ML20076M669

Comments on 830712 Public Meeting Re Environ Concerns for Application for Ols.Util Should Present Analyses of Environ Risks Associated W/More Severe Types of Very Low Probability Accidents in Environ Rept

ML20076M669
Person / Time
Site:	Marble Hill
Issue date:	07/12/1983
From:	Frey D AUDUBON SOCIETY
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8307210035
Download: ML20076M669 (6)

Text

._

d!

l fr D

The Indiana Sassafras Audubon Society of Lawrence, Greene, hionroe, Brown, N1 organ & Owen Counties g

7 July 12, 1983 Id- M 47

\

3 sbN '

TO: liUCLEAR RLUILTORY CTMISSION I

( LICEI;SII:G BRANCH US 1,

/ , B. J. YOUNGBLOOD, CHIEF f,'s' s", RS: E VIRONME'EAL COI;CERUS ASSOCIATED UITH MARBLE HILL'S GPERATION i

Sassafras Audubon appmciates the opportunity of a public meeting (July 12, 1933) to expmos environmental concerns at the beginning of the I.'RC's environ:: ental im-pact myiew of the Marble Hill application for operating licenses.

MARDLE HILL'S CAPABILITY TO WITHSTAI:D A SE7ERE ACCIDEIE Thn quality of Marble Hill's construction and compomnt parts, and the quality of the day-to-day opration and maintenance of the plant, will determine the severity of Marble Hill's impact on the human and natural resources of the mgion in which it is situated from radioactive emissions.

The location of Marble Hill in a mgion of seismic activity adde a further dimon-sion to the risks associated with its operation, as does the physical natum and drainage system of the site, which could Inighten the consequences of radioactive mlease s.

While concermd about the intermittent m3 nase of radiation into the envirorcent as a consequence of small-scale accidents, our principal concern is whether Marble Hill has been and is being constructed to withstand rare catastrophic accidents such as earthquakes, a com-alt accident of the type that occurmd at TMI-2, and a Class 9 accident.

The NRC informed Public Service Indiana (PSI) on August 3,1980 that Envircrenntal Poports submitted by applicants for construction permits and oPrating licenses on or after July 1,1980 should include a discussion of thc environmntal risks as-sociated with the mom sevem kinds of very low probability accidents (Class 9 accidents) and that PSI should pmsent analyses of these accidents in the ER m-carding Marble Hill.

em

%$ The tmnd of the pmcent Uuclear Regulatory Commission is to trade-off safety in QO terms of cost, and to use Probabilistic Risk Assessment (PRA) for judgments on the no overall risk nosed by a nuclear plant. The Commission has stated in their severe o accident policy statement that "Considering the low probability of com-mit ac-ou cidents, the Commission does not intend to mquim the use of conservative design criteria and analysis methods of the sort that have been applied to ergimond U0 c

safety featums (safety mlated equipment) mquimd by NRC mgulations for design g< basis accidents." (48 Fed. Fog.16020).

'om

$20 This we cannot accept. The ACRS has noted that the NRC has not even attempted to define what it means by a com molt, and that com melt may be incapable of quan-fe0l l ll1 10

'(0 a s!! / A n

~

tification. Co=nissiorer Asselstirn, in his additioral views on the Commission's covem accident policy, said that he could not support the Cornission's approach for maolving severe accident questions for existing plants and those under construc-tion, or the judgmnts in the proposed policy statement on the likely outcome of the Comnission's evaluation's of covere accidents. Commissioner Gilinsky shares Com-missiomr Asselstim's concerns and those of the Advisory Committee on Reactor Safe-cuarde(ACRS).

We ask that Marblo Hill's capability to withsSud a severe accident (core melt) be evaluated in tle ER in terms of the quality of Marble Hill's construction and con-sequence mitigation features.

A QUALITY ASSUR/ DICE PROGRAM FUNDAMEUTAL TO SAFE COPSTRUCTION OF A UUCIER Plidff The establishment of a Quality Assurance Program by Public Service Indiana was a >

basic requirement of a construction license for Marble Hill. P.cgion III NRC has asserted that the " basic elements" of a Quality Assurance (QA) Program sme in place when a construction license was granted PSI in lW8. PSI, however, failed to ex-ocute a QA Prograu, which is also a basic requirement. This "ailure resulted in stoppage of safety-related construction (for a 20-month period) in lW9 becauce of faulty concrete construction and failure of PSI to conform to ASME codes and pro-cedure s.

The Proceedings of the November 27 and 28,1979 Hearings on Marble Hill befom the Subcommittee of Environmnt, Emrgy, and Natural Resources, entitled CONSTRUCTION PROBLFHS AT IOdtBLE HILL NUCIER FACILITY: NUCLEAR REGUInTORY COMMISSION OIERSIGHT document the poor-quality concrete construction of Marble Hill, and the QC-QA prob-lens of PSI which_resulted in the substandard construction.

The failum of the NRC to take effective action to remdy the QC-QA failure at Marble Hill until literally forced to do so is also documented. The URC regulatory process was criticized at the Pmceeding because of its reliance on inspection of utility records as opposed to independent verification of the quality of the construction.

The public roccived a number of assurances after resumption of construction of Marble Hill of the high-quality of PSI's performance. In Ibcember 1982, Nunzio Palladino, Chairman, URC, publicly referred to Marble Hin's recent construction as above av-erage. It was shocking, therefom, to learn soon after Palladino's ansonneryt_,

that Public Service Indiana had failed to establish an adequate QC-QA program for electrical construction.

The URC CONFIRMATORY ACTION LETTER sent to PSI in early February, and the NRC NMICE E VIOLATION sont to PSI on April 25, 1983 attest to the extent and severity of PSI's violations. Considering the severity of the violations and the fact that this was a second offenso failum on the part of PSI to establish an acceptable QC-QA Program for a vital part of Marble Hill's construction, Sassafras Audubon wishes to register an obiection to the manmr in which Region III NRC handled the electrical construction work-stoppage and the lifting of the stop work order, without the opportunity for pub-lic scrutir;y of the results of the investigation, and type and extent of remdial work meded.

A PSI-URC rnws Islease of June 29, 1983 informed the public that the NRC had found the niingations on c3cetrical welds unsubstantiated and that the NRC had lifted the Stop Work Order.

_3 r

Disturbing questions remain as to the significance of the electrical work-st.oppage.

i , 'It is worth noting that PSI, in their letter to the 13C of May 24, 1983, reported

. that they would not be in full compliance with VIDIATION E until July 31, 1983,

! and VI0IATION B until August 31, 1983 Both VIOIATIONS involve material tracea-bility problems.

The NRC,' in their report of January 24-28 and February 24-25 inspoctions, noted on pace 20 that:

"On April 23, 1982, PSI reported that all evidence indicated that CIJV Catercry J, activitios were rapidly approaching an out of control l condition. On Jum 4,1982, CIJV issued a Stop Work Order WWO),

stopping Category I installations. This- SWO was lifted on July 28,

, 1982, (Reference - PSI status report dated August 9,1982). (emphasis added)

In the report of Nunzio J. Palladino, Chairman, NRC, of May 26, 1983 to Ice H.

Hamilton, Representative, 9th District, Indiana, on REGUIATORY EXPERIENCE AT MARDLE a

HILL, it is noted that:

i "The NRC resident inspector reviewed the stop work order and the cor-rective measures being taken and found them to be adequate. An in- t spection September 1982 by a Region III electrical specialist revealed i no problems with traveler control or material traceability" Since the NRC observed in their NOTICE OF VI0IATION that:

! " ...the licensee and the electrical contractor failed to take prompt corrective action to resolve material traceability problems identified i in April,1982 on MCAR003 The material traceability problema have ,

been transferred from a Management Corrective Action Report (MCAR) to an

[ NCR, etc. The material traceability problems still axisted qn January 4

- 22 1983." (emphasis added),

i the failure of the NRC resident inspector and Region III clectrical specialist to detect the severity of the failure of PSI's QC-QA Program, is another example of -

the NRC "looking but not seeing." The question must be asked whether the NRC would have been Cuilty of looking without seeing in January 1983 were it not for a worker's allegations?

The NRC issued a Systematic Assessment of Licensee Performance (SAIP) report on September 30, 1982, which concluded that Marble Hill ranked as one of the be~st con-i on ro ects in NRC ~ Region III, which is unfortunate under the circumstances.

i 'struct{1C' It W hensible that there has been no public accounting of the significance l . of the~ electrical work stoppage -(prior to lifting orthe SWO) at a time when PSI l and the Indiana Public Service Commission is trying to make PSI ratepayers help pay L

for construction of Marble Hill (CWIP).

L PSI's lack of committment to a.QC-QA Program was seen foria number of years.in their

[ failure to provide adequate storage and maintenance of materials. . An NRC NOTICE OF

- VIOIATION of January 15, 1980 was acecmpanied by a lengthy list of storage and

! maintenance nonconforrances of vital parts of the plant, e.g. a routron detector

' positioning device assembly had.been stored outdoors, rather than indoors as re .

l quired by Westinghouse for 18 months without maintenance; and motor operated main-steam isolation valves were stored" outdoors rather than the required irdoors (level B) for at least 10! months when detected, although ' accept tags indicated level B storage.: Shipping containers were noted to be wet internally. Iack of an adequate l

f -

- 4 ., ,, - - _ . +___-m ,. . .. . ..--c

_4_

materials quality control program was identified by the IBC in 1c/78.

The poor record and poor attitude of PSI toward development and ilaphnentation of a Quality Assurance Program for construction of Marble Hill, and the storace and maintenance of vital parts prior to their instrllation in the plant, raises doubt not only on Marble Hill as a quality product, but whether PSI can be tmated to operate Marble Hill safely and mliably.

REC 04MENDATION OF MARDIR HILL FOR QUALITY ASSURAIEE PILOT PROGRAM Tha Quality Assurance Branch of the NRC mcently announced its intent to institute studies of Quality Assurance Programs for construction of nuclear power plants and to select two nuclear plant sites at which major quality control-quality assur-ance deficiencies have been identified in the past for their pilot program.

Sassafras Audubon asked on May 5,1983 that Marble Hill be considered a candidate for the QC-QA pilot program. No reply has been received to this request.

00 TfAll24EITf SrRENGTH OF MARBLE HILL The lac is emphasizing the importance of containment strength, as well as the in-hemnt omrgy and radionuclide absorption capabilities of the containment design, in mitigating core-mnlt consequences.

The Com:aission has stated (Proposed Policy Statement on Sevem Accidents) that com-melt accident evaluations and containment failum evaluations should continue to be performed for a mpresentative sample of operating plants and plants under construction and for all future plant designs, the analyses to be as realistic as possible and to include dynamic and static loadings from steam and non-condensibles, basemat pemtration by core-melt materials, and effect of acrosols on engimemd safety featums. We ask that such evaluations be made of Marble Hill's containments.

Concrete construction of Marble Hill prior to the work-stoppage of 1979 was sub-standard, with batches of concrete poured under unsatisfactory conditions, and vi-bration practices insufficient to insure even distribution of concmte around m-inforcement bars. What portion of the contain: rents at Marble Hill had substandard constmction? What portion of this construction was quality-tested for soundmss?

How mliable the methods employed? Could portions of the containment be deeply flawed and go undetected? Could Marble Hill's containment withstand a core-melt accident?

The contairment liner was subjected to a serious accident. While mpaired, is it inhemntly as strong as before?

5'INIR0124EIRAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMEIR Sassafras Audubon is concermd with what will be considered " safety-related" or hnon-safety related" electrical equipment at the Marble Hill plant, and as a con-sequence what will be environmentally qualified and what will not.

Gomral Design Criterion 4,10 CFR Part 50, Appendix A, requima that all equip-ment important to safety be qualified to survive accident conditions during which it is called upon to function for the life of the plant (40 years or 32 full-power years). This qua'ification criterion is based on the . premise that safety systems j

, are worthless unless they can withstand extmmn stmas.

During the TMI-2 accident equipment n1 cor.sidered "important to safety" was used to mitigate the accident and pmvent com reltdown. The lessons Inarred Task Force concluded that:

"all systems and compomnts which can cause or aggravate an accident or can be cal 3cd upon to mitigate an accident must be identified and classified as compomnts important to cafety and required to meet safety-grado equiprent."

The precent Commission has been guilty of weakening rather than strengthening the requirerents for environmental qualification of electrical equipment. We ask that the URC staff use the Iossons Icarmd Task Force conclusion as the basis for des-ignating compomnts important to safety and required to meet safety-grade equip-nont.at Marble Hill.

WESPINGHOUSE STEAM GENERATORS GENERICALLY DfECTIVE Steam Gemrator Tube Integrity is an unresolved safety issue (USI) of the Nuclear Regulatory Commission. The Westinghouse Steam Gemrator D-4, D-5 models to be in-stalled at Marble Hill are subject to vibration-induced tube wear and cannot be operated at full power. Weatinghouse has proposed a " technological fix" but it has not been adequately tested. What will constitute adequate testing? How long at full-power operation?

Is there convincing proof that the fully-rolled tubes of the D-4, D-5 models will prevent or reduce wastage in the time frare that it might take for auch problems to develop? Is it possible that stresses machimd into the roll could make the tubes mom susceptible to cracking ,in thn lonn run? Has the effectivemns of the mw tube support, desigmd to Induce wastage, been adequately tested under full-power operation?

PRESSURIZED THERMAL SH0CK Ueutron irradiation of reactor pressure vessel wold and plate materials decreases the fracture toughness of the materials, and makes it more likely in a severe pres-surized overcooling event of vessel failure.

Marble Hill's reactor pressure vessel is composed of materials similar to those of operating reactors whose pressure vessels have become embrittled and are not ex-pected to safely operate the design-life of the plant.

Have any design-modifications been made at Marble Hill to lescen mutron radiation embrittlement? Is Marble Hill likely to achieve 32-years of full-power operation?

SEIOMIC QUALIFICATION OF !ECHMICAL AUD ELECTRICAL EQUIPMMiT AT MARBLE HILL The New Madrid rift represents a high risk earthquake area where another majc?

quake is overdue. An impact of 6.0 on the Richter scale is estimated to have oc-curred in the Marble Hill area from the New Madrid earthquake. Will the equipment requimd to safely shutdown the Marble Hill plant, as well as equipment whoce func-tion is not required for shutdown, but whose failure could result in adverse con-

.o e

,  % s ( a

. , , . , - ~

M <-

(

i

,N., ..,

s ,-

ts. r .. s

,..t

's ditiona ubich might impair shutdown hetions, be errdrorzentallf qualified to ,

withstand the effects of an onrthqsake of 6.0, onlthe'hichter scale? '

Another concern is whether the snent 3 [ucl otop4 y 'facilkty is on the same qualla rocis f'oundation as the reactor ~y.ontad.rnent bu11v9?g? Uttet is the seismic cqtogory of construction of the apent 1%1 storage facIllty? ' '+ . .

N _'.

~ Youre sincerely z'

~

'fr24. of)zMk%[' m Mrs. David G. Frey f Energy Pd. icy Committeo, SAS s 2625 S. Smith Ro&1 s s Bloomington. Indiana 47401, -

. s s s.

5 cc: Ice Hamilton ~ , ,

F. McClookoy N '

\,

L. Parvin Prico ,'

.t

.g N

4 d

_ . -.