View source for 05000352/LER-1985-080, Motions to Reopen Record on Contentions V-3a & 3b & to Stay Operation of Unit 1.LER 85-80 Reported Potential Threat in Possible Failure of Cooling for Control Structure Affecting Safe Shutdown of Plant

{{Adams
| number = ML20138R301
| issue date = 11/12/1985
| title = Motions to Reopen Record on Contentions V-3a & 3b & to Stay Operation of Unit 1.LER 85-80 Reported Potential Threat in Possible Failure of Cooling for Control Structure Affecting Safe Shutdown of Plant
| author name = Anthony R
| author affiliation = ANTHONY, R.L., FRIENDS OF THE EARTH
| addressee name = 
| addressee affiliation = NRC ATOMIC SAFETY &amp; LICENSING APPEAL PANEL (ASLAP)
| docket = 05000352, 05000353
| license number = 
| contact person = 
| case reference number = CON-#485-179
| document report number = OL, NUDOCS 8511180533
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PLEADINGS
| page count = 3
}}
{{LER
| Title = Motions to Reopen Record on Contentions V-3a & 3b & to Stay Operation of Unit 1.LER 85-80 Reported Potential Threat in Possible Failure of Cooling for Control Structure Affecting Safe Shutdown of Plant
| Plant = 
| Reporting criterion = 
| Power level = 
| Mode = 
| Docket = 05000352
| LER year = 2085
| LER number = 80
| LER revision = 
| Event date = 
| Report date = 
| ENS = 
| abstract = 
}}

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U.S. NUCLEAR REGULATORY COMEISSION ... ATOEIC SxFSTY & LICELSIhG AFFLL SOArJ Docket No. 50-352,353 OC REs PHILA. ELEC. CO. Limorick Gsn.St2. Units 1 & 2.                       Novonbor 12,1985 t
MOTION BY h.L. ANTEONY/F0E TO TriE APPEAL BOA'.tD TO REOPEN THE RECORD ON OUR CONTENTIONS V-Ja and 3b IN TEE LIGHT OF NEW INFORMATION IN PECO,'s LETTER OF ITSI- REACTOR.
10/31/ 5 to the BOARD,        AND MOTION FOR A STAY OF OPERATION OF'UY. kc A letter to the Board from PEco, dated                            copy   of Licensee 10/31/85, Event Report # 85- 80 which was recorded on 10/8/85            enef83e The new c        g   hte8 g orded was that (p.A-2) "a potential existed for the occurrenceZof an operating condi-
                                                                         ,e J y y
* tion not covered by the plant's operating or emergenc; procekdIr              s,pecifically the loss of both redundant Control Structure Chilled Water Systdt:s".
EXISTING SAFETY RAZARD         We wish to inform the Board that this potential is one which threatens us and the public because of the possible failure of cool-ing for the control structure and resultant loss of essentini equipment for esfe shutdown of the plant.        As the LER warns (1-2):
because the loss of both of the chilled water systems had not previously been postulated, plant procedures did not address actions to be taken to assure the existence of appropriate environmental conditions within the Control Structure following the event.
We concur in PEco' admission of the gravity of this situation by its letter andN rwarding of the LER,but we emphatically disagree with PEco "that no further consideration of this matter by the Atomic Safety and Licensing Appeal Board is neceesary ". we assert that the decision of the Licensirig Board in the second PID in favor of the Licensee, (L3P-94-31 ) in so far as it was based on findings from the evidence presented on our contentions V-3a and V-3b, is now disquelified becauce of the new infor=ation included in LER 65-60.
L3's authorization of a license to operate the plant for the ssee reason is not now valid since L3 found that flooding of the Control Building end the disabling of the cooling system          equipment,essentiel for safe shutdown,was not a possi-bility.      LER 95-50 now finds this pos-ibility an istediate one,without any sure l
procedure for offsetting its effects.
Since the Board in its decision,ALAB -819, affirmed LEP-84-31 on 10/22/85, it cust also reconsider its decision and suspend it until trere have been l
further hearings on contentions V-3a,3b based on the infor rtion in LER 65-30.
lle cove that the Bo+rd suspend ALAS-519 and reopen the record or 7-3a,3b,rnd we -ove,further, th?t the Bosrd stry the operetion cf Unit I until there is a determination from this       renewed hearing that flooding nill not prevent cafe shutdown of the reactor.
(1.3 CRITERIA FOR REOTENINC TEE RECORD.       We assert thet our motion to reopen is tice-ly since it was not until 10/31/S5 we or the Board knew of this potential threat which is not covered by the plent's operating or emergency procedures. (2.)
The diabling of the chilled water pumps could leave the control building with               ;
uncertain cooling facilities for tre Main Control Rope, Auxiliary Equipment 2com, A-3 Energency Switchgear Roots end Bettery (85-90 Rooms.,r he lo)ss of these rooms and the t
B511180533 851112                                                                   l
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squipment and parsonnel involved,bacaucs of cxcessiva h0at.could pravant safo i   shutdown in en catrgancy and preCOnt the possibility of ths r: actor operating out of control. There could he no more significent end fundamental safety is e ue than this. (3.) A differtnt decision would heve been remehad on contentions
     " 3e,3h if the hearing had revealed this new potential for the disablins of the Coatrol Building cooling by flooding from breaching of the cooling tower basins throuch collapse o! the toners.       LB would have had to consider mitigating action to prevent this by accepting two of the remedies called for in our conclusions Isee Anthony /F0E Iindings , submitted to L3 5/2/84, p.9 )
: 2. Remove  the h=:e.rd of the pipeline erT1 osions by ordering their relocation..
: 4. Protect the turbine building and the reactor building from flooding from cooling tower pond rupture by a dike across between towers and plant.
FR$IOUS TESTI%05Y 03 BREACliILG OF BASINS M D FLOODING OF CONTROL EUILDILG .
During the crossexaminetion and testimony before LB on 3/22/84 four tiRC staff witnesses, Kuo,Romney,Tescott,and Lefave, recorded in the notes of testimony significant consequences that would result from a pipeline explosion (or from a railroad explosion or tornado of similer force).(Transcript pp. 9240 to 9394.)
Both cooling towers would collapse and the falling sections would open breaches in both tower basins 50 feet wide. Each basin holds 7 million gallons of inter.
The basins would lose helf of their contents in 6 minutes; some water would drain east and some west,the rest would flow dcwn to the plant and pool et the turbine building. The NRC witnesses testified that there would be no edverse effects on the    control building because the water could not enter.
Our c'ntentions V 3e.,3b must now he reconsidered becauce FECo says in LEn 95-80    thet weter can enter .nd diseble the chilled water pumps,cupecie.lly via unit 2 construction openings. The effect of cooling tower basin breacnes has to be evaluated in new hearings. This subject also encompe.sses an aspect of our contentions which concerned the tensions and hazerds to safe operation of unit 1,in operation,while unit 2 is not loeded and partially constructed. It now hes been reverled by PECo th .t pe thesys     td entrances exist w 5.ich cen allow flooding from unit 2 to unit 1.       This h-card to sefe enerttion and s?fe shutdown of unit 1 is e pa.rt of cur contentions. It tuet te e part of reopened he rin~s .
INADE :UATE PECO MDIES & D PROCDUR3S VS FLOODIWG AND LOSS OF CCSTROL BL. COOLING.
The following analysis deconstrates that the protection PEco has provided agsinst the flooding of the control building,es set forth in LEE 85-80,as a re-sult of a pipeline explosion.collepse of both cooling towers and the breaching release of the tower basina is not capable of holding back phe(8s-SO,p. A-3)of 7 million g.11ons in six minutes. Uor is  the use of"purce"  fan operation  a reliable elter-native to protect the sensitive control equipment from overheatin6 and failure,

thoroby oli=inating tho Ecans for cafe shutdo:n. In the hearings bcforo L3 on I     our contentions (cbove) the NRC eitnsecos accepted our scenario of eimultansous effects from a pipeline explosion (or tornedo,or railroad explosion) which would combine the collapse of both towers,the breachinc of both basins and other de=ege to structures such es the turbine building. The new inforcetion in PEco's LER 85-80 shows the vulnerability of the unit # 2 structure,(p.A-2) in thet During the evaltation for the proposed modificetion,the incomplete construc-tion of certain b.rriers to water intrusion in Unit 2 was recognized.
The possibility of thic intrusion of water into the control building through flooding into unit       2 was not considered by tha URC witnesses because the open-ings in unit #2 were not an issue.          FECo now says the t (LER 85-90, p.A-4 )
The cause of tre condition w s personnel error in incorrectly evaluating and deferring the grading an d feiling to recognize the safety significence of te=porary construction openings.
The heating record must be reopened and evidence weighed on this new safety hazard. Further= ore,the corrective =easures have to be evaluated in e heering.
There is no present assurance that PECo has considered simultaneous(85-80,p.A-5                                                effects froc )
a pipeline explosion nor that such en explosion would not blow openings despite Necesssry engineered berriers(having) have been installed in the Unit 2 con-struction openings and higher curbs (have been) instelled at permanent plant eccessways to assure that floodwaters will not enter the control structure to the extent (emp.added) that the loss of safety-rele ted eqtipment will result.                                                          l PECo appears to accept the inevitability (above) of floodwaters in the oon-trol building,nerely trying to limit the " extent" of flooding. This does not i
seem to us to be e responsible approach to protectinc vit 1 plent shutcown equip-ment. And sandbers set up as e te=porery barrier in erpectation of unusuel rain, es in September for hurricane Glorie (85-so,p.A-5) is not                                                          solution of the threat of flooding which satisfies          NRC's sa fety regulations.                                                  Nor could a sand-bag be.rrier be expected to withstend the force of 7 million callons in six cin-utes released from the tower besins. Our propos 1 of e per e nen t b=_rrier cust be reconsidered in re-opened safety hearings.
Further evidence of the vulnerrbility of openings between Unit 1 end Unit 2
,        is included in NRC inspection S5-30,1-ted 10/21/55 (rers.( 1.1-3 } which deteribes a leak of redioective water free unit I radnecte tc unit 2 pipe tunnel and eccess root,to the depth of 18 inches, 8/1-2/65. The report includes these el?rming corrents: (6.1 3).."it wes not det'rmined how or when this ve.lve had been opened
         ...(it) mey heve been overlooked in the valve lineup procedures because it was thought to be e Unit 1 velve...(6.1.4) the potential for more serious concerns eristed.."
There is no substentiation in 85-80 (p.A-3) for PEco essertions: "elterne-tive means and sufficient time would have been av=ileble to recove he?t from criticel erenc of the control structure" end "these reek te=peratures would only be sustained for e few hours...the electricel conponents..would be able to fune-tion as designed." Ve assert that a scenrrio of 90 outdoor tempereture for 10 to 20 hours must be assessed as one of the fscterc against such cooling,in a re-newed hearing i        ce s:THC Ste.f f Counsel.LB, Docketing , PECo, l   *
* F.Romeno,Others on Serv. List,                                                                           [h'ecrec.tfullycbmitted,Cr b (~ 4                '
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Bor le6 Moylan,Pa.19069
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