ML20207F181

Petitions NRC to Suspend Operating License of NMP for NMPNS Unit 1 Until Such Time as NMPC Releases Most Recent Insp Data on Plant Core Shroud & Adequate Public Review of Plant Safety Accomplished Because of Listed Concerns

ML20207F181
Person / Time
Site:	Nine Mile Point
Issue date:	05/24/1999
From:	Judson T, Katz D, Penn S AFFILIATION NOT ASSIGNED, CITIZENS AWARENESS NETWORK
To:	Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
2.206, NUDOCS 9906080086
Download: ML20207F181 (3)

Text

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1 l May 24,1999. i Drl William Trdvers L  !

. Executive Dhector of Operations i United States Nuclear Regulatory Commission

Washington,DC 20555.

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' Dear Mr. *Invers; As provided under 10 CFR 2.206, Citir. ens Awareness Network, Coalition on West Valley Nuclear Waste, Environmen-tal Advocates Greens of Orester Syracuse, Nuclear Information and Resource Service, Oswego Valley Peace and .l Justice, Siesta Club (froquois Group), 'tudent Environmental Action Coalition (SU/ SUN %E5P), Syracuse Anti- ,

. Nuclear EITort, Symcuse Peace Council, and Dd Steven Penn, Ph.D., pedtion the U.S. Nuclear Regulatory Commis.

! sion to suspend the operadng license of Niagara Mohawk Power Corporatiun (NMPC) for the Nine Mile Point Unit l One (NMP1) nuclear power generating station. The petition calls for suspension of the license until such time as '

' NMPC teleases the most recent inspectiota data on the plant's core shroud and an adequate public review of the plant's safety is accomphshed because of the following new and unreviewed information and safety concerns:

1) The public canact rely upon NMPC to accurately perfbra the data analysis necessary to calculate the extent and rate of cracking in the cure shuvud. As demonstrated in two leuers to the NRC by Dr. Steven Penn (December ,

,14,1998 and March 17,1999) the research studies commissioned by Niagara Mohawk to estimate crack growth tales ,

(COR) in the core shroud were replete with procedural errors including selective omissiott of data and calibration

, inconsistencies in electropotentiokinetic reactivity (EPR) measurements used in calculations of the CGR. In many  ;

- instances, the studies neglected proper error analysis, m@senting the accuracy with which the reported CGR was  :

'known and against which new data must be checked. While we acknowledge that the issue of estimating the CGR is  !

, - less relevant given the recent' direct measurements of the CGR, the public still has no assurance that the calculations

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and research being performed by NMPC and its research contractors is being conducted in an accurate arid unbiased j

manner 1.ingering public doubt over the research practices of NMPC necessitates a public review of the inspection .

data to assess the true safety status of the core shroud. Further, the NRC has not' evaluated Dr. Penn's letters, and has .

stated it does not plan to review Dr. Penn's second letter until Fall 1999; NRC's refusal to assess these analyses poses  ;

an 12.,&:.4 safety issue. The most recent inspection data must be properly analyzed and publicly reviewedprior to any potential restart in order to assess the current state of the core shroud material and the sgety concer?s of contin-urd operation ofNMPl.

' 2) NMPC and NRC bave reported in the May 1999 laspection that cap screws instaBed as a Inodification to the core shroud ir 1997 suffered intergranular stress corrosion cracklag (AGSCCh resulting in the fracture of at j

' least one of t", e cap screws. He cap screws were part of bow spring mechanisms designed to prevent tie rods from  ;

. rubbing against the cote shroud. With the fallute of one of the tie rods between 1995 and 1997 due to improper i

insta11abiand the inferior material chosen for the cap screws, NMPC's record on installing repairs to the core shroud, ,

and NRC's record on approving and overseeing them, indicate: (1) that NMPC's designs warrant in-depth review by j c the public: and (2) that the implementation of repairs requires closer scrutiny to assure safe operation of NMP1. The i fact that the material chosen by NMPC and approved by NRC for the cap screws was so susceptible to IGSCC, the same mechanism by which the core shroud is believed to be deterioriating, indicates a shocking lack of forethought on l

the part of the licansee and a dismaying inadequacy of oversight by the regulator. This new data concerning the cap

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screws, widch has come to light since NRC approved the repair designfor V9 and V-10, raises sfety-signhicant  ;

quesdons about the credibility ofNRC's approval of the vertical weld repair design, and necessitates afurtherpublic review of the design's adequacy in order to determine the level of sqfety before restart ofNMP1.

3) Data from the May 7999 laspection of the NMP1 core shroud is I.cw and NRC staff review will not occur I prior to restart of the reactor on the current refueling outage schedule. his data constitutes new information on a  !

significant safety issue, and permitting restart of the reactor before the data is reviewed and a safety evaluation issued ,

I L eanstitutes an unteviewed safety issue. This inspection was initially scheduled for a mid-cycle outage afler 10,600 i 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of operadng cycle 13 (approximately November 1998). He mid-cycle outage was required by NRC prior to '

restart in 1997 because of the unprecedeated extent of deterioration of the core shroud.- Analysis of the inspection  ;

data 3 and a safety evaluation were necessary to determine (1) the extent of crackmg,(2) to assess the safety consequences  ; oI continued opersion of NMP1 with a severely cracked core shroud, and (3) to begin collecting emptrical data on IGSCC i and core shroud deterioration as part of an industry directive to monitor the age-related degradation of boiling water 3

j reactor internals.1 M0 990524- R However,NRC postponed intreim at NMPC's requ L'r PT2 i

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• 11 cracks would not apptoach the next safety-significant threshold until the end of the operating cycle. The NRC staff's I

letter tu NMPC approvi-g postponement of the mid-cycle inspection states: "This approval of NMPC's request . l does not affect the NRC staff's earlier letter and SE dated May 8,1997." The approval of postponement only deferred  !

the necessary review of the status and level of safety of the core sl roud. Therefore, a review of the most recent l

inspection data to assess the current extent of cracking in the core shroud and a safety evaluation based on that  ;

assessment are necessary before the reactor is allowed to restart, as would have been the case during the tntd-cycle ,

i inspection. $ubsequent NRC approval of an unprecedented and unproven repair designfor vertical welds tssued prior to the inspection and review of the May 1999 data, does not preempt the previously determined need to assess the ccrual extent of cracking in the vertical welds and the structuralintegrtry of the core shroud.

4) NMPC has informed NRC that a public review of the core shroud inspection data during this refueling ,

outage would place an " undue regulatory burden *' on NMPC management and posalbly compromise safety at NMP1. NMPC management acknowledged that they have insufficient resources to respond to the regulatory process l and the pubhc on issues relevant to safe 0peration of NMPl. This fact in itself constitutes new information and an  !

unreviewed safety issue relating to the core shroud inspection and implementation of the proposed core shmud repair.

NMPC's record during the last 2 operating cycles and during this refueling outage do not warrant that level of trust.

Moreover, there is precedent for increased concern about NMPC's ability to self. assess its safety performance at NMPl. In a civil penaky issued agilnst NMPC on November 6,1997. NRC cited "significant regulatory concern" with Nh@C for violations at NMPl: the panel investigating the violations discovered, among other things, *inad- ,

equate management oversight" and " fall [ure] to monitor the effcetiveness of maintenance activitics for safety-signin- )

cant plant equipment in order to minimize the likelihood of failure and of events caused by the lack of effective i maintenance." These are issues directly pertinent to the failure of the tie rod installation (1995), faulty stesign of the bow spring modification (1997), flawed smdies on core shroud boat samples (1998), postponement of mid-cylcio inspection (1998), and miscalibration of instruments for vertical weld inspection (May 1999). Further; the core Shroud  ;

r1 NMP1 is known to be "the worst case of cracking in the nuclear industry" (Union of Concerned Scientists). 'Ihe  ;

question of" undue regulatory burden"is not relevant with a precedent-setting case of reactor degradation, but rather e requires the strictest regulatory oversight and a full public review. Finally, if the licensee cannot guarantee that l compliance with regulatory requirements can be met while protecting the public heahh and safety, this constitutes a  :

viointion of NMPC's operating license. Therefore. NRC should suspend NMPC's operating ItcenseforNMP1 untt!

there has been a public review of the May 1999 inspection data and the proposed repair to V-9 and V-10 and the safety l of continued operation of the reactor can be determined. Postponing restart ofNMP1 would eliminate the issue of

" regulatory burden" for NMPC management and ensure that the safety signylcant work being conducted during this ~;

refketing outage is properly reviewed.

Therefore, for all of the above stated contenttons, the Petitioners call upon the NRC to suspend NMPC's operating license for NMP1 by postponing the scheduled restart date until such time as a public meeting can be held in Oswego , l County to review the most recent core shroud inspeedon data and the nroposed repair design to core shroud welds V-9 and V 10.  !

Sincerely, Tim Judson Syracuse Peace Council 924 Durnet Ave.

Syracuse,NY 13203 Deborah Katz Executive Dimetor Citizens Awareness Network PO Box ft3 Shelbume Falls. MA 01379 Kyle Rabin Envirunmental Advocates 353 Ilamilton Street Albany. NY 12210 l

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Howar(Hawkins Orcens of Greater Syracum -

PaulOunter Director, Reecent Watchdog Project . .

Nuclear Information & Resout cc Scryicc 142416th Street NW, M04 l

j Washin5 ton,DC 20036 j

. lleidi Siegfried -

Oswego %11cy Peace & Justice Martha Loew

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President

- Sierra Club, Iroquels Omup -

David Radley Student Environmental Action Coalition Wendy Harris -

Simon Morrin .

Syracuse Anti-Nuclear Esort

• 924 Bumet Ave.

Syracuse, NY 13203 Dr. Steven Penn, Ph.D.

Department of Physics i i

Syracus UniYClaity l

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