ML20203E829

Requests NRC Convene Public Hearing on Revocation of Operational License of Niagara Mohawk Nine Mile Point,Unit 1 Nuclear Power Generating Station Based on Listed New Info

ML20203E829
Person / Time
Site:	Nine Mile Point
Issue date:	12/14/1998
From:	Gunter P, Harris W, Judsen T AFFILIATION NOT ASSIGNED, NUCLEAR INFORMATION & RESOURCE SERVICE
To:	Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20203E731	List: ML20203E728 ML20203E829
References
2.206, NUDOCS 9902170319
Download: ML20203E829 (10)

Text

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( e, Deccaber 14,1998 Dr.Wt!!iam Travers

.; l Execu'tge Director of Operations

, {.;.. U4ited Sates Nuclear Regulatory Commission j

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• As ovidgd under 10 CFR 1206, Nuclear Information and Resource Service, Syracuse

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A uclear Effort, The Syracuse Peace Council, Green Party of Greater Syracuse,

' Pea Action of Central New York, Student Environmental Action Coalition, U knvir inental Advocates, Oswego Valley Peace and Justice Council, Safe Legacy, Chentago Nonh, and Citizens Awareness Network petition the U.S. Nuclear Regulatory l C9mmigion to convene a public hearing on the revocation of the operational license of '

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NkgartRohawk's Nine Mile Point Unit I nuclear power generating station based on the g j

, fo!!owing newinformation.

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. ,( .:;- 1) N ara Mohawk, operator of the Genen! Electric Mark I Boiling Water Reactor in

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.- ,. S a, New York is experiencing age-related degradation ofreactor coreinternals,

" ' most notably of the reactor's core shroud. Intergranular Stress Corrosion Cracking

- .' k (IGSCC)is occurring along both the hodrontal and vertical welds of this safety-

'.related component. Niagara Mohawk has based its conclusions for continued Soperation without inspection on a non-conservative analytical model for crack growth

. '. gate utilizing base materials, namely unfrradiated metal, not representative ofin situ Mtal found in reactor core. - - -

'2) Additionally, Niagara Mohawk's reliance on a single inspection forIGSCC along

.e  ; vergical welds on the Core Shroud to project future crack growth rate is a non.

, .f.'. coruiervative evaluation. Niagara Mohawk took this single data point and back

7. . . .

• calerMated to a presumed onset of cracking early in the reactor's operation. This utility

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., ' practice is non physical and based on pure speculation about the initial condition of -

the cracks. If the onset of venical cracking is in fact more recent, then the crack 4.' . growth rate is sigolficantly greater than asrumed in the NRC staff s Safety

.1* .. Evaluation.

3) Niagara Mohawk has indicated that the cracking of the shroud has moved outside of the Heat Affected Zones (HAZ) along vertical welds of the core shroud. The Petitioners contend this constitutes an unreviewed safety issue. Because existing L ~ y analyses are based on the explicit assumption that cracking initiates in the HAZ

.. .' . .- 1o thermal etresses resulting from the welding process, cracking extending outside

,. -1 o e HAZ represents a new and unasalyzed challenge to the structural integrity of j

( theyre shroud that is not bound by the current aafety evaluations.

.: /

• 4(By dyerring its mid-eyele inspection Niagara Mohawk has contradicted industry  ;

, . . dvisdries for more detailed reevaluations of Core Shroud cracking as an indicator for '

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• Veracking in other safety-related reactor vessel interral components that could only be incomplished through additional inspections.

' . 5) .The Core Shroud cracking presents an unquallfled risk to public health and safety

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.since the NRC has yet to calculate either an associated risk factor based upon the

.F . y Sevel ofcore shroud cracking or determined to what extent of Core Shroud cracking .

-{,:l,, ' , ,provides an unacceptable safety risk. '

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~ d.Y.' , l ins Core Shroud is a large stainless-steel cylinder that surrounds the reactor core and l .

senes to control the uniform flow of water around the reactor core. The shroud provides for.the structural alignment of the reactor core geometry and the alignment for the

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co(plete insertion of tbc control rods required to shut down the reactor. The Cors

' Stiftud is thus i safety related component fabricated of Type 304 stainless steel plates.

,These plates art welded end to end to fonn rings. The rings are then welded one atop the v .4 ether.to form a! barrel shaped component within which the reactor core is housed. Earlier

.i inspections of the core shroud have revealed cracking along both the horizontal (i.e. ring

' :to dng) and vertical welds (i.e. piste to plate) of the component. Cracking of the Core Y:l .

Shrend is attributed to Intergranular Stress Corrosion Cracking (IGSCC) and is f."-

• 4ependent on opemting time, coolant chemistry, carbon content, neutron radiation

'5 exposure, residual stress from welding and fabrication and operating stresses as identified

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.,in NUREG-1544 " Status Report: Intergranular Stress Corrosion Cracking ofBWR Core

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. shrot41s and Other Internal Components," dated March,1996. The residual stress from welding cohfined to an area immediately bordering the weld has b,een termed the Heat Affected Zone (HAZ). The Core shroud additionally serves a vital safety function in the event of an accidem. The intact Core Shroud, along with the Emergency Core Cooling

" system, combhie to prevent significant core damage dudng a loss orcoolant accident by

~ ,ininimizing the period of time that the reactor core is uncovered. If the Core Shroud is not - - -

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.' intact; the safety' analyses for these postulated accidents are invalidated. Iniddition, ri, (shifting of the core shroud rings or plates, because of their proxirrity to the reactor core, 4

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could. prevent the insertion of one or more control rods. The resulting reactivity

,k,%J glitcursion consequences could be severe. In 1995. Niagara Mohawk installed tie rods to -

laterally hold the stacked Core Shroud rings together after substantial cracking in their

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,, 6erimontal welds was discovered.

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. ] M '. . After discovery ofcracking along the venical orlongitudinal welds of the shroud and

' prior to the 1997 restart, Niagara Mohawk sought to allay public and regulatory concern over the questionable structural integrity of the safety-related component by committing to a rdd cycle inspection after 10,600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br /> ofoperation. Following restan ofUnit 1,in ' ~-

a letter dated, February 27,1998, Niagara Mohawk requested relief from its mid-cycle

.ihspection commitment and for the NRC to defer the inspection commitment until

! .]. . bompletion of the unit's full fuel cycle at 14,500 hottrs ofoperation. I i* b ,

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On NeNember 2,1998, the NRC staffinformed Niagara Mohawk that relief from their

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mid cycle inspection commitment was acceptable. NRC concluded that thereis.

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reasonable assurance the reactor can be safely operated during the extension because "the

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structural integrity of the vertical welds will be maintained with safety margin (s) specified lg the ASME (American Society of Mechanical Engineers) Code." The agenr

.;appip/s staff determined the ernek growth rate estimued by Niegera Mohawk w

.. well%priate, based on a review of meta!1urgical testing of two vertical weld samples, a 2 . .' is on measurements and calculations performed by both the company and the N

.,y ' . , . TH.tVTILITY METHOD FOR PREDICTING THE CRACK GROWTH RATE

%F THE CORE SHROUD IS NON-CONSERVATIVE t.' 4 .

4! , ,. ongoing cracking to this safety-related component and oth

. ! l'~ :: operational conditions. " Technical Evaluation Report On EPRITR-105873 BWR Vessels and Internals Project, Evaluation of Crack Growth In BWR Stainless Steel RPV

'Interhal" dated .)anuary 27,1995 and submitted by Argonne National Laboratory states in

.its Conclusion and Recommendations "The BWRVIP crack growth model appears to provide e good cons!ation with a large database of experimental measurements of CGRs

{crackgrowth rates] fbr un/nadia/cdmerterlats (emphasis added) under a range ofwater

- 2' chemistry cond]tions that bound those expectedin-reactor."' The Argonne National

Laboratoty (ANL) goes on to state "One limitation of the database is that it constats  ;

. ,r -: solely ofunirradiated, ba.se materials. The heat affected zones ofwe!dments could have

-somewhat higher impurity levels than these base materials and neutron Duence will

.*~ . produce a number of changes in the material. There are very few lifcmy) validcrack rrowth meantrements for tiradiatedmaterials. (emphuis added). Discussion in EPRI

- TR-105873 on the applicability of the model to irradiated materials is limited. The benchmark comparison with ultrasonic (UT) measurements on actual core shroud cracks

- presentpi in the report are not very conclusive because the uncertainties in the UT measurciments and the residuel stresses could mask easily variations in the CRG Wation..,2 -

4

'.In it [ Safety Evaluation Report dated June 8,1998, the NRC reviewed the EPPI Topical

.c . lepe e TR.105873 "BWR Vessel and Internals Project, Evaluation of Crack Growth in d t ?B W11 Stainless SteelInternals (BWRVIP 14)." The NRC reiterated ANL findings that

.. V- . , the B1

/RVIP data base correlation was limited due to the fact that it consists solely of

!" ' 6nitrai Liated base materials. "Weldments and their associated fhsion heat affected z

. ' douldaave somewhat higher impuritylevels due to flux / copper contamin

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ty diffusion than the wrought base metals that are solely considered in the data

.j i base q

' krelation. It is well known that changes in irradiated materials properties ans a strongfunction ofcertain impurities. In addition, there are few, if any, valid crack ~

- p,rowth measurements for Irradisted metals."3

,D'Ted

- heal Evakr.dien Repen rm EPRI TR-Ioss73, BWR Vessels and Intemals ProJoct, Evaluation d Cra:k (keath in BWR Stainleu 3tect RPV Internal." January 27,1998 Argonne National Laboratory u,7 .

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. Ibid., p l. '

.'- *- 8 "5afe:> Emir-ation ofEPRI Topica! Rapon TR 105873 'BWR Vessel and Intemals Project Evaluatio

., f a V8.. . Crack Growth In BWR Stainters SteelIntemals, (BWRVIP 14),'" hat E 1998, U.S. Nucitar Reguimory

'Comtristien, DivWen cfEnanecting, OUlce of Nec! car Rexter Regulation, p. 3.

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The Petitioners are additionally concerned'that the utility's single inspection of the vertical cmcking is a single data point from which the crack growth rate is being determined. The Pedtloners comend that the reliance on this one inspection data point is a nopp' conservative elemem included into the crack growth rate analysis and safety

" .isval$ tion. The Petitioners contend this to be ofgreat concern forthe simple reason that

.Ywitho6t observed data on the crack growth rate neither the NRC nor Niagara Mohawk

$* . Jeandlaim an understanding of the degradation mechanism. No field data is in fhet -

' avalfable for vertical welds. A single measurement for crack growth was made on the H8 weld. The depth of the crack measured during the 14* fueling outage was less than that

, v. .4. measured during the 13* fbeling outage. Niagara Mohawk drew no concl

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instead discarded this data as being irrelevant. NRC simply adop

.etility's erroneous thinking. The Pethioners contend that in fact the margins of error are

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large enough that measurements cited without their correspohding error may appear not

' to Srow or even " heal". In measurements of crack size and crack growth the errors must

.be cited in order to understand the allowed range orpossible growth rates. If we assume

.the errors in crack. size as cited in NRC Safety Evaluation (Docket No. $0 220) then even a measurement ofno crack growth over the period of a single rdador cyc!c yields an error

. ., in crack growth rate which is more that three times the size of the NRC's stated

- d conservative values of 5 x lo inches / hour. Therefore unless the error is cited, any Si -

valna presented for the crack growth rate is irrelevant.

l

. , . ' , ' ' Ther re, the Petitioners maintain that modeling used by the utility to project the crack Tro

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at Nine Mlle Polnt Unit 1 is non-conservative in its assessmem of the cmek potantial for degradation of the core shroud and other remetor intamal

. i... i , componenti. Before the utility can accurately state a crack growth rate, they must first l .'.

~, measure a crack growth rate with sufficient accuracy . Before ut!!! zing any model to

.projapt the ersek growth, the utility should first demonstrate that such a model can e- -

accunsrely describe an established dataset ofcrack size over time. Projecting crack 1 _ ._

• growth froma single measurement of the crack size is both nonconservative, poor science,___ _.

and economically self-serving.

l p. The Petitioners observe that other fbreign utilities in assessing the cracking of similar 7}

• model and vintage boiling water reactor core shrouds have opted to either permanently

., close their 10 SCC damaged reactors or completely replace the shroud and its related

, ;.;i components. -

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• "For examp!c, Tokyo Electric Power Company (TEPCo) took its Fukushima l-2 offline l

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- ,. on August 12,1995 to begin a maintenance outage that included the total replacement of

' ' the rare ahroud and associated components of the 784 MWe boiling water reactor. In - 1

. July,1998, TEPCo had completed the core shroud replacement ofits Fukushimal-3.

The German Repub!!c's General Electric boiling water reactor at Wuergassen was pensamently closed in 1995 after Gmnan nuclear regulators refused the implementation '

,of tlie tie rod fix on the reactor's cracked core shroud.

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CRACKING OUT51DE THE HEAT AFFECTED ZONE CONSTITUTES AN

..UNEEVIEWED I!AETYISSUE

.. Cra of the vertical welds at Nine MDe Point Unit 1 was first addressed publicly in a

.meeti dated April 14,1997 by Niagara Mohawk and NRC officials in Oswego County,

. New rk. Two presenters for the Niagara Mohawk stated that cracking was discovered o(vertihl welds in two locations on the Core Shroud (V-9 and V-10). Dr. Richard St$h with ALTRAN Corporation stated that be had carefully reviewed enhanced visual

e , . Ique videos of the V-9 and V 10 welds. In his presentation viewgraphs entitled T ' "C

'ag Patterns Provide Evidence Of Reasons For Cracking Otservations @ V-9 and

~? . . " . '

V-1 ' one of the bullets which Dr. Smith references reads

• CRACKING REMAIN 5 Y. < #OMAL i PREDOMINATELY IN THE WELD HAZ."

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Dr mith acknowledged, .

! "The cracking is, tends to have features that are running perpendicularly to the

. wel . irection and also fbatures where that turns and tends to run down the long part ofit

}the d). The crack, in essence, meanders in a path that includes born axial features and vertical features and all in between, but generally, the cracking stays within the heat

., afected zone, predominately." '

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Dr. WIIchael P. Manahan, MPM Technologies, Inc, similarly acknowledged in his l ). . . e pr tation " Analysis of Shroud Weld V-9 and V-10 Cracking" that the cracks along the

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,, welds ars "prsdominately" within the vertical weld heat affected zone. %e

! . . . ~j , . Petitioners take note of the utility's use of "credominatelv" as the operative word. Both Di. $thith and Dr. Manahan use this word to carefully describe the observed cracking l .~ ,

condition. They do not say that cracking is " exclusively" within the heat affected zone. __ - _

j .

ncir analysis acknowledges that cracking is occurring outside the traditionally viewed i H Affected Zone. The IGSCC along the vertical welds as described by Dr. Manahan acks that are running bed in the axial direction and are connected by horizontal 1

segments. Dr. Manahan goes on to explain that "whenevar cracking is discovered it i

'is vg, y important to gain an in depth understanding ofthe mechanism of the cracking to l ,; .be sure that we can snanage itys a .:: .

l. ".- The Petitioners contend that any effort by the utility or the regulator to ininimize the 1

. /.' " :signVicance ef cracking observed outside of the traditionally viewed Heat Affected j y #i.

. Mones of these vertical welds stifles an in depth understanding of the 105CC mechanism.

. 17. . .

The Petitioners contend this condition to be a previously unrecognized degradation that ~ -

. . .- 'NRC and industry purport to seek.

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.h Video Tape of the April 14,1997 NRC Public Moc.ing With Niagara Mohaut on the Nine Mile Potat 1Init hCors Shnnid. - '

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Purthermore, Mr. Martin McCormlek, the presiding official for Niagara Mohawk at the

. . . :: public meeting, when asked whether the obsetved emeking on the vertical welds is nehistvely within the Heat Affb:ted Zone responded: "

,'k What we said was that all the cracking that we have seen and measured here is in

" the Heat Affected Zone. There are some indications which have, are weld attachment

. points that are not in any way associated with the vertical crack welding. So l don't want to characterire it as saying there isn't same areas away,just adjacent to the Heat

. Alrected Zone, but we have a reason ,for that being there. We did not go around and

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. analize and look at that whole plate. That's a huge plate. We did look at the Hes,t -

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Affected Zone as part of the inspection and that's where we found the indications. 'Ibere

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.am in indications that would indicate its beyond that that are due to Intergranular Stress 4errosion Cracking"'

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7 t Thdetitioners contend that the Niagara Mohawk has observed " indications' or c outside of the areas on the' Core Shroud where IGSCC was anticipated to be found.

- These "indleations" in the base material of the plates however were not thoroughly

' ' indstigated, analyzed nor measured by the utility. The Petitioners contend that the omission ofinspections and analysis ofthese non-traditional " indications" constitutes an

}' . .

.unreviewed safety issue.

.J BY DEFERRING ITS MID-CYCLET INSPEC. ION NIAGARA MOHAWK H

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CONTRADICTED DTDUSTRY ADVISORIES FOR MORE DETATIIT)

Mu;- , REEVALUATIONS OF CORE SHROUD CRACKING AS ANINDICATORFOR

.; CRACKING 1N OTHER REACTOR VESSEL INTERNALS.

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" ' - , ' .As representative ofindustry experience to date, Niagara Mohiwk's Nine Mile Point Unit 1 inspections indicate that the unit has observed the most advanced degree of - - - -

- Intergrshular Stress Corrosion Cracking ofits most robust reactor internal compo  ;

Core Shroud. Cracking along vertical welds has been estimated to run as deep as 80%

.through wall of the one and one-halfinch thick wall. This degree of cracking on both th vertical wcids and along the horizontal welds of the Core Shroud, hu not been observed

, in any4ether U.S. boiling water reactor to date.

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The Pshtioners are aware of Bolling Water Owners Oroup (B WROG) advisories to

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.4: member re utilities as presented in ear 11er meetings regarding IGSCC damage to saf

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', ' i . ~ . ' . p components. In a meeting on June 28,1994, the BWROG in an industry .

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,, "5 ion to NRC enthled " Core shroud and vesselInternals Concerns" states that ud cracking is a sipal to reevaluate, in more detail, the potential for cracking in ~

. . . , , ,oth esselinternals."  ;

s .

The Petitioners contend that Nine Mile Point Unit 1 Core Shroud exhibits the most exte$sive cracking known within US Industry experience and thus warranted additional -

. inspisctions and analysis of those inspections not only for implications regarding C9te

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• g ,' ' viewgraphs, NRC3WROC Meeting Cor Shroud And VesselIntemals Con: erns, June 24.1PM.

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.q - Shroud lategtley but additions.! safety-related reactorintemal components. An empirical

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P model onIGSCC should be developed which is both accurate and predictive. Moreover,

' a etimplete safety analysis should be developed to assess a level ofrisk as a function of thvextent of Core Shroud crseking.

The Petitioners were exercising good faith that Niagara Mohawk in its pledge to ecmduct

, , a mid-cycle inspection made a conimitment to immediately participate in the

,, . development of such an empirical model on IGSCC. The Petitioners were exercising S.-

$: . gopd fahh that Niagara Mohawk would honor its commitment to a mid-cycle inspection ofthe Core Shroud as pledged at the April 14,1997 public meeting. The Petitioners now

}. .. .believe that the utillry was exercising a "balt and switch" tactic to merely advance the

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, resta'rt of the ' age degraded unit witbout regard for its advanced degree of component

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degradation of the Core Shroud and potentially other reactor vessel internals.

NRC HAS NOT CALCULATED AND PUBLISHED THE RISK FACTORS ASSOCIATED WITH CORE SHROUD CRACKING NOR DETERMINED TO WHAT EXTENT OF CORE SHROUD CRACKING CONS 111u u,S AN UNACCEPTABLE SAFETY RISK AND THUS CONTINUED OPERATION OF NINE MILE POINT UNIT 1 CONSTITUTES AN UNQUALIFIED SAFETY RISK

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' . . The.NRC has not published supplements to Generic Letter 94-03 "Intergranular Strest

. G ~. Corrosion Cracking of Core Shrouds in Boiling Water Reactors" (July 25,1994) not s ,

4 W15EG-1544 " Status Report: Intergranular Stress Corrosion Cracking ofBWR Core

,-P -Shrouds and Other Internal Components" (March,1996) determining and identlfying to g, . .

whatlextent core shroud cracking constitutes so unacceptable safety risk.

.- The Petitioners contend that in the absence of such a finding, the continued operation of - - --

. Nine Mile Point Unit 1 with extensive cracking along vertical and horizontal welds copstitutes an unqualified and unacceptable safety risk.

. . v..

At the public meeting on 24 September 1998 in Oswego, Simon Morrin of Syracuse asked the NRC representatives the following question:"What extent ofcore shroud cracking would represent a safety risk great enough to require the shut down ofNine c

.~. Mile One? Or more to the point, have you performed any calculations in order to assign

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associatedrefused risk factor for a yiven level of core shroud cracking?" The NRC to anst er the question. ne petitioners contend that the public

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' deserves an answer to this qwestion. In light of the extensive core shroud cracking and the ieeergely delayed inspection, this question is ofparamount importance.

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CONCLUSION .

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• Therefgs, for all of the above stated contentions, the Petitioners call upon the NRC to revoke h.'lagara Mohawk's Ilcense to operate Nine Mile Point Unit 1.

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g ' PaulGunter, Director

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Reictor Watchdog Project .

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. Nuclear Information and Resource Service

'!. ', '142416" Street NW Suite 404

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_ 234 Sal! Spring Road Syracuse, NY 13224

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. Syracute Peace Council l

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Andrew R.oth-Wells The Green Party of Greater Syracuse

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. Diane Swords Peach Action ofCentra1New York 658 West Onondaga Street 1 Syracuse, New York 13204 .

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