ML20133B579

Responds to FOIA Request for Records Since Jan 1985, Evidencing Request by Individual or Group of Work Stoppage, Licensing Investigation or Other Related Investigation of Plant.Je Putenney Encl

ML20133B579
Person / Time
Site:	Fermi
Issue date:	05/28/1985
From:	Felton J NRC OFFICE OF ADMINISTRATION (ADM)
To:	Heban L AFFILIATION NOT ASSIGNED
References
FOIA-85-271 NUDOCS 8507200328
Download: ML20133B579 (1)

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\...../ ERY t8 E85 Ms. Linda A. Heban 311 Hawthorne Lane IN RESPONSE REFER Rossford, OH 43460 TO F01A-85-271

Dear Ms. Heban:

This is in response to your letter dated April 10, 1985, in which you requested, pursuant to the Freedom of Information Act (F0IA), records since January 1, 1985, evidencing a request by any individual or group for work stoppage, licensing investigation, or any other related investigation of the Fermi 2 Nuclear Plant.

On May 8, 1985 and May 22, 1985, Mr. Stephen Isaacs of my staff telephoned your home and spoke with your father about your request. Me could not provide us with any clarification about your request, and you have not contacted Mr. Isaacs. Without additional, specific information as to the nature of the records in which you may be interested, the staff has identified the enclosed copy of a January 28, 1985, letter to Mr. Harold Denton from Ms. Jennifer E.

Puntenney of the Safe Energy Coalition, Detroit, Michigan.

If you have any questions regarding this response, please telephone Mr. Isaacs on 301-492-7604.

Sincerely, l w =mh

• J. M. Felton, Director Division of Rules and Records Office of Administration

Enclosure:

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• Detroit, Michigan * (313) 5318943 "Better cctive today than radioactive tornorrow" January 28, 1985 Mr. Harold Denton Director, Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

Pursuant 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;.anddus-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 sur' ' Laitations or conditions as are required to assure operation during the period of the comple-tion i _;h items will not endanger public health and safety."

The significant safety allegations and documentat$on 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 ard 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 1984 the by Duke Power, the problem of how long it takes to retrieve the $

40 documentation has not been addressed at Fermi 2. Retrieval of in- D 10 formation for many critical parts of the plant is not readily avail- 11 able, some not available at all and could take days To retrieve.

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Page Two i Letter to Harold Denton In addition to the above information the following documen-l 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 of Licensing at the NRC, Branch I, the schedule and problems of the Emergenc System (y Informa SPDS) aretion Sy. stem (ERIS)and the Safety Parameter Display 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 has been delayed according to this letter. June, 1985 was the antici l But, a December 12, 1984 letter (EF-72264) patedfrom implementation date.

Wayne Jens to T.M.

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

l The cc7putar systems in our view must be operational and func-tional in a higly automated nuclear plant. NUREG 0737, Supplement I i supports the need for this matter to be thoroughly investigated and l 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 designs for the electrical and instrumentation systems are raised. Delays in fuel loading at Permi 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 that there has been serious problems with document control, inadequate paperwork associated with l

construction, and no adequate control on the design process. Through-out the project several thousand design chsnges have been made accord-ing to the PSC.

These criticisms from the Michigan PSC staff has raised our ,

concerns that other areas in addition to the electrical and instru-mentation systems identified by the SALP report could be problematic.

Sources at the plant have told us that documentation is not there for many : systems that underwent design changes over the last fifteen years. These sources indicate documentation was not recorded or it was lost.

Further investigation into other areas besides electrical and instrumentation for confirmation that all records and documenta-tion of design changes has been completed 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 planfs data base systems, the . Safe Energy Coalition would like your office to investigate how safety issues in no. 1 and 2 interface.

The total picture must be looked at.

3). RADWASTE PROCESSING SYSTEM The Radwaste Processing System will not be tested and functional L_

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Pago Thrco Letter to Harold Denton at 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 October 11,1984 (EF-71992) and December 18,1984 (EF-720355. dated De-troit Edison plans to use the NUS Corporation's portable radwaste system for liquid and solid radioactive waste. Portions of the permanent facility as indicated in a' December 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 a2d 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 xposure 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-tems are being used to protect their environment, health and safety.

4). FIRE PROTECTION The Safe Energy Coalition is still not satisfied with the NRC's <

discretionary decision to allow Detroit Edison to fuel load and operate l Fermi 2 withoutan alternate shutdown system in place. Portions of the  !

NRC staff, including 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 III management and other staffers were protesting "be-cause the new interpretation compromises Appendix R (Code of Federal Regs.-Fire Protection) and safe 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."

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Pagd Four Letter to Harold Denton and relay room the NRC identified in the June 5,1984 and July 11, 1984 meeting summaries by M.D. Lynch, Project Manager, have been ad-dressed by your staff and Detroit Edison.

Better fire wrap, cleaner facilities, more sprinklers, more personnel are surely only the first steps to your policy of defense in depth. To allow Detroit Edison the option to delay installing an alternate shutdown system until the first fuel outage (1986) is inexcusable with the length of time Edison has had to reroute cables and design and implement an alternate shutdown capability elsewhere in the plant. In the January-February,,1980 issue of Nuclear Safety, an article entitled " Fire Hazard and Consequences of Fire in Nuclear Power Plants," states " Fires can damage safety related control or signal cables.or equipment, which may interfere with safe shutdown of the nuclear reactor." It further reports that

" Redundant safety-related systems could be lost or rendered inoper-able because of a relatively small localized fire."

The Safe Energy Coalition vehemently opposes the continued relaxing of NRC strict standards for fire protection knowing the realized hazards that fires pose at nuclear plants,especially with the Fermi 2 plant design without the alternate shutdown system in place.

In the M.D. Lynch summary document of July 11, 1984, Detroit Edison supplied the NRC with a brief fire protection history for Fermi 2. In this summary, Edison's knowledge of the Browns Ferry Fire of March 22, 1975 was well documented,by themselves>with review groups and task forces formed to deal with the issue of fire protection.

During this time Detroit Edison had Fermi 2 shut down from 1974-77 for financial reasons and to catch up on their engineering design back-log. Regulatory guides were issued in 197 6 and 1977, ANSI Standards were released in 1979, followed by NRC regulations, Appendix R in 1980. Edison has had ample time to implement the needed defense in depth fire protection that includes the most critical component, an alternate shutdown capability.

We request that full implementation, prior to fuel load and low power operation, of the shutdown system be required. Further in-vestigation, explanation, and justification for NRC approval of Edison's fire protection systems is in order. We regard this as a very serious matter and would like public hearings called under Section 2.202 (Show Cause).

5). GENEPJiL ELECTRIC MARE I BOILING WATER REACTOR AND CONTAINIiENT Serious problems have become apparent with this older, obsolete reactor design, particularly in regards to the constructability, i accessability and the ability of the containment to hold in a serious accident. Design modifications had to be made at Fermi 2 to the torus and the Drywell steel. The small containment, defects in the pressure-suppression system (torus) and the volumes of possible failures for this type of reactor cannot be, in our view, ignored in licensing this plant. It should not be put in the " generic, unresolved" category of the NRC to be solved sometime in the future.

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Letter to Harold Denton

/ In the book, the Colt of the Atom by Daniel Ford, as early as i i 1971, the Atomic Energy Commission (AEC) through its safety analysts proposed to senior AEC officials the banning of "the pressure-suppre,s-sion containment scheme" of which Fermi 2 is included. Technical analysis was never challenged and no objections were ' raised on scien-tific grounds. The reply by Joseph Hendrie, Senior AEC official, was the following: "the acceptance of pressure-suppression containment concepts by all elements of the nuclear field, including Regulatory and the 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 .

continued cperation of licensed plants, would make unlicensable the G.E. and Westinghouse ice-condenser plants now in review and would generally create more ttrmoil than I can stand thinking about."

This 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 either endanger public health and safety, increase worker exposure, or contaminate the surrounding environment. More thorough investi-gations and hearings are, we feel, warranted. Fuel loading should

, not be expedited because of lack of solutions.

Compromising the safety of people and the environment because Detroit Edison 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 Safe Energy Coalition petitions your office to inves-tigate the aforementioned serious unresolved safety issues with great diligence and thoroughness with public input into these matters.

In addition, we ask that the NRC do_ not issue a fuel load / low power license until these investigations have been completed and the problems successfully resolved.

Sincerely,

% b 4V Jennifer E. Puntenney cc: Attorney General Frank Kell'ey Governor James Blanchard Roger Fischer, Chief of Staff, Mich. Public Service Commission Senator Carl Levin Senator Don Riegle Al Ernst, Attorney for Wolverine Power Supply Cooperative Representative Sander Levin  ;

Representative John Dingell i Monroe County Board of Commissioners i

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