ML20094S659

Comments on Proposed Rule 10CFR50 Re Sufficiency of Justification for Continued Operation for Wisconsin Electric Power Co,Point Beach Nuclear Plant I & Ii.Streamlining NRC Licensing & Regulatory Roles Inadequate in Solving Problems

ML20094S659
Person / Time
Site:	Point Beach
Issue date:	08/10/1984
From:	Proudman S WISCONSIN'S ENVIRONMENTAL DECADE
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-#185-924, FRN-49FR8445, RULE-PR-50 2.206, NUDOCS 8408210349
Download: ML20094S659 (12)

Text

.

- g

^

. = .;. .

?'JiOC ell i 3 _ _ ,

649FL / W W Wisconsin's Environmental Decade 114 North Carroll Street, Suite 208, Madison, Wisconsin 53703 (608) 251 7020 IC'EIE 230 W. Wells St., Suite 309, Milwaukee, WI 53203 (414) 272-1607 UJI*hC 324 W. Wisconsin Ave., Suite 1, Appleton,WI 54911 (414)734 5403

.o..o '84 AGO 15 P12:24 n...se.,

Co.,,n,:n

1. 1. (h b L.* 2: C ' t .. 4f TO: Secre.tary SDfi ethe Commission vs. Nuclear Regulatory C'[,,,,,nn Commissitid," Washington, DC 20555 Judita tindier Attention: Docketing and Service Branch Kurt Lued%s No"n'o",

• FROM: Stephen Proudman n.caud mina Wisconsin Environmental Decade, Inc.

Environmental Qualification Standards Commenter DATE: August 10, 1984 St.FF

"*$',*" e',$** RE: Comments on the suf ficiency of the Justification f or Sa >**"' Continued Operation for Wisconsin Electric Power T,M, E'n'let Company's Point Beach Nuclear Plant I & II c= tar 'ao "=* 49 Fed. Reg. 8445 (March 7, 1984)

ECO Batistan t$ tor Richclis Lasse Gmunanity Coordinator KGn L0nnQulSt Ensurenm3ntal Mrnstest VickiK M31in Envronmental Educsten Coerdenstor Donna P4:Nrman Cor'troit3 C&roI Pf0ff@rkorn Ofloce M5neger Jamey Potte*

Network Coorcorsstor JGne R@yno6dt l /dr'9snostrative A s s.s t& *1r Fachard L. Spivey Dorector 09 AdntentstrCloon Mitmaukee Cansae6 M2ry d>GO222tdl toucer,on orrve Coor$nsvor

\tNoG"DentroQ S0monostrGerve

,: s s's t8nt Appleton Convess  !

Artnur Cyts Edgention Orove

! Assocers ,

I2mente $ue >8a'nt Adernistrat<ve a s... tant

)\y'

)a \

.j , (j a e..s.n C ...

,ev.a .r.,.r. g' a: e>U: .LU& lT i

'),kf f) /)

• 1  %

Edscat.cn o ove ,,,,1,.,

, s s_.

o...e rune, g, ,_.3 /'

"[,'",'ll'"' 8408210349 840810 PDR PR 50 49FRB445 PDR DM.' kCd by card..[O ,f,, ,

6 INTRODUCTION:

In the wake of the accident at TMI II, the Nuclear Regulatory Commission ordered all reactors to comply with environmental qualification standards by June 30, 1982. This ruling was incorporated into all reactor licenses to assure that safety and q uality control measures would be upgraded and rigorously maintained to prevent any f uture accidents. In 1982 the NRC changed the rules which amended the licenses of all 72 operating nuclear power plants to suspend that deadline.

In extending the compliance deadline, the NRC made a finding that each plant could be operated saf ely pending completion of environmental qualification. According to NRC records this finding was based upon utility filings called " justification f or continued operation" (J CO's ) . According to the Union of Concerned Scientists findings, most of the reactor equipment associated with cooling and emergency cooling systems did not meet environmental qualification standards. The purpose of the JCO's was to demonstrate that a plant was safe enough to operate despite the difficulties in equipment.

In a oversight of democratic principles the NRC provided no opportunity to comment on the sufficiency of the JCos. UCS sued the NRC and won a decision which ordered the NRC to provide an opportunity for public comment on this' procedure.

I am grateful to the UCS in their efforts to allow for independent review of this most critical process which directly concerns the health and welfare of the general public and surrounding ecosystems near each operating reactor.

COMMENTS:

The comments I w ill make are based on my review of the Technical Evaluation Report (TER) prepared f or the NRC by the Franklin Research Center (FRC); the Safety Evaluation Report (SER) by the NRC staff that addresses the TER; and later i qualification documents. Due to geographical limitations I was unable to trace many key documents made available to the public by the NRC in their Document Reading Room in Washington, D.C.

l The most common problem I had in my review was that some inf ormation was withheld f rom the FRC report because the licensee (in this case Wisconsin Electric Power Co.-WEPCO), claimed the inf ormation was " proprietary" in nature, which I assume means l' that the information contained trade secrets of some sort. This

~

made it difficult, if not impossible, to comment on the adequacy of the qualification review. In an industry which is at this point in time struggling to survive even under immense subsidizations from the federal government I fail to understand how the NRC can allow any utility to withhold inf ormation in a t

critical review of safety requirements. The review of each j component in question remains incomplete, in my opinion, until 2

equitable access to information is_provided.

The order and organization of the records was poor in many instances making the job of reading and following the presented logic a very difficult task. In many cases I could not even read the licensee's response to NRC evaluations thus making my commentary impossible.

I must make a comment on the scope of the TER review. The NRC asked WEPCO to submit a list of all safety related components including documentation to show that they were qualified. "SCEW sheets" were provided which contained inf ormation on the conoition for which equipment was qualified as well as the conditions to which the equipment could be exposed during an accident. According to UCS, the NRC's evaluation never questioned the licensee's assertions or examined the basis f or the assertions. They only looked at areas where equipment qualifications did not appear to meet the requirements of an accident condition. This means that WEPCO's statements in 1981 that equipment was qualified due to whatever justification were never reviewed by the NRC or FRC. The review sDly covered equipment that WEPCO identified as deficient. This is a gross assertion and makes the scope of the TER review gravely deficient at best. .

As I understand the role of the NRC, it is to regulate and license the reactors of the nuclear industry. It's role has been reevaluated af ter the seriousness of the accident at TMI II was realized through new and continued research findings by engineering experts. Unf ortunately the type of gross experiment is not an adequate learning lesson f or a technology which can have serious and undetermined (the debate continues) biological effects in forms of life.

8 At a nuclear-fuel-cycle conference held in Atlanta in April 7, 1984, NRC member Frederick Beinthal was optimistic in assertions that "the NRC in the 1990's could retreat into something like a Federal Aviation Administration f or nuclear power pl a n t s. " According to Beenthal the problem with the industry is simply stated, "the technology of nuclear power is proven, but the institutions that generate and regulate the power need fixing." I would say this may be only partly true. After i reviewing this TER I am of the opinion that if the technology

, were proven then this would not be evidence of such a large

number of unqualified components in reactors such as the Point Beach plants. If the confidence is then f or j ustification then why is this evaluation process full of discrepencies and

misleading inf ormation? On the human side of the industry, if the confidence exists for demonstrating sound competent management then why is the industry in such financial trouble and why does it take a lawsuit to allow the general public to become

! involved in process concerning the public's safety?

. I realize af ter completing this review that the bureaucratic entanglements are enormous, however, strenmlining the NRC's 1

3 . - _ - - - - .- . - -

licensing and regulatory roles is not an adequate answer to eliminating problems involving individual components governing the mechanics of a reactor's safety systems. This is a technical problem needing' straightf orward attention and adequate documentation for proof of suf ficiency.

The following list is an item by item description of safety-related components which were f ound to not be qualified by the FRC. For these components many justifications for continued operation were submitted af ter the TER was filed. Comments are included for each item.

lism 21: Electric Motor located in Auxiliary Building FUNCTION: Safety injection pump motor.

CATEGORY:

. Qualification for deficiency improvement not established.

.No adequate documentation of qualification.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

COMMENT:

. Unable to read licensee response to NRC SER.

.FRC comments on licensee response:

.WCAP-8754 was cited by licensee as evidence of qualification. FRC says this is not an adequate analysis that de te rmine s an actual in plant service life for the safety injection motor pump.

lism 25: Electric Motor located in the Auxiliary Building.

FUNCTION: Containment spray pump motor CATEGORY--Qualification Not Established

. Documentation evidence of qualification inadequate.

. Inadequate agency degradation evaluation

. Qualified life or replacement schedule not established.

. Criteria regarding radiation not satisfied.

COMMENT:

In the licensee's response concerning the motor's qualifications f or perf orming under high humidity, the rational used was based on an assumption that the location of the motor is such that high humidity Js got szpssted in that part of the auxiliary building. This is not an acceptable scientific judgment.

4

21ss 26: Electric Motor located in the Auxiliary Building FUNCTION: Component Cooling Water Pump Motor CATEGORY: Qualification f or deficiency improvements not established.

.No adequate documentation of qualification.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

. Criteria regarding radiation not satisfied.

COMMENT:

The laboratory test report of this vital component in the reactor's cooling system (s) was not used in full in the qualification process. Reasons for receiving only parts of the research report are the size of the report and the " proprietary" classification of the reports. This does not allow for a thorough review by outside reviewers, 1133 22: Electric Motor in the Auxiliary Building FUNCTION: Residual Heat Removal-Pump Motor CATEGORY: Qualification not established.

. Documentation of evidence inadequate.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

. Program not established to identify aging degradation.

. Criteria regarding radiation not satisfied.

COMMENT:

The ref erence report WCAP-8754 includes unacceptable test date which establishes a qualified life (r' inning hours) under an assumed radiation level (temperature) for this motor.

There is no analysis, according to the PRC that determines the actual in-plant service life.

There was no maintenance schedule submitted, for the record, for the bearings / lubricant.

r 1133 28: Electric Motor in Containment FUNCTION: Containment air accident from cooler motor.

CATEGORY: Qualification not established.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

. Criteria regarding aging simulation not satisfied.

. Criteria regarding radiation not satisfied.

5

COMMENT:

For Items 28,29,53 [Containent Emergency Fan Cooler Motor, Splices, and Bearing Lubricants] deficiences were found in a combination of eight areas of qualification. The proposed resolution by WEPCO (November 23, 1983) is for additional analysis and documentation. No other record is available to document what action was taken, therefore the component remains unqualified.

lism 22: Electrical Cable Splice in Containment.

FUNCTION: Electrical splice f or containment air accident ft.n coolers.

CATEGORY: Qualification not established.

. Documentation of evidence is inadequate.

COMMENT:

Licensee is siting a document for a similar motor (which cable splice is connected to) as the evidence for qualification. No tests were done directly involving this component.

l Most of the Licensee response is illegible, which makes commenting difficult.

, lism 3Q: Resistance Temperature Detector in Auxiliary Building.

FUNCTION: Measures RHR Suction and Discharge Line Temperature Conversion.

CATEGORY: Qualification not established.

. Aging degradation evaluated inadequately.

COMMENT:

The licensee has not satisf actorily stated that the installed model is equivalent to currently manuf actured models.

It is also not clear whether any environmental qualification tests have been done f or this item.

Itsa 31: Motor control center located in the Auxiliary Building.

l FUNCTION: 480 Volt Electrical Power distribution.

~

CATEGORY: Qualification not established.

COMMENT:

Unable to read licensee's response to the NRC's SER.

Jtem 22: Electrical Thermocouple Cable located in containment.

___ ___ ._ _________6__ _ _ _ _ _ _ _ _ ,

FUNCTION: Reactor core thermocouple cable connection.

CATEGORY: Qualification not established.

COMMENT:

Licensee states the item is not environmentally qualified even though the TMI Action Plan requires it to be. The licensee then says it intends on qualifying the item, if possible, by the environmental qualification deadline but there is no record of this action.

lism 3H: Electrical instrument cable in containment building.

FUNCTION: Conducts acoustic signal transmission.

CATEGORY: Qualification not established.

COMMENT:

The licensee has referenced a report for RSS-6 coaxial cable. However, the manuf acturer has stated that although the cable passed the test it is not suitable for the application because the signal alterations and temperature resistance capability are not adequate.

Itsm 32: Electrical Control Cable located inside and outside containment.

FUNCTION: Electrical distribution.

CATEGORY: Qualification not established.

' COMMENT:

No test report was submitted by the licensee to be reviewed by an independent reviewer. According to the FRC evaluation the licensee stated that the PORV block values which the cable supplies power to are not safety related equipment and theref ore the cable does not require qualification. However, according to NUREG 0737, Item I I .7.1 indicates that power supplies require upgrading to maintain the ability to either open or close the PORV block values. The licensee should insure that the cable is also qualified.

Itsm 12: Electrical instrument cable located inside and outside containment.

FUNCTION: Instrumentation Cable.

CATEGORY: Equipment not qualified. Adequate similarity between equipment and test specimen not established.

COMMENT:

N e i'th e r SCEW sheet nor the licensee's provide 7

I sufficient information to establish that the installed equipment is the same as the equipment tested. It is not saf e to assume that one piece of equipment which is similar to another can have test results which apply to both.

2123 5Q: Lubricant located in the Auxiliary Building - safety injection

• pump area.

FUNCTION: Safety injection pump motor bearing lubricant.

CATEGORY: Qualification not established.

. Documented evidence of qualification inadequate.

. Adequate sim ila r i ty between equipment and test specimen not established.

, . Aging degradation evaluated inadequately.

. Program is not established to identify aging degradation.

. Criteria regarding aging simulation not satisfied.

. Criteria rege ng peak temperature exposure not adequate.

. Criteria regar._ag radiation not satisfied.

COMMENT:

BaBed on the FRC report very little documentation exists on the lubricant, particularly it's f unction under high temperature and radiation conditions. No f urther documentation was provided.

Item 51: Lubricant located in the Auxiliary Building component cooling pump area.

FUNCTION: Component cooling water pump bearing lubricant.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualification inadequate.

. Adequate sim ila r i ty between equipment and test specimen not established.

l

. Aging degradation evaluated inadequately.

. Program to identify aging degradation not established.

' . Criteria regarding aging simulation not satisfied.

. Criteria regarding peak temperature exposure inadequate.

COMMENT:

The manufacturer of the grease has never subjected their products to tests involving exposure to radiation.

ADDITIONAL COMMENTS:

Major inadequacies in all of the above-mentioned evaluation categories. There is no real documented evidence of necessary tests according to the PRC's report. How then, can another JCO approval be given?

8

lism 52: Lubricant located outside. containment.

FUNCTION: Pump and motor bearing lubricant.

CATEGORY: Equipment qualification not established. Same as for Item 50.

lism 53: Lubricant located in containment.

FUNCTION: Fan cooler motor bearing lubricant.

CATEGORY: Equipment qualification not established.

. Adequate similarity between equipment and test specimen not established.

. Qualified life or replacement schedule not established.-

. Criteria regarding peak temperatue exposure inadequate.

lism 51:- Lubricant located in containment.

FUNCTION: Valve motor operator lubricant CATEGORY: Equipment qualification not established.

. Documented evidence of qualification is inadequate.

. Adequate simila rity between equipment and test specimen not established.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

. Program to identify aging degradation not established.

. Criteria regarding aging simulation not satisfied.

. Criteria regarding peak temperature exposure inadequate.

. Criteria regarding radiation not satisfied.

COMMENT:

Checksheets 5F through SI were withheld due to the

" proprietary" nature of information they contained. This makes the job of commenting very difficult, lism 55: Lubricant located outside containment.

FUNCTION: Pump motor bearing lubricant.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualification inadequate. .

. Adequate sim ila ri ty between equipment and test

, specimen not established.

. Aging degradation evaluated inadequately.

. Program to identify aging degradation not established.

. Criteria regarding aging simulation not established.

. Criteria regarding peak temperature exposure 9

inadequate.

. Criteria regarding radiation not satisfied.

COMMENT:

Checksheets 5F thru SL were removed due to proprietary nature of their contents. This makes the task of commenting extremely difficult.

21sm 56: Lubricant located in containment.

FUNCTION: Motor operated valve and geared limit switches lubricant.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualification inadequate.-

. Adequate similarity between equipment and test specimen not established.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

. Program to identify aging degradation not established.

. Criteria regarding aging simulation not safisfied.

. Criteria regarding peak temperature exposure inadequate.

COMMENT:

Proprietary information withheld making comments difficult.

lism 61: Motorized valve actuator located in containment.

FUNCTION: Actuates pressurizes PORV block valves.

Equipment qualification not established.

CATEGORY: Documented evidence of qualification inadequate.

. Adequate similarity between equipment and test specimen not established.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

t COMMENT:

Proprietary information withheld. Not enough information to make comments.

1 Jigm 62: Motorized valve actuator located in containment.

I FUNCTION: Actuates reactor vessel safety injection line valves.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualification inadequate.

Sua

o 4

. Adequate similarity between equipment and test specimen not established.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

COMMENT:

Proprietary information withheld. Not enough information to make comments.

lism fia: Motorized valve actuator located in containment.

FUNCTION: Actuates RHR inj ection line valves. Actuaces cold by saf ety injection line valves.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualifications inadequate.

. Adequate similarity between equipment and test specimen not established.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

COMMENT:

Proprietary inf ormation withheld making commentary incomplete.

lism 65: Motorized valve actuator located in the component cooling heat exchanges area.

FUNCTION: Actuates steam-driven auxiliary feedwater turbine steam supply line valves.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualification inadequate.

. Adequate si m il a r i ty between equipment and test specimen.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

COMMENT:

Proprietary inf ormation has been withheld. Comments cannot be made based on available information, lism 66: Motorized valve actuator located in the Auxiliary Building.

FUNCTION: Actuates component cooling water supply lines to RHR heat exchanges valves.

CATEGORY: Equipment satisfies all requirements except 11

qualified life or replacement schedule justified.

. Aging degradation evaluated inadequately.

. Qualified life or replacement schedule not established.

COMMENT:

Proprietary information withheld. Not enough information available for which to comment.

lies 24: Electric Motor located in the Auxiliary Building.

FUNCTION: Safety injection pump motor.

CATEGORY: Equipment qualification not established.

. Documented evidence of qualification inadequate.

. Adequate similarity between equipment and test specimen not established.

. Aging degradation evaluated inadequately.

. Program identifying aging degradation not established.

. Criteria regarding radiation not satisfied.

COMMENT:

According to FRC WEPCO has not provided an analysis that determines an actual inplant service lif e f rom the data provided in reterence report WCAP-8754. WEPCO has not submitted any qualification documentation that would establish a qualified lif e f or the motor to the lead splice and bearing lubrication sy stem.

ADDITIONAL COMMENTS:

There are a total of 22 other components of not qualified status in Project No. 506. They are Item Nos: 25, 26, 27, 28, 29, 30, 32, 36, 39, 42, 50-56, 61, 62, 63, 65. This reviewer did not have ample time to complete a thorough review of these components and their deficiencies.

12