ML20084N307

Discusses 831025 Petition Requesting That Util Be Required to Show Cause Why OL Should Not Be Suspended.Licensee Should Be Asked to Take Essential Actions to Address IGSCC Problem

ML20084N307
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	05/10/1984
From:	Richardson C VERMONT PUBLIC INTEREST RESEARCH GROUP
To:	Palladino N NRC COMMISSION (OCM)
References
NUDOCS 8405160466
Download: ML20084N307 (3)

Text

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' Vermont Public Inttr:st Res: arch Group,Inc. 43 Stat 3Str :t.M:ntp:ll:r.V rmsnt05602.(802)223 5221 VPIRG:t UFri:.E r 00CKETy,. N E.~

May 10, 1984 5" ANCR Nunzio J. Palladino, Chairman United States Nuclear Regulatory Commission -f f

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1717 H Street , NW - Room 114

...'...e Washington, DC 20555 3

RE: Docket No. 50-271/ Vermont Yankee /

VPIRG/VYDA 2.206 Pe ition - 10/25/83

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Dear Chairman Palladino:

On October 25, 1983, the Vermont Public Interest Research Group (VPIRG) and the Vermont Yankee Decommissioning Alliance (VYDA) submitted a petition, pursuant to 10 CFR 2.206, to the United States Nuclear Regulatory Commission (NRC) requesting that the Vermont Yankee Nuclear Power Corporation (VYBPC) be required to show cause why its operating. license for the Vermont Yankee Nuclear Power Plant (VYNPP) should not be suspended. VPIRG and VYDA asked that the licensee be ordered to take essential actions to address the Intergranular Stress Corrosion Cracking (IGSCC) problem' at the VYNPP and to provide reasonable assurance that the facility could be operated safely.

The petition asserted that inspections performed at the plant by the VYNPC were inadequate because the licensee used an unreliable Ultrasonic Technique (UT) testing method and a consultant Mag-naflux, Inc., that har' performed inadequately in simulated testlng studies (See EPCI - 1570 - 2, August 4, 1983) for ' deter-mining IGSCC indication size. The groups also contended that responses to inspection results, such as weld overlay repairs, were insufficient because they were based on unproven data. Additionally, they pointed out that the NRC staff and the Advisory Committee on Reactor Safeguards were in disagreement about the implications

-RECdL CH.:.y;pf the pipe cracking problem and the reliability of UT testing at Boiling Water Reactors (BWR's) which created serious questions about the nuclear industry's management of the problem.

14 ten e< 2_: U Harold Denton, the Director of the NRC Office of Nuclear Reactor Regulation denied the petition in a letter dated April 16, 1984.

He concluded that, "no adequate basis exists to take the requested action at this time." In waiting nearly six months to rule on the VPIRG/VYDA petition, Mr. Denton failed to fulfill the-intent of 10 CFR 2.206 (b) which states that the Director of the NRR, "shall institute...or shall advise...within a reasonable time..."

8405160466 840510 PDR ADOCK 05000271

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VPIRG and VYDA believe that there are sufficient grounds to require a show cause proceeding on the VYKPP operating license. Although they are well aware that 10 CFR 2.206 (e)(2) precludes an appeal, per se, of the Director's decision, they ask that the Commission institute a review on their own volition of NRC and nuclear industry management of the IGSCC problem because current policies have not dealt effectively with this important issue. Moreover, the consequences for nuclear safety and economics are likely to be severely adverse due to the mishandling of these problems. A review of the decision in this case would be , of course, a necessary component of the Commission's review.

Pipe cracking at the nation's BWR's currently affects at least 18 of 23 older operating units. Despite the fact that it has been common knowledge for decades that non-conforming stainless steel material is prone to IGSCC, most plants continue to operate with substantial portions of their Primary Pressure Boundry Systems containing corrosion susceptible metals.

Many of these plants have known damaged primary cooling components,;

ard measures taken by industry to mitigate the hazards posed by leaving these compromited systems in service, thereby justifying continued operations, such as by the installation of leak detection equipment and relying on the unproven " leak-before-break" theory, do not provide a reasonable assurance of safety.

The only sensible course would be to require replacement of non-conforming metals with low-carbon materials designed to be IGSCC-resistant. Although many NRC staff members have recommended this approach,. top management has been reluctant to take this impcrtant step. Instead they have continued to recommend more incomplete and unreliable repairs which are both risky and costly.

In 'the case 'of the VYNPP, economy and safety walk hand-in-hand r because~early replacement is the cheapest, as well as the only proven method of assuring system reliability. In Vermont,ffor example, it will cost the utilities at least $17 million more in replacement power costs alone-to replace'the Recirculation and Residual Heat Removal System-in the current September 1985 schedule, than if the work was performed this summer--due to interium actions, power supply and in#1ation considerations, according to_the Vermont Department of Public Service.

Finally, we belkye that the situation is too important for the Commissioners to rely wholy on staff recommendations. A review of the comments made by the Commissioners at meetings with the NRC staff.on IGSCC concerns,.shows occasions (e.g. November 9) when members were dissatisfied with staff handling of the issue.

That concern should be-followed to its natural conclusion. Clearly, a more thorough review is needed.

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page 3 May 10, 1984 Respectfully submitted, g h c kW ~

Cort Richardson Nuclear Project Director Vermont Public Interest Research Group CR:gh on

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