ML20090F185
| ML20090F185 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/27/1983 |
| From: | Bradley Davis AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 8307050095 | |
| Download: ML20090F185 (3) | |
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200 Gettysburg Pike Mechanicsburg, June 27,1983
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-Secretary of the Commission U.S. Nuclear Regulatory Commission Re: Docket No. 50-289 Washington, D.C. 20555 Amendment to Facility-Operating License DPR-50
Dear Sir:
The Nuclear Regulatory Commission is proposing in the Federal Register of May 31, 1983 to amend the operating license for Unit 1 of Three Mile Island to waive a hearing on the matter, citing No Significant Hazard.
This is outrageous.
It~is outrageous that 20,000 steam tubes shouldhave been repaired by a new and untried method, with the NRC looking on, without any request for an amendment of the license until after.the job is completed, and with no recognition of the danger.
There should be a strong suspicion that the company is not acting in good faith when it waits to file for the amendment -
not when the tube repairs are completed, not when the so-called
" tests" are completed - but waits until the day regulations.
are filed which could waive an evaluation of the license amendment as not posing a hazard.
Then, finding they had filed too soon, the company withdrew their request and filed three days later to make sure they would be evaluated under the new regulations.
It is hard for me to believe that the NRC would not want to take an especially close look at the procedure whenthe company is acting in this way.
There IS a significant hazard posed by this repair and a hearing should have been held BEFORE the repairs were ever attempted.
I do not'have to be an engineer to know this.
Common sense alone tells me that when you use a technique for the first time there are unique. risks being posed.
In this. case we are_not talking.about a hole in a pipe letting a little clear water run ou.t.
We are talking about radiation escaping.
We are talking about on'e broken pipe flailing around to destroy i
nearby-ones, as was predicated at Ginna~,' leading not just to
.a minor leak but to possible deterioration of the whole ggo system. Certainly you cannot blind yourselves to the significant Mo' increase in'the. probability or consequences of the accident jo that could happen at this plant if the repairs do not work.
mE These kinetic expansions, as they are euphemistically called, were done by two mine blasters - one who had not used his l
expertise for years. and the other who _ hurriedly got a license
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just to do this job.
The first cluster of pipes which were
" expanded" (blown up) resulted in damage to almost as many-h neighboring pipes.
No doubt these men got-better with practice -
but how much better?
How many new holes, cracks and stressed.
points were created by.the' blasting itself?
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Page 2-
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Comments on Amendment Proposed to DPR-50 i
B.-Davis I understand there was a final outer ring which could not be repaired at all.
I understand that no-one is claiming the leaks are stopped, only slowed.
I understand the original leak tolerance has been increased sincethe-repairs-were done.
None of these things reassure me that
- this is a routine procedure or a routine request.
The
-fact.that 2/3 of the tubes in the steam generator were repaired would seem in itself to dictate a hearing.
When were 2/3 of a reactors steam generator tubes ever repaired at once before?
I must come back-to using common sense again.
I understand that expanding the tubes smooths out grooves of some kind manufactured into the tube.
Haven't those grooves provided a measure of expansion which will no longer'be there when the pipe is stressed once more?
I believe there is no welding, no soldering, not even any Elmer's glue applied to either end of the repair.
In aircraft I am told that a somewhat similar " sleeving" of-two metal tubes has proven unsuccessful as soon as any vibration develops.
Vibration will shear off the original tube just above the
" sleeve."
Certainly there is some vibration under normal operation.
In times like the Unit 2 accident, operators
- reported tremendous vibration-so great they had to shut the thing down.
These pipes did not just have a couple little holes or cracks.
According to an NRC staff briefing, when the leaks were discovered, they were so bad it was impossible to get-over two pounds of pressure in the vessel.
On the secondtest they were able to get up to 15 lbs. but no more.
You started with a big problem.
Even the most tested reliable procedure should have had scrutiny with that big a job.
According to the proposal submitted by GPU the repairs create a' new tube to tubesheet joint and ' remove the degraded portion from the-primary system pressure boundary.
Again, common-sense tells me-that this has to ' create new operating conditions for this system.
Testing the results with a computer model or. a miniature mockup hardly seems enough to " prove" that this altered system will work.
It1certainly does not seem to qualify for the
- definition of "no changes" in the steam ' generator.
Frankly,'I am not-sure I trust.GPU's safety evaluation.
A company which~ encourages falsifying leak rates and cheating on operator exams.t6 keep ' the plant running does not seem to me to be above falsifying a few tests as well.
Who has evaluated the system and the qualifyin And who has seen any of the. evaluations,?g tests besides GPU?
We were told that the reports-were classified because they were proprietary information.
Is the public being asked once more simply to trust GPU? ~
3 m
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t Page 3 Comments on Amendment Propsed to'DPR-50
- B. Davis I questionLGPU's sincerity in claiming No Significant Hazard when thev filed both for a Class I license amendment-($1,'2'00. fee) and for a Claes IV ($12,300 fee)
- simultaneously.
I am leery as well of their desire to
. rush the amendment through by asking the NRC to "Please act by June'15."
In addition they askedrhe NRC to combine the conditions.for license with the publishing of request
. for amendment.
In all of the request for amendment there is no mention of any compensatory measures to be taken for the operation of a. steam generator with 2/3 of its tubes repaired.
Only one sentence even hints that GPU might have to run the plant at less power or some other restriction.
"The Commission, howeveri proposes to determine that the. application does not involve a significant hazards consideration because compensatory measures will be employed to provide a level of safety in operation with the repaired steam generators commensurate with thr anticipated of the facility had it not experienced the need to repair steam generators. "
By all the standards I have mentioned this does pose a Significant Hazard.
It does require a public hearing.
The facility is changed, significantly.
It is changed dangerously with a bargain basement repair that is calculated to.get the plant back into the rate base, not to allow it to operate safely in a manner which will protect the health and safety of'the people who work in the plant and those who simply live in the area.
Your own staff has predicted more steam generator accidents will happen.
You cannot afford to be casual about Unit 1
- being the next accident to happen.
Yours truly, Beverley vis G
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