ML20136C196

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Requests 15 Minutes to Present Stated Issues to NRC During 970204 Meeting on Myaps
ML20136C196
Person / Time
Site: Maine Yankee
Issue date: 01/09/1997
From: Blanch P
AFFILIATION NOT ASSIGNED
To: Zwolinski J
NRC (Affiliation Not Assigned)
Shared Package
ML20136C110 List:
References
NUDOCS 9703110309
Download: ML20136C196 (5)
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Text

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I From PAUL BLANCH <PMBLANCH91x.netcom.com>

To: WND2.WNP3(jaz)

Date: 1/9/97 12:00pm i subject MY Commission meeting ]

1 Friends: ~

. The Commission contacted me yesterday and gave me about one hour  ;

to = submit this request. Looks good for the meeting.

l 1/8/97 L

Dr. Andrew Bates' USNRC Office of the Secretary Washington DC'20555-0001 FAK; 301 415-1672 l

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Subject:

Commission Meeting on Maine Yankee l

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Dear Dr. Bates:

It is my understanding the Commission will be conducting a

~

l l meeting on =

Maine Yankee on February 4, 1997. I have been actively supporting j = many of the concerned residents and their_ questions regarding-the = safety of the plant.

! I have been communicating with the NRC Staff related to some of  ;

these = safety issues. These issues are discussed in my attached  !

position = paper regarding the NRC=B9s ISAT report of October 7, 1996. These = issues have been forwarded to the Staff and I have yet to receive any = meaningful response.

My additional cor.cern is the NRC position that:  ;

" .... Commission adjudicatory decisions are clear that compliance

with the Commission regulations is essential to a determination of = adequate protection of the public health and safety under the Atomic

Energy Act."

The memorandum refers to Section 185 of the Atomic Energy that =

provides that Operating Licenses are issued "upon finding that the = facility authorized has been constructed and will operate in = conformity with ... the rules and regulations of the Commission." =

(Emphasis added.)

! The ISAT report is clear in that the plant has not been verified

( to = be in compliance =B3 with Commission regulations =B2

! therefore the = minimum safety requirements have not been i

satisfied. Until a complete = verification of compli.ance is i

4.

! 9703110309 970306 l

PDR ORG NRRA PDR vs I

_. . . _ _ _ ~_ _._ _._ _ . _ . _ _ . _ . _ _ . _ _ _ -

conducted, nuclear safety can not be = assured.

i The ISAT report states: =B3 Maine Yankee was in general I

conformance = with its licensing-basis although significant items '

of = non-conformance were identified. =B2 This appears to be =

acknowledgment that.the plant is not in compliance with ,

Commission = '

l -Regulations. The Staff and the Commission then concluded =

l

B3 performance at Maine Yankee was considered adequate for

l operation.=B2 It mystifies me as to how this determination was l made = with the_ apparent admission of regulatory non-conformance.

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l Given these questions and other issues related to the safe 1 l operation = of Maine Yankee, I respectively request 15 minutes to L

' present these = issues.to the Commission during the' meeting of 1 February 4,1997. I = will be speaking on my behalf and on behalf '

of many of the concerned = local residents in the vicinity of the Maine Yankee plant, j

I look forward to your favorable response. ,

Sincerely,

. Paul M. Blanch- l 135 Hyde Rd. West Hartford CT. 06117 860-236-0326 COMMENTS ON MAINE YANKEE ISAT REPORT DATED OCTOBER 7, 1996 In her letter dated October 7, 1996 Dr. Jackson stated to Mr.

Charles =

D. Frizzle =B3The purpose of the ISA was to determine whether Maine =

Yankee was in conformity with its design and licensing bases;=B2 Dr. =

Jackson completely avoided addressing this objective. The simple

= answer is that the plant is not in compliance with =B3its design and = licensing bases.=B2 This conclusion is supported by the content of = the very ISAT report attached to this letter.

It appears the tone of the report is different from anything I l have.= ever.seen come out of the NRC. They refuse to even l attempt to = directly address the issue of compliance with the  !

regulations and use = words-such-as: =B3These tests may have .

shown some degree of = cavitation and an_ uncertain, but likely l l very small, margin. These = limiting conditions would exist only l in the low probability. event of = a large break LOCA.=B2 What does this actually mean? To me it means that both the NRC and = the licensee don =B9t know if the ECCS system will operate l

even at =

2440 Mwt. They state that these systems will not likely function

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l i

a e

at =

l l 2700 MW~but they fail to address the issue if they will operate at =

l 2440MW. ~ This appears to be int'entional deception of the' general j = public and.the State of Maine.

. Throughout the' document they use the words: =B3These limiting =  :

j conditions would exist only in~the low probability event of a i large'= break LOCA.=B2 A large break LOCA is'part of the design

' basis and = the ECCS systems must function for this design basis event. This is = like saying I don =B9t need seat belts, air bags

- of brakes because the = probability of needing them is very low.

i- On page =B3v=B2 the NRC states: =B2 Maine Yankee was in general =

, conformance with its licensing-basis although SIGNIFICANT ITEMS j OF =

, NON-CONFORMANCE WERE IDENTIFIED [ emphasis added).=B2 Translated this = means the licensee is not in compliance w!th the j requirements.

On page =B3vii=B2 the NRC states: =B3there is a lack of a e questioning = culture which has resulted in the failure to identify or promptly = correct significant problems in areas perceived by management to be = of low safety significance.=B2

- What are these significant problems = and why does_the NRC allow I them to operate?

i j On page 19 of the report the NRC states: =B3The ISA team 4- reviewed = this information and concluded that these heat i exchangers could be = considered operable at the higher thermal 1 J values resulting from plant = operation at 2700 Mwt.=B2 1 The NRC has no authority to determine if a component is operable.

l The licensee has a formal process outlined in Generic Letter 91-18 = and if the operability of a system, structure or i i component (SSC=B9s) = is in question, the licensee MUST make a '

formal determination of = operability. The NRC did this in the j past and got burned and = admitted to me they do not have this i authority. This issue was = discussed in an NRC Inspector

!. General =B9s report transmitted to me on =

j July 11, 1994.

At the top of page 20 the NRC again conducts operability =

determinations in violation of their own statutory authority.

4 i On page 21 they state: =B3WO 96-01785-00, completed August 9, ,

. 1996, = '

j- (SCCW), did not demonstrate whether these valves would perform i their = safety related function.=B2 Why is the plant operating

1. if it can=B9t = be shown that safety systems are operable?

Page 23 =B3The ISA team did not consider the licensee's j position = that the 345 kV system back-feed operation, completed 1

J r ,-T - e -- . . -- . . - , , , - - _.

- - - - . - - - < - - - - - - = ,

t l

l l within six = hours, was an acceptable basis for compliance with l the FSAR and Maine =

l ' Yankee Design Criterion 39.=B2 This is an open acknowledgment that = the plant is not in compliance with the design basis l therefore not in = compliance with the regulations.

l Page 29 =B3The ISA team found that the licensee was not meeting 10 =

CFR 50.49 requirements in that there were certain electrical =

components that were not qualified for their expected environment

= following a design basis event.=B2 With this one statement the l NRC = admits the plant is in violation of the; regulations.

Page 30: =B3a walkdown on July 24, 1996, of reactor containment that = revealed 30 components outside of Maine Yankee's design basis.=B2

'These are only examples but the very clear message is that the-plant = is not in compliance with the design basis and not in compliance with = the regulations and the NRC lets them continue to operate.

In my opinion,_given the fact'that a token audit uncovered many areas = of non-compliance, Maine Yankee should not be operating this plant = until they complete a review as required by last week =B9s 50.54 f = letter from the NRC. They are breaking the l law and the NRC is = helping them.

.I could continue and' cite many other examples but it is very l clear to = me that the NRC did not want to ask the difficult questions because = the knew the correct answer would result in a plant shutdown for not = being in compliance with the regulations.

I have recently reviewed the NRC. report on Connecticut Yankee. =

Comparing the two reports, the information contained in the MY report = is every bit-as condemning as the'CY report. Some'of the same = deficiencies, such as the NPSH for the containment recirculation = pumps, were identified at both plants. The difference is the =

=B3 spin =B2 put on the MY report.

From my perspective, the NRC is again covering their own incompetence = and embarrassment created by UCS=B9s disclosure of falsified LOCA = codes and the NRC=B9s Inspector General =B9s Event Inquiry dated May =

8,-1996. Maine Yankee, with all the deficiencies identified in the'=

l ISAT' report, should conduct a complete design review before the plant = is allowed to continue operation. It is clear from this-report, the = plant in non-compliance with both the design and licensing bases. The = conclusion of =B3(C]onsidered adequate for operation =B2 is totally = unsupported by any objective evidence and is contradicted by the = report itself.

l l

I ' Sincerely, Paul M. Blanch-135 Hyde Rd. West Hartford CT. 06117 860-236-0326 Paul M. Blanch Energy Consultant >

l 135 Hyde Rd.

West Hartford CT 06117 Tel: 860-236-0326 .,

Fax:-860-232-9350 /

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