ML20083J601
| ML20083J601 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/04/1984 |
| From: | Lewis M LEWIS, M. |
| To: | Palladino N NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8401100205 | |
| Download: ML20083J601 (3) | |
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":hairman Fallidino M ? -C Pi:06 ustac Washington, 0.';. 20555 Lear chairman pallidino;
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The Commission itself has been hearing staff reposals fif ~~the:Reptar.t of TMIdl.
This cecurred on Dec. 5,1933 Apparently the':o=ission will tear-these propost.ls directly. The Commission tnerefore snould also hear answers to these pronosals directly also.
(staff Responce dated 12-29-33.)
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?1<,ase consider his letter as a "public coment" on the Staff's Iroposals presented at the Cec 5, 1933, meeting.
[f The' Staff Proposals for a Restart of OMI#1 are very limited and go only to the heart of
. one or two issues: management competence and cheating. The Staff Proposals do not comprehensively or definitively put these issues to rest. Also the Staff proposals io not put to rest any other issues previous to, e entinuing or subsequent to the TMI#2 accident.
5 I am going to mention only one problem that has recently emerged andis not even mentioned on the TMI*1 restart record. This is only a representative problem of many problems that have been completely ignored in the rush to restar. TMI#1. :.:any problems are even more immediate and even more ignored.
The problems of the
- cleanup at TMIe2 are growing and have been completely eliminated from consideration 1
E in the Restart Docket by unreasonable and dangerous Comission Policy.
h Nonetheless, the problem that I will limit this letter to has ally recently 5
surfaced (3 years ago), and is not even mentioned on the restart docket.
"url assemblies have degraded while in spent fuel storage pools.
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( Eisenhnt to Vollmer incidenh)have any relationship to the TMI#1 Restart?" There are many is
-31 83 The question then becomes, "How in the World can this Frairie Island Trairie Island incident has a direct bearing on the TMIrl Restart.
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The atmosphere above the fuel communicates - between TMI#1 and TMIc2.
Any fuel drop or" situation (which) pool could result'n release of fission products" (3rown to Seyfrit,10-21-33,Page 4)in the spent fuel pool would then directly affect the safety of the TMI#1 Restart.
This issue has not bee. explored in the M
Restart Hearings.
In fact Commission Flicy has precluded incluion of this issue in the Restart Hearings.
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2.
TMI#1 is a pressurized water reactor.
P4Rs have recently been required by the GC to ;erform fuel maneuvers to minimize neutron bombardment and subsequent E
embrittlement to the RPV wall as a prophylactic against pressurized thermal shock These fuel maneuvers call for placing spent fuel rods in the outer row
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damage.
of fuel rods. These maneuvers requre the movement of fuel rods.
Some of these fuel rods can be degraded causing failures and subsequent release of fission products.
=.5 None of the ramifications of fuel rod maneuvers using degraded fuel rods have.
been investigated on the TMIs1 Restart docket nor anywhere else.
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, 'B401100205 840104 gDRADOCK 05000289 PDR D3i J
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3 The Prairie Island incident and the corrosion of the Eteam Generator tubing at TMI52 bear many striking similarities; a.
The actual cause of the failure has not been pinpointed.
In the Irairie Island incident stress corrosion cracking was the cause of the failure. The contaminant or the handling that caused the stress corrosion is still unknown, but thiosulphate contaminatbn is suspect.
In the TMI41 CTNG tubing failure, stress corrosion was the cause of the failure. The contaninant or the haniling that caused the stress corrosion is still unknown, but thiosulpnate contamination is suspect.
b.
3cth at TMI#1 and at trairie Island, the stress corrosion seems to be isolated incidents that could not 'oe observed either at other reactors or in otner parts of the same reactor.
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30th the Prairie Island incident and the T.W 1 tubing corrosion have taken years to wind their ways thru the N?.0 staff's analysis and nave still not been fully defined as to cause not put to sleep as to safety significance, d.
3oth the TMI#1 tubing failure and the Prairie Island incident have many safetysignificant repureussions that have not been explored especially as far as the question of pressurized ther al shock is involved. Failure of steam generator tubing can lead to a thermal shock problem at T:H#1 and failure of fuel rods could lead to many problems, not excluding a power excursion accident. A PFA could stress the RPV wall while cold water is being injected. Therefore a %el-failure could cause a presurized thermal shock to the RFV wall.
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The above examples are not the only simiLsrities that connect the Prairie Island incident and the OTSG tubing failure at TMI#1.
These examples will suffice so as not to belabor the paraalels.
4 The dangers of fuel storage and tr&nsshipment have been significantly increased with the knowledge afforded by the Prairie Island incident. TMI#1 has been 17 service for an extended period.
Many of the spent fuel rods in the common pool have been stored for elose ts a decade. Some were made or could have been made at a facility owned by Kerr McGee in Charron. The Kerr McGee facility is presently both the subject of a movie,"Silkwood,"
and a Court case,"Silkwood vs Kerr Hegee." Silkwood worked on the plutonium fuel rods for the FFTF, a breeder, in Idaho Fall.
In the Court trial, workers testified that similartnsafe and deficient practices went on on the other side of the Kerr McGee facility making fuel rods for IRRc such as TMI#1.
Intervenor 14wis attempted to bring this up as a Contention in the TMI#1 Restart Hearings and was ruled out of order by the Board since the Board did not see a " nexus" between the TMI#2 accident and the possibility of fuel failures.
There are dangers from fuel failures during the restart of TMI#1. Whether or not these dangers will mimic or have a nexus to the TMI#2 accident is supercillious at this or anytime.
In all fairness, the Commission must investigate the TMI#1 Restart from the point of view afforded by the fuel failures at Prairie Island. The similarities are too multitudinous and pointed to ignore anymore.
The information is in the public domain. The issue is not new to the TMI71 Restart Docket as it was brought up as a contention early in the proceedings and improperly dropped.
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- 5. Further, the problems of fuel failure have direct significance in the rAnagement and cheating phases of this TMI11 Restart Hearing. For instance, improperly kept leakage records have played a significant.: art leadin6 up to the T7.I42 accidant.
Similarly, improperly kept chemistry records for the spent fuel pool at pairie Island lead to the fuel failures.
There is no telling where poorly kept records can and will lead to safety problems atTv141.
Fuel failure and tubing failure are only two exanples.
The point is that faultymoord keeping in the ;ast can and dees lead to future problems. Iliminating bad manarenent at this tine will not elli. ate tne seeds of destruction sown by bad management in the past. This State will be sitting on a powder keg waiting for the next accident if TMIdl is ever allowed to restart.
1 do not mean that this letter is definitive oc comprehensive.
The above discussion is a very suwrficial treatment that is limited both by time restaints,TXIsl Restart decision is pending, and resource restraints, Intervenor has provided all his own monies in this intervention.
3ecause of these restraints, Intervenor has submitted this very important issue as a "public comment." I knew that the NRC and its staff's resources are also strained.
I also know that the Applicant will probably not envision that a full fair hearing of these issues will be to its own benefit even though a full fair hearing would be to the Applicant's benefit.
I can only hope that the NRC vill see fit to investigate these issues fairly and completely.
A full, fair investigation must benefit all concerned:
- 1. The NRC by showing its concern and fairness.
- 2. The Applicant by showing that the plant is safe or how it can be made safe.
- 3. The public by providing far the public safety as required by the AT.A.
I appreciate any time that the Commission gives to this letter and public comment.
Respectfully submitted, ivi. 1. L E w i 6 6504 BRADFORD TERR.
' Hila, PA.19149 215 CU 9 5964 1-4 -84 l
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