator inspection port, and installation of redesigned valves in the nonfunctioning Powdex demineralizer, proscribing restart pending adequate spill-proof test results and resolution of the noise problem in steam genera. tors A and B. 2. Continue licensing moratorium on North Anna #2, requiring the same inspection and repairs as those for North Anna !1. (NAEC would also request that the licensing moratorium be continued for Sequoyah since this reactor also has a Westinghouse turbine. ) 3. Keep Surry !1 closed, pending its steam generator replace-ment, as unsafe to operate with its multiple related problers; plugged steam generator tubes in excess of 25%, cracked turbine, and questionable seismic resistance. 4. Maintain Surry !2 shutdown pending repair of cracked turbines, i redesign and repair of Powdex demineralizer, installation of seismic reinforcements, and stringent testing of new steam j generator and condenser tubing. j I i i l

i i i l. These letters have been referred to the Director, Office of Nuclear Reactor For Regulation for treatrent collectively as a petition under 10 CFR 2.205. L the reasons set forth in this decision, the requests are denied. j As bases for her requests, Mrs. Allen expressed certain concer'ns and posed I These concerns, and the questions regarding the Surry and North Anna Stations. NRC responses are as follows: Concern: VEPCD's revere problers with Westinghouse steam generators at Surry were to be avoided at North Anna by the presence of fresh water, by the absence of Yet according chloride, and by the use of the Powdex demineralizer or polisher. to VEPCO's 12-10-79 report, the spills of tne resins into the steam generators at Nc-th Anna actually created Surry-like corrosion conditions and the beginning cf similar corrosion and cracking in 35t of the tubes. i

Response

The licensee's report dated Decec6er 10,1979 entitled, " North Anna Power l 1 Station Unit 1, First Refueling Steam Generator Inspection Report," stated that I tube support plate corrosion observed at North Anna 1 appeared to be similar j t l to the early stages of the denting phenotena affecting other plants, especially I those with salt water cooliag. This corrosion process has been attributed ~to secondary water chemistry in other plants with the primary causal agent being ~ j ] However, the licensee concluded this could not be the case at North f chlorides. l i Anna 1. Therefore, the licensee and Westinghouse personnel made a review of the North Anna 1 plant chemistry to determine what causative acent might have induced i J i

l l _3' l the tube support plate corrosion. As stated in the licensee's report, it was, observed that a rajof disch'arge"of resins from the Powdex polisher into the i steas generaters occurring in February'1979 produced acid sulphates which may ~ ~ i have led to plate corrosionYnii subsequent denting. ~ The licensee went on-to say that'"Although the effects of sulphates on l -"i 4 l SG chemistry were not well understood at the time, it appears the Ptwdex polisher rbs' ins may have contributed cr/are responsible for tube support plate corrosion- ~ i seen at North Anna 1." The problems affecting pressurized water reactor steam generators result frem corplex interactions involving steam generator chemistry, materials, and \\ I theral hydraulic behavior. We do not knew all of the complex interactions j of steam generator chemistry which can lead to aggressive chemicals concentrating ~ and depositing on tube support plates. A great arount of research and testing is n::w underway to identify. these cocplex interactions. Tube denting occurs when carbon steel tube support plates experience l corrosion (chemical deposition) at the locat, ions where the tubes pass through the plates. The corrosion product occupies a greater volume than the original. i support plate caterial and squeezes down on the tube thereby ' deforming it. If corrosion continues, gross deformation and eventual cracking of the support plate and tubes result. We had not anticipated the occurrence of denting at North Anna 1, even at its earliest stages, based on experience in other plants using secondary all-volatile treatrent and freshwater condenser cooling. However, it was so ] l identified in the licensee's December 10, 1979 report and it was our

responsibility to evaluate the l'icensee's report to determine if the North Anna 1 steam generators could continue to operate without impairing thi health and safety of the public. -- - Our safety evaluation report for the licensee's December 10,1979 report - ' ~ was sent to the licensee -in a letter dated February 4,1980. In our report we stated that the licensee had acted in an appropriate manner to' identify the cause of early corros'io'n' on th'e tube support plates and had provided a ' satisfactory ~ explanation. k'e further stated that-the licensee had implemented conservative maint,enance (all row 1 tubes in the steam generators were plugged) and corrective actions implemented comensurate with the findings of the steam generator inservice inspection at Ncrth Anna 1. Finally, we stated that continued operation of the 1 Nor;h Anna I steam generators would not endanger the health and safety of the ~~ public. 'Since then we have continued our review of the licensee's corrective actions regarding tube incegrity, tube support plate corrosion, and changes in steam generator chemistry. Our review has been based'en long term operation of the North Anna 1 steam cenerators. On April 8,1980 we sent a letter to the licensee re-questing additional information regarding the licensee's corrective actions with respect to: (1) hideout return of acid sulphates due to previous contamination from polisher resins, (2) oxygen control, and (3) the licensee's corrective boric acid treatment at the North Anna 1 steam generators in January 1980. l The licensee has stated its response will be provided for our review in June l_980. Secondary water chemistry and its effect on steam generator tube integrity is a high priority concern of the NRC. Due to the conplexity of the corrosion l ~_

s ~ l ~ problem involveh anh he' state-of-the-art as it exists today, we have imposed' 'a ' license condition 'fer operating plants that requires the implementation of l 4 a secondary water chemistry monitoring and control program. The required program developed by the licensee with input from reactor l v'endors and other consultants ac' counts for site and plant-specific lactors ~~

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that affect chemist.ry conditions in the steam ger.erators and allows for the Morit'inous' feedb'a'ck df 'ned"kn'eJledg'e da'ined 'from operating experience. ~ ~ ~ This licensing condition was cade part of the North Anna 1 operating license by Amendment issued on December 28, 1979 and was a condition to the operating licens issued for North Anna 2 on April 11, 1980. In 1978, the NRC undertock a review of generic safety issues to determine these issues with potenticily significant public safety implications which should qualify as " Unresolved Safety Issues" for reporting to the United States Congress. The NRC review included the development of proposals by the NRC staff which I were reviewed and approved by the NRC Comissioners. This review described in a repert, NUREG-0510, entitled " Identification of Unresolved Safety Issues P, elating to Nuclear Power Plants - A Report to Congress" dated Jar.Jary 1979 identified Task Action Plan A-3, Pressurized Water Reactor Steam Generator Tube Integrity, as a high priority action item requiring resolution.- Task Action Flan A-3 provided a description of the problem; the staff's appr'oaches to its resolution; a general discussion of the bases upon which cor.tinued plant licensing or operation can proceed pending completion of the task; the technical organizations involved in the task and estimates of the manpower required; a description of the interactions with other HRC offices, the Acvisory Comittee on Reactor Safeguards and outside organizations; estimates

l - c; ..:.ne r.- of funding required for contractor supplied technical assistance; prospective. dates for corpleting the task; and a description of potential problems that* ~ ~ I could alter the planned approach or schedule. i In addition, the reorganization of the Office of Nuclear Reactor Regulation, j i which took place on April 28, 1980, has created a new branch defined as the Chemical Engineering Branch whose duties now include the review of water' chemistry[ i and the evaluation,of water chemistry management. F Also, licensees with pressurized water reactor steam generators have established a joint steam generator ewners group utilizing the expertise of the Electric powcr Research Institute to conduct high priority research and testing in these ratters. Finally, the Powdex demineralizer system at North Anna 1 was incorporated into the design of the f acility prior to the occurrence of the Surry steam i i generator problems. i Ccncern: 1 One NRC engineer likens the corrosion to a " malignant tumor," all of whose cells must be removed if' North Anna's steam generators are to regain health. Nevertheless, the NRC has permitted the installation of a steam generator in-spection port to be put off until 1981, after the second re-fueling at North Anna fl.

Response

In the licensee's report dated December 10, 1979, the licensee committed l at our request to installing inspection ports in the North Anna 1 steam generators during the second refueling outage. And, in our letter of January 21, 1980, we requested the licensee to install these ports in the steam generators at f I North Anna 2 prior to start of operations. As specifically stated in our letter, f the installation of these inspection ports was to facilitate monitoring the t

. progression of tube denting and tube support plate degradation and to facilitate the removal of tube sections fcr laboratory examinations. Inspection ports installed in steam generators will not in;themselves inhibit the corrosion process responsible for steam generator tube denting and cracking. ' ~ Maintaining a steam generator.'s;" health" as you state in your. letter involves several actions. They. are: (1) adequate secondary water chemistry monitoring and control, (2)- periodic steam generator surveillance inspections, (3)' cer'rective'. actions once steam generator corrosion and tube denting is identified, and (4). continuing research in the corrosicn phenomena involved. Both North Anna 1 and 2 will have the ports installed at the next regularly . scheduled steam gener ator inservi:e inspection specified in the Technical Specifi-cation:, for each unit, which is the first occasion that these ports would be csed to perfccm their intended function as described above. Concern: According to NRC Atlanta, the damaging resin spills at North Anna were caused by a semi-autcratic system ralfunction with Powdex valve insufficiencies requiring redesign. Thus North Anna f1 is currently operating without demin-eralization.

Response

The Powdex demineralizer system at North Anna 1 is presently bypassed whili the licensee completes an engineering evaluation for possible design changes to the Pcwdex system. Hcwever, the licensee is presently maintaining k'estinghouse specified steam generator chemistry specifications without the use of the Powdex demineralizer system.

Also, the licensee, on the recommendations of Westinghouse, has installed hydrogen ceasurement apparatus (Kent-Cambridge Mark IV Hydrogen Analyze 4 the secondary water systeru ~ The hydrogen analyzers will enable the licensee to monitor dissolved hydrogen continuously and thereby determine. any corrosion rates in the steam generators. Concern: Ironically, such a Powdex cemineralizer has just been installed in Surry l f 2, down for over a year for steam generator replacement (a difficulty some NRC It must now follow that engineers thought demineralizers might have prevented). the same redesign is required at Surry #2 to prevent a restart and subsequent resin spill which could begin Surry's $133 million steam generator repair troubles anes.

Response

The deminerali:c.- system being installed at Surry is a different type of The North Anna system than the systers presently installed at North Anna. deminerali:er system is a Powdex system and the Surry system is a Deep Bed The Powdex Demi eralizer. There is a basic difference in these two systems. system utilizes a powder flock to precoat a series of filter elements contained ~ within each cemineralizer vessel whereas the Deep Bed system utilizes resin There are two beads on top of an internal piping network in each vessel. protecting rechanisms at Surry which mitigate a resin dump such as occurred at North Anna in that the slots and holes in the Surry Deep Bed Demineralizer internal piping network are significantly staller than the resin bead diameter which prevents most of the resin from escaping. Also, each Surry Deep Bed Demineralizer vessel is equipped with a wire screen to prevent' the escape of the resin beads into the effluent. x

.g-Concern: As noted earlier, resin spill effects upon the secondary che::iistry can cause corrosion and cracking not only in the steam generators,-but also in the turbines. Since the turbine building at North Anna is settling abnormally, trie risk to turbine integrity is enhanced; periodic shiming has already been neces sary. n,

Response

The relationship between turbine disc cracking and steam / secondary water chemistry has not yet been verified. Therefore, it carnot be stated at this-time whether the resin spills at North Anna 1 could cause' and/or contribute to postulated turbine disc cracking in the North Anna 1 turbine. As part of the industry related study regarding the generic turbine disc cracking problem, the Electical Power Research Institute is presently evaluating the effect of secondary water chemistry on turbine disc integrity. By letter dated February 25, 1980, the NRC requested information from licensees with operating Westinghouse turbines regarding plant specific operating history of secondary water chemistry and the possible effects on turbine disc cracking. We are presently evaluating the licensees' responses. With respect to Ncrth Anna 1, the licensee has indicated that for 331 days of cperation, the measured pH, cation conductivity, and sodiurn concentrations indicate steam carryover (i.e. igurities) to the turbine at less than 0.25 percent. Therefore, the NRC staff believes that steam chemistry at North Anna 1 is a very unlikely factor regarding turbine disc integrity. However, until all the studies are coplete, we cannot make any specific conclusions regarding North Anna 1 and the question of turbine disc cracking and effects of secondary water chemistry.

i

  • -j n

The question of turbine integrity (i.e., missile risk) at North Anna 1 and 2 has been an issue before the Appeal Board. On April 7,1980, the Appeal Board issued a Memerandum'and Order (ALAB-589)in the North Anna 1 and 2 proceeding ( 7 regarding the issue of risk to the facility from torbine missiles. The Appeal' '} Board had heard testimony from the NRC and the licensee last June regarding i i the probabilities associated with turbine missile risks, as well as the factors of conservatism built into thesIprebabilities. More recently, the NRC sta'ff and the licensee submitted affidavits describing the recent phenor.ana of crack.in i 4 in Westinghcuse steam turbines. The investigation of this matter is ongoing and will net likely be ccmpleted until next fall. On the basis of the inferration, I supplied thus far, the Appeal Scard cencluded that the-turbine disc cracking i being experienced else here is not likely to occur to any haz:rdous extent at North Anna 1 prict to the next refueling shutdown now scheduled for Decenter t i of this year. The Appeal Board noted that the licensee has comitted to have I 1 the Unit I turbine inspected during the December shutdown, and has instructed I the licensee and staff to irnediately report any proposed deviation from that l comitment to the Appeal Board.' Upon completion of the analysis of the turbine i cracking problem, the staff and the licensee nust report back to the Appeal Board,; addressing in detail the known causes of the early cracking and ary required j and necessary actions to correct the problem. i With respect to turbine building settlerent, the staff has previously i evaluated this matter. Theoretically, if the turbine support structure were allcwed to tilt (or bend due to settling or tilting) without limit, some bending. ' of the turbine shaft (over and ab'ove the bending associated with the natural sag line) might occur. Ultimately, it is possible that the increased shaft

1 ~ I ; bending may produce additional cyclic stresses in the shaft, and thus raise 2 the probability of a fatigue failure of the shaft. However, we do not believe that a shaft failure in itself.would lead to disc failure and. missile generatien. We believe that a shaft failure would lead to severe braking of'the rotor by way of friction between the rotary and secondary parts of the turbine, causing the retor to sicv down and stop without missile generation. ~ Cur viewpoint is supported by actual turbine f ailures which produced similar { internal rotor conditions. Specifically, there have been turbine failures near operating speed wherein disc rupture occurred, but without missile ejection. i The disc ruptures induced a dynamic imbalance of the rotor components, thus l braking the rotor to a stop. A similar condition would be produced by a broken i shaft, wherein imbalance cf the damaged rotor would cause severe internal friction j i which would dissipate the rotor energy, mostly in the form of mechanical defor-1 l maticn and heat. j In addition to the above considerations, the turbine building at North Anna j

1. is being measured for indication of settlement by the licensee according l

4 to the technical specifications for North Anna 1. Based on the above, we do not believe that turbine pedestal settling at j North Anna 1 has any significant effect on the potential for turbine missile generations. j Concern: At both Surry units, the turbines are known to be cracked, with NRC staff listing Surry Unit il in Category AA and Surry Unit !2 in Category A. Although unlike North Anna, the Surry units are not now under review by an Appeal Board concerned with turbine missile risk, that risk would seem to be even greater under current Surry conditions and thus deserves the direct attention of the Cox.i ssion. I l

l t _12. I

Response

Turbine disc cracking has not been discovered at both Surry units, nor e are the turbines knean to be cracked as stated in Mrs.- Allen's letter. A key-i way crack was discovered in one disc on the Surry 2 turbine low-pressure retor during the fall of 1979 but it has been repaired and reinstalled in good condition. I At the time of your February 18, 1980 letter, Surer 1 had not been inspected f cr turbine disc cracking. H& sever, because of turbine vibration resulting f rcm the Icss of three blades, Surry 1 was shut down on february 19, 1980. l This During this shutdown, the licensee decided to inspect the turbine discs. inspection has been completed and no keyway or bore cracking was discovered { [ cn Surry 1. Therefore, the Surry turbines are in good condition as far as turbine l missile risks are concerned. Repairs have been made on the blades daraged at j Surry I on February 19, 1980. 4 The f ollowing questions have been posed by Mrs. Allen: i Wny did VEPCD make no 2/79 report of the significant and damaging i a. 200-300 pound resin spill in the North Anna steam cenerator of 2-27-79? ? l b. Why did the NRC require no report? Why did the North Anna plant continue in operation after the spill ~ c. as opposed to closing for clean-up of the resins from the steam generators? l Why did the NRC on-site inspector not know of the spill until l d. months after it had taken place? 2 Was the NRC inforced before the four (4) succeeding spills? If l ) e. so, what action was taken? Was the major resin spill of 2-27-79 related to the volume control f f. tank discharge and Iodine-131 at 310 tices specified value reported on 2-27-79 or to the " uncontrolled release to the storm drain" of 2-28-79? (See April and May OUSR's of 1979) l

. What are the implications of the three September 1979 spills on g. l the 10th,12th, and 15th, followed by the radiation release accident of September 25? h. Have resin-spill effect warnings been sent to cther licensees with Powdex demineralizers and Westinghouse steam generators? l i. Was HRC's first notice of W turbine disc cracking and missile pro-blers the anonymous letter of November 5,1979 suggesting a " flagrant l i Westingho,use violation"?,, j. In tercs of reportability, NAEC is puzzled as to why the 3-26-79 reactor scram at Browns Ferry il was not a reportable event since l it was "due to false high pressure and low water level signals generated when concrete inat was dislodged during a floor drilling operation struck a local panel." d Todzy we are concerned with the implications of disgruntled employees at Erowns Ferry cutting the cords and removing the mouthpieces of 'i "between 65 and 70 inplant telephones" this past weekend. What does l this event say of worker responsibility or worker comprehension of the safety necessity of inplant communication? Will there be an HRC investigation? Response to cuestions (a), (b), (d) and (e): Five resin spills occurred at North Anna 1 on February 27,1979; July 19, 1979; and on September 10,12, and 15,1979, respectively. The February 27, 1979 spill transferred 200 to 3b0 pounds'of resin into the steam generators following a precoating of the filter elements with resin in the "B" Powdex vessel. The transfer occurred during vessel refill operations when leaking discharge valves j caused a pressurization transient in the "B" vessel. The July 19,1979 spill occurred when the pipe from the mix tank became plugged and spent resin was then carried into the steam generators. The mechanism causing the remaining three events was the same as that which occurred on February 27,1979 - the September 10,12, and 15, events occurring in the "A" Powdex vessel, the "D" ~ Powdex vessel and the "C" Powdex vessel, respectively. The introduction of resin into the steam generators is not presently a I

r f 1 ; i Likewise, demineralizer malfunctions are not reportable events. reportable event. Therefore, the licensee was not required to report the five resin spills to l the NRC and the resident NRC inspector first learned about the spills in late Howe ver, - ; November 1979 during the licensee's steam generator inservice inspection. the licensee did report these Sesin spills in its December 10, 1979 report already I e discussed elsedere in this decision. The hich priority Task ction Plan A-3, " Pressurized Water Reactor Steam Generator Tube Integrity" has been mentioned previously. The questions of 1) l additional re jirements for reporting equipment failures in the secondary feedwater i i system and 2) the effect of secondary steam / water chemistry requirements are j i being evaluated in this Task Action Plan. This task is presently scheduled for ccroletion in Septe:rber 1980. i i Based on the independent investigation of the NRC and the President's ij Cc=ission on the Three Mile Island Nuclear Accident, it was determined that NRC rust devote a higher priority and proportion of its manpower to the eval-uation of reactor operating experience in order to establish requirerents for repcrting operating events. f Therefore, changes have been made within the NRC, to inplement the findings noted in the above investigations. Within the Office of the NRC Executive i Director for Operations a new office has been created which is designated as AEOD has the Office of Analysis and Evaluation of Operational Data (AEOD). } been established to evaluate and analyze operational data associated within I ~ l all NRC offices involved with operational data collections, analysis and feed-back.

l ~ r - 15 ~ i i The Office of Inspection and Enforcement has augmented its evaluation and j analysis of all incoming licensing event reports to determine if reporting r requirements need revision or changes to reflect tirely operating reactor experience. P The recent reorganization of the Office of Nuclear Reactor Regulation has created a new branch designate'd as the Operating Experience Evaluation Branch l ~ (0EEB) whose c : ties include the continuing systematic assessments of reactor 6 operating experience to establish requirements for reporting operating events. i This office will provide the Nuclear Reactor Regulation interface with the Office for Analysis and Evaluation of Operational Data and coordinates with i the Office of Inspection and Enforce ent on matters involving operating j experience evaluation by the NRC and the industry. l J Finally, as a result of the Three Mile Island accident, an, independent nuclear ] industry group designated as the Nuclear Safety Analysis Center (NSAC) has been established to determine a reliability data base from operating reactor e xp er1' ence. Therefore, based on the efforts of these new organizations within NRC, it can be expected that NRC reporting requirerents will continue to be t revised and/or augmented to reflect updated operating reactor experience. Response to question (c): On February 27, 1979, North Anna 1 steam generator water chemistry analysis indicated, abnormal operatir.g conditions. The pH was depressed and the conductivity [ elevated. These abnormal chemistry indicators were attributed to the resin spill and subsequent injection of 200 to 300 pounds of resin into the three steam generators. i

.16 Maximum blowdown was being obtained on each steam generator prior to the i l resin spill and, therefore, the licensee did not take additional actions to elevate.the pH. Approximately 81/2 hours after the spill, ongoing chemistry analysis indicated a favorable upward trend in the pH samples and a downward i trend in the conductivity. measurements. - ~ The licensee notified its vendors of t,he event and remedial actions, including plant shutdown, were discussed. Since a plant shutdown from greater j than 95 percent pener c;erations would require 24 hours, the decision was made i There was noted concern by the by the licensee to keep the plant on line. licensee and its vendors that a shutdown could result in a resin melt with plate ou+ on the tubes. Since pH measurerents were within norcal cperating specifications within 14 hours of the spill, it would appear at this tire that the licensee's decision to keep the plant on line was correct. 4 Response to question (f): The resin spill at North Anna 1 on February 27, 1979 was not' related to the North Anna 2 volume control tank discharge and subsequent iodine-131 release which ocurred on February 27 and 28,1979. The resin spill occurred in the secondary system of North Anna 1 whereas the North Anna 2 volume control tank discharge and iodine-131 release were related to a common high level waste drain tank and inlet line in the sarpling system of the primary coolant system of l North Anna 1 and 2. Response to question (g): The North Anna 1 transient which occurred on September 25, 1979 has been l t I

i i analyzed in detail hy the NRC. Inadvertent operator error, equipment failure and continations thereof have been examined in great detail. We do,not at this l time see any inter-relationship between the three resin spills occurring in September 1979 and the September 25, 1979 event at North Anna 1. Response to question (h): The NRC has not at this time issued any bulletins to licensees with Powdex demineralizers and Westinghouse steam generators. However, licensees with -Westinghouse turbines, as rentioned previously, have been required to provide plant operating data and experience regarding steam / water secondary chemistry. Also, as prime contractor to licensees with Westinghouse and Coctustion { Engineering corpor.ents, the Electric Power Research Ins;itute is now conducting research and testing on the phenomena of steam generator corrosion and tube cracking and the inter-relaticnship of secondary water chemistry and impurities including resins. Response to question (i): ~ A chrcnology of events cencerning NRC's knowledge of the disc cracking problem is presented below. Surry 12 was shu*dcwn in the summer of 1979 for steam generator repairs. During this shutdown, the licensee determined to have the Westinghouse Corporation (turbine vendor) refurbish the low-pressure rotors of the Surry #2 tu rbi ne. During the refurbishment, in September,1979, the vendor discovered a crack in one disc. This discovery was the 'first indication of keyway cracking. This disc was repaired in the fall of 1979. No special report was sent to the NRC at this tire hy either the licensee or the vendor and no such i report was required. j During the period October 23 - 30, 1979, the Point Beach #1, (Wisconsin Electric Cc=pany) low-pressure rotors were inspected by the vendor and the second infication cf keyway cracking was identified.

~ On October 30, 1979, the vendor discussed this natter with the licensee / owners of Westinghouse turbines at a meeting held in Charlotte, North Carolina. On November 5,1979, the NRC was notified of the crack found in the Point Beach #1 low-pressure rotors during a meeting held with the ikcensee. On November 17, 1979, the Director of Inspection and Enforcement received sc a copy of the ancnymous letter. On Nos mber 20, 1979, the NRC staff discussed these natters (by telephone). with the turbine vendor. The vendor notified the staff that keyway cracks had now also teen observed in the rotors of Palisades and Zion (1 during inpections just corpleted in November 1979. On November 27, 1979, the NRC received a letter from Consolidated Edison (Indian Point) advising that the turbine vendor had discussed this problem i with the licensee. On December 17, 1979, Westingnouse briefed the NRC staff on the now culti-i unit keyway crack problem and the results of all insoections conducted by the turbine vendor to date. 1 Finally, since December 17, 1979, the NRC staff has been in continual con-i tact with Westinghouse and licensee / owners regarding this matter. A Disc Integrity Task Force corposed of representatives of Westinghouse and the j licensee /cwners has been formed for the specific purpose of disseminating information related to keyway and bore cracks among Westinghouse, utility osn'ers and the NRC staff. Other aspects of the turbine disc cracking nulti-unit prcblem have been discussed elsewhere in this decision. i 3 B 6

l i c Response to question (j): i You refer to two incidents that occurred at the Browns Ferry Nuclear Plant,- j a reactor scram at Unit 1 on March 28, 1979 and the disabling of in plant telephones on February 15,"1980. At the tire of the r'eferenced reactor scram, licensees were not required to report 'each reactor scrar Our regulations j ~ (10 CFR 50.'72) have recenily'been amended to require prompt reporting of all I reactor scrams at a f acility. 'he NRC Office of Inspection and Enforcement t ha. reviewed and evaluated the Tennessee ! alley Authority (TVA) investigation of the scram. There was ne damage to any instrumentation. The scram was caused by a piece of concrete itpacting and producing vibrations in the instrument system panel. The Office of Inspection and Enforcerent has concurred with TVA's assessment that a forcal report is not required. With respect to the incident on February 15, 1930 involving the plant telephones, cur Office of Inspection and Enforcement was notified of the event on the morning of February 16, 1980. Since tnis event involved the destruction of governaant property, TVA also notified the Federal Bureau of Investigation (FBI). Under our interface agreement with the FBI, the latter is conducting I the investigation of this incident. The Office of Inspection and Enforcement did verify that none of the security phones in direct communication with the NRC had been disabled. As soon as TVA discovered the damage to the inplant s phones, they placed in service two-way radios to replace the damaged telephones until repairs were co:pleted. We understand that the FBI and the Department of Justice are presently continuing their investigation of this incident. 1 I B L

j l f Evaluation of Recuests for NRC Action. The five requests for action are repeated in abbreviated form with the staff's evaluation: 1. Shut down North Anna Unit 1... As stated previously in this decision, the Appeal Board has determined that recent events regarding turbine disc cracking do not warrant the shutdown of . No~rtNhnna 1 at this tiie in' order 'to ' inspect the turbine. ~ ~ ; ~ Instalhtier, of steam generator inspection ports has previousl'y b'een discusseg in this decision. These ports will be installed at North Anna 1 prior to restart ; I after the second refueling outage scheduled for December 1980. Ue do not know at this time whether the licensee will decide to place the l presently bypassed Powdex demineralizer back into operation. The licensee is f presently conducting an engineering evaluation of the demineralizer system. l However, we do know that the licensee is maintaining steam generator water chemistry within the specificatioos specified by the steam generator vendor. Also, the licensee has installed sensitive hydrogen monitors in the secondary I ~ i system for determining corrosion rates in the steam generators. New procedures: have been iglemented for the daily analysis of secondary water chemistry for, dissolved oxygen content, amonia, and pH determination of condensate, feed-i water, and blowdown sagles. l Following a reactor scram at North Anna 1 on February 20, 1980 and prior j t to restart of power operations, intermittent mechanical noise was picked up on the plant's Loose Parts Monitoring System (LPMS). Tests and analysis by the licensee and Westinghouse acoustical experts identified the noise as i i originating in the region of the reactor vessel head and the steam generators. i ? i

The licensee and Westinghous.e acoustic personnel continued to conitor and analyze the intermittent single event noises. On February 22, 1980, the licensee i proposed an augnented LPMS surveillance program to the NRC staff as a basis for continued poder operations at North Anna 1. This augmented surveillance program was approved by the NRC staff. - On March 6,1980 a NRC acoustical team inspected the North Anna 1 LPMS, the LPMS plant procedures z-nd the acoustical data files. The NRC team concluded' i that the noise signals were coming from the secondary side of the steam genera. tors. The team further concluded that the licensee was doing all possible to evaluate the diagnostic infor ation and that the licensee's augmented LPMS surveillance I program provided an adequate basis for continued power operations. t Following a reacter trip on April 3,1980, the LPMS again registered single _ e vent intermittent noises from the region of the reactor vessel head and steam

enerator B.

The single event noises appeared to be of the same frequency and amplitude as re orded in the period February 20 to February 28, 1980 period. In a special report dated May 1,1980 the licensee provided the results 4 t .of the Westinghouse acoustic evaluation of LPMS single event noises recorded at North Anna 1. Westinghouse determined that the inpact noise was coming from the secondary side of steam generator B and was caused by an object wei hing : 5 4 cunces or less. The analysis further indicates there ray be other objects i i in the secondary side of steam generators A and C. The noise in the reactor vessel head was analy:ed as noise reflections from the secondary side of the steam generators. The analysis further concluded that no loose parts are considered to be in the Reactor Coolant System. In its report the licensee

~__ r

  • t comitted to inspect the. steam generator B for loose part objects at the next i

outage. During a scheduled outage at North Anna il from May 24, 1979 to June 4, 1979, the licensee inspected the secondary side of. steam generatoi-B and i located and retrieved an object approximately 1 1/2 inches long and 3/8 inches i in diameter. The object is believed to be a center screw from a grinding wheel. -l The object was located on the top of the tube sheet between the No. I row tubes-l l and adjacent to a blowdown line. On June 4,1379, North Anna #1 recc=enced power operations. Since then, intermittent noise signals have registered on the LPMS. The licensee is l continuing to reniter and analyze the intermittent noise signals and conferm f to the augmented LPRS surveillance program rentioned above. 2. Continue licensing moratorium on North Anna Unit 2 and Sequoyah... The NRC Comissioners approved the licensing of Sequoyah for fuel loading and low peser testing (5" of rated pcwer) on February 28, 1980. The fuel loading and low power testing license for Sequoyah was issued on february 29, 1930. 4 I The NRC Comissioners approved a similar license for North Anna 2 on April 10,1980. The license for North Anna 2 was issued on April ll,1980. The installation of steam generator inspection ports has been discussed elsewhere in this report. The installation of these ports at North Anna 2 will be installed prior to restart after the first refueling outage. The licensee plans to use the Powdex demineralizer system at North Anna 2 i for initial cleanup of the secondary system and to establish secondary chemistry limit specifications. For power operations greater than 5 percent the licensee will bypass the North Anna 2 demineralizer as is now being done for North Anna 1.

i ) . Also, the licensee will use'the new procedures for determining secondact chemistry, ~ limits as described elsewhere in this decision for North Anna 1. Finally, depending on the engineering evaluation of the North Anna Powdex demineralizer system, the licensee may in the future make redifications to preclude resin injection-f ~ into the steam generators and place these systers back into operation. i The Technical Specifications (Appendix'A) to the licenses for both Sequoyah 'and North Anna 2 stipulate that' prior to exceeding 5% power, the low pressure ' ~ turbine shall be subjected'to a preservice inspection. Xs part of' this inspection, the li:ensees are recuired to fully examine the bore and keyway region of the discs in e?ch low pressure turbine. l These required inspections have already been completed at Sequoyah and ' North Anna 2 and no turbine disc cracking has been found at either turbine. 3. Keep Surry Unit 1 closed... We have approved the operation of Surry 1 with up to 28 percent of the i steam generator tubes plugced, and as long as the Surry I steam generators are periodically inspected in accordance with the license condition for Surry 1, we find this acceptable for the operation of Surry 1. As discussed previously in this decision, Surry I does not have cracked. l turbine discs. l Seismic matters for Surry I have been resolved. All safety related piping analyses related to the March 13, 1979 Show Cause Order have been completed and modifications completed as necessary. Other seismic questions regarding +

d as-built conditions and anchor bolts have been demonstrated to be adequate for L assuring safe operation of Surry 1.

4. Maintain Surry Unit 2 shutdown...

The Surry 2 turbine has been repaired and is' in good condition as disc elsewhere in this decision. The Surry 2 demineralizer system is not of the same design as North Anna as discussed elsewhere in this decision. The seismic adequacy of Surry 2 is presently under NRC review and Surry 2 will not start up until we are satisfied that the piping systens have been adequately analyzed and codified if su required. i Ste'am generator testing was stipsiated as part of the Surry 2 steam genera The steam generaters were hydrostatically tested after installa repair program. I,; tion in accordance with the approved Surry 2 repair program. Condenser tube testing is not presently specified in an NRC requirement for The questions of (1) additional requirements.for reporting equipment Surry 12. f ailures in secondary feedwater systers, (2) the monitoring of condensate for the purpose of detecting condenser leakage, and (3) repair and testing of con-denser tube leaks is being addressed under Task Action Plan A-3 described elsewhere in this decision. The licensee is presently monitoring condensate effluent from the condenser. The condensate effluent for the purpose of detecting condenser tube leakage. is monitored on a daily basis for conformance with the steam generator vendor specifications. i

~ i 1 r Conclusion I have determined for the reasons set forth above that there exists no adequate basis for taking the' actions requested by Mrs. Allen. Accordingly, ~ ~ the request of Mrs. Allen is denied. ^ r A copy of this decision wi11 be placed in the Commission's Public Document Room at 1717 H Street, N. W., Washington, D. C. 20555 and the local + ~ Public Document Roots for the Surry Power Station located at Swem Library, .l College of William and Mary, Williamsburg, Virginia 23185 and the North Anna Power Station located at the Board of Supervisor's Office, Louisa County Courthouse, Louisa, Virginia 23093 and the Alderman Library, Manuscripts Department, University of Virginia, Charlottesville, Virginia 22901. A copy of this document will also be filed with the Secretary of the Commission f or Co mission review in accordance with 10 CFR 2.2C6(c) of the Commission's regalations. in accordance with 10 CFR 2.206(c) of the Commission's Regulations, i this decision will constitute the final action of the Cotmission 20 days after date of issuance, unless the Commission on its own rotion institutes the i review of this decision within that tire. r a !i &$/f. Harold R. Denton, Director ~ Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, l this 20th day of June 1930 1

f 7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Doc ets Nos. 50-280 ) 50-281 VIRGINIA ELECTRIC AND POWER COMPANY ) 50-338 (Surry Power Station Units 1 and 2;. ) 50-339 North Anna Station, Units 1 and 2) ) NOTICE OF ISSUANCE OF DIRECTOR'TldCISION URIER W UR 62.206 By letter dated February 18, rebruary 22, February 28, April 25, and May 25, 1980, Mrs. June Allen, on behalf of the North Anna Environ-mental Coalition (NAEC) requested that the Comr.ission take various actions c ancerning the Surry and North Anna Power Stations. Upon review of the material submitted by Mrs. Allen, and upon con-sideration of other relevant information, I have determined not to take the actions requested. Accordingly, the requests of Mrs. Allen are denied. A copy of the decision in this matter is available for inspection in the Cornission's Public Document Room,1717 H Street, N. W., Washington, D. C. r 20555, and in the local public document rooms for the Surry Power Station located at Swem Library, College of William and Mary, Williamsburg, Virginia 23185 and for the North Anna Pcwer Station located at the Board of Supervisors Office, Louisa County. Courthouse Louisa, Virginia 23093 and at the Alderman Library, Manuscripts Department, University of Virginia, Charlottesville, Virginia 22901. A copy of this decision will also be filed with the Secretary for the Cormission's review in accordance with 10 CFR s2.206(c) of the Commission's regulations.

7590-01 As provided in 10 CFR &2.206(c), this decision will constitute the final action of the Cornission 20 days after the date of issuance of the decision, unless the Cermission on its own rnotion institutes a review of this decision within that tirne. FOR THE NUCLEAR REGULATORY COMMISSION ~ _. -.. = e-Harold R. Denton, Director Office of Nuclear Reactor Regalation Dated at Bethesda, Maryland, this 20th day of June 1950. --ese mW-.m-H wHPm&w MWM

  • b 6

4 I l

a L%# LT i k' ~i 491 M B \\l/4 CI 'Q V I L'ib/ l Ni V e L~i'Q ! Ml. \\.Ml"il.f, j [ V [ N C$ ~.rlott esville, Tirgisia Yaili g idtress: 412 Cwns I:rir, F eb r..ary 18, 1980 I==t a ville, Alc e=a 35501 (2,05) 535-0678 Co:r.issiccer Peter Bradford * ~ U. S. Nu-J.ca. Regulatery Cc=ission Vashington, D. C. 20555 Re: Defective da-NerW er design Related corrosion and cracking i: ~ ^ Steam Generatern & surbine-tisc.s j %. the h:ter of Tirginia Electric and Pcver Cc=pany ~.' Y',.,*pm, e 1 Kerth A m Power Station, Units 1 and 2 f.' ' ' Docket Nos. 50-338 and 50-339 OL ~~ y.. Sw., Nuclear Power Station, Units 1 and 2 dk *b,.;:y rf s ' d.;. Deeket Fes. 50-280 and 50-281

. ~e E T'.'ts'n'95-

\\/r - 'M.93 Of.

Dear Cc-i ssioner Eradf ord:

/ i.. 1.; i < NLEO ce= ends the decision of the Cc=ission to require as Tcsirennental I= pac: State =ent (EIS) en the experimental replacement of steam generators at the Surry Power Station. After.o nary =cuths had passed since Mr. Denton's 2-1-79 denial to FJ.IC of both a public hearing and am EIS, ve had virtually abandoned hepe. Ve vould like to think that our letters of 3-4-79, 5-5-79, and 5-14-79 vere of some use to - yon in your del.iberations, a.nd are grateful for your decision to reviev. Our le :er ~ oday veuld aga.in ask your prude : action -i the light of recent disturbing developwerts: - Vesti gheuse (y) admission of turbine dise crackdre Discovered at both Surry reactors Potential at both North Anna reactors, already under Appeal Board reviev for turbime =issile treblems . Detec:ise Pcvdex de=inera15:er design, leading to --Tive (5) resia Ap_i3h t: North Anna (1, the largest of 200-300 pounds occurring on Februny 27, 1979 (the same date aliquid discharge from Unit f2 VCT entered am unrestricted area in f2... Iodine 131 vas 310 times value specified is 10 CTR Part 20..."); c:hers occurring 7-19-79, 9-10-79, 9-12-79, and 9-15-79 -Secer.da-v S e -.is trv pr:blems from the foregoing spi.lls h leadirg to cer-esien and crackier is steam generater support pl.ates and tubes as ven as is turbine dise keyvays leading to possible disc bursts

NAEC vould call the attentien of the Cc:rission to the striking inter-rel atedres s-and the irocy--of the fore-going proble=s. l Surry yy.pcois severe problems vith Vestirghouse steam ges-Cenditiens craters at Sur-y were to be avoided at North Anna by the presence of fresh vater, by the absence of chloiide, and at Nerth A==a by the use of the Povdex de-4"eraliser or polisher. Yet accerding to Vf'.PCO's 12-10-79 report, the stills of the 71s ir s in t o th e s t e am r e n e ra t o rs a t No rth Arma a c tuallv. created Surrv-like eer-esien eceditiets and the becinnist t o f s imila r c e rre s i on and c ra c kin e im 3 5". o f _ th e tub e s. Che== therapy - - One SEC engineer likens the corrosion to a "=alic: ant tumor," all cf vbese cells must be re=cred if North Anne 's Hey =2n,e at c s_p re tc r_euir health. Nevertheless, the NEC has permitted the installatien of a steam renerater _ irs r et ti en po rt to be put eff until 19E1, af ter the secend re-fueling at Nerth Anna 81. OefectiTe According to NEC Atlanta, the damaging resin spills Ee-4 ertll:er at North Anna vere caused by a se=i-aute a tic system e.tl-Desig: fgt.ien vig: Fevdex valve insufficiereies recuirier re-desire. Thus Merth Aan: il is currently operating without d e=L: era 11:ation. Eedesign Ironically, such a. Fevde de-iecralizer has just been at installed is Surry f2, devn.f or over a year for stea= geserator Su../ F2 rer' ace >ent (a difficulty se=e NRC engineers thought da 'nera.1-isers =ight have prevented). It =ust rev fellev that the same 7.edeliD $1 re=uir'd Et Eur?' '2 t o 2re'e: t J re ? *tTt 2=2 subseevent resim still vhieb eeuld berim Sur-v's 5133 tillien s t e z r e n e ra t e r re t.a i r t roubl e s a.r ev. Se c onda.ry-As noted earlier, resir still effects upon the see-Ch e=is try ceda rv che-1stry can cause corrosic amd cracking not c=17 Aff e cts i= the steam generators, but also is the turbines. Since Turbimes the turbire buildirr at_ Korth >- a is settline abeemallv. the risk to turbine integrity is e 4=nced; periodic shim ni=g has already. been necessag. Surry At -both Sur-e units, the turbines are krevo to be Turbine cracked. vith NRC staff listing Surg Unit /1 in Category AA Xissile and Surry Unit #2 in Category A. Although unlike North Anna, Risks the Surry units a.re not new under reviev by an Appeal Beard cc :er=ed with turbine rissile risk, that risx vould see: to be even greater under current Surry cenditions and thus de-serTes the direct attestien of the Cc 4 3sio=. 1s the light er the ec=plexity and mu=ber of unsolved proble=s at Nenh A :a and Surry (including condenser neg1cet described in detail 5-5-79, a leak prcble: at North Anna cov), the Cealitien hereby asks the Ce= issieners to take the fellev-d- e first i: stance since KRC staff appreval of int actie

  • YEPCO's ecuti ved operatien vi-Ji calftsetiening stear generaters is a catter of record:

l. Shut devn North A :a il for _erbine inspection. t installatics of stear generater i seeeties rort, and installation of redesirted 3 ves in the nee-1 functiering Pevdex de-~imerzliser proscribing restart pending adequate spill-prcef test results. 2. Centinue licensing morateriu= en Norti /d:a !2, reqriring the same inspectics a:d repeirs as- [ these fcr North Anna fl. I (FAI:: veuld tisc request that the licensing morateriu: be centi:ued for Sequeyah sic e this reactor alschts a Vestinghouse n:rbire.) 3. Teep Surry El closed, pe: ding its stea= generator replace =ent,as unsafe to operate with its cultiple related proble=s: plugged stear generater tubes in excess cf 25%, cracked turbice, and questionable seis=ic resista:ce. ~ 4. Mairtzi: Surry /2 shutdev: pendi:g repair of cracked turbines, redesign and repair of Pevdex de=ineralizer, installation cf seis=ic reinforce =ents, and stringent testing of rev ster ge erator and c: denser tubing. The Coalition further asks the Co -4 ssic=ers to investicate the felleving related satters: a. V:7 did TTJC0 =ake no 2/79 repcrt of the significant and dz=cging 2C0-300 pound resis spill in the North A :a stea= generator of 2-27-79? b. V:7 did the K?.C require no report? Why did the North A::a plast centinue in operation c. after the spill as opposed to closing for clean-up cf the resirs fic: the stet ge:erators ? b

l 4_ 1 d. kty did the NRC c=-site inspecter not kncv of the spill u :il months after it had taken place? Vas the NRC infer =ed before the four (4) succeedi=g e. spills? If so, vhat action vas takes? f. Vas the =ajor resin spill cf 2-27-79 related to the volu=e centrcl tank-discha:;s a=d Iodise-131 at 310, ti=es specified va.lue reported c= 2-27-79 or to the "u= centr:11ed release to the s:cre d.ai.n* cf 2-28-79? (See April and May OUSR's of 1979) g. k'na: are the implicatic s cf the three Septe=her 1979 spills en the loth,12th, and 15th, f ellev'ed by the radiation release accident cf Septe=her 25? h. Kave res52-spill effect var-4cs bee: ee : to other licensees vith Pevdex demiserali:ers and Vestinghouse s tea = generators 7

i. Var KRC's fint notice of E tur"-

" c cracking and missile proble=s the arc =y=cus letter cf Novecher 5,1979 suggesting a 'flagrast Vesti ghouse viclation"? The Coalities believes that Coc=issien i:Testigation of, the, foregeing has safety significance bey :d Virginia reacteri. Ihank you for yeu prcfessic:a1 censideratic:. Size erely, = O v%I me e President, FJ2C P. S. I: ter=.s cf reportabilit7, EA.LO is pu::.2ed as te why the 3-2S-79 re.acter scra= at Brwns Terry il vas not a repertable event sir.ce it was "due to false high pressure and low water level signals generated when concrete hat was dislodged during i a flocr drilling operation s uck a la pnel." Today ve u e ec cer:ed with the 4--licatices of disg: ::tled emplcyees at E.v us Terry cutting the cerds and re=cring the mouthpieces cf "betveen 65 and 70 ispit:t telephones" this pas: veekend. Vhat does this even: say of verker respensibility er verker cc.,.rehe=sien of the sa.f ety recessity cf i= plant cc:-4 catic=? Vill there be an K:.C i:Testigatien7 t i

NORTH ANNA INVIRONMLENTAL COAllfiON Characttesv111e, Tire rin Esil bg Ltt.r e e s : 412 Ctens I: rive i 2=tsville, Alaisca 35501 (205) 536.-0678 Tehruary 22, 1980 Chair =an John Ahearne U. S. Nuclear Regulatory Cencissica n f \\ Washington, D. C. 20555 ,,l, g r:[r.;c, ; / ' [*'-

Dear O.airnan Ahearne:

After the attached letter was written, NAEC ' ]i ~ #8

  • O A )

learned of new and additional proble=s in the f/a, N stea= generator for North Anna Unit #1 (discovered 4e, %q, G af ter a jaritor's r:ep accidentally caused the reactor t-g, \\ to scra= earlier this vec k). Thus we wuld amend cur request il en page 3 c,f the 2-15-E0 letter enclosed to read: 1. (The Coalitien hereby asks the Cc=nissioners to) Ecep Nerth Anna il out of service pend-ing resolutics of the scise preble: in stern generatcrs A & B, restoratico of noz=11 sec-endary chemistry, installatien of stea= gen-erator inspection port new as opposed to 1951, inspection for turbire cracks, and insta11atica of redesigned valves in the non-functioning Fcvdex de=inerali:er, prescrihirg restart until satisfactory spill-proof test results are shem. ~ Thar.k you for your professional i:terest and attention. Sinc erely, _b A l e Alles (Mrs. P. M.) l President, NAIC l Enc 1csure

NORTH ANNA ENVIRONMENTAL COALITION Charlettesville, Virginia Maili=g Address: 412 Owens Drive February 28, 1980 E=ntsville, Alabama 35801 i (205) 534-.0678 Mr. Thomas Gibbons, Esq. l Office of Core.issioner Peter Bradford l U. S. NUCLEA.R REGUIATORY COMKISSION Vaahington, D. C. 20555

Dear Mr. Gibbons:

I hope that by new your effice has received NAEC's letters to Co:ssissioner Bradfora of yebruary 18 and 22. Because ve appreciate your interest in VEPCO steam zenerator Mobing at both the Surry and North Anna sites, e ve are entlosing two additional ite:ns: -NAEC's January 7 news release on North Anna corrosion problems (written before ve knew of decineralizer defects and 4 additional resin spills); and --NRC's 1-21-80 letter about the installation of an inspection port for stern generator surve4Wnce at North Anna; Unit #2 now, Unit il in 1981 { Ve do hope that the Co::rnissioners vill cencur that with the continuing stean generator problecs at North Anna it would be unwise to valt for over a year before inst 2114ng an in-spection port f or North Anna Unit fl. ~ The Coalition was glad to le$rn that the Conrtissioners i are also following closely the newly revealed dise-crash troblems in Vestinchouse turbines. As you know, the North i Anna Appeal Board has retained jurisdiction over the " turbine missile issue" at North Anna. i In that regard, NAEC would call you attention to a report of ten years ago, June 25, 1970, in which NRC Inspector W. A. Crcss=an vrete to 7. J. Long that Vestinzhouse turbine blades cere out more ea sily than anticitated and that ACRS is looking at proble=s associated with centair:nent rienetration by a tur-bite blade. We would inquire the results of the ACRS study and its relation to the newly revealed Vestinghouse defects. Did their study take into account the settlement of the turbine pedestal at North Anna and the necessary sh4=437 i I look forvard to bearing from you. (O -Sincerely, M e--. Enclosures une Allen

4.' neo u y_ ,e UNITED STATES - y ) c, NUCLEAR REGULATORY COMMISSION o^ I WASW.GT O N, D. C. 20555 .'4 ' j:! tgv jnN 21 BM Docket Nos. 50-388 and 50-339 Mr. W. L. Proffitt Senior Vice President - Power Virginia Electric and Power Company Post Office Sox 25e65 Richmond, Virginia 23261

Dear Mr. Proffitt:

l

SUBJECT:

INSTALLATION OF IUPECTiOS~ PORT O'i STUM GEi!EPATORS AT NORTH ANNA PCER STATION, UNITS 1 AMD 2 Accumulating information indicates that the steam generators in corr.ercial pressurized water reactors are showing problems including tube cracking, support plate corrosion and increased denting of steam generator tubes. s. I am cancerned that the progression of tute denting now occurring is not being adequately addressed with respect to engoing investigations and' to the development of presentative measures to eliminate this problen. As you knew, recent steam generator pr0blems, such as occurred at your Surry Power Station, have led to extensive shutdown periods. The tGC staff strongly believes increasedjurveillance~ir.easuf ei are necessary to ~ nonitor the progression 6f" tube 7enting in steam generators and to be able to remove tube section.s for laboratory examination. Therefore, to facilitate monitoring the progression of denting, access ports, similar to these at Surry and other plants, should be installed just above the upper support plate in each steam generator. These ports should be of adequate size and location to allow inspection of the upper support plate and upper support plate flow slots and to permit the removal of selected tubes. l Therefore, in addition to your December 10, 1979 connitnent to install these C inspecticn ports at florth Anna Power Station Unit 1 prior to restart after M f b 'e]r the second refueling, we recuire that you cake a similar co rnitment for 'p h florth Anna Power Station Unit 2 prior to start of commercial operation. ,1 t Sincerely, d./i ?yk = L ~

9. F. Ross, Jr., cting Director Division of Project Management Office of Nuclear Reactor Regulation I

cc: See next page

I f 1 NORTH ANNA ENVIRONMENTAL COALITION Charlottesville, Tirginia EAiling Iddress: 412 Owens Irive j 1pril 25,1960 Hunta ville,1142 maa 35801 (205) 536-0678 The r n E. Gibbon, Esq. Legal assistant to Rei Defoetive deci=eraliser design Oc=zissicner Peter 3radford Strbine disc-cracking ) Uc S. EUCLEAR EEmTOP.! Colc41SSION VIPCO ncs-reporting Washington, D. C. 20555 In the Matter cf Tirginia Iloctric and Power Cc=pacy North Anna Power Statien, Units 1 and 2 Docket Noe. 50-558 and 50 339 CL !k:.:Ty IncluLr Powar Staticu, Unita 1 and 2 Deekot Nes. 50 250 and 50 481 Dear Mr. Gibben I have to laugh at myself, beginning yet another letter to you and Cc::nise icner 3rsiford whe.n our enr11er efforts seec to have teen se widely unread and unanswered. j Never-heless, it e cets important to " develop the record" fcr historians and accident coc=ie s tens of the fur. ire, as well l Es for potential steam generator epih=iclogists sed pathologists. 'D::ss, to emise our telephone conversation of April 14, 1980: Ee Pewder ~Iorth Anna Unit f2 was granted a Icw-pcwar license Du ireralizar despite the defective design, nalfunction ( 5 resin Oefoeta spills in 1979 ), and current non operation of the Perdex deminaralisar at the site __.._. g -Tou, ";ursonally, were unaware of the (Ma*eralizar) [ problem" (1) 4 - he DC st A't nsde no nentien of the Powdez decineralizer dif fienities "at se.y of the briefings" i 2e he bine -Tou will check into why TEPCO's turbire disc cracking Diso Cracking at Ik:rn (2 in the su:ner of 1979 was not reported to the KBC, leaving the KBC staff to first learn of rush ) problems fro:n Tisconsin Electric cn Novenber 5,1979, t fellowed by an anonysous letter of November 17,'1979 { alerting XIC to the Testinghcuse owners' seeting of October 50, 1979 i i Then KA30 has endeavored to explore TIPCO's s eening non-repert-l ing of either problec, KRC staff answers have fallen into the old [ TI?CD-;rotective pattern familia.r to KA2C since 1973, criticised by l the.7sstice Department in 1977, and mocked by the NOTE "Dcublespeak Aws.rd" of 1979. (1) Please see 2-1B-80 letter to Co=issioner 2radford, and 2-26-20 letter to you with K1EC's 1-7 40 news release re decin. resin spill. [ t h

j / ^.' l 4 r t are EEC reperting requirements really so whi=sical and sub.- j ective f -that a sericus resi: spill initiating significant l stes= Esmeratcr corrosien need not be reported? i -that the IRO resident inspector at North 1 :a i eculd be ~asare of the reais spill for ac=that -that a cracted turbine disc requiring removal and Y,rewcrk frc: S rry (2 in the st=:: mar of 1979 j ~ requires no 32C reporting by either VIPCO or TT l s Lo yeu s=d Cc:r.".esierer Iradferd as as with 32C staff zee i bers who maintaisO C-i 1 -that a majcr resin spill is not a reportable event? l -that.turbire disc cracking is *=ct a safety-related i itee" despite turbine =insile pctentialf { 4 -tLat turbire failure is "largsly an econocie pretle="? s I shall stop here, with the hope that trevity will assist f tirely answers to-our Febr:ary letters to ycu and Ccmissioner I 3radford, particularly to the== bered questicus and requests therein. Further dec =entatics will be supplied upon request. i S m*k yc: for your professic:a1 atta= tion. I appreciated j your calling, j m,__ . =. { Sincerely, h ne 111s= (Mrs. P. M.)' l President X130 i i ec: Richard E. Poster, Iaq. -{ l e I l l i

'LNORTH ANNA ENVIR.ONMENTAL COAllTION Charlottesville, Virginia Esiling idires s : 412 Owens Drive May 25, 1950 R::staville, Alabassa 35601 (205) 5 & o678 Ihemas R. Gibbon, Esq. Legal Assistant to Re: NAEC's 2-1E-E0 letter to Cc=issioner Peter Bradford Cc::=issioner Bradford U. S. Nuclear Regulatory Co=ission I Washington, D. C. 20555

Dear Mr. Gibbon:

Tour telephone call of May 23 came as a real shock! It was hard i to believe what you were telling me: that NAEC's comprehensive letter of February 18 to Ccanissioner Bradford had been seen by neither him nor you. This is the wre puz-ling because of the following circum- ~ ' ' stances: -The NAEC 2-1S-50 letter was tailed on 2-24-50 with a separate cever O ctter dated 2-22-60 not only to Cem-missioner Bradf ard but to each of the other ce=issioners. ---On 2-26-60 a follev-up letter on'the same subjects, and referencing the 2-15-50 lett er, was = Ailed to you. -On 3-7-50 Ken Clark of NRC Region II noted that questiens from NAEC's 2-15-50 letter had been referred to Region II. -On 3-12-60 Dr. Bruce von 2 ellen of DeKalb, Tmnois vrote Cc=issioner Bradford requesting ansvers to the 2-15 NAEC Q's. -On 4-14-50 you and I discussed the 2-2S-80 letter to you, and you agreed to check on what disposition had been rade of the 2-15-E0 letter :o Co==issioner Bradferd. -On 4-29-50 NAIC mailed the 2-15-60 letter to Dr. Plesset, asking fer ACRS investigation of Powdex demineralizer proble=s. Fro = the foregoing, I am sure you can see why NAEC might assume that the seriors concerns raised i= the 2-15-50 letter would through some avenue have gained the attention of the Cc=nissioners. The letter has aise been released to the press. In any event, as we agreed on the phene on Friday, I am = ailing another copy in this letter. Ihe 2-lS-letter was based en careful research, and upon tele-phone conversations with NRC's Leon Engle, Michael Kidd, and Paul Kellogg. l NAEC finds it reprehensible that the NRC staff failed to cention the in-I capacitated de-h eraliser at North Anna in any of its briefings in re-gard to the licensing of Unit #2, and that Westinghouse and VEPCO failed to notify NRC of turbine disc-cracking. Reprehensible but not surprising. Sincerely, I 1 7 s [neAllen i}}

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