ML20149M125

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Submits Comments on Maine Yankee Isat Rept
ML20149M125
Person / Time
Site: Maine Yankee
Issue date: 11/20/1996
From: Blanch P
AFFILIATION NOT ASSIGNED
To: Zwolinski J
NRC
Shared Package
ML20149M049 List:
References
NUDOCS 9612120304
Download: ML20149M125 (3)
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I From: PAUL M. BLANCH <PMBLANCH91x.netcom.com>  !

To: JZ <JAZWOL9aol .com> I Date: 11/20/96 1:47pm-

Subject:

Maine Yankee Meeting John:

Just thought you may want my comments on the ISAT report even though - the NRC got a copy at the meeting last night. Dave Lochbaum and Dr. -

l Myers were also on the panel. I would like a formal response to the - issues addressed below.

l 11/17/96 COP 91ENTS ON MAINE YANKEE ISAT REPORT DATED OCTOBER 7,1996 In her letter dated October 7,1996 Dr. Jackson stated in her letter - 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. -

l The simple answer is that the plant is not in compliance with -B3its - design I and licensing bases.-B2 This conclusion is supported by the - content of the l Very ISAT report attached to this letter.

l l It appears the tone of the report is different from anything I have - ever j 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, i but likely very small, margin. These - limiting conditions would exist only j in the low probability event of - a large break LOCA.-82

What does this actually mean? To me it means that both the NRC and - the i licensee don-B9t know if the ECCS system will operate even at =

2440 Mwt. They state that these systems will not likely function at - i 2700 MW but they fail to address the issue if they will operate at =  ;

2440MW. This appears to be intentional deception of the general = public and the State of Maine.

Throughout the document they use the words: -B3These limiting - 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.

l On page =B3v=B2 the NRC states: =B2 Maine Yankee was in general = conformance with its licensing-basis although SIGNIFICANT ITEMS OF =

NON-CONFORMANCE WERE IDENTIFIED [ emphasis added].-B2 Translated this - means the licensee is not in compliance with the requirements.

i On page =B3vii-B2 the NRC states: -83there is a lack of a 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 them to operate?

l 9612120304 961210 l PDR. ORG NRRA PDR g

l i On page 19 of the report the NRC states: -B3The ISA team reviewed - this l information and concluded that these heat exchangers could be - considered l operable at the higher thermal values resulting from plant - operation at 2700 l Mwt.-B2 l

l The NRC has no authority to determine if a component is operable. -

The licensee has a formal process outlined in Generic Letter 91 and if the operability of a system, structure or component [SSC-B9s) = is in

! question, the licensee MUST make a formal determination of - operability. The NRC did this in the past and got burned and - admitted to me they do not have is authority. This issue was - discussed in an NRC Inspector General-B9s report transmitted to me on =

l July 11, 1994.

l At the top of page 20 the NRC again conducts operability = determinations in violation of their own statutory authority.

l On page 21 they state: =B3W0 96-01785-00, completed August 9, 1996, -

l (SCCW), did not demonstrate whether these valves would perform their - safety l related function.-82 Why is the plant operating if it can-B9t - be shown that l

safety systems are operable?

Page 23 -B3The ISA team did not consider the licensee's position - that the 345 kV system back-feed operation, completed within six - hours, was an l acceptable basis for compliance with 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 therefore not in - compliance with the regulations.

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 l were not qualified for their expected environment - following a design basis i event.-B2 With this one statement the NRC - admits the plant is in violation of the regulations.

j l Page 30: -B3a walkdown on July 24, 1996, of reactor ccntainmeit that - l 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 i in compliance with the design basis and not in compliana 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 l

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 law and the NRC is - helping them.

I could continue and cite many other examples but it is very 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. -

l Comparing the two reports, the information contained in the MY report - is

l every bit as condemning as the CY report. Some of the same = deficiencies, l

such as the NPSH for the containment recirculation = pumps, were identified at both plants. The difference is the -

-83 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 -

ISAT report, should conduct a complete design review before the plant - is l allowed to continue operation. It is clear from this report, the - plant in i i non-compliance with both the design and licensing bases. The - conclusion of l l =B3(C]onsidered adequate for operation-82 is totally = unsupported by any l l objective evidence and is contradicted by the - report itself. l l

Sincerely, i

Paul M. Blanch 135 Hyde Rd. West Hartford CT. 06117 860-236-0326 l

I i Paul M. Blanch

! Energy Consultant ,

135 Hyde Rd. 1 West Hartford CT 06117 l Voice 860-236-0326 Fax 860-232-9250 l

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