ML20082P405
| ML20082P405 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/07/1995 |
| From: | Marini F MASSACHUSETTS, COMMONWEALTH OF |
| To: | Selin I, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20082P402 | List: |
| References | |
| NUDOCS 9504260231 | |
| Download: ML20082P405 (10) | |
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April 7,1995 Commissioner Ivan Selin U. S. Nuclear Regulatory Commission Washington,DC 20555
Dear Commissioner Selin:
I am writing in support of the Town ofDuxbury Board of Selectmen and Duxbury Regulatory Advisory Committees request that the Nuclear Regulatory Comission include in their inspection of the Pilgrim Nuclear Power Plant in Plymouth the following-1.
Potential age-related deterioration of safety related reactor internals at Pilgrim
- their direction, ongoing monitoring and repair.
2.
Parts or components known to be a problem at Pilgrim; parts or components susoected to be a problem.
3.
NRC oversight 4.
NRC communication with neighboring communities I have enclosed a copy of their earlier letters. I would appreciate it if you could advise me and the Town of Duxbury of the Commission's position on these issues. Thank you for your cooperation and I look forward to hearing from y
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M ancis L. Marini State Representative FLM:ceo Enc.
cc: Attorney General Scott Harshbarger Duxbury Board of Selectmen Ms. Mary E. Lampert 9504260231 950419 PDR ADOCK 05000293 P
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L March 21,1995 Commissioner Ivan Selin U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE:
Plymouth / Pilgrim Nuclear Power Plant in-Vessel VisualInspection by NRC
Dear Mr. Chairman:
The Duxbury Board of Selectmen, in cooperation and support of the town's Nuclear Advisory Committee, is requesting the Nuclear Regulatory Commission include in the upcoming inspection's review of the following:
1.
Potential age-related deterioration of safety related reactor intemals at Pilgrim - their direction, ongoing monitoring and repair.
2.
Parts or components jglown to be a problem at Pilgrim; parts or components susoected to be a problem.
3.
NRC oversight 4.
NRC communication with neighboring communities The attached communication prepared for the Board of Selectmen by the Nuclear Advisory Committee goes into significant detail, expanding on the above noted issues.
The Board would also be interested in knowing if there is any possibility of at least one NRC meeting in Plymouth, rather than Washington D.C., to give local residents an opportunity to discuss their concems with you.
Thank you for this opportunity. We look forward to hearing from you.
Very truly yours,
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i 148 Washington Street Duxbury, P.assachusetts 02332 March 30, 1995-
Dear Representative Marini:
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As you are aware, the town of-Duxbury, Massachusetts is in the Emergency Planning Zone for the Pilgrim Nuclear Power
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Station. We are located across the Bay, to the North.
1 Pilgrim NPS is scheduled for a re-fueling outage March 25, 1995.
During the outage, an In-Vessel Visual ~ Inspection is planned.
Also, I understand certain repairs are i
scheduled.
For example: replacement of the turbines; shroud repair; and, completion of the so-called " Phase I" Motor i
operated Valve replacements.
j During the outage, and before Pilgrim NPS goes back on line, I have made a request to Chairman Ivan Selin, Nuclear i
Regulatory Commission, that the technical concerns described j
in the enclosed letter be part of the inspection; repaired ~if' i
appropriate; and their status discussed with the public here I
in Plymouth. The letter was signed by seventy some odd follow =
l citizens. The Duxbury Doard of Selectmen have made a similar request and a copy of their letter is enclosed.
j You will notice, my concerns fall into four categories:
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potential age-related deterioration of safety related reactor internals at Pilgrim - their detection, on-going monitoring and repair i
parts or components known to be a problem at Pilgrim; parts or components suspected to be a problem at Pilgrim; NRC oversight; and, NRC communication with the neighboring communities.
l I would appreciate it if your office would reinforce my letter of concern by sending a similar request to the Nuclear Regulatory Commission and by requesting the same of Governor Weld and Attorney General Harshbarger.
Thanking-you for your interest,
.m cx.s -r E l i ?_ C_x m Mary Elizabeth Lampert
- I
0 148 Washington Street Duxbury, Massachusetts 02332 March 10, 1995 Commissioner Ivan Selin U.S. Nuclear Regulatory Commission Washington, D'.C.
20555
Dear Mr. Chairman:
As you are aware, the town of Duxbury, Massachusetts is in the Emergency Planding Zone for the Pilgrim Nuclear Power Station. We are located across the Bay, to the North.
Pilgrim NPS is scheduled for a re-fueling outage March 25, 1995.
During the outage, an In-Vessel Visual Inspection is planned.
Also, we understand certain repairs are scheduled.
For example: replacement of the turbines; shroud repair; and, completion of the so-called " Phase I" Motor Operated Valve replacement.
During the outage, and before Pilgrim NPS goes back on line, we request that the following technical concerns be part of i
the inspection; repaired if appropriate; and their status discussed with the public here in Plymouth.
Our concerns fall into four categories:
potential age-
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related deterioration of safety related reactor internals at Pilgrim - their detection, on-going monitoring and repair; parts or components known to be a problem at Pilgrim; parts j
or components potentially a problem at Pilgrim; and, NRC oversight and communication with the neighboring community.
We request that this correspondence be regarded, and treated as, a 2.206 petition.
AGE RELATED DETERIORATION We base our concern about the issue of age-related deterioration of safety-related reactor internals on:
1.
Pilgrim's repair history 2.
The report of the NRC and Oak Ridge National 1
Laboratory " Boiling Water Reactor Internals Degradation Study", NUREG/CR-5754, September 1993, j
(Appendix I).
l 1
4 3.
The NRC/BWROG Meeting, " Core Shroud and Vessel Internals Concerns", Rockville MD, June 28, 1994, (Appendix II) 4.
The memos of the November 1994 inspection of the Oyster Creek, N.J.
BRW/ NPS, NIRS Report, (Appendix III).
The NRC/ Oak Ridge Report identified major aging mechanisms that are limiting the functional life expectancy of safety-related components in BWR's.
The report documents the potential effects of aging of (25) selected BWR components.
These parts are listed as safety-related reactor internal components because they are utilized for maintaining the core support geometry, reactor coolant flow, and core heat transfer.
According to the Report,
" Failures of internals could create conditions that may challenge the integrity of the reactor primary containment system..."
(p.42)
Thus, loss of function of these components constitutes a
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precursor event for an accident in the reactor.
Because of their significance, we would like assurance all (25) components have been thoroughly inspected during the current outage and that they are free of any stress corrosion cracking and other signs of fatigue.
The importance of a thorough inspection is further augmented by an overhead from the NRC/BWROG Meeting, June 28, 1994 that stated,
" shroud cracking (a problem at Pilgrim] is a signal to reevaluate, in more detail, the potential for cracking in other vessel internals" (25) Reactor Core Internals Susceptible tg Ace-related Deterioration Listed in " Boiling Water Reactor Internals i
Aoing Decradation Study" (NUREG/CR-5754). preoared inr HEC by Qak Ridae National Labgratory, September. 1993.
1.
steam dryer 2.
steam separator 3.
steam separator support ring 4.
shroud head 5.
shroud head bolts 6.
top guide (GE Service Alert [RICSIL 071])
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core shroud 8.
core plate (GE Service Alert [RICSIL 071], cracking Wuergassen,GR )
9.
orificled fuel supports (OFS's) 10.
shroud support including access hole covers i
11.
core spray internal piping 12.
core sprpy sparger 13.
feedwater sparger 14.
jet pump assembly i
15, in-core neutron flux monitor housings 16.
in-core neutron flux monitor guide tubes 17.
in-core neutron flux monitor dry tubes i
18.
control rod drive (CRD) housing 19.
jet pump sensing line 20.
neutron source holder 21.
control blades 22.
vessel head cooling spray nozzle 23.
control rod guide tubes 24.
surveillance sample holders 25.
differential pressure and liquid control line.
The Report, p.3, states, "The fuel assemblies, control rods, and in-core monitors are reactor components also located inside the reactor vessel...
[they] will not be included in the scope of the present study".
Because, they perform important functions, we hope they will be an important part of the inspection.
PARTS / COMPONENTS KNOWN TO BE A PROBLEM AT PILGRIM CORE SHROUD A shroud " repair" is scheduled during the up-coming outage.
We are concerned about how extensive the repairs will be.
Will the shroud be replaced or merely patched?
j Our concern stems from an awareness of the different approach taken in Germany at the Wuergassen NPS and at the Oyster Creek NPS in NJ.
At Wuergassen, one of the original reactors to show signs of shroud cracking, the German nuclear regulators required replacing the shroud in lieu of installing a "fix".
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e In contrast, we understand, Oyster Creek was allowed the cheaper and quicker route, a "fix". They used 10 tie rods, attached to the top and bottom of the core shroud assembly, to prevent lateral motion.
However, the bottom part of the "fix" is hooked into holes in plates of Type 304 stainless steel welded to the shroud. This steel is vulnerable to IGSCC. It seems akin to repairing "This Old House" by replacing an upright and attaching it to a rotted sill.
Thus, if Pilgrim's proposed "fix" is in anyway similar to Oyster Creek's, we would be concerned about the structural integrity of the material the " tie-rod" was tied to; and potential for a loose parts problem.
FAULTY WATER LEVEL INDICATORS Water level Indicators activate emergency cooling systems in the event of an accident and shut down the reactor.
If they do not work, there is a threat of the release of radioactive steam and meltdown.
Paul Blanch first identified this generic problem at Northeast Utility's Connecticut NPS's.
At Pilgrim, like other BWRs, the problem is due to high pressured gas in the water - the result of a pipe design deficiency. He proposed remedies.
However, Pilgrim chose to repair only half of the safety devices.
Pilgrim claims the rest of the "fix" is not important because, "the operators were trained without using reactor-water-level instruments as a guide".
We are told training is a substitute for operable equipment. This is not acceptable as demonstrated November 8, 1993 when the operators 1
inattentiveness to readings resulted in the activation of the reactor-protection system and emergency safety systems. A similar problem occurred in 1986.
Status at Pilgrim; and, will this be inspected and corrected during the March 1995 outage?
LACK OF QA FOR FUEL POOL COOLING SYSTEM DURING LOCA/ LOOP In 1992, a study at the Susquehanna NPS by David Lochbaum and Donald Prevatte concluded there is a major (previously
)
unidentified) meltdown risk that is generic to BWRs.
The design flaw can occur in the event of an accident or the loss of off-site power.
Though there are backup diesel generators to protect a 4
a e
reactors cooling system if power is lost, there are no such diesel backups for a reactor's used fuel pool.
During a LOCA, the normal cooling system would be useless l
because it runs on electricity.
Activating the backup system manually would expose plant workers to fatal levels of radiation.
Status at Pilgrim; and, will this be inspected and corrected during the March 1995 outage?
MOTOR OPERATED VALVES During an accident, some valves close to stop the loss of steam or water through broken pipes and others open to let in emergency cooling water.
If not operating, there is a threat of serious radioactive release and meltdown.
Robert Pollard, Union of Concerned Scientists, has pointed out two types of problems with Pilgrim's MOVs.
First, many have malfunctioned and second they have not been tested in accident conditions.
Pilgrim plans to fix some of the MOV's during the March 1995 outage.
In 1989 the NRC issued a notice to all plants requiring correcting the MOVs.
These measures were deemed necessary by the NRC because it had found that under emergency conditions valve failures "will occur much more often than had been previously estimated".
Since 1993, Pilgrim has reported to the NRC at least four instances in which such valves failed in the course of normal operations and during testing.
In 1994 Pilgrim was called to the NRC regional Office to explain why their MOV's were still causing so many problems and to show their valves would work.
Status and why is Pilgrim not being required to fix all MOVs during the March 1995 outage?
LACK OF CONTAINMENT INTEGRITY Torus Vent, a previous "fix for this problem, allows e
venting of radioactive effluents directly into our atmosphere Will this be corrected in the March 1995 outage?
DRYWELL LINER CORROSION VULNERABILITY Status at Pilgrim; and, will this be inspected and corrected, if necessary, during the March 1995 outage?
STATION BLACKOUT VULNERABILITY Status at Pilgrim; and, will this be inspected and corrected during the March 1995 outage?
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i ROSEMONT TRANSMITTERS Status at Pilgrim; and, will all be inspected and t
corrected during the March 1995 outage?
PARTS / COMPONENTS POTENTIALLY.A PROBLEM AT PILGRIM POTENTIAL FUEL ROD CORROSION Fuel rods hold radioactive uranium in the reactor core Excessive radiation release and meltdown can result Chris Hall, an engineer from Oregon, identified how a system used by Teledyne since 1987 to heat treat zirconium alloy tubes (which are made into fuel rods and installed in all GE designed plants, including Pilgrim) is seriously flawed.
The flawed rods are particularly vulnerable in BWRs such as Pilgrim, in which the rods can develop a nodular rust like scabbing condition called nodular corrosion. According to Hall, Pilgrim is " ripe" for problems.
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- October '993, the NRC issued a warning to all nuclear power d
plantr n:. rming them of the problem - no corrective action i
or rec was required.
- PilgriL uims this is not a problem snd that they have
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methods to identify this problem, isolate it, and in the next outage remove it.
What happens if a number of rods fail at once?
Status at Pilgrim; and, will this be inspected and corrected during the March 1995 outage?
SUBSTANDARD AND/OR COUNTERFEIT PARTS t
The parts perform a variety of functions from protecting against electric overloads to keeping equipment securely anchored during earthquakes.
1 Threat unknown.
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- In 1987, Steve Comley identified the wide use of counterfeit parts in the industry.
The NRC, in 1988, issued a notice to plants to identify
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and correct the problems.
Apparently, due to the expense for the industry, the NRC withdrew its request.
In 1990, the U.S.GAO issued a report on substandard parts.
Pilgrim was among the plants identified using parts which did not meet government standards -nuts, bolts, pipe fittings, circuit breakers and fuses.
The NRC has not asked plants, like Pilgrim, named in the GAO report to replace the parts.
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- Pilgrim was quoted in a August 5, 1994 press report saying that without an NRC directive, no action will be taken.
- Status and will corrective action be required during the March 1995 outage?
NRC, OVERSIGHT & COMMUNICATION WITH PUBLIC Oversicht It has come to our attention that the U.S. Nuclear Regulatory commission has been allowing violations of its own regulations at nuclear power plants, including Pilgrim.
We understand, the Commission chooses not to enforce its regulations by issuing a notice of enforcement discretion (NOED).
This allows nuclear reactors to operate in violation of the terms of their licenses.
Since September 1989, we understand the NRC has either waived or chosen not to enforce regulations at nuclear reactors over 340 times.
Of the last 100 industry requests for enforcement discretion, the Commission has granted every one.
Pilgrim NPS has been issued at least (7) NOEDs or waivers since 1989.
This places Pilgrim in a ranking of 14th of the number of NOEDs issued nation wide.
See attachments for reactor-specific data.
This policy concerns us because it allows Pilgrim NPS to restart and continue operation when regulations require the nuclear reactor be shut down.
The NRC's claim that enforcement discretion is used to promote the safest course of action by the licensee doesn't make sense to us.
Allowing the reactor to operate can not pose less risk to public health and safety than keeping the reactor shut until it meets regulations.
We request this policy be terminated and the NRC revert to enforcing their regulations to protect the health and safety of our citizens.
Communication We look forward to having these ie. sues resolved. We commend the NRC for it's new policy of welcoming members of the public at some of your meetings with the licensee; however, it is not practical for citizens and their official 7
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representatives to. travel to King of Prussia, Pennsylvania.
Therefore, we recommend such meetings be held in-Plymouth.
This would be especially important before Pilgrim goes back l
on line, after the March 1995 outage, so we could have an
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opportunity to discuss the above issues.
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sincerely, i
Name Address f
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