ML20236K023

CRC Supplement to Intervention Petition.* Submits Supplement to Intervention Petition,In Accordance W/Aslb Order

ML20236K023
Person / Time
Site:	Millstone
Issue date:	07/06/1998
From:	Burton N AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20236J981	List: ML20236J978 ML20236K023
References
98-740-02-LA, 98-740-2-LA, LA, NUDOCS 9807090111
Download: ML20236K023 (10)

Text

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DO'X{~FD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD U ~3 P3 :04 i l

l Before Administrative Judges:

Thomas S. Moore, Chairman >

Dr. Richard F. Cole Dr. Charles N. Kelber f

In the Matter of  : Docket No. 50-423-LA NORTHEAST NUCLEAR ENERGY  : ASLBP No. 98-740-02-LA l COMPANY  : I

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, (Millstone Nuclear Power  :

Station, Unit No. 3)  : July 6, 1998 CRC SUPPLEMENT TO INTERVENTION PETITION The Citizens Regulatory Commission (" CRC") submits herewith its supplement to its intervention petition, in accordance with the ASLBP order dated June 15, 1998.

10 C.F.R. 52.714(b)(1) Contentions l

1 I. The license amendment assumes a certain proportion of the recirculation spray system (RSS) coolant will supply the containment spray ring during the LOCA design basis l

' accident; however, since the systems have not been tested, it has not been determined that they will be functional, that is, that the flow will be divided as postulated.

Northeast Nuclear Energy Company ("NNEC0") has submitted the results of computer programing in support of its postulation that a certain proportion of coolant will be supplied to the containment spray ring, ECCS systems, direct injection to the loons and that the RSS will function as intended during the LOCA design basis accident.

The amendment entails a physical reduction of the flow within the system by half, modifications of piping, a reduction in the number of spray ring holes; the remaining system flow is to supply l 9907090111 900706 l

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.the ECCS, including direct injection to the coolant loops. ,

According to a communication by the licensee to the l I

Nuclear Regulatory Commission (NRC) dated February 16, 1998

! (Docket No. 50-423, B17050), the licensee has made eighteen (18) l modifications to the RSS since 1985, when NNECO conducted limited i system flow testing. l

.According to said communication, eight (8) of the eighteen modifications were made prior to the 1996 shutdown. These were:

MP3-85-004 " Tubing Protection Barriers" MP3-85-014 " Supports Required for Seismic Interaction" l

MP3-86-094 " Modifications to the ESF Status Panel (31HA-ANNMB2E" MP3-88-009 " Modification to the Cold Leg Recirculation Array" MP3-89-013 "MP3 Containment Design Pressure Change" MP3-92-004 "Limitorque Torque Switch for Operators Material Change" MP3-93-015 " Replacement of 3RSS*MOV23AthroughD" MP3-94-162 " Installation of RSS Containment' Sump Flanges" According to said communication, ten (10) of the eighteen i

l modifications were to have been completed prior to restart:

MP3-96054 "RSS Cor.ponent Temperature Rerates" MP3-96056 "RSS Support Modifications Outside Containment" MP3-96063 "RSS Support Modifications Inside Containment" MP3-97042 " Mini-Flow Test Line for RSS Pumps C & D" MP3-97045 "RSS Pump Restriction Orifices to Prevent Suction Line Flashing" MP3-97063 "RSS Expansion Joint / Support Modifications" 2

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MP3-97094 " Fill / Vent Lines ECCS Loop Seal" MP3-97102 " Reinstatement of RSS Cold Leg Direct Injection" l i

MP3-97106 "Switchover Time Increased (10 min.-25 ,in)" l MP3-98008 " Modification of RSS Pumps' Seal Water Cooler."

NNECO has a history and a propensity to supply incorrect  ;

i calculations and information for computer modeling. Faulty l 1

calculations and incorrect information provided to Westinghouse  !

and Stone & Webster in the past have contributed to additional problems in the RSS. Such problems contributed significantly to the March 1998 debacle involving expansion joints damaged j by severe vibrations. Indeed, the Independent Corrective Action Verification Program (ICAVP) identified programmatic problems and trending in calculations and calculation control. l If calculations and information provided for computer simulation are faulty or incorrect, computer simulation is inadequate. If the l I

computer simulation is inadequate, it could fail to take into account the potential harm to containment, including structure fracture, because of inadequate reduction in pressure. >

Inadequate simulation presents a serious hazard to the public and employees of the plant.

NNECO has submitted no documentation to establish that it i conducted actual testing of the system, other than pump flow tests, )

nor that any contractor or subcontractor conducetd actual testing or modeling of the systems in place. l

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As a point of comparison, when air-binding issues involving l l

the charging system came to light during a Safety System Functional 1

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{ Inspection, NNECO engaged a subcontractor to conduct simulations l

i from two models.

l II. Reduction by half in the RSS flow results in a major change in capacity which requires actual testing.

NNECO has concluded it was necessary to reduce the number of spray holes in the containment spray ring to create the estimated flow requirements.

The estimated flow requirements are to assure adequate reduction ir containment pressure within the prescribed titre and to allow >

removal of airborne contaminants in the containment atmosphere.-

NNECO has submitted no documentation to establish that it l

l conducted actual testing of the system, nor that any contractor or subcontractor conducted actual testing or modeling of the system.

i CITIZENS REGULATORY COMMISSION l'

l By: ~

aA LUA e- - -

Nancy rton, Esq.

L 147 r ss Highway Redd'fg Ridge CT 06876

Tel. 203-938-3952 l

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f

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ATOMIC SAFETY AND LICENSING BOARD l

Before Administrative Judges:

Thomas S. Moore, Chairman Dr. Richard F. Cole Dr. Charles N. Kelber In the Matter of  : Docket No. 50-423-LA NORTHEAST NUCLEAR ENERGY  : ASLBP No. 98-740-02-LA COMPANY  :

(Millstone Nuclear Power  :

Station, Unit No. 3)  : July 6, 1998 AFFIDAVIT Susan Perry Luxton, having been duly sworn, hereby deposes as follows:

1. I am above eighteen (18) years of age and I believe in the obligation of an oath.

2. I reside at 180 Great Neck Road, Waterford, Connecticut.

3. I have personal knowledge of the matters set forth in the Citizens Regulatory Commiosion petition for intervention and supplements.

4. I am a member of the Citizens Regulatory Commission and desire and hereby authorize CRC to represent me in proceedings before the Atomic Safety and Licensing Board regarding the March 3, 1998 license amendment application which is the subject of this proceeding.

5. I reside at 180 Great Neck Road with my family, which includes two young children.

6. My residence is within the five-mile priority emergency evacuation zone of the Millstone Nuclear Generating Station.

7. I have long been concerned about the safe operation of Millstone Station.

8. Since my. family and I live within the five-mile priority emergency-evacuation zone, we reside within the area that could not I

only be directly impacted by an accident at Millstone with off--site

-consequences, but within en area in which the licensee is required l

to provide protective actions in such event.  !

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9. The license amendment at iacue involves critical modifications to the RSS, a critical safety system at Millstone Nuclear Power Generating Station, which modifications have not been tested to determine if they are fully functional.

10. Approval of such amendment, without adequate and appropriate l J

testing,.will have the effect of reducing safety margins at Millstone, will impact me should an accident result from reduced safety margins. l j

-11. Accordingly, I believe 1 am a person direct'ly affected by the .

l proposed action. )

Susan Perry Luxton l

STATE OF CONNECTICUT SS:

COUNTY OF NEW LONDOP i day of 1998.

Subscribed and sworn to before me this Commissioner of the Superior Court /

l p

Notary Public

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

l Thomas S. Moore, Chairman Dr. Richard F. Cole Dr. Charles N. Kelber In the Matter of ,  : Docket No. 50-423-LA NORTHEAST NUCLEAR ENERGY  : ASLBP No. 98-740-02-LA I COMPANY  :

(Millstone Nuclear Power  :

Station, Unit No. 3)  : July 6, 1998 AFFIDAVIT Joseph Besade, having been duly sworn, hereby deposes as follows:

1. I am over the age of eighteen (18) years and I believe in the obligation of an oath.

2. I reside at 21 Fif th Avenue, Waterford, Connecticut.

3. I have personal knowledge of the matters set forth in the ,

1 Citizens Regulatory Commission petition for intervention and supplements.

4. I am a member of the Citizens Regulatory Commission and .

I desire and hereby authorize CRC to represent me in proceedings l before'the Atomic Safety and Licensing Board regarding the March 3, 1998 ,

license amendment application which is the subject of this proceeding.

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5. I reside at 21 Fifth Avenue with my family.

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6. My residence is within two miles of Millstone Nuclear Power Generating Station.

7. I have long been concerned about the safe operation of Millstone Station.

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8. Since my family and I live within the five-mile priority I

emergency evacuation zone, we reside within the area that could not only be directly impacted by an accident at Millstone with off-site consequences, but with!.n an area in which the licensee is required to provide protective actions in such event.

9. The license amendment at issue involve critical modificatichs to the RSS, itself a critical safety system at Millstone Nuclear Power Generating Station, which modifications have not been tested to determine if they are fully functional.

10. Approval of such amendment, without adequate and appropriate testirg, will haev the effect of reducing safety margins at Millstone and will impact me should an accident result from the reduced safety margins.

11. Accordingly, I believe I am a person directly affected by the proposed action. i l

Joseph Besade i

i STATE OF CONNECTICUT ss:

COUNTY OF NEW LONDON Sworn to and subscribed before me this day of 1998 Notary Public 2

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

I Thomas S. Moore, Chairman Dr. Richard F. Cole 1 Dr. Charles N. Kelber

'l In the Matter of  : Docket No. 50-423-LA i NORTHEAST NUCLEAR ENERGY  : ASLBP No. 98-740-02-LA COMPANY  :

(Millstone Nuclear Power  :

Station, Unit No. 3)  : July 6, 1998 AFFIDAVIT Clarence 0. Reynolds, having been duly sworn, hereby deposes as follows:

1. I am above the age of eighteen (18) years and I believe in'the  ;

j obligation of an oath.

2. I reside at 5 Lancashire Drive, Waterford, Connecticut.

3. I have personal knowledge of the matters set forth in the Citizens Regulatory Commission petition for intervention and supplements.

4. I am a member of the Citizens Regulatory Commission and

! desire and hereby authorize CRC to represent me in proceedings before the Atomic Safety and Licensing Board regarding the March 3, 1998 license amendment application which is the subject of this proceeding.

5. I reside at 5 Lancashire Drive with my family, which includes a young child.

6. My residence is within the five-mile priority emergency evacuation zone of the Millstone Nuclear Generating Station.

7. I hava long been concerned about the safe operation of Millstone Station.

8. Since my family and 1 live within the five-mile priority emergency evacuation zone, we reside within the area that could not only be directly impacted by an accident at Millstone with off-site j 1

consequences, but within an area in which the licensee is required to provide protective actions in such event.

9. The license amendment at issue involves critical modifications to the RSS, itself a critical safety system at Millstone Nuclear Power Generating Station, which modifications have not been tested to determine if they are fully functional.

10. Approval fo such amendment, without adequate and appropriate testing, will have the effect of reducing safety margins at Millstone, and will impact me should an accident result from reduced safety margins,

11. Accordingly, I believe I am a person directly affected by the proposed action.

Clarence O. Reynolds STATE OF CONNECTICUT SS:

COUNTY OF day of 1998 i Sworn to and subscribed before me this Commissioner of the Superior Court Notary Public i

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