ML20210R666
| ML20210R666 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/10/1999 |
| From: | Judson T SOCIETY AGAINST NUCLEAR ENERGY |
| To: | Hood D NRC |
| References | |
| 2.206, NUDOCS 9908170182 | |
| Download: ML20210R666 (3) | |
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August 10,1999 162 Cambridge St.
Syracuse, NY 13210.
Mr. Darl Hood j
NRC Project Manager, Nine Mile Point Units 1 & 2 U.S. Nuclear Regulatory Commission
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Mail Stop 8C2 i
Washington, DC 20555-0001
Dear Mr liood,
This letter is to confirm our conversation on July 21 about the concerns of Syracuse Anti-Nuclear Effort regarding the status of our petition 2.206 (filed on May 24), and the upcoming NRC performance review I
mecling on Nine Mile Point Units 1 and 2. You had called for three reasons: 1) to notify SANE that our
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request in the petition for a public meeting to review the safety margins ofNine Mile Point Unit I (NMI) was still under consideration by NRC; 2) to inquire whether SANE and other groups were still interested in a public meeting specifically devoted to the safety status of NMl; and 3) to ascertain what our
- concerns were regarding the reactor performance review a; i what we hoped to see addressed in the perfbrmance review, to be scheduled in late September or early October.
We appreciate your initiative in notifying us of the status of our petition, and we are pleased that the NRC is eviewing our concerns.: However, we are disappointed in the Petition Review Board's previous decision not to fully address the petition before NMI was allowed to restart. Specifically, the PRB's j
assessment that our concerns, while sufficient to qualify as a petition 2.206, did not present issues that j
wouldjustify postponing restan is inadequate! The concerns, as they were presented with new information and unreviewed safety issues, were directly relevant to any continued operation of the reactor. NMI should not have been restarted until these safety concerns had been fully addressed. A -
thorough public review was warranted before restart. Since the age-related degradation continues, that review is still warranted, even if it is belated.
Since our filing of the 2.206 petition, the event reports at NMI have only further substantiated our case that reactor safety has been compromised. Cracks were identified in the Main Drain Line (MDL) and Control Rod Stub Tubes (CRST) as a result of a hydrostatic test of the Reactor Vessel the day of the scheduled restart. The MDL leak is panicularly troubling. As a small-diameter pipe, the MDL is only scheduled for inspection once every eight years. The leak, which was detected by visual inspection and not remote sensing, was fortunately discovered before restart, llad the MDL burst during operation there would be no way to stop the draining of the reactor vessel.
These cases raise two concerns: A) the NRC's " leak-before-break" model for assessing the safety of aging reactors is inadequate; and B) the problem of cracking in pipes and internals is not confined to the core shroud, but may be spreading throughout the reactor internals, pipes, and other systems. The latter represents an unanalyzed condition which is only being identified piecemeal, through incidental cases:
the core shroud (1995-present), emergency core coolant condensers (1997), main drain line, and control rod stub tubes (1999). Togetiser, however, they reveci a pattern of degradation of reactor components and systems and suggest overall embrittlement of the reactor. TI'e condition of the core shroud, the most robust intemal component, is a bellwl ether for the status of othe.m rtor components and systems.
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' Finally, the recently relen~ sed core shroud inspection results indicate that one of the welds (V.10) is g
experiencing a crack growth rate which is on the order of or greater than the limit set by the NRC in the O
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- November 1998 safety cvaluation. The measured values were also much greater than the CGR predicted by Genera! Electric. In addition the large measurement error (approximately 10 microinch/ hour) i
. provides a great deel of uncenainty compared to the NRC's CGR limit of 22 microinch/ hour. For safe h
operation the measured CGR should be at least 2 sigma below any established safety limit.
1We believe the need for a public meeting to review these issues has only increased since our petition was 3
' tiled.' Funher, we believe the plant performance review meeting would be inadequate to address our j
concerns. The performance review discusses operator performance for a given period of time, whereas
. our safety concerns focus on reactor degradation which extends across many operating cycles.
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In addition to thS p6blic meeting on the NM1 core shroud, a performance review of Nine Mile Point Units 1 & 2 is also of pressing need. Nine Mile Point has experienced a rash of scrams and of coolant and electrical system failures which suggest a problem in operator training and perfonnance. We feel it I
is important to the success of the performance review process that the NRC and the public be able to i
'discem issues of operator performance 'and reactor integrity, and be able to distinguish their safety
. significance when necessary. For these reasons, we reiterate our request for a public review of the 1999 core shroud inspection and the safety status of NMI, separate from the meeting to review plant performance at Nine Mile Point.
Sincerely, i
. E-Tim Judson Syracuse Peace Council
- Syracuse Anti-Nuclear E%rt '
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cc: Dr. William Travers, NRC
- Hubert Miller, NRC Region ~ l Deborah Katz, Citizens Awareness Network
.Kyle Rabin, Environmental Advocates Howard Hawkins, Greens of Greater Syracuse Paul Gunter, Nuclear Information & Resource Service Heidi Siegfried, Oswego Valley Peace & Justice Martha Loew, Sierra Club-Iroquois Group David Radley, Student Environmental Action Coalition 1Wendy Harris, Syracusc Anti-Nuclear E%rt Simon Morrin, Syracuse Anti-Nuclear Effort Dr. Steven Penn, Dept. of Physics, Syracuse University i
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