ML20136C196
| 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) | |
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
Subject:
Commission Meeting on Maine Yankee l
l
Dear Dr. Bates:
It is my understanding the Commission will be conducting a
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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
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9703110309 970306 l
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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 =
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-Regulations. The Staff and the Commission then concluded =
B3 performance at Maine Yankee was considered adequate for
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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 have.= ever.seen come out of the NRC.
They refuse to even 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
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 l
and = the licensee don =B9t know if the ECCS system will operate even at =
2440 Mwt.
They state that these systems will not likely function
~
i a
e at =
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 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.
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On page 21 they state: =B3WO 96-01785-00, completed August 9,
- 1996,
=
j-(SCCW), did not demonstrate whether these valves would perform their = safety related function.=B2 Why is the plant operating i
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
- -. - - - < - - - - - - =,
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within six = hours, was an acceptable basis for compliance with l
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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