ML20236P601
| ML20236P601 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/07/1998 |
| From: | Burton N AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20236P592 | List: |
| References | |
| 98-743-03-LA, 98-743-3-LA, LA-2, NUDOCS 9807170046 | |
| Download: ML20236P601 (4) | |
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g UNITED STATES OF AMERICA DOCKETED NUCLEAR REGULATORY COMMISSION USNRC l.
ATOMIC SAFETY AND LICENSING BOARD
,% JUL 16 All:12 l
Before Administrative Judges:
l Thomas.S. Moore, Chairman O g~ ~ '
'~
Dr. Richard F. Cole
/OJ~~
Dr. Charles N. Kelber in the Matter of
- Docket No. 50-423-LA-2 NORTHEAST NUCLEAR ENERGY
- ASLBP No.' 98-743-03-LA COMPANY (Millstone Nuclear Power July 7, 1998 Station, Unit No. 3)
' CRC SUPPLEMENT TO INTERVENTION PETITION The Citizens Regulatory Commission (" CRC") submits herewith l
its supplement to the intervention petition, in accordance with the ASLBP order dated June 16, 1998.
10 C.F.R. f2.714(b)(1) Contentions
- 1. The proposed dewatering system does not meet criteria for a permanent devatering system because one of the components, l
the diesel-powered air compressor, is not safety-related.
i Northeast Nuclear Energy Company ("NNEC0") asserts in B17141 that'the proposed dew'atering system meets the requirements of Standard Review Plan 3.4.1, which provides as follows:
If safety-related structures'are protected from below-grade groundwater seepage by means of a permanent dewatering system, then the system should be designed j
as a safety-related system and meet the single failure proof criterion.
Yet, NNECO acknowledges in Section 9.3.3.4.1, Insert "C,"
that
[e]quipment accessible for repair (such as the portable
' diesel compressors) is non-safety-related.
Thus, the air compressors which are components of the proposed dewatering. system do not qualify as safety-related and, hence, the criteria of Standard Review Plan 3.4.1 are not met.
l 9807170046 980707 PDR ADOCK 05000423 i; O
II. The proposed amendment contradicts the current FSAR.
The current Millstone Nuclear Power Station-3 FSAR provides t
l in pertinent part as follows:
1 3.4.1.2 Permanent Dewatering System There is no safety-related dewatering system for Millstone
- 3. This system is not applicable.
i The proposed amendment inserts the phrase "for adverse i
hydrology events" between the words " system" and "for" in the first sentence of $3.4.1.2. However, such insertion does not negate the asserted inapplicability of " Permanent Dewatering System."
Thus, it appears that the applicant seeks approval for a proposed amendment to design and install a permanent dewatering oystem within the criteria of Standard Review Plan 3.4.1 while I
retaining a contradictory assertion in the FSAR.
III. The proposed amendment' fails to correct the false I
assertion in MNPS-s FSAR that "[t]he containment and all other Category I structures are protected from groundwater inflow by a waterproof membrane below the groundwater level."
i Millstone Nuclear Power Station-3 FSAR 2.4.14 provides in pertinent part as follows:
The containment and all other Category I structure are arotected from groundwater inflow by a waterproof membrane 3elou the groundwater level.-
This statement appears to contradict NNECO's acknowledgment trLits April 1, 1998 license amendment request submission that:
Degradation of the waterproof membrane has been detected, i
allowing groundwater inleakage.
Further, in B17141 Attachment 3, NNECO estimates that:
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The amount'of groundwater which consistently bypasses the rubber membrane and enters the RSS sumps is presently on i
the order ot 750 to 1000 gallons per day.
NNECO further acknowledges that the volume of water involved l
in the inleakage is subject to fluctuations owing to seasonal and climatic. conditions.
IV. Materials submitted in support of the proposed license amendment fail to demonstrate that the air-driven pumps are adequate to maintain operability of all four RSS pumps under all climatic conditions.
The materials submitted by NNECO fail to demonstrate that the air-driven pumps are adequate to maintain operability of all four RSS pumps under all climatic conditions.
Although MhPS-3 FSAR asserts that the controlling event for flooding'at the site is a storm surge resulting from the occurrence of the " probable maximum hurricane"("PMH"), the submissions fail to demonstrate operability under all climatic conditions.
V. The proposed amendment fairs to demonstrate adequate review of the conditions which may have developed sub-containment basemat prior to detection of groundwater inleakage in the estimated. amount of 750 to 1000 gallons per day.
NNECO's submissions provide no information regarding sub-containment basemat conditions, including poss.ible erosion, tunneling and other changes, attributable to the undetected degradation of the waterproof. membrane.
The presence of 750 to 1000 gallons per day of inleakage of groundwater raises significant issues as to whether the integrity of containment is affected moreover, NNECO's submissions are silent o
as to the length of time the inleakage has gone undetected and the L
reasons for failure of detection.
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Similarly, although MNPS-3 FSAR assumes certain subsurface soil-and groundwater conditions at the site, such conditions may no longer present themselves owing to the unexpected degradation of the waterproof membrane.
NNECO has'provided no analysis whatsoever from a professional geohydrologist, for example, concerning current conditions and their impact, if any, on the functionality of the proposed license j
amendment.
'hNECO itself acknowledges'the dangers inherent in failure to adequately and appropriately address the degradation of the waterproof f
membrane. In bl7141,-Attachment 3, NNECO stated:
On May 23, 1997,- a Configurement Management Program review revealed that inleakage of groundwater results in a potential to flood.the Recirculation Spray System (RSS) pump cubicles
~in the Engineered Safety Features (ESF) Building, if the l
nonsafety-related sump pumps should fail to operate. This could result in the loss of both trains of RSS. [ Emphasis added.]
f NNECO has a history and a propensity to supply incorrect calculations and information in its assessments of safety systems.
.Such problems contributed significantly to the March 1998 debacle involving expansion joints in the safety-critical RSS system when
- the expansion joints were damaged by severe vibrations. Indeed, the identified Independent Corrective Action Verification Program (ICAVP) programmatic problems and trending in calculations and calculation control.-
1 CITIZENS REGULATORY COMMISSION
~l By:
A.a Nancy rton,,Esq.
147 r ss Highkay Red 'ng Ridge CT 06876 Tel. 203-938-3952 L
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