ML20083G887

Expresses Concern Re 840801 Fuel Loading Date Since Insufficient Time Allowed to Obtain Replacement Parts Per IE Bulletin 83-06

ML20083G887
Person / Time
Site:	Limerick
Issue date:	12/30/1983
From:	Lewis M LEWIS, M.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
NUDOCS 8401040372
Download: ML20083G887 (2)

Text

'

o i. i. c_ W l b g) ' g fV M BRAD! ORD TERR.

PHilA, PA.19149 l Darrell Eisenhut *-

Division of Licensing IBNRC -

Dear Mr Eisenhut A letter from Mr Kemper of PECo arrived today. It was al copy of a letter sent to you on Dec. 27,3983 The letter said that PEC o hoped to begin fuel loading on or before Aug.1,1983.

I have several letters in front of me that make such a sdadule totally inapprpriate and even dangerous. The first letter is from Mr Starostecki to Mr Kemper of PECo.

The Subject of the letter is NRC IE Bulleting 83-06 (Non Identical Replacement Parts) Request for Extension of Response Time, dated 22 Dec.1983 InMrStarootocki'sletterfromtheNRCgranting extenbion of time to make sure  !

that replacement parts will do the jSb to which they are originally designed, The l NRC grants Mco a 90 day extension. '

These replacement parts will be used in many of the systems directly and indireetly involved in fuel loading. There will not be sufficient time for the NRC to qualify PEcos response as adequate and safe if the fuel loading is scheduled or allowed by Aug.1 or sooner. Many of the problems with replacement parts have been .

I cubtle and hard to find until they snack a reactor system out of functioning. -

l I'shall usa the examples in the IE Notice 83-06 to demonstrate my wariness of PEcos  ;

accelerated fuel loading schedule. l Check valves: Check valves ares used extensively all oter the nuclear industry as part of leakage correction maintenance. Even the newest reactors have minor leaks. I Limerick would be a yery improbable reactor if it did not have check valves installed as part of the leakage adnienance system . Also this leaka6e maktenance system could have to be qualified and in operation to keep the fuel loading from being a very wet and messy operation. Although the fuel itself might be loaded safely , surely subsequent leakage adatenence without check valves would be both messy and dangerous to workers. Starting fuel loading withet qualifying check valve replacement parts is just asking for increased difficulty handiing cpilld and leakage maintenance with attendent increased and unneeessary exposure to workers and possibly the public.

At least two types of control switches are mentioned in the IE Notice 83-96 .

Control switches are used in all control functions in a reactor and the laoding cystem. In fact , a problem about control switches in the polar crane at TMI#2 may have caused a Bechtel employee to be transferred to the SW. I do not understand how the transfeir of an employee of a subcontractor fixed a control twitch problem , but apparently the NRC feels that was sufficient fixing needed on the controll switches. I hope more direct solutions will be used to guarantee that there will be no fuel drops during loading at Limerick . One such solution tight be to qualify all replacement parts for all switches before fuel loading as Lia= rick. In the haste of fuel loading an unqualified replacement patt might just accidentA&ly find its way into a control switch. This cannot happen if oll replacement parts are qualified before fuel loading. An unqualified replacement part for any control switch should not be allowed on site.

8401040372 831230 DR ADOCK 05000 0

2

) .

Another pr.rt* thatbs mention 2d in th5 IE Notics 83-06 is air opdated pilot valves.

There are naay air operated valves in the various systems of the Limerick reactor.

There is not telling at this time the effect of the failure of one or more of these valves. Ihny of these valves will have had replacement parts already installed due to the testing required to qualify them. Until and unless all of these valves are qualified including their respective replacement parts , there is a lack of safety ingxx inhcrent in their use, i

Bc.ttery power is essential for loss of offsite power. During fuel loading battery power

} < vill be especially essential since there will be no reactor generated power. AsiaAlso

( dicsel generator power will also be dependent upon the very control switches previously mentioned in this letter. This leaves a reactor during fuel loading very and usually more than usually dependant upon battery power during fuel loading. This means the batteries must be up ot full charge. The batteries cannot be upto full charge t:ith defective circuit boards. Defective circuit beards that kept the betteries from gettieg up to full charge were one ofs the problems cited in the IE Notice.

The above concerns are not comprehensive , def' P.,ive or complete. They do show a pattern that is most disturbing and ladicative of a lack of concern for saf'aytx safoty.

I cincerely hope that the Nhc will not allow fuel loading in a Limerick reactor that has notaven met substantial concerns voiced in IE Notice 83-06 over a year ago.

• Ancther concern that has arisen recently is that pipes on the Limerick site were ellowed tofreeze. The weather was especially cold. This freesing of pipes is an old problem at nuclear power p1 Ants. It was supposedly settled years ago by the additbn of heaters where needed. I h9pe that the NRC will check this problem out at Limerick. If the fuel loading date is really August, the necessary heaters chould have already been in place and operable.

Further I am very concerned that the external water sources for Limerick can also freeze. Both the Perkiosent and the Bohyulkill Rivers freeze solid on occasion.

I have seen them so fromen. I an apprehensive that a company that cannot keep on site piping from freezeing have done sufficient work to make sure there off site cupply or supply piping will not also freeze. One thing for sure is that there ,

won't be a hard freeze in August.

Very truly yours, , f

- l , ]. . }[ ,/ '

'N  ?  !,

/

- M. l. LEWIS 6504 BRADF0 liv IERR.

PHILA., PA.19149 ii

. . .. .- - . . .3

= ~ - ~' ~~-~~~~-m .

-...a-* * ' ~ ' ' '" "^'~~ ~ ^' ~~~' "~ '~

' ' ~

.t,.

,.-._,____,.m s , ,7 ... -- - n O:. / ,

ENVIRONMENTAL COALITION ON NUCLEAR POWER t Headquarters: 433 OMgo h,e, E EM&ge, Pa.16801 i  ;

6504 BRADFORD TERR. '

PHili, PA.19149 .

4 1, i,.

rarrell Eisenhut LENRC Washin6t on, D.C 20555 i

I i

h i

! J 4 m .-

1 4

l J

~b