ML20087F281
| ML20087F281 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 03/14/1984 |
| From: | Lewis M LEWIS, M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8403190038 | |
| Download: ML20087F281 (4) | |
Text
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IJ ITED STATES T AMERICA NUCIEAR REGUIATORY COMISSION BEFOR THE ATOMIC SAFETY AND LICENSING BOARD W
In the Matter of Docket Nos.
50-352 oE4 MR 16 A!0:57 Philadelpn!A Electric Company 50-353 ol (Limerick Generating Station Mar h 14,1984.
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BRANCH Intervenor fewis' MOTION FOR NEW CONTDtTION BASED 5 IE NOTICE NO. 84-17.
INTRODUCTIN On 3-10-84, Intervenor Ipwis received IE Notice No,84-17 : Problems With Liquid Nitrogen Cooling Components Below the NIL Ductility Temperature, issued 3-5-84 The Notice contained very new hformation which was not previously available to Intervenor Inwis or any public source to which Intervenor Ipwis had access or knowledge Specifically, the very new information in IE Notice No. 84-17 is the cause of the " Cracks in BWR Mark I Containment Vent Headers" which wavedescribed in IE Notice No. 84-01.
IE Notice No. 84-17 describes problems which can occur at Limerick Nuclear Powcr Plant. The reason that IE Notice No 84-17 relates to Limerick is that 1.
IE Notice refers specifically to BWR owners and operators.
Limerick is a BWR.
I 2.
The Notice refers to Mark I containment. I,imerick is a Mark series containment which is similar to the Isrk I containment in many respects.
3 The notice refers to systems and parts that are jresently incorporated in the Limerick design, Containment, inerting, vent head ers.
4.
The Notice specifically broadens the area of concern to include many applications:
" Licensees who have used liquid nitrogen (or other potentially very cold fluids) in applications where the fluid could come in contact with eafety-related components subject to brittle fracture should consider inspecting these components for possible indication of cracks."
5 This information is very new and has not been incorporated in design. The potential for a finanetely strapped utility to hurry construction and operation to avoid desiga changes is very attractive.
PEco, the owner of Limerick,has been referred to in the papers and in its own rate filings as having less than the "best" bond ratings.
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Background
This action stems from the concern that Intervenor Iewis has with the potential for Pressurized thermal shock in the Limerick Boiling water reactors (BWRs.) One of the conditions necessary for pressurized thermal shock to present a problem not incorporated in the design is that some or all of the asterial involved in the procsurized thermal shock be below its NIL ductility temperature and therefore in a brittle condition. Intervenor incorrectly limited his previous concern to the RPV only and also incorrectly assumed that the only way that any material would be chilled to the or below the NIL ductility temperature is by having the. NIL ductility temperature raised by the ection of neutron flux.
E Notice 8%17 shows that the RPV is not the only system wherein the temperature can go below the NIL ductility temperature in normal operation and that the RPV wall is not the only system that can be so affected.
Therefore. Intervenor raises a contention with a much broader area of concern than just the RPY wall and a much core potential for decreasing temperature below the NIL ductility temperanture than those materials so affected by neutron flux.
Due tb these considerations of the breadth of affected systems and potential for lowering temperature into the brittle range below the NIL ductility temperature, the definition of pressurized thermal shock as previotdy proposed by the NRC staff will not suffice for all possible problems. The contention will still include the area and concern of pressurized thermal stress as FIS is a distinct subset of problems cassed by lowaring the temperature of an affected material below ibs NIL ductility temperature.
As previously discussed in Contention I42, NII, ductility temperature is the temperature at and below which a material, usually metal, experiences an abrupt decrease in its toughness and, sometimes, ductility properties. *pecifically, tgfg ghgd ausg[k5in g blems at' Hatch No 2 was liquid nitrogen.which is ra
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Liquid nitrogen is se canditions.
Much of the liquid nitrogen system is safety related. As safety related squipment, the liquid nitrogen system must pass engineering and NRC reviews. However, thene reviews are limited to known quantities. Also some parts of the liquid nitrogen system are not reviewed in depth as these parts are not considered safety related.
Previously placement of the liquid nitrogen lines were not considered a safety related problem.
E Notice No 6+-17 mentions how placement does become a sfaetyrelated problem, "where the fluid could come in contact with safety related components subject to brittle fracture." Further the IE Notice does not limit titself to liquid nitrogen but also, includes "(or other potentially very cold fluids)." Therefore all i
potcutially very cold fliuds and their placement in the containment should be looked at from the view)oint of safety.
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How Limerick can be affected.
Any area or component that is in close proximity to a liquid nitrogen line or n potentially very cold liquid is in danger of being chilled below its NIL.
ductility tosperature. Design stress, which is not peesently required to nest the low toughness inherent in decreasing the temperature below the NIL ductility temperature.could easily break the chilled Imrt.
Since this is a new concern based on new asterial and inforantion only known for a few days,
there is little likelihood that the design of LimericIc is presently designed to take into account this new information from IE Notice 84-17.
Depending on the conponentor/ system, a distinct and present danger exists that a Class 9 accid:nt could ensue endangering the public health and safety.
This concern is further aggravated by the conditions at Limerick and the financial conditbn of PEco.
1.
In answer to Frank Roanno's interrogatories on welding, the Applicant gava statements that some welds had been inspected wh&chlater the Applicant admitted were not inspected. From this change in Applicant's statements, j Applicant can be seen to have a very f1sid view of what is happening at the sito. Therefore, admonitions from the Applicant cannot be taken at face value for thio grave concern.
- 2. Dua to the limited help that I gave Mr Romano with his Contention and the work that i put into the room PEco provided containing ans* w to intervenor interrogatories, I found that there were many engineering change orders and field change orders that did not appear to have full followup. This will umke determining actual routing of liquid nitrogen lines and lines enntaining potentially very cold flHds very difficult.
- 3. Limerick mit 1 is very near to fuel loading. Fuel "has already been moved onto the site.
There is also a big push on the part of PEco to operate the mit soon.
The push to operate is pred$cated upon a 3aw in Pennsylvania that a utility any not charge customers or rate;syers for a plant until it is "used and useful." Used and useful is considered equivalent to producigg electricity.
PEco is paying alot of overtime on the }imerick site right now. Putting Limerick on line would aid PEcok financial picture as PEco could then petiibn the PA PUC to put PEco's Limerick in the rate base.
All these financial considerations weigh against PEco doing a timeconsuming but necmaary evaluation to assure the health and safety of the public against any prob 1das, associated with this very new concern of components being cooled below their
! NIL ductility tesperature by potentially very cold fluids.
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' Conclusion.
l Therefore,Intervenor respectfully submits a new contention for the ccasideration of the Atomic Safety and Licensing Board:
The Limerick Generating Station Imits 1 and 2 design is deficient because liquid nitrogen or other potentially very cola fluids can cool vital components of the plant below the NIL ductility temperature of the susceptible materials of which they are manufactured.
Basis IE Notice No %-17 describes a particular problem of cracking in the vent head:r at Hatch no 2 caused by liquid nitrogen cooling the vent header aaberial below its HIL ductility temperature. The IE Wotice goca on to generali7e the conccrn to all ligid nitrogen lines and potentially very cold fluids. This conctrn is very new and not included in the SER or any other pertinent document in this instant proceeding. The problem is further compounded by actions on the ptrt of the Applicant that demonstrate its rush to completion ani operation for reasons that are not related to safety.
I have sent this out to the entire nailing list on or before 14 March 1984 l
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Phrvin I. Iawis 6504 Bradford Terrace Phila, PA 19149 (215) cU 9 5964 J
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