ML20101U805

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Petitions NRC to Institute Proceeding &/Or Investigative Actions Into Significant Safety Matters at Plant.Requests That Low Power/Fuel Load License Not Be Issued Until Items Resolved
ML20101U805
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 01/28/1985
From: Puntenney J
SAFE ENERGY COALITION
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8502080053
Download: ML20101U805 (5)


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So- 3'll Safe EnergyCoalition 17736 Five Points

  • Detroit, Michigan * (313) 5318943 "Better active today than radioactive tornorrow" January 28, 1985 1

Mr. Harold Denton l Director, Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission )

Washington, D.C. 20555 1

Dear Mr. Denton:

Pursuan; to the Code of Federal Regulations for Energy (10) under Section 2.206, Requests for Action and Section 2.202, Order to Show Cause, the Safe Energy Coalition of Michigan hereby petitions the U.S. Nuclear Regulatory Commission to institute proceeding on and/or investigative actions into the significant safety matters at Detroit Edison's Fermi 2 nuclear power plant.in Monroe County, Michigan.

We are also asking that the office of Nuclear Reactor Regu-lation along with Region III of the NRC not issue a low power / fuel loading license until these items are successfully resolved andujus-tified. Further, we ask that the activities authorized by the opera-ting license be as such so that they can be conducted without endan-gering the health and safety of the public. Section 50.57 (5) (b) of the Code states that, "Each operating license will include appropriate provi-sions with respect to any uncompleted items of construction and such limitations or conditions as are required to assure that operation during the period of the comple-tion of such items will not endanger public health and safety."

The significant safety allegations and documentation presented henceforth, warrant our concerns and justify our request for thorough and full investigation, show cause, and public hearings on these matters.

1). COMPUTER SYSTEMS Information systems at Fermi 2 are " awful" according to sources we have been in contact with. Consistency in the different data systems and their coding has not been maintained. Further, input into the data base has not been consistent with the codes used for indexing documents. There is difficulty retrieving data, and there has not been time to fix these problems. To compound the situation Detroit Edison has reduced personnel that take care of all documentation and vaults. Further allegations b Construction Team AssessmentCAT) (y our sources in conducted reveal that despite the Summer of 1984the by Duke Power, the problem of how long it takes to retrieve the ago$

documentation has not been addressed at Fermi 2. Retrieval of in- D 1-formation for many critical parts of the plant is not readily avail- d li able, some not available at all and could take days to retrieve.

8502000053 850128 PDR ADOCK 05000341 H PDR ,

{ JI' Page.Two-LLetter to Harold Denton LIn addition to the above information the following documen-

.tation'is available on this matter:

In an October 6,1984 letter (EF-72264) Wayne Jens, Detroit

. Edison's Vice-President, Nuclear Operations, to B.J. Youngblood, Chief the schedule and problema of tha System Emergenc (y' Informa SPDS) tion Sy. stem (ERISof Licensing at the are described.

ERIS, the automated data acquisition system provides data for

.the SPDS and for the dose assessment function. The SPDS is a pri-mary function'for the control room operations personnel. These.sys-tems electronically interface with many plant systems. The schedule for acceptance of critical plant systems Jas been delayed according to this letter. June, 1985 was the antici But, a December 12, 1984 letter. (EF-72264) pated implementation from Wayne date.

Jens to T.M.

Novak, NRC Assistant Director for Licensing, in Attachment C, it is indicated the ERIS/SPDS completion date has been. changed to December, 1985.

The computer systems in our view must be operational and func-tional in a higly automated nuclear plant. NUREG 0737, Supplement I.

supports,the need for this matter to be thoroughly investigated and resolved.before fuel loading.

2). .AS-BUILT DESIGNS

.In the :SALP #5 report (Systematic Assessment of Licensee Per-formance) issued recently, the problems of lack of records for the as-built designa for the electrical and instrumentation systems are raised. Delays in fuel loading at Fermi 2 as of this date are con-tingent on the correction of this problem.

According to the Michigan Public Service Commission's . Staff Investigation into the Enrico Fermi 2 Nuclear Project, = February, .1984 ,

Detroit Edison's internal audits showed thatothere has been serious '

problems with document control, inadequate paperwork; associated; with' f' construction, and no adequate control on the design process. Through- ','-

out the project several thousand design changes have been made accord-

'ing to the PSC. '

These criticisms from the Michigan PSC staff has raised our , j

-concerns that other. areas in addition to the electrical andLinstru- ,

mentation systems identified by the SALP report couldLbe problematic.

Sources at the plant have told us that documentation is not there fot , ' #s >

manyasystems-that underwent design changes over the last fifteen. 7 '

years. These. sources indicate documentation was not recorded or-it was lost.

Further investigation into other. areas besides electrical s

and 0 instrumentation 'for; confirmation tbat all records and documenta-tion' of design changes has been dumpleted properly and} fully. Because of the alleged problems mentioned earlier in Matter .no.1, that is with the coding,-indexing,'and retrieval of information from the' ,

plantb data base systems, the Safe Energy Coalition would like your i office to investigate how safety issues in no.1 and 2 interface.

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The total picture,must be looked at.

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.3). RADWASTE PROCESSING SYS' TEM .

I' TheRadwasteProcessingSystemwillko'tbetegtedand'funct'ional A- .

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Pag: Thr': 0 Letter to Harold Denton Et the time of fuel load according to two letters from Wayne Jens to B.J. Youngblood, Ch~ief of the NRC Licensing Branch No. 1, dated October 11, 1984 (EF-71992) and December 18, 1984 (EF-72035). De-troit Edison plans to use> the NUS Corporation's portable radwaste system for liquid and solid radioac,tive waste. Portions of the permanent facility as indicated in a Dacember 12, 1984 letter (Wayne Jens to T.M. Novak) (EF2-72028-Attachment C) necessary to support the vendor radwaste system are to be completed before initial crit-icality and the complete system by " warranty run." In addition, Edison has no program for disposal of potentially radioactive oil.

In 1979, Detroit Edison engineers found serious design flaws.

with almost every subsystem of the Radwaste Processing Facility at Fermi 2. In an April,1980 study by the NUS Corportation, " Report of Evaluations: Enrico Fermi 2, Solid aad Liquid Radwaste Systems,"

confirmed that "the system as designed and installed was inoperable, inefficient, unsafe, and uneconomic." Edison engineers were further criticized by the Michigan Public Service Commission staff investi-gation in February, 1984 for ignoring " numerous elementary design consideration and basic laws of physics." Some of these included:

extremely poor piping arrangements, locations of valves and motors, disregard for radiation exposure levels, unnecessary and excessive person power, etc.

The. report further states that " modifications to the Radwaste '

facility have been extensive including the rip out of large compon-ents, piping, and relocation of equipemnt, etc. Inherent features of the original design will continue to inhibit efficient operation

.of the radwaste system."

The Safe Energy. Coalition believes it is the responsibility under the Atomic Energy Act and Code of Federal Regulations to ensure the safe operation of this facility. -This,in our opinion is not the case at this time. We request further investigation into this matter and insist on making public the NUS Corporation's proprietary portable radwaste system. The public has the right to know what sys-

, teas are being used to protect their environment, health and safety.

t 4). FIRE PROTECTTON The' Safe Eaergy Coalition is still not satisfied with the NRC's j discretionary decision to allow Detroit Edison to fuel load and operate Fermi 2 withoutan alternate shutdown system in place. Portions of the NRC staff,iincluding Region III fire inspectors and the Director, Mr.. James Keppler, in mid-1984 had been very critical of NRC's new interpretation of the 1980 fire protection rule. In a June 11, 1984 issue of'Inside NRC,' Charles Ramsey, a Region III inspector stated -

that. Region 11-1 management and other staffers were protesting "be-cause the new interpretation compromises Appendix R (Code of Federal Regs.-Fire Protection) and safe 4 shutdown capability." NRC staff protesters claimed without implementing alternate shutdown systems at Detroit Edison's Fermi 2 plant, that "them is no way to bring the plant to a safe shutdown if a fire hits the control room."

The problerokwith fire protection in the cable spreading room

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[gr- andi rrilay room the' NRC identified f A i,he June 5, i964andJuly11,

  • '.1984' se'eting . summaries by M.D. Lya'ch, Project Manpgsr, have been ad-

~ dressed by your staff and Detroit Edison. 1 t..

'Better-fire wrap,. cleaner faciIit'ies, more sprinklers, more F

personnel are surely only the first+ steps to your policy of defense

-i n' depth.' To allow Detroit Edison the option to delay installing Jannilt'ernateJshutdown-system until the first fuel outage (1986)

'is'insrdusable with the length of time Edison has had to reroute cables in11 design and. implement an alternate shutdown capability 1 e1~s Where41n the plant.J In the January-February,,1980 issue of ,

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LN uclear Safety, an article entitled " Fire Hazard $d = Consequences of-Fire in Nuclear Power Plants,." states " Fires can damage safety related coqtrol.or signal cables or equipment, whJch may interfere

' ' with safe shutdown of the nuclear reactor." It further $ ports that YRedundant' safety-related systems could be lost or rendered inoper-a ble.becduse,of a relatively small localized fire."

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The Safe Energy Coalition vehemently opposes the continued

? relaxing of-NRC. strict standards for fire protection knowing the

, . realized hazards tha.t fires pose at nuclear planta,especially with a the' Fermi ~ 2 plant design without the alternate shutdowx system in place.-

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,i In the -M.D. Lynch summary document of July 11,1984, Detroit

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Edison: supplied the,NRC with a 1.rief: fire protection history for ,

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. , , Permi'2. In'this:stama'ry, Edisotos. knowledge of the Browns Ferry '

'% ,Viren ofJMarch 22,3975 was well.dcadmented,by.themselves,with review

.Jgroups'and task < Mrc'es formed'to deal with the issue of fire protection.

EDuring this Ltime. Datroit Edison had: Fermi 2 shut-down from 1974-77 for-

. f financial reasons and; to catchlup on their engineering design back--

(log. . Regulatory guides were . issued in 197' 6- and 1977, - ANSI Standards

  1. ^- Dwere : released in 1.979,' followed by NRC ' regulations, Appendix R in

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1980.^" Edison has had ample-time.to~ implement thegne'eded defense.in-depth: fire'.: protection thatiincludes the'most critical component,

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-an alternate shut ~down capability. . 7 15:Cg[1jpowerloperatiod We requedti.lythat fulliimplementation, prior to fuelliosdLand~lowE gof the shutdownEsystem be required. Purther'in- 1 a g 7 . vestigation, iexplanation, and_ justificetion. fon NRC ' approval' of, 3  % iEdison'sifire; protection'sys_tems-is;intorder.' . Met re' gard ~ this as -a

., (veryfserious matter ~ and .~would 'like public hearings called under

  • ' ;Section%2.202i(Show Cause)._

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5erious problems have~ b'ecome: apparent witli thisfolder, Jobsol~ete

.. reactor _ design,'particularly.11n!regards tosthe con ^structabilityp r ~ ^: accessability,and4thecability'of the:containmentatolhold in a seriousc (acci' dent.i Design _ modifications had totbe made;atiFermi~2~~to-the.

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y q; torus ~ and the LDrywellisteel. Ahe small containment, defects 'inithe -

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V for thisitype system,(torus);and' of Treactor cannot be, the in volumes our / view, of possible ignored _

.fi _ Mn@ic'ensir g7this-- plant. . tit should not be put. inithd.>" gen.eric,.

y j '<eunredo.lve cdtegoryfofjtheiNRC{tobesolved1sometimeinthefuture. g

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- Page Five Letter to Harold Denton In the book, the Cult of the Atom by Daniel Ford, as early as

. 1971, . the ' Atomic Energy Commission (AEC) through its safety analysts, c proposed:to senior.AEC officials the banning of "the pressure-suppres- -

sion containment scheme" of which Fermi 2 is included. Technical

. analysis was never challenged and no objections were raised on scien-

. stific grounds.: The reply by Joseph Hendrie, Senior AEC official, t

was.the following: "the acceptance of pressure-suppression' containment

'.. . concepts by all elements of the nuclear field, including Regulatory

.andrthe A.C.R.S.,.is firmly embedded in the conventional wisdom.

Reversal of this hallowed policy, particularly at this time, could .

well be'the'end of nuclear power. It would throw into question the W' continued operation of licensed plants, would make unlicensable the

~~G.E. and, Westinghouse ice-condenser plants now in review and would generally create more termoil than I can stand thinking about."

cThis matter has been ignored for too long. The Safe Energy Coalition. requests resolution of this generic issue and guarantees

'from the"NRC that Fermi 2's reactor design and operation will not meither endanger public health and safety, increase worker exposure, s

-.or. contaminate =the surrounding environment. More thorough investi- t

gations and* hearings are, we feel,. warranted. Fuel loading should W inot.be expedited because of lack'of solutions.

7 Com' promising the , safety of people and the environment because s Detroit @ ison.now faces economic crisis with the huge cost escala-tions'and delays, cannot be tolerated. Expedition of a license

- -is .not in order = because of the unresolved safety. issues we have

detailed. .The S.afe Energy ' Coalition pe.titions your office to inves-s atigate the aforementioned serious unresolved safety ' issues with great 1 dilige'nce 'and tthoroughness with public input into these matters.

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' m In addition, we ask thatjthe NRC dou not issue a fuel. load / low

< 90 3 power license until- these, investigations have been completed and the -

problems-successfully' resolved. -

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Jennifer-E.lPuntenney-

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fi cc:"; Attorney GeneralLFrankfKelley .

  • 12 Governor. James:Blanchard:'

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(RogerJFischer$; Chi,effof/Staffh Mich.:Public ServicejCommission"'

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C O Senator-CarlsLevin .

j a jSenator: Don Riegle:' ~:,

T A11Ernst,1 Attorney for WolverineLPower Supply Cooperative 7 fRepresentativeiSander Le'in" v g L. - MRepresentativerJohn1 Din ell - . .

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