ML20080J735
| ML20080J735 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/13/1984 |
| From: | Stewart C JACKSONIANS UNITED FOR LIVABLE ENERGY POLICIES |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8402150175 | |
| Download: ML20080J735 (4) | |
Text
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4 February 13,1984
- 2CKCJD UNITED STATES OF AMERICA NUCLEAR REGULATORY COMhESSION
'84 Fu 14 P3:16 BEFORE THE A'IDMIC SAFETY AND LICENSING BOARD
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e In the Matter of
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MISSISSIPPI POWER & LIGHT
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Docket Nos. 50-416 COMPANY, et al.
)
50-417
)
h (Grand Gulf Nuclear Station,
)
Umu l ad 2)
)
SUPPLEMEhT TO JACKSONIANS UNITED FOR LIVABLE ENERGY POLICIES' REQUEST FOR HEARING AND PETITION FOR LEAVE TO INTERVENE Pursuant to an Order dated January 11,1984 of the Atomic Safety and Licensing Board in the above-captioned proceeding, Petitioner Jacksonians United for Livable Energy Policies hereby submits the Supplement to its Request for Hearing and Petition for Imave to Intervene filed November 17,1983, amended December 11,1983. The contentions which Jacksonians United for Livable Energy Policies seeks to have admitted in this proceeding, to be considered at first prehearing conference set for February 29,1984, are as follows:
JULEP 1: Petitioner contends that the Safety Evaluation on Amendment 10 to NPF-13, Grand Gulf Nuclear Station, Unit 1, unrealistically assumes perfect fuel.
The operators who installed the fuel currently in place had no significant experience in running this type of plant. Not a single member of the plant operating staff has previously held a commercial operator's license. (See Attachment No.1.) The NRC has expressed concern that these operators may have been improperly certified, a problem now under investigation. (See Attachment No.1.) This lack of experience and possible lack of satisfactory training and qualification make it much more likely that the cladding may have been damaged enough to affect safety criteria during insertion.
8402150175 840213 PDR ADOCK 05000416 G
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1 JULEP 2: The safety evaluation of the High Pressure Cooling System (HPCS), based on the questionable assumption of perfect fuel, leave's a problematic gap in safety performance.
The HPCS activates only at intermediate and high pressure. Imperfect fuel could result in fuel performance failure at a lesser pressure at which the HPCS would not a
activate. This problem is particularly pertinent during the lower pressule of start.up and testing conditions. Such a failure could cause fuel damage and lead to a release of radiation.
This would adversely affect the health and safety of JULEP member Dale Wallace, as well as many others in the area surrounding Grand Gulf. This measurable gap in safety should i
be addressed immediately.
JULEP 3: The safety evaluation of Amendment 10 in its entirety is unrealistically based on single failure criteria. That is, unless one thing by itself poses a danger to the public, the risk is not considered significant enough to address. This constitutes a serious short-coming of the evaluation and may well render it an ineffective attempt to accurately ascertain safety hazards.
Consider, however, just a few of the thousands of incidents that have occurred i
at nuclear power plants across the country:
- The 1979 disaster at Three Mile Island resulted in part from the failure of a i
valve to open, a leak in the steam generator, and a leak in the rods.
- In 1970 Commonwealth Edison's Dresden 11 nuclear power plant in Morris, i
l Illinois, released radioactive iodine into the containment vessel at 100 times the allowable concentration. The accident resulted from a false meter signal, a stuck monitor, and l
emergency core cooling system problems.
- In 1982 the Robert E. Ginna nuclear power plant released radiation after a pipe in the steam generator broke and a safety valve in the generator opened when it should l
have remained shut. During the seventies this same plant shut down several times due to l
a broken turbine block and numerous pipe leaks.
j
- In 1980 the Crystal River nuclear plant of the Florida Power Corporation shut down because of a loose electrical wire and a false signal.
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u 3-h is clear that multiple failures occur fiequently. This, in fact,is the source of many of the problems cecurring in the industry. To refuse to consider the possibility of more than a single failure is to ignore reality and serious potential safety hazards.
(wLk 0 - but Cylithia Ann Stewart Chairperson, JULEP 9
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION N. },go BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'84 f514 P3:16 In the Matter of
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CFFL:
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MISSISSIPPI POWER & LIGHT
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Oggh$* l50416 COMPANY, et al.
)
50-417
)
(Grand Gulf Nu lear Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " SUPPLEMENT TO JACKSONIANS UNITED FOR LIVABLE ENERGY POLICIES' REQUEST FOR HEARING AND PETITION FOR LEAVE TO INTERVENE" in the above. captioned proceeding have been served on the following as indicated:
BY INDIVIDUAL ENVELOPE WITHIN FEDERAL EXPRESS PACKAGE SEh"I' TO THE NUCLEAR REGULATORY COMMISSION,1717 H Street,N.W., Washington, DC 20555:
Herbert Grossman, Chairman Dr. James H. Carpenter Administrative Judge Administrative Judge Atomic Safety & Licensing Board Panel Atomic Safety & Licensing Board Panel Dr. Peter A. Morris Docketing & Service Section Administrative Judge Office of the Secretary Atomic Safety & Licensing Board Panel N.R.C. Staff Atomic Safety & Licensing Appeal Mary E. Wagner, Counsel Board Panel-BY HAND DELIVERY TO THEIR OFFICES, AS NOTED:
Mississippi Power & Light Company Robert B. McGehee ATTN: J. P. McGaughy, Jr.
Wise, Carter, Child & Caraway Assistant Vice President, Nuclear Production 925 Electric Building Electric Building Jackson, Mississippi Jackson, Mississippi BY FEDERAL EXPRESS PACKAGE SENT TO THEIR ADDRESS, AS NOTED:
Jessica H. Laverty Troy B. Conner, Jr.
Robert M. Rader Conner and Wetterhahn, P.C.
1747 Pennsylvania Avenue, N.W., Suite 1050 Washington,DC 20555 The copies were all sent or delivered by me this 13th day of February,1984.
bbb bbc Cynthia Ann Stewart Chairperson, JULEP
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g NUCLEAR REGULATORY COMMISSION WASHIN GTON. O.C. 20555 g;
-c>,r OFHCE OF mE COMMISSIONER November 10, 1983 MEMORANDUM FOR THE COMMISSIONERS
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SUBJECT:
MISSISSIPPI POWER AND LIGHT'S GRAND GULF UNIT 1 On November 7,
- 1983, Jim O'Reilly and members of our staffs.I visited Grand Gulf in the company of The plant is the' first BWR-6 with a Mark III containment in the United States.
I would like to share a number of observations with you:
1.
The plant has been held down for the last year and a half by two basic problems.
Design deficiencies in the drywell cooling system were identified during start-up testing.
Extensive modifications were required and these took from October 1982 to June 1983.
On October 20, 1982, Region II issued a Confirmation of Action letter (COA) that barred recriticality until serious deficiencies in the surveillance procedures and Technical Specifications were corrected.
Licensee compliance with this COA was completed in September, 1983.
The plant start-up program has been further delayed by a recent fire in a diesel generator room.
Not yet re;olved are newly discovered problems with the documental 1on of operater training qualifications.
It appears, operators may have been improperly certified.
Region II and OI are currently investigating.
The licensee has committed to raqualifying, if necessary, or recertifying the operators.
MP&L estimates that the retraining vill be completed and ready for Region II review approximately one month after the plant returns to cold shutdown.
Jim O'Reilly estimated that the Region II review would take about a month, assuming things went well.
2.
Grand Gulf has received two consecutive low SALP ratings in Plant Operations and Operational Preparation, and in Preoperational and Surveillance Testing.
These are the most important areas.
The next SALP, which was due to be started in August, has been postponed.
I believe the Commission should have an update on these ratings before any licensing decision.
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3.
Not a single member of the plant operating staff has previously held a commercial operator's license.
MP&L has hired temporary " advisors" with shift operating experience, as a way of plugging the experience gap.
The difficulty I see with this is that the advisors with experience have no direct responsibilities; and the licensed shift supervisors with responsibility have no experience.
The advisors are under contract to stay until the plant reaches full power.
I expect they will leave after that.
Not having had to go through a rigorous licensing process for this plant, it is unclear what they know of the plant specific details, both hardware and administrative controls.
Being temporary employees, they don't have a strong
- incentive to master these details.
I believe-that the Commission should establish minimum experience levels for each shift at Grand Gulf which would be required before full power license approval.
Specifically, there.should be an experienced shift supervisor on each shift.
I would give the utility the option to qualify the current advisors for this role by having them obtain an SRO license for Grand Gulf.
The staff should be prepared to give license examinations to the current advisors.
4.
A general observation:
NRC's approval of the advisor approach to dealing with the lack of experienced operators has resulted in the establishment of " body shops" for formerly licensed operators.
These body shops pay much higher salaries than utilities such as MP&L and LILCO for the operators who might be interested in changing jobs.
We are in effect encouraging experienced operators to become transients by creating jobs which offer them more money with less responsibility and less effort.
If we insisted on some number of permanent experienced operators at new plants, we would put the body shops out of business, and we would free i
up a pool of experienced operators for utilities.
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f, Victor Gilinsky 4
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