ML20083E507
| ML20083E507 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/27/1983 |
| From: | Lewis M LEWIS, M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| REF-GTECI-A-49, REF-GTECI-RV, TASK-A-49, TASK-OR NUDOCS 8312290246 | |
| Download: ML20083E507 (4) | |
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UNITED STATES CF A: ERICA
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NUCLEAR RIT,UIATORY COMV.ISSION 1
3: fora thi Atomic Safety ani Licemine Board In the matter of Phiahielphia Elect.ric 'ospany Dockets Nos. 50- 352 and 53-35E.E5f'kE (LimerickCeneratingStation, Units 1 and 2)
'83 DEC 27 Pl2:28 Intervenor Iewis' Motions based on NEWLY RECEIVED INFOR7.ATION M7PIONF :
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- 1. Reconsideration of previously summarily disposed Contention I-62'3Cn: dig i MJ~
ERANCH
- 2. Acceptance of a new contention
- 3. Certification to the Commission of a question 4 Clarification to the ALAB that Contention I-62 is a major part of this hearing
- 5. Any and all other contentions, motions and appeals thAt ray properly preserve Intervenor's rights on this record.
Backcround:
Intervenor has fought long and hard to have the Contention on the problem of Presa:rized thermal shock heard in this proceeding. The NRC has a:imitted to the problem of FTS in IVRs but has not allowed the problem of FTS in 3 yrs is substantial.
On Dec 2,1983 a M and O from the AIA3 (dated hov 30,1983) was delivered to Intervenor denying my appeal of the Summary Disposition as " interlocutory."
On or about Dec. 7,1983, The M and O from the ASI3 on Limerick was received denying reconsideration and gra & g Applicant's Suuary Disposition of Contention I-62.
Part, and in intervenor's view-much, of the reasoning of the Board to grant Applicant's Summary Disposition was that Intervenor~ could not provide data actually generated for BWRs such as Limerick.
Subsequently to the receipt of the above M and Os, just such data arrived at the Intervenort door in the form of a submission by the Applicant. The data was in the reports," Common Sensor Failure Fvaluation Report" dated August 93 and delivered to Intervenor 12-15-83, and " Control Systems Failures Evaluation Report" dated September 1983 Both these reports were prepared for the Applicant by the General Electric Company, Nuclear Inergy 3usiness Operations, n.n Jose, California, 95125, and authored by Dr s.H.Slivinsky.
Intervenzeis perplexed that this very succinct and particularized report was not presented to Intervenor during discovery although it was obviously being reviewed within the Applicant's organisation during the discovery period ofr Contention I-62.
Intervenor believes that his discovery rights were abritiged in that this document was within the Applicant's organization during, discovery on ontention c
I-62, that this document was pertinint to discovery on entention I-62, and that this document.was not delivered to Intervenor until after all appeal routes on the *ummary Disposition of Contention I-62 were exhaucted.
8312290246 B31227 PDR ADOCK 05000 G
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How do the aforementioned reports immet and relate to Contention I-62?
Further this "new information" must be directly applicable th the q FIS in 3WRs such as Limerick.
herein are not comprehensive or all inclusive. They are merely demonstrative.B
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Example 1. In the M&O of Dec 7, 1983, The ASIB finds,"The Staff has accepte d the reactor vessel resulting from a malfunctinn during the co It also has accepted the. reportedestimate of 12 5 psi 3ressure rise.
offered nothing to cause us to reject this position."
a
..Intervenor has
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At the time of the M&O, Mtervenor could not offer anything to cause the Board to reject the Staff's acceptances because intervenor did not have the
'new information' in theGE reports. Specifically, Intervenor points to table, Criteria for Elimination of Systems and Components of Systems from
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Control System Failure analysis." See Elimination Criteria N2" Operator actions
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as a result of indications are not considered control functions for the control system failure analysis." and N5" Systems or components which cannot affect reactor parameters within 30 minutes of the loss of any power bus or combination thereof "
g And especially N6," Systems which are not used during normal power operations E
For example, startup, shut down and refueling systems not used during normal operatio may be eliminated (from control systems failure analysis)."
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The above quotes provide several reasons to reject the Staff's acceptance of 5
a 12.5 psi pressure rise during a rod drop accident during startup or hydrotest.
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Hydrotest is done in a full solid condition. *he reactor is filled up with water M
and jressurized to a certain value. Often certain valves are ' tied down' so that 5
they will not lift and ruin the test. By the admissions in the gg 1.
hydrotests are done during shutdonn.*ontrol systems are not analyzed for failur GE report 55 55 normal operation and I don't believe that the Tech Specs allow for such.It's difficult M
2.
Operator actions are not considered
?!!!
This means the same situation can occur at Limerick that has occurredpart of the cont Z
during the accident at TMI#2.
AIJ Brenner is very familiar with this accident as he was law clerk to the Chairman of the Board for the TMI Restart Hearings.
Namely that' operators can act inappropriately intensifying the accident and that inappropriate operator action is 9
not analyzed.
5 3.
Systems of components which cannot affect reactor parameters within 30 minutes of the loss of any power bus e combination therst.
y This 30 minutes is entirely ' arbitrary and does not square with previous accidents E
The above specifics demonstrate that the GE reports were 1.
pertinent to the Contention I-62 and
(.M 2.
provide several reasons to reject the staff's acceptance of a 12 5 psi y@~5 pressure rise during a rod drop accident.
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3 Example 2. PAO Dec,7,1983 the ASIB finds? It (the Staff) cencluded that violation of pressure limits in a 3WR startup could only occur if water level was not adequately controlled."
Adequate control is the subject of Chapter 4 Page 1-0054 of the GE Report," Common Sensor Failure Evaluation Report" dated August 1933 and prepared for the Appliaant.
Specifically Instrument lines 6and 7
,"A break in this line will cause an increase in feedwater folw. without operatir intervention, this could lead to a high water level scram." As discussed in Example 1, inappropriate operator intervention is not analyzed. A similar case can be made for lines 13 thru 16.
Here we have all the elements spoken of by the Staff as needed for a violation of pressure limits:
- 1. A BWR start up
- 2. inadequate water level control due to lack of analysis to see about the operator's actions in the face of a common sensor line break.
The above specifics demonstrate that the GE reports were
- 1. pertinent to the Contention I-62 ani
- 2. provide several reasons to reject the Staff's acceptance of a 12 5 psi pressure rise during a rod drop accident,startup or common sensor failure.
Example 3 The ASIS finds,"Thus there is no basis for arguing that the pressure in the L merick BWR RPV doesnot have to follow the steam water saturation curve as far i
as FIS is involved, because of the possibility of external flooding." This fin:iing directly contradicts the e1% h tion criteria discussed in Fxample 1.
perhaps ilooding is unlikely, but it is not impossible under the eliminatbn criteria from control system failure analysis. Specifically, any system that will not affect parameters of reactor pressure within 30 minutes are not considered.
A control system that would flood the reactor vessel could fail and not have been analyzed by the admission in this table (N5).
There fore this report does provide a basis for arguing that external flooding could cause the FIS problem in the Iiaerick IER. Further, the above specifics denonstrate that
- 1. that the GE reports are pertinent to Contention I-62 and
- 2. that the GE reports provide several reasons to accept the possibility of external flooking and consequent FTS problems at the Limerick 3irn.
Finally the question of Fluxes must be met.
Here the Board provides insurmountable tests to the Intervenor and full succor to the Applicant.
That historic data is ranging all over the place does not sway the Board from finding in the Applicant's favor.That predicted and actual fluxes at Peachbotto*m differ by 40fo does not sway the Board. Apparently the Soard believes that if a number is inaccurate, it is therefore " conservative."
Intervenor's problem is further compounded as the instrumant lines for the flux are not analyzed because the do not meet the criteria to be' analyzed.
Therefore the Applicant could say about anything and would be accepted due to the Boards' previous rulings for the Applicant.
Intervenor admits that he cannot meet the Board's tests as far as the issue of fluxes are involved, but objects to the Board's tests on the basis of unfairness.
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Fir. ally Intervenor wishes to bring a IE Notice to the 3 card's attention.
IE Information Notice No. 83-8 2". Failure of safety / relief valves to open at BWR final report." This failure of BTR safety relief valves to lift adds credence to a FI? at a 3WR, A FIS could occur if safety relief valves failed to lift caus&ng a hot reactor to go solid.
Only the area of water injection would be coiled providing all the necessary ingredients for a FIS.
Sur. mary:
On the basis of the above, Intervenor respectfully requests that
- 1. Contention I-62 is retreived from Summary Disposition and reinsta6ed with an extended discovery period to provide discovery for the new information in the GE reports.
- 2. that any new material which surfaces shall be allowed to provide new contentions where appropriate 3
that in the alternative the question of PTS in SWRs such as Limerick be certified to the commission 4
that in the alternative if rejected, that Contention I-62 be clarified to the AIAB as a mojor part of this hearing for Limerick.The basis is that this is the only contention -
. wli:h goes to the basic issue of poor design.
- 5. In the alternative, Intervenor respectfully petitions the Board as to direction in determining what other rights he might have in this confusing and unfair world'of adiinistrative law.
Intervenor will send this Motion out on 25 Dec 1983. I received IE Notice 83-82 on 23 Dec S3 adn the GE reports on 15 Dec 83. That's why I have to send my Motion out on 25 Dec 83, to the whole distribution list.
I wish everyone a Happy Holiday.
Respectfully submitted,
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Marvin I. I4wis 215 cU 9 5964 G
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