ML20233A859

Mothers for Peace Public Comment on Exigent LAR to Modify TS 3.7.5, Auxiliary Feedwater System

ML20233A859
Person / Time
Site:	Diablo Canyon
Issue date:	08/19/2020
From:	Swanson L Mothers for Peace
To:	Christopher Newport NRC/RGN-IV/DRP
Lee S, 301-415-3158
References
EPID L-2020-LLA-0176
Download: ML20233A859 (3)

Text

From: "Lucy J Swanson" <janeslo@icloud.com>

Subject:

[External_Sender] Re: Many more questions about AFW and pipe corrosion Date: 19 August 2020 10:43 To: "Newport, Chris" <Christopher.Newport@nrc.gov>

Cc: "Seeley Linda" <lindaseeley@gmail.com>, "Josey, Jeffrey" <Jeffrey.Josey@nrc.gov>,

"ZamEk Jill" <jzamek@gmail.com>

Thank you, Chris, for this very prompt reply.

We look forward to hearing from you or from Ms. Jeffrey in the near future. The plan to follow written information with a phone call is excellent.

Please note that I have added Jill ZamEk to the cc line. She is another Mother who is involved in our effort to learn more about these matters.

I hope you can enjoy a vacation without the combination of covid and smoke interfering too much, Chris!

Jane Jane Swanson janeslo@icloud.com On Aug 19, 2020, at 10:21 AM, Newport, Chris <Christopher.Newport@nrc.gov> wrote:

Jane, Thank you for the questions, all very good. As you can imagine, we have asked many of the same questions ourselves.

I am on vacation right not but we will work to get you a formal written response to the questions below as soon as we can.

Additionally, I would be glad to talk with you (and anyone else who may be interested) over the phone. Oftentimes a lot more information can be conveyed via a phone conversation than through a formal written response.

-Chris Newport Diablo Canyon Senior Resident Inspector On: 19 August 2020 10:07, "Lucy J Swanson" <janeslo@icloud.com> wrote:

Chris, Mothers for Peace has been looking further into issues related to PG&Es request to revise technical specifications for the AFW in order to assess and repair possibly corroded piping in Unit 1.

We have been in communication with people experienced in nuclear engineering and NRC regulation.

Here is a list of questions we have formulated. We would appreciate replies from you via email or phone. If you prefer phone, I request it be a conference call so that I can ask Linda Seeley and maybe a third Mother to join me. We are all trying to comprehend unfamiliar materials, so several sets of ears are a big advantage.

1. Why hasnt PG&E been monitoring pipe wall thicknesses on a regular basis? Why did it take a serendipitous notice of a leak to get PG&Es attention? The NRC long ago ordered plant operators to monitor pipe walls. See the first attachment, dated 1987.

2. The problem of thinning pipe walls is clearly a more serious matter than I could have surmised when listening to the discussion during the August 14th meeting. Thinned pipe sections that ruptured have killed 4 workers at Surry in Virginia.

3. Does PG&E really need an exigent tech spec before assessing pipe wall thicknesses in Unit 1and fixing any problems? It would seem that they should have been monitoring the pipes on a regular basis anyway. Waiting or delaying would seem to just add to the risk of pipe failure and resulting injuries - or worse.

4. The thinning pipe walls in Unit 2 were discovered because of a 3.9 gallon/minute leak in one of the pipes that was discovered when they were repairing a hydrogen gas leak (a serendipitous finding). How did so many AFW pipes on Unit 2 thin below ASME allowable limits without being monitored or noticed? If PG&E was implementing an effective pipe wall thinning monitoring program, these sections would have been detected and remedied before leaking water on the floor.

5. One of our advisors said this: "If the AFW piping has already degraded to the point where it has already lost structural integrity, then repairing the pipe while at power makes good sense. If you shutdown and cool down the reactor, you need to use AFW to supply feed water to the steam generators to cool the core. If there is concern that the AFW piping could rupture after AFW starts up, pressurizes the piping and feeds the steam generators during the cool down, it probably makes good sense to try to repair the problem without shutting down." Do you agree ?

7. What if PG&E finds that there is much more damage to the AFW piping in Unit 1 than they postulated? It takes 7 days to repair one AFW line. Aren't there 4 AFW lines? What if they are all thinned? Will the AFW be shut down for 28 days? Why would they surmise that they are NOT

thinned? Wouldn't common sense dictate that common conditions exist in both units? What are the dangers of having the AFW non-operational?