ML021900648
| ML021900648 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/03/2002 |
| From: | Lochbaum D Union of Concerned Scientists |
| To: | Grobe J, Hackett E Office of Nuclear Reactor Regulation |
| References | |
| Download: ML021900648 (9) | |
Text
Union of Concerned Scientists Citizens and Scientists for Environmental Solutions Jrul\\ 3. 2002 Mr..John A. Grobe. Chairman Davis-Besse 0350 Panel United States Nuclear Regulatory Commission 801 \\Varrenville Road Lisle. I1, 60532-4351 Mr. lE.dwin Mi. llackctt, Assistant T'eam Leader Davis-Besse Reactor Vessel Head Degradation Lesson-Leamed Task Force United States Nuclear Regulatory Commission Washington. DC 20555-0001
SUBJECT:
DICKENS OF A STORY: GHOSTS OF PAST, PRESENT, AND FUTURE AT DAVIS-BESSE
Dear Mr. Grobe and Mr. Hackett:
The Union of Concerned Scientists (UCS) continues to examine the Davis-Besse near-miss loss-of coolant-accident. We recently obtained a number of documents from the NRC's Public Document Room that shed additional light on the matter. In case our review doesn't cover ground you have already been over, we are passing along things we have discovered to the Davis-Besse 0350 Panel and the Lessons Learned Task Force. We have not enclosed the source documents. Since we obtained them from the NRC's Public Document Room, we assume that they are readily available to you. If you have any problems fetching the documents, let me know and I can send along copies.
What Does the NRC Mean by "Acceptable"?
In its Final Root Cause Report dated April 18. 2002, First Energy reported that the NRC had inspected the boric acid corrosion program at Davis-Besse and judged it acceptable. This conclusion appears to have been based on this NRC statement:
"The purpose of this letter is to advise you that our audit of your boric acid corrosion prevention program has resulted in an acceptable finding and we now consider this issue to be closed." '
The NRC sent two NRC staffers and a consultant from Brookhaven National Laboratory to Davis-Besse between September 11-13, 1989. The report issued following their inspection did indeed contain the aforementioned "acceptable" statement, but it also contained this statement:
Thomas V. Wambach, Senior, Project Manager-Project Directorate 1I1-3, Office of Nuclear Reactor Regulation, Nuclear Regulatory Commission. to Donald C. Shelton, Vice President --Nuclear, Toledo Edison Company.
"Prevention of" Boric Acid Corrosion at Davis-Besse Nuclear Power Plant (Generic [Lettcr 88-05), (TAC No.
6S915)," February 8, 1990.
Washington Office: 1707 H Street NW Suite 600, Washington DC 20006-3919. 202-223-6133 FAX: 202-223-6162 Cambridge Headquarters: Two Brattle Square
- Cambridge MA 02238-9105.
617-547-5552.
FAX: 617-864-9405 California Office: 2397 Shattuck Avenue Suite 203. Berkeley CA 94704-1567
. 510-843-1872 FAX: 510-843-3785
July\\'. 2002 Page 2 o1"9
,l oh\\\\ inll area'; of boric acid corrosion pre\\ C1tion could be enhanced at the Da\\ Is-cssc a)
System and operations engineers who perforlm boric acid leak inspections should have some formal training prior to performing the inspections.
b)
Inspections performed by the system and operations staff should be documented formnally."
la, cons..
who accompanied the NRC inspectors to Davis-Besse and nine other nuclear plants s
eq& :. _
.,hored a report for the NRC. In that report, he stated:
"i -*lant audits showed a considerable variance in the mode and quality of boric acid corrosion p:- --.ms between utilities. The degree of importance of a boric acid corrosion control program a
..zied considerably between plants. In the plants where a reasonably high priority was given ic.
-_rohlem, the leaks were identified and corrective actions taken in a timely manner."
Ih Table 2 :- is report, the consultant graded the boric acid corrosion programs in nine areas. Davis Be_.se \\a- --a.:t #9 in his tabulation. He assigned Davis-Besse grades of "2" in the areas of "Procedure fo: Daina:z -E-aluation" and "Training of Inspectors." According to Section 5.3, "Evaluation of Audit Results."
--_-.de of "2" meant "Unsatisfactory." Only two plants received lower overall scores than D\\ is-Be'-. The majority of plants (seven) received better overall scores than Davis-Besse.
UCS xas
-:)pointed to discover that the NRC determined that two of nine (22.2 percent) of the boric ac:d conr program elements were unsatisfactory, yet still accepted it. In fact, if we understand the constltanit* report correctly, Davis-Besse could have been graded "unsatisfactory" in all nine elements and still received an "acceptable" finding from the NRC. Talk about unsatisfactory! The NRC did.... Rsk, yet alone require, Davis-Besse to remedy the elements of its program determined to be u:natisfa&:.
In many ways, this is worse than not knowing that their program was bad. The NRC knew it.. as ba, accepted it that way.
iCS-09a Why did the NRC "accept" the boric acid corrosion program at Davis-Besse after determining that over 20 percent of the program was "unsatisfactory"?
ICS-09b If the 0350 Panel determines that restart is "acceptable," will "acceptable" rely on one or more NRC findings of "unsatisfactory" conditions at Davis-Besse? In other words, will "acceptable" and "unsatisfactory" stop being synonymous to the NRC?
How Did :-. :>-Besse Accomplish What Cher Wanted to Do, Turn Back Time?
TFhe NRC -_::5 concluded its heightened regulatory efforts for the plant were necessary as a "result q/the s.-ies of;-:
-.'emis thal for'mned a long histoy ofli,/'cctive and diacequate attentioni and direction in the o/'
Wrioý:
IIa (fintenaance of the Davis-Besse facility."
J C.1 C,2a-..
.ki. Brookhaven National ILaboratory, "Survey of Boric Acid Corrosion of Carbon Steel
( -..iponc: -
Nuclear Plants." NUREG/CR-5576, June 1990.
ulyiI ) 2002 P3c 3 of 9
\\Whi"c this conclusi on appears contemporary, it actually applicd to a Jlunc 9. 1985, loss of I'*cd\\\\,atcr cvcnt at Da% is-Besse.3 hat event. according to the NRC. resulted in a conditional core damiage I'rCqLIncv of' 3.6x 10-', an extraordinarily high risk given that other near-misses haxve values in the l x 10 to l x10 range. In fact, the NRC reported that only two other events at Babcock & Wilcox nuclear plants like Davis-Besse had as higher or higher risk in recorded history. Those events were a March 20, 1978, loss of power at the Rancho Seco nuclear plant in California (permanently shut down in the early 1990s due to safety and economic concerns) and a September 9, 1977, loss of feedwater event at Davis-Besse.
The 1977 event at T)avis-Besse also had the extraordinarily high conditional core damage frequency of 3.6x10-2.4 This was not surprising considering that it was the same event and the company had done nothing to lessen the risk after the first near-miss.
As the NRC itself concluded, chronic and systemic management problems caused the very, very serious near-miss at Davis-Besse in 1985. The NRC must share some responsibility for that near-miss because it was a virtual repeat of a 1977 near-miss at Davis-Besse that the NRC tolerated without any upgrades at the facility. The NRC must have concluded that the "unsatisfactory" 1977 near-miss was "acceptable" until lightning struck a second time in 1985.
As the company's root cause team concluded and NRC's AIT confirmed, chronic and systemic management problems caused the very, very serious near-miss at Davis-Besse in 2002. The NRC must share some responsibility for that near-miss because the agency "accepted" a boric acid control program in 1990 that it knew was "unsatisfactory" in over 20 percent of the areas evaluated.
UlCS-1Oa How many times must the people living around Davis-Besse be subjected to American Roulette?
LTCS-0Ob What tangible steps will NRC take to prevent chronic and systemic management problems from causing yet another very, very serious near-miss-or worse-at Davis-Besse?
Why Should Anyone Believe the NRC's Ouija Board?
As UCS documented two years ago,ý the risk assessments performed for nuclear power plants are fundamentally flawed. Among other deficiencies, the risk assessments assume there is a negligible chance of reactor vessel damage. UCS went to the NRC's Public Document Room on June 28, 2002, to examine the plant-specific risk assessment for Davis-Besse submitted by the plant's owner in March 1993. We wanted to confirm that potential reactor vessel damage had been downplayed in the Davis Besse risk assessment as it had been in the dozen-plus risk assessments we have reviewed for other nuclear plants. But UCS was denied access to this document by the NRC.
The Significance Determination Process (SDP) used by NRC to evaluate the safety impact of the reactor vessel damage at Davis-Besse is almost exclusively based on the "secret" plant-specific risk assessment."
3 Nuclear Regulatory Commission, Press Release No. 87-24, "NRC Staff Reduces S900,000 Fine Against Davis Besse by S450,000," February 12, 1987.
Nuclear Regulatory Commission, NUREG-1231, "Safety Evaluation Report related to Babcock & Wilcox Owxners Group Plant Reassessment Program," November 1987.
[iDaid l ochbaum, Union of Concerned Scientists, "Nuclear Plant Risk Studics: Failing the Grade," August 2000.
L Douglas V. Pickett, Senior Project Manager, Nuclear Regulatory Commission, to Guy C. Campbell, Vice
.loy 3. 2002 PHge 4 oC 9 The NR"s S,-1)P vorksliccts I'Or Davis-Besse are 49 pagces long, incltdiig ti& nransnilttal letter, Cover sheet, and table of contents. It refers to the Davis-Bcsse risk assessment approx\\i:nately 43 separate times.
In fact. it has only two rcf'rericcs: (I) the Davis-Besse risk assessment, and (2' NR(C staff p)apcI SFCY 99-007A titled "Recommendations for Reactor Oversight Process hinprovenmen:' (Follow-up to SF,(Y 99-007)." The SECY paper claimed that the new oversight program would be scrutable, transparent, and based on publicly available information.
But the NRC does not allow the public to look at the information it uses to assign safety significance to events. Shame on the agency". UCS would request that the NRC staff' revise SECY-99-007A to reflect its actual rather than intended practices, but the agency would probably classify the revised document "confidential" and hide it from the public, too.
UCS located a publicly-available, at least for the moment, document addressing,lie treatment of reactor vessel damage:
Because of the stringent design and surveillance practices applied to reac-,or pressure vessels in the U.S., failure of the reactor pressure vessel has traditionallv been considered incredible.
Containments for U.S. nuclear power plants are not designed to withstand the loads associated with gross rupture of the reactor pressure vessel.
Davis-Besse demonstrated the utter fallacy of assuming "stringent" surveillance practices. That the reactor vessel at Davis-Besse did not fail is due more to luck than the skill of either the plant owner or the NRC. Reactor vessel damage has occurred and will likely occur again. It is non-conservative and just plain foolhardy to pretend that it,vill not. Someday, the good luck iiay run out.
Yet the NRC used the flawed, deficient, and non-conservative risk assessment last fall to justify deferral of the mandated inspection for CRDM nozzle damage. And it is this risk assessment that the NRC is now using to determine the safety significance of the reactor vessel head damage at Davis-Besse. Yep, the agency is using a risk assessment specifically discounting reactor vessel damage as a possibility to determine the significance of reactor vessel damage. That's at least two stops past absurd on the sheer folly train.
The NRC's revised reactor oversight program is allegedly risk-inforiied. It purportedly uses risk insights to focus plant owner and NRC attentioii towards the most safety significant areas. For example, the plant-specific risk assessiments determine the importance of a system or comnponent by calculating the chances of reactor core daniiage with and without it. The importance values are then sorted to'distinguish the highest risk systems/coiiponents froiii those having the least risk. The NRC's inspectors select systems and components froom the.top of that list for their audits.
President - Nuclear, First Energy Nuclear Operating Company, "Davis-Besse Nuclear lPoweri Station - Site-Specific Worksheets For Use in the Nuclear Regulatory Commission's Significance Determination Pirocess," March 14, 2000.
SNuclear Regulatory Commission, N'REG/CR-6042 Rev. 2, "Perspectives on Reactor Safety."
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Will tile NRC all-N~ thle public to look at the 1993 lDavis-Besse risk assessment?
Ou t of, ciiriosi v. M h' did the N IC staff' use' hle old 1993 1)avis-Besse risk assessmnint to dc" clop it Significance lDeterniniat ion Process wo rkshieets whIIen the up1 daltedl 1999 plan [t sabt e assessmfenlt "as5 readly av ailalhle? D~id the staff prefer tn use an old1 "scCr~
- ' rep~ort inlsteadl of' a recently u1)dat ed version that the publie Could OWNtai?
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.Iul\\ 3, 2002 Pagc 6 of9 I'CS-I I c It the Davis-Besse risk assessment remains "secret" but it the basis for tile SI)P call, why should the public believe any NRC pronouncement on safety significance derived, in large part, on "secret" information?
I CS-IlId If the Davis-Besse risk assessment remains "secret," will the NRC retain the 0350 Panel in place following restart indefinitely to compensate for the public being unfairly excluded from access to this key information?
UCS-Ile Will the NRC require the Davis-Besse risk assessment to incorporate the real risk from reactor vessel failure before the plant restarts?
iCS-1 if When the NRC revamp its reactor oversight program to enable its inspectors to audit areas non-conservatively omitted from the plant-specific risk assessments?
Did First Energy repeat Callaway's mistakes?
NRC Region IV cited the owner of the Callaway nuclear plant in Missouri with a violation of occupational radiation exposure control requirements.9 NRC Region IV was disenchanted because:
"As described in Section 20S2 of this report, six jobs that accrued more than 5 person-reins each during Refueling Outage 10 exceeded their projected job doses by more than 50 percent because of a number of performance problems."
Radiation Work Permit RWP 2000-5 132 was written by plant workers at Davis-Besse on April 6, 2000, to cover the vessel head cleaning task during the 12"' refueling outage. It estimated a total job dose of 100 trero. Due to various performance problems encountered during the task (evidenced by Condition Reports CR 2000-0994 on April 16 th, CR 2000-0995 on April 1 6"', and CR 2000-1037 on April 17"', the estimated total job dose was revised upwvard again and again to a final estimate of 600 toRem. RWP 2000-5132 was closed on April 25, 2000, after the vessel head cleaning was completed. The total actual dose was 224 mRero, over 100 percent higher than the original guesstimate.
While 224 person-toReno is lower than 5-plus person-rem, Callaway and Davis-Besse both experienced initial radiation exposure estimates significantly below actual radiation exposure estimates. The falsely low estimates impeded informed decision-making on shielding, mock-ups, and other means of limiting overall worker exposures. In addition, part of the reason for the higher-than-planned radiation exposures at Davis-Besse is the failure of management to install MOD 94-0025, which would have facilitated inspection and cleaning of the reactor vessel head. The as-low-as-reasonably-achievable (ALARA) regulation was seemingly violated by First Energy's repeated decisions to defer MOD 94-0025 from outage to outage and allow workers to soak up radiation while struggling to inspect and clean the reactor vessel head.
And it's not like Davis-Besse has an exemplary radiation protection program. If media accounts are accurate, contract workers at Davis-Besse carried little radioactive "souvenirs" with them to contaminate apartments and motels across the US of A.
SArthur T. I lowell, III, Director - Division of Reactor Safety, Nuclear Regulatory Commission, to Garry I Randolph, Vice President and Chief Nuclear Officer, Union [-lectiric Company, "Callaway Plant -- NRC Inspection Repoit No. 50-483/00-17," October 4, 2000.
July 3, 2002 Page 7 of"9
[('S-I 2a l)id First Energy violate the ALARA regulation by repeatedly deferring MOI) 94 0025?
UCS-12b Does NRC Region III have a different approach to worker radiation safety than NRC Region IV, given the fact that Callawvay was cited for the same poor radiation control practices that Region III let Davis-Besse get awvay with?
Is First Energy merely recycling excuses and promises'?
As you know. I attended two of the three public meetings conducted by the NRC in Oak Harbor, Ohio on
,June 12, 2002. 1 heard Mr. Lew Myers and Mr. Randy Fast of First Energy repeatedly speak of the need to catch uip to the rest of the industry. Mr. Fast outlined more than once a scheme to bench-mark programs at Davis-Besse against the industry's best. Mr Myers, on at least two occasions, remarked that his operators needed to break their silence when they notice leaks and problems inside containment.
This all sounds really nice. It also sounded really nice all the times we've heard it in the past. The company needs to back up its words with deeds. After the company missed several opportunities to figure out that boric acid corrosion was damaging valve RC-2 inside containment in 1999, First Energy informed the NRC:
"As noted in the IR [NRC inspection report], following the determination that boric acid corrosion was the most likely cause for the missing nuts on the body-to-bonnet bolting of valve RC-2, a thorough evaluation of the issue was conducted and extensive, effective corrective actions were developed. Greater sensitivity to the effects of boric acid corrosion on plant equipment were noted in the IR and integration of these insights into plant processes and operational philosophy are being institutionalized by: 1) developing a revision to the Boric Acid control program and the Work Process Guidelines on plant leakage, including the benchmarking of industry standards and practices, to reflect higher standards for monitoring, evaluating, documenting and controlling boric acid leakage: and, 2) providing additional training to management and the technical staff to address the technical issues of boric acid control, the DBNPS Boric Acid Control Program and requirements, lessons learned from the RC-2 event, and industry experience. We will continue to stress the use of a questioning attitude and conservative decision-making in managing and resolving identified issues." '( [emphasis added by UCS here, but apparently not by First Energy there]
Prior to joining UCS, I worked as a consultant on PSE&G's Salem 2 restart project in 1995/1996. Salem was then in the regulatory doghouse for non-conservative decision-making. To roll out expectations on questioning attitude and conservative decision-making, PSE&G instituted many measures to back up the really nice slogans it sent to NRC. For example, senior managers conducted a series of informal luncheons with first-line supervisors and workers. To complement training sessions, PSE&G added a column titled "Catch of the Week" to its weekly employee newsletter highlighting issues raised by workers. This attention not only reinforced to workers that management did indeed want to hear about problems, but it also helped calibrate workers to the important threshold question for reporting problems.
In short, PSE&G backed up its nice-sounding words with meaningful, tangible actions.
Guy C. Campbell, Vice President - Nuclear, First Energy Nuclear Operating Company, to Nuclcar Regulaioiy Commission, "Response to Inspection Report Number 50-346'98021 (DRP)," July 1, 1999.
July 3. 2002 Page S 4I 9 U CS-13 What tangible actions has First Energy taken to back tip its rosy proclamations and assertions about "questioning attitude and conservative decision-making"'
Will the NRC enforce existing regulations'?
The NRC recently reported that "the licensee.for Davis -Besse did not have a regulatory con01it7C17t to clean, the reactor pressure vessel (RPV) head." ' UCS is more than a little baffled by this announcement.
To be perfectly frank, we do not believe it to be true. During the NRC public meeting conducted in the Commissioner's Auditorium on March 20, 2002, UCS presented information to the NRC staff. Among that material (which only consisted of five pages so it should not have been overwhelming) was this statement:
Davis-Besse UFSAR Section 5.2.3.2, Materials Exposed to Reactor Coolant, page 5.2-15 states "All materials exposed to the reactor coolant exhibit corrosion resistance for the expected service condition.... Sensitized stainless steel weld overlay (cladding) is permitted."
Lest anyone think we "cut and paste" words out of context to suit our purposes, here's the precise wording from the UFSAR itself:
5.2.3.2 Materials Exposed to Reactor Coolant All materials exposed to the reactor coolant exhibit corrosion resistance for the expected service conditions.
The materials used, as given in Table 5.2-10, are 304SS,
- 316SS, Inconel (Ni-Cr-FE).
or weld deposits with corrosion resistance equivalent to or better than the other materials listed.
These
'materials were chosen because they are compatible with the reactor coolant.
The RCPB contains no furnace-sensitized, wrought austenitic stainless steel.
Sensitized stainless steel weld overlay (cladding) is permitted.
The carbon steel exterior surface of the reactor vessel head is neither corrosion-resistant nor clad with stainless steel. Thus, when highly corrosive boric acid crystals were discovered on this surface, the Davis-Besse UFSAR-as an absolute minimum-- required it to be cleaned. After all, it was clearly material exposed to reactor coolant. The existing Davis-Besse design and licensing bases clearly and unequivocally require boric acid to be cleaned off the reactor vessel head. If First Energy, for wvhatever reason, wanted to leave the boric acid on the exterior surface of the reactor vessel head, they had to either comply with the requirements in UFSAR Section 5.2.3.2 or legally change it. Ignoring that requirement year after year should not have been an option.
IJCS-14a Will the NRC require First Energy to conform with UFSAR Section 5.2.3.2 or revise UFSAR Section 5.2.3.2 to match what the company does about boric acid before restart?
IICS-I14b If the NRC truly believes that First Energy, or any other nuclear plant owner, lacks a regulatory commitment to clean the reactor vessel head of highly corrosive material that can cause catastrophic failure, shouldn't the agency undertake as Job #1 getting that regulatory commitment? If not, why not?
Anthony J. Mendiola, Chief - Section 2 Pro.ject Directorate 1II, Nuclear Regulatory Commission, to Paul NI.
Blanclh, June 19, 2002.
,luly 3, 2002 Page 9 of 9
[he jiscovery oF Cigni ficant reactor vessel head damage occurring as a esulIt of neglect \\VOuld seem to undeirmine confidence in both the plant o% ner and the NRC. But it doesn't ha\\c to yield that result. Tih company and the NRC could demonstrate with deeds rather than wvords that this is a learning opportunlily. Or the%' could sustain the business-as-usual attitudes that created this near-disaster by accepting unsatisfactory conditions and blithely dismissing true safety hazards. We hope for the former but will be monitoring closely for signs of the latter.
Sincerely, David ILochbaum Nuclear Safety Engineer
\\Vashington Office