ML20136E945

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Forwards 970122 Ltr from R Wise Re Inspection & Review of Allegation RIV-96-A-01 26A.NRC Resolution of Concerns Also Encl
ML20136E945
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/30/1997
From: Blanch P
AFFILIATION NOT ASSIGNED
To: Jun Lee, Mulley G, Zwolinski J
NRC (Affiliation Not Assigned), NRC OFFICE OF THE INSPECTOR GENERAL (OIG)
Shared Package
ML20136C110 List:
References
NUDOCS 9703130385
Download: ML20136E945 (5)
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From PAUL BLANCH <PMBLANCH61x.netcom.com>

, To s , WND2. WNP3 ( j a z ) , TWD1. TWP4 (gan) , WND2 . WNP4 ( j x13 ) , KPD1. . .

Dates.

1/30/97 12:58pm subjects songs i f

Dear concerned whistleblower..

1Please respond to me or.to the NRC if'you care.

Paul ,

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+

! UNITED STATES )

NUCLEAR REGULATORY' COMMISSION 1
REGION IV 611.RYAN PLAZA DRIVE,. SUITE 400 ,
ARLINGTON, TEXAS 76011-8064 l

4 January 22, 1 997' 4

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Paul M. Blanch-1 35 Hyde Road West Hartford, CT 0611 7 '

s

Dear Mr. Blanch:

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Reference:

' Allegation No. RIV-96-A-01:26A l .This is in reference to Ms. Jean Lee's May 16, 1996, letter which

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acknowledged receipt of,your electronic mail regarding spent fuel j

-activities at San Onofre Nuclear Generating Station.-(SONGS) Unit  !

. 1. Additionally, the letter advised you'that Region IV had  :

' oversight. responsibilityLfor SONGS, and that Region IV would be  !

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conducting' appropriate review or inspection follow-up and that you would be advised when Region IV had completed its review.

During our' inspection and reYlew of your concerns we considered the SCE findings. Our inspection was completed and our findings are summarized in the Resolution of Concerns, enclosed with this letter. Your concerns are underlined and NRC findings are in bold text. Additionally, enclosed i'or your reference and

'information is a copy of NRC Inspection Report 50-206/96-06 that documents our inspection at the SONGS Unit i facility.

Although you may find that the'NRC'was not able to fully substantiate your concerns, this does not necessarily mean that we find the-facts as you stated them to be untrue. It means only that we were unable to obtain objective evidence to corroborate your statements through interviews, document rVith) }D 9703130385 970306 PDR ORG NRRA

l reviews, and/or direct observation.

We believe that our' actions in this matter have been responsive to your concerns. We take our safety responsibilities to the public very seriously and will continue to do so within the bounds of our lawful authority. Unless NRC receives additional information that suggests our conclusions should be altered, Region IV plans no further action on this matter except as noted for our review of the NOB-LOCK membrane issue.

Sincerely, Russell Wise Senior Allegations Coordinator

Enclosures:

As stated cc w/ enclosures:

Allegation file RESOLUTION OF CONCERNS

Reference:

Allegation No. RIV-96-A-0126A 1 . The SONGS Unit 1 Spent Fuel Pool has numerous spent assemblies with broken pins, degradation of all of the spent fuel assemblies continues uninterrupted as there is no approved means to ship the assemblies off site.

Section 4 of NRC Inspection Report 50-206/96-06 documents the NRC review of spent fuel pool activities and the inspection concluded that SONGS Unit 1 was in compliance with all limitations and requirements established in the Permanently Defueled Technical Specifications.

Southern California Edison's review concluded and reported on August 1 6, 1 996, that presently, there are a few known failed fuel pins located in the SONGS Unit 1 spent fuel pool (SFP).

However, a routine analysis of the SFP water indicates that there has been no further degradation of the fuel cladding while it has been stored in the SFP. There are no known loose fuel pellets on the floor of SFP. In the mid 1980's, a visual inspection of the SFP floor was performed which confirmed the absence of loose fuel pellets.

Your reference that a concerned individual discussed this concern with his management but was dissatisfied with the response, and the concerned individual's immediate manager engaged in l intimidating conversations with the concerned individual was not reviewed.

_ _ _ . _ . _ _ . _ _ _ _ _ _ _ _ . _ _ . _ . _ . = _ _ _ - - _ . . - _ _ _ _ _ _ _ . _

NRC reviews all concerns of harassment and intimidation (H&I).

However, the identity of the individual who was the subject of HEI is required before NRC can conduct an investigation to determine if H&I occurred.

2.

There have been numerous leaks of radioactive water from the stainless steel-liner of the SONGS 1 SFP. Although the pool employs a leak = detection / collection system, it is known that failure of operating personnel to monitor this system has-resulted in radioactive ' contamination of a 480 volt room structure wall near the pool and local contamination of soil near the pool (boric acid crystals have been found in outside soil surface areas near the Pool). The exact extent of contamination is unknown and it is possible that an underground t radioactive Plume may be migrating away from the pool to the

! beach- , underground water'supplias, etc. ,

In October 1994, the NRC conducted a team inspection to review the potential forcleaks from the dTP and to determine SCE's ability'to detect such leaks. The inspection determined that there have been leaks from the SFP liner at various times and the leakage was the source of' contamination of the 480 volt room wall. No evidence was found that- boric acid crystals were identified on outside soil surface. areas near the pool.

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RIV-96-A-0126A The potential impact of' soil contamination resulting from SFP j leaks was also considered. Based on our review of the j i information obtained by SCE during our 1994 inspection, we l understand that water has been leaking into the SFP monitor '

well. (The term " monitor well" can be misleading because the SFP monitor is a leak detection system designed to catch and prevent any leaks from contaminating the outdoor soil,-and is not a groundwater monitor well.) There were not indications of leaks to the soil around the. buildings, but this cannot be verified  !

because no groundwater monitor wells exist in the area.

However, we have found that SCE has provided reasonable assurance that SFP leakage is not currently contaminating the soil around the buildings for the following reasons. SCE has taken steps to maintain the water level in the monitor well l below the groundwater table. As a result, the hydrostatic head of the groundwater would tend to result in groundwater leaking into the monitor rather than the slightly contaminated water leaking out of the monitor. This is consistent with j information contained in the March 10, 1995, submittal which l ' documents the water in the SFP monitor well has about half of i the tritium activity as the SFP, indicating that= it is some l combination of groundwater in-leakage and leakage from the SFP.

, To prevent leakage of spent fuel pool water into the ground and i ultimately into the beach and underground water reserves, a i waterproof membrane 40 mils thick, known as Amercoat Corporation l l iNOB-LOCKi was placed under the SFP bottom slab and on the pool l

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walls below grade.

( The membrane was not installed above elevation 1 21-01. The membrane and installation were'in accordance with Specification-l 'BSO-2576 which cannot be found in the SONGS documentation' There has been no system, testing: done for the membrane.known The environmental membrane hasqualification been in service

for approximately 30' years, has likely experienced degradation.
Its exact condition is unknown.

i The SCE review determined that there are no local water supplies-in the immediate vicinity of the site. Water is l

imported from the Tri-Cities Water District and the Camp Pendleton groundwater supply is upstream from SONGS.

Groundwater has a seaward gradient which indicates' the water flow-is toward the ocean.' Therefore, a radioactive plume from L SONGS could not move towards any local water supplies.

SCE has concluded that although the condition of the waterproof )

membrate is not empirically known, engineering judgment  ;

considers the membrane to be intact. It is unlikely that the 1 membrane has deteriorated.because of its underground conditions. I Membranes do not generally deteriorate unless they are subjected I to sunlight exposure and dry-wet cycles.

NRC will verify with the licensee that there are no other uses intended for'the membrane that are not stated in the FSAR, 1

RIV-96-A-0126A but.may be a part of the plant's licensing basis. We will provide you the results'of our inquiry at a future date.

Since the pool stainless steel liner has experienced corrosion resulting in leakage, it is inevitable that the stainless steel fuel cladding will also degrade with time greatly increasing the probability of transport of fuel = fleas to the pool water and the environment.' The corrosion could weaken the cladding to the point that massive disintegration of fuel-pin- structure would occur in a major seismic event. This would contaminate the pool extensively resulting in a major cleanup: effort and possible offsite effects. In the worst cases, both the fuel and pool structure .would' experience' failure in an earthquake resulting in unacceptable offsite doses to the public.

SCE has reported that eight commercial nuclear power plants have used, or are using, stainless steel-clad uranium dioxide fuel.

Those reactors include four boiling-water. reactors and four pressurized-water reactors. Investigations of commercial spent fuel performance indicate that there was no evidence of stainless steel cladding degradation during fuel pool storage.

J SFP chemistry-is closely' tracked to ensure that water quality is l

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maintained. As long as the strict chemical limits are maintained, degradation of the fuel cladding is not expected.

(See Section 4 of NRC Inspection Report 50-206/96-06).

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.Section 9.1.2 of the Updated Final Safety Analysis Report for San Onofre Nuclear Generating Station Unit i documents that the spent fuel pool racks which hold the' spent fuel are designed to withstand a seismic event.

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Paul M. Blanch j Energy Consultant l 135 Hyde Rd.

West Hartford CT 06117 Tel: 860-236-0326 Fax: 860-232-9350 l

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