ML030730412

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Questions 02/24/2003 Meeting Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors
ML030730412
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 03/04/2003
From: Steele J
Action for a Clean Environment
To: Steven Bloom
NRC/NRR/DLPM/LPD4
References
Download: ML030730412 (3)
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Text

Action For a Clean Environment Adele Kushner, Executive Director SJoanne Steele, Director. Oconee N4uclear Project Steven Bloom "arc.l, LH aO(32 U.S Nuclear Regulatory Commission ,

"OWFN 8G9

Dear Mr. Bloom,

I listened in on the meeting February 24 related to the Order Establishing Interim ln*pection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors. In cleecking files I found the Duke Energy Corp Oconee Nuclear Stations units 1,2,&3 30 Day Response to the NRC bulletin for Reactor Pressure Vessel Head and Vessel Head Penetration NoZzle Inspection Programs, dated Sept 6, 2002.

Quoting the letter: - ,

"* 'Duke has scheduled replacement of Reactor Pressure Vessel Heads (RPVHs) for Oconee Units 1 ana 3 following current.operating cycles' No RPVH inspections are planned for these units prior to RPVH replacement"

"* "Unit 2...is schedule to begin last refueling outage prior to head replacement in October 2002. The established inspection plan for this outage follows the graded approach developed at Odonee over the last several years This graded approach has been previously described.to NRQ Staff in response to previqcs, bulletins. Duke also plans to do 100% volumetriObladeprobe inspection of the previously un-repaired nozzles'

- To summarize, the'ONS-3 RPVH inspection plan-  :,,.

  • 100% visualinspection of all CRDM nozzles
  • Blade probe Volumietric inspection of all remaining unprepared nozzles to locate both ID and OD initiated axial and circumferential cracks and potential leak pathways.
  • Dye penetrant-inspection of indeterminate blade probe UT(ultra sound technology) inspection path results

-o Duke's tonfidence in this'graded approach is based upon technical justification and

. previous efforts and experience.., further strengthen by additional Oconee Unit 2 specific

  • analysis that determnine core damage frequency associate with this situation is well below regulatory Guide 1."174 thire6sh6 valves and no fuel riod týa7lhres would occur given'.

unlikely occurrence of a rod ejection accident.

It is our opinion at Action for a Clean Environment that safety would dictate shutting down the Oconee reactors until the vessel heads are replaced. It appears the old vessel heads have never had a complete 100% inspection as your recent order recommends and that under your order they would wait until refueling to do so. That is two more months for Unit 3, 8 months for Unit 1, and next year for Unit 2. North Anna had greater deterioration of CRDMs than previously.

calculated, which could turn out to be the case at Oconee.

319 NWynn Lake Circle, Alto,, GA 30510-5218

Action For a Clean Environment "AdeleKushner, Executive Director Joanne Steele, Director, Oconee Nuclear Project My questions

1. Why do you consider itethical to "jump the gun" in your words, and post a document that rates the 3 worst reactor heads in the country as low susceptibility to deterioration, especially unit 3 of Oconee that is still in bperation, BEFORE replacements are done? I've seen no posting of a correction. This gives a false sense of security of the present situation.

2.2.What if simultaneous rod ejections occur, and there is tearing of insulation during that accident, and clogging of the sump from debris?

3. How will the reactor be shut down if there is damage and leaking at a fast rate?
4. Has Davis-Besse's head been replaced yet?
5. Is the North Anna reactor that had 49 serious cracks remaining off line until vessel head replacement can be done?
6. In the meeting th6re was mention of unidentified 'leaks of up to one gallon per minute from the prirlary systems that may drip onto the vessel head or seams. This could add up to 1,440 gallons a day or 43,000 gallons ina 30 day month Is this common? You said it may be important to iden~tify these leaks. Iwould think so!
7. How are the CRDMs monitored when the reactors are in operation?
8. How is the vessel itself tested for strength and integrity? These reactors ýre so old, and the metal is bound to deteriorate all around. We believe total inspection of the entire vessel should be done, top to bottom, inside and out. Is that possible?

Oconee reactors were relicensed before all the concerns of aging reactors were fully taken into consideration. We recommend that these and other reactors being considered for relicensing be held to their original licensed operation. Problems will continue to arise with the vessels Nuclear accidents would be catastrophic and impossible to clean up Financial resources don't exist to meet emergency response to serious accident,'nor can'emergency plans prevent the resulting high death and cancer rates a radioactive released from a damaged reactor, Thank you for prompt reply'to these questions Sincerely Joanne Steele

'Action for a Clean Environment Oconee Project Director Cc: ..

Mary Olson Director Southeast Office Nuclear~lnformation Resource Service 319 Wynn Lake Circle, Alto, GA 30510-5218 706-778-3661 ph./fax adelek@alltel.net http://www.ailtel. iet/-adelek

""W. printed on 100% recycled unbleached acid-free paper

Action For a Clean-Environment

-Adele Kushner, Executive Director, Joanne Steele, Director, Oconee Nuclear Project Cc:

Paul Gunter Sen. Carol Jackson Georgia State Capitol Director Nuclear-Reactor Watch Dog Project Atlanta, GA-Nuclear Information Resource Service Jim Hardeman Senator Zell Miller' U S Senate Georgia Environmental Protection Division Washington, D C Georgia Department of Natural Resources

'Tom Benko David Lochbaum -Sierra Club

.Nuclear Engineer Pickens County, S C Union of Concerned Scientist Joan 0. King Dr.'Judith Johnsrud , Adviser Board Member National Sierra Club Action for a Clean Environment Working Group on Nuclear Waste ph./fax 319 Wynn Lake Circle, Alto, GA 30510-5218 e 706-778-3661 adelek@alltel.net ° http://WVww.alltcl.net/-adelek 1LJ printed on 100% recycled uhbleached acid-free paper

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