ML20210E191

Suppl to 860215 Petition for Leave to Intervene on 860130 & 0205 Requests & Provides List of Contentions Vs Amend to License NPF-39

ML20210E191
Person / Time
Site:	Limerick
Issue date:	03/19/1986
From:	Anthony R ANTHONY, R.L., FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
CON-#186-556 OLA-OLA-2, NUDOCS 8603270271
Download: ML20210E191 (8)

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U.S. NUCLEAR REGULATORY C(EEMISSION~.. ATOMIC SAFETY & LICENSING BOARD PHILA.ELEC. CO. Limerick Gen.Sta. Units 1.& 2. Docket # 50-352,353 &

OgE}CED March 19,1986-SUPPLEMENTTOR.L. ANTHONY /F0EPETITIONTOINTERVENEOF 1/30/86,2/5,-

and LIST OF CONTENTIONS 2/15/86, vs. AMENDMENT TO LICENSE.NPF-39 oo MR 24 PR:1Y On2/15/86 Anthony /F0Efiled 11 contentions on the above issue along with a petition to stay the operation kC Limerick' reactor untiltheteststhatwereproposedtobepostpone[NNecompleted.We now,asinstructedbytheBoardinitsorderof3/14/86,supplementand add to these contentions,and, we further submit contentions vs. Amend-ment # 2. Our supplement to our contentions on Amendment # 1 follow.

Cont. 1. (Supp.) NRC was not justified in finding that. the amendment involved no significant hasards consideration because of the increas e d 1 risk of plant failure and radioaraive releases from mal-function of check valves in which weaknesses could have been revealed through the tests that were postponed. Therefore,the amendment does pose signifi-ca nt hasards and cannot qualify for categorical exclusion under 10 CFR 51.22 (c) (9) and 51.14 (a),and an impact statement and/or environmen-tal assessment are required under 10CFR 51.20. (Cont. 2).

I j cont. 3. The test limit was extended from 18 months to 26 months.

! This means an extention of risk from wear and aging of the valves mad

! instrument lines for 8 additional months beyond the Technical Specifi-cation (TS) limits.

i Cont. 5. The check valves can malfunction in several wayes stick open, i stick closed, rupture or separate from the pipe. Excessive coolant pres-sure could cause this,and discharge radioactive liquid and steam at over l 1000 PSIG, and more than 500 F. into the secondary containment. We

! now know that such releases can penetrate the outer walls to the out-I side environment,as recorded recently in Region I, Inspection 86-02.

1 The Safety Evaluation,p.2 cites FSAR 15 6.2. as covering a leak i

event from these lines but it does not evaluate the consequences from high temperatures and pressures from the rupture of one or more of these

.l valves and the effects on interfacing systems.

l l PECo or NRC give no probability figures for the failure of these I valves or the ratio of incr easedrisk of failure in the 8 months added ,

but we have some indication of the industry experience in a letter,Cooney 8603270271 860319 PDR ADOCK 05000352

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to Bernero, 1/29/86, cited in the cover letter Butler to Bauer, 3/3/86 for Amend. # 2. Included in Table 2 are some small valves from Rock-well under penetration # I -13A and I -45 A . These come under Amend.

1. 2buttheremaybeRockwellorAtwood&Morrill"kn$$udedinthecheck valves of Amend # 1. Table 1. (1/29) rates valves from these two com-panies as more prone to failures, Rockwell with 28 " meaningful failures reported" for 492 valves and Atwood & Morrill with 6 failures for 61.

The latter are check valves although of a larger sise.

The Rockwell failure rate is 1 out of 18. If this rate is applied to the approximately 110 check valves covered in Amend # 1 (TS Table 3.6 3-1 Part B.) the possible failed valves equal 6 out of 110. With the possibility of 6 valve failures at any moment we believe that PEco has no basis for the conclusions (Safety Eval.p 2(SE) on the reliability of the valves, nor is there any evidence :to substantiate:

The staff concludes that the condition of the valves is not expect-ed to change significantly during the short extention period.

In addition,in case of a valve or line break, we assert that the discharge cauld not be assured to be handled (S.E. p.2) by the standby gas treatment system since a radioactive spill was recently pumped to the easite holding pond (Insp. 86-02, p.9 ). The staff,therefore, has no basis for the conclusion there will be no significant increase in radiation exposure either ensite or off (SE, pars.3.0) and that there is no significant hasards consideration .

with Co n t. 11. If PEco had been functioning in good faith3due regard for the safety of the public and its workers ,it would have taken advantage of the periods when the reactor was shut down,to provide safe operation, by carrying out the required tests under 4.6 3 4 . The monthly operat-ing records show the reactor at sero power for 16 days in August, 3 in Sept., 9 in Nov., 3 in Dec.1985,and 9 in Jan. 1986,1.e.40 possible days.

Cont. 12 (new) The grave consequences of an instrument line or valve rupture are set forth in the postulated accident under FSAR 15 6.2.2.1 .

l The operator could be called upon to shut down the plant. But the mor-mal plant instrumentation and controls (15 6.2.2.2) could very possi-bly not be available since the imetrument line may " serve as an instru-mentation manifold with multiple transmitters" as we showed in Cont.7 l

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Cont. 13 (new) Since PBco provided no operating record from its own experience or the industry to assess theisliability of the valves or the failure rates, its conclusions of reliability (SE p.2 ) are to be viewed as unsupported assumptions without any technical authority.

And the staff's conclusions in the same way are assumptions without bases and, consequently,the conclusion of no significant hasards is unsupported by evidence and is erroneous and hense must be rejected by the Board.

SUBMISSION OF CONTEN'HONS BY ANTHONT/F0E YS AMENDMENT # 2 TO LICENSE NPP-39, TO SUPPLEMENT OUR PETITION OF 2/26/86 TO INTERYENE.

We acknowledge the order for consolidation of the proceedings on Amendment # 1 and Amend.# 2 by the Board on 3/14/86,and the direc-tion to file our contentions on the same date as supplements to # 1.

We submit below our contentions on Amend. # 2.

We understand that Amend. # 2 has connected with it an exemption from 10 CFR 5b App. J. We address these jointly as such as is possible in our contentions. We continue our numbering sequence from Amend.# 1.

Cent. 14 ( #2) We are in disagreement with findings by NRC on p.1 of the amendment, Para. l., A through E.,and we combine this with Cont.

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Cont. 15 #2 (Rxemption p.2, para.II ) We find no basis in the regu-lations,and none is cited by the staff, which would authorise its

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oonclusions that approval of the proposed extention (TS 4.6.1.2, above in para.II) is warranted and is authorised by the greating of this one-time exemption.....

We contend that the extention to Surveillanos Requirements for TC 4.6.1.2 is met warranted and authorised by the granting of the exemp-tion. We find the staff has apparently fabricated this causal conneo-tion between exemption and amendment,and %Ae Board must correct and void this fabrication.

j cont. 16 #2 (para.II) Shutting down the plant is no justification

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for extending the time for the tests. Nothing ia the regulations pre-vents a shutdown for tests.

There are ao records to show what the probabilities are for fail-ure of the valves. Gecord of leaks and maintenanos are only part of the facts needed for an evaluation. The staff provides no proof that PEco has provided an adequate basis for postponing the tests. There is se proof of " negligible reduction in containment intergrity? We assert 3 that it will be degraded and that the staff's evaluation is superfietal, I

devoid of factual substantiation.

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Gent. 17 f2.(p.3 , para III ) Thero are ne statistics to prove " tradi-tionally good maintenance histories " i We see this as another staff I

un s upported conclusion and we believe the Board will reject it. We mete that the staff adds emphasis to our pointing out in Cost.16,deg-falso

redation of safety during the extention,with its assurance that there '

are margias "to accomodate any additional degradation likely to occur

, during the period of the extenties" There is no assurance that there l are margias sufficient to offset the kind of leakage recorded in LER 85-102. However,we recognise the staff's admission of degradation.

Cont.18 #2. PEco gave unusual emphasis to the leak reported in a dry-l well isolation valve by voluntarily submitting LER 85-102. This l valve had to be closed manually because it would not shut off adequate-ly and it has continued as a manual valve. Th e significanoe for Amead.

! #2 is the inclusion of 5 valves k TS 4.6.1.2.g with similar code to HY-51-17016A, recorded in LER 85-102. The 5 are : Ev-51-1F041 A,C,D, and -1F050 A and B. In addition TS 4.6.1.2.d has 4 similar ones in the series: HV-51-lF017 A,C,D and -lF027 A. With the kind of leak po-tential recorded in LER 85-102 the performance of these valves is in question. There is no assurance that these valves would not "cause the allowable technical specification values to be exceeded"( Exempt, p.4 )

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We assert that the staff reached an erroneous conclusion thus:

" assurance that leakage shall not exceed technical. specification al-lowable values,will be met with this one-time extention..."

Cont. 19 #2 We point out that PEco is olouding the real issue in stressing the temporary nature of the exempties (Exempt. p. 5.)We state the real threat to the safety of the public in stretching the interval between leak test from a limit of 24 months to 33 months for 27 valves'and from 18 months to almost 26 months for 10 valves. With I

extention of the test interval the probabilities for faults in the valves accelerate,with increases in malfunction as in LER 85-102,above.

Further statistics on the failures of valves in the same cate-1 gory as those,in Cont. 18,above, are included in Tabissl&2 arthe let-ter,Cooney to Bersero,1/29/86 (Safety Eval. p.1.). Yalves made by i Atwood and Morrill are recorded to have 6 " Meaningful Fsilures Report-ed" out of a total of 61 valves. Of the 37 valves included in Amend.

1. 2, 5 are Atwood & Morrill check valves (Table 2) EV-51-1F050A,-lF050B,

-1F041 A, -lF041C and 1F041 D* From the A.& M failure rate in table 1 13.one out of 10 1 & M valves fail. This would indicate that there is

! a 50% possibility that one of the 5 valves above could fail in the period of extention to the testing schedule.

Cont. 20 #2 (Exempt. p.5 ) PECo' assertion of " good faith efforts" ,

to justify the presence of special circumstances under 10 CFR 50.12 is fraudulent. PECo withheld carrying out the required tests,we be-

! lieve deliberately. There were 40 days from August to January when i the plant was shut dows.(see Cont. ll.}PEco proved its bad faith by

skipping the tests when they should have,and could have,been done.

The staff errs in concluding a " good faith effort",the existence of special circumstances,and that the exemption is acceptable.

Cont. 21 #2 (Exempt. p. 6 ) The Commission erred in determining that f the exemption satisfies 10CFR 50.12. We assert the opposite. It will

! endanger life and property,the security of the community,and is not in the public interest,as we have shows above.

Cont. 22 #2 Also,as we have amply demonstrated, this exemption and the amendment will have a signifiotut impact on the environment. The Commission erred in determining there is so significant impact.

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l Cont. 23 #2 ( The following contentions will refer to pages in the .

Safety Evaluation-for amendment #2 except as otherwise stated )

(p.1 ) Pour letters from PECo are thought by MRC to justify the amend- ,

I ment and exemption. We disagree as follows: ~

l 2/5/86 letter gives no figures to support the conclusion that ne  !

" difficulties with leakage of these valves should be anticipated".  !

There is no substantiation that "the underlying purpose  ;

2/25/86.

of the regulation is met",or that special circanstances are present, j od faith efforts to comply",or that"the ori-or thatofPECe teria "made p(v) have been met."

50.12(a)(2) l 3/3/86. It seems remarkable to us that a letter dated March 3,1986 by Mr.Daltroff in Philadelphia should have been included is the is-

. suance of Amendment #2 and the Exemption dated 3/3/86,Bethesda, Md.

We disagree that LER 85-102 can be concluded "to be an isolated fail-ure",as we have shown above,or that it has "no effect upon the con-clusions and basis for the current amendment request",or that " the subject request... poses no significant hasards . considerations."

Cont. 24 #2 (p.2,3) We disagree that these valves" tend not to have problems meeting leakage criteria",as demonstrated in LER 85-102. We assert also that the figures in the NPRDS tables (1/29/86 letter ) ,

as we have shown above, do not support the conclusion that these valves should not " be expected to experience undue difficulties in 1

" Attach-meeting the leakage criteria." (See" Safety Related Check Yalves#

ment 1. )

Cont. 25. #2 In contention # 8 we cite the study by Sarah M. Davis which picks out Residual Heat Removal and Low Pressure Injecties lines and valves as especially vulnerable in interfacing systems reactions ,

in case of LOCA. The failure rate of thee valves is referenced in- l Cont.19 Table 2 (1/29/86) shows 2 of these valves .in' RER Cooling Return and 3 in RER LPCI (Low Pressure Core Injection). We assert l the exact opporne conclusion from the staff's from the evidence above, l and we expect the Board will reverse the staff's determination that(p 6):

the proposed changes will have little or no effect encontainment integrity and that the proposed amesament will not alter any of the accident analyses.

We ask the Board to find that the proposed changes are not acceptable.

Cont. 26. #2 (p.7) We trust the Board will agree that the test interval for the 18 month surveillance vaivas extention jeopardises public and employee safety and that the integrity of these valves is in question and there is no proof that they will not be subject to added degrada-tion during the extention,as we have shown above. We disagree with the staff findings (1) through (4) and ask the Board to reach the opposite conclusion from the staff's and find that the changes have great safety 1

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significance and will alter the accident analysis and that they are not acceptable.

Cont.27. #2 (p7,8) We ask the Board to reverse the staff's determis-ations and to find that the amendment does involve increases in efflu- j onts offsite,and increased occupational exposure,and inorsases the risk of radiological accidents and plant malfunction,and it thereby does involve significant hasards consideration. We also ask the Board to find that the Environmental Assessment of*no significant impact # I is in error,and the amendment does not meet the eligibility criteria for categorical exclusion under 100FR 51.22 (c) (9),ner does it meet the requirements of 10 CFR 51.22 (b) on environmental impact.

Cont. 28 #2 (p.8) We ask the Board to find the opposite conclusion to the staff's and find that the amendment and the exemption do not provide assurance ,

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security nor to the health and safety of the publio.

We ask the Board to make a parallel finding on Amendment # 1 on the the basis of the evidemoe we have submitted.

Cont. 29 This contention involves Amendments #1 and # 2. We find no documents or evidence to support that the Commission has fulfilled its obligation to the State (Penna.) under 10 CFR 50 91 (b) in rein-tion to these two amendments to the license. We ,therefore,ask the Board to find that the amendments were issued in violation of the above regulation.

Respectfully submitted, hhh he hW}

Box 186 Moylan,Pa.19065 I certify copies by mail to:

NBC Sec., Docketing, Staff Counsel, F. Romano ConsrandWetterhahn5

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/""'%, UNITED STATES '

! NUCLEAR REGULATORY COMMISSION

! OFFICE OF PUBLIC AFFAIRS, REGION I 631 Park Avenue, King of Prussia, Pa.19406 1.,.....,/ Tel. 215 337 5330 I-86-28 February 26, 1986

Contact:

Karl Abraham Ann Overton .

.NRC STAFF REQUESTS ACTION ON SAFETY RELATED CHECK VALVES d

The staff of the Nuclear Regulatory Commission has asked the Owners' Groups representing ' operating nuclear power plants in the U.S. to take prompt action in addressing concerns that have arisen regarding safety-related check valves. Check valves are designed to prevent the reverse flow of water in the pipes.

On November 21, 1985 a loss of power and water " hammer event at the San Onofre Unit I nuclear plant near San Clemente, California, raised serious questions about the design, testing and maintenance of safety rUlated check valves.

The NRC Incident Investigation Team report on that event, issued in Janua ry, ' concluded that the most significant aspect of the event was the failure of five safety related feedwater check valves. The root cause of these failures is still under review at the San Onofre plant. The NRC staff is concerned that the event might have significant generic implications for all nuclear power plants.

In a letter to the Owners' Groups, the NRC staff is asking them to take whatever actions are appropriate to preclude similar ch'a11enges to plant safety systems. The Owner:,' Groups have been asked to meet with the NRC staff within 30 days to discuss their views and intended act. ions. -

-There are four designers of nuclear steam supply systems for commercial nuclear elect,ric generating plants. They are Westinghouse Electric Corp.,

General Electric Co. , Combustion Engineering Inc. and Babcock & Wilcox Co.

Each has an '0wners' Group which consists of representatives from the utility c

j1 8;.; Co*PanieA ths. oWnjahj operate the plants.

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Currently J there are 98 nuclear plants' licensed to operate in the U.S.

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