ML050620272
| ML050620272 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/28/2005 |
| From: | Gunter P, Lochbaum D Nuclear Information & Resource Service (NIRS), Union of Concerned Scientists |
| To: | Diaz N, Jaczko G, Peter B. Lyons, Mcgaffigan E, Merrifield J NRC/Chairman, NRC/OCM |
| References | |
| G20050150, LTR-05-0103 | |
| Download: ML050620272 (7) | |
Text
'S EDO Principal Correspondence Control FROM:
DUE: 03/21/05 Paul Gunter Nuclear Information and Resource Service EDO CONTROL: G20050150 DOC DT: 02/28/05 FINAL REPLY:
(NIRS)
David Lochbaum Union of Concerned Scientists TO:
Commission FOR SIGNATURE OF :
ROUTING:
Followup to NRC Briefing on Nuclear Fuel Performance -
Significance Determination Process (SDP)
DATE: 03/03/05 Reyes Virgilio Kane Merschoff Silber Dean Burns/Cyr Caldwell, RIII ASSIGNED TO:
NRR CONTACT:
Dyer SPECIAL INSTRUCTIONS OR REMARKS:
Add EDO and Commission on for concurrence.
Chairman and Commission to review response prior to dispatch.
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OFFICE OF TIHE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: Mar 03, 2005 08.36 PAPER NUMBER:
ACTION OFFICE:
LTR-05-0103 EDO LOGGING DATE: 03/02/2005 AUTHOR:
AFFILIATION:
ADDRESSEE:
SUBJECT:
ACTION:
DISTRIBUTION:
LETTER DATE:
ACKNOWLEDGED SPECIAL HIANDLING:
NOTES:
FILE LOCATION:
Paul Gunter UCS Nils Diaz Followup to NRC briefing on Nuclear Fuel Performance --Significance Determinatin Process (SDP)
Direct Reply RF, SECY to Ack 02/28/2005 No Commission should review response prior to dispatch Made publicly available in ADAMS via SECY/EDO/DPC ADAMS I
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03/24/2005 DATE SIGNED:
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Citizens and Scknflsts forEnVlrDninentalSoluiJons February 28, 2005 Dr. Nils J. Diaz, Chairman Dr. Gregory B. Jaczko Dr. Peter B. Lyons Mr. Edward McGaffigan, Jr.
Mr. Jeffrey S. Merrifield United States Nuclear Regulatory Commussion Washington, DC 20555 By Email: SECY@nrc.gov and U.S. Postal Service
Dear Mr. Chairman and Commissioners:
OnFebruary 24, 2005, in the closing of the Commission Briefing on Nuclear Fuel Performance a question was raised on thb regulatory interface with the power reactor operators'and nuclear fuel vendors with regard to the Significance Determination Process (SDP). Nuclear Information and Resource Service (NIRS) stated that it would submit a formal question for a response from the Commission and staff given the late hour of the meeting. Attached please find related questions submitted in follow-up by both NIRS and the Union of Concemed Scientists.
As background, Jim Malone, Vice President, Nuclear Fuels, Exelon Generation Company, LLC stated to the Commission (slide 33 of the industry panel's presentation) that "We experienced an unacceptable number of fuel defects in Exelon Units" [emphasis in original]. Quad Cities 1 replaced defective 233 assemblies after becoming the industry leader in radiation exposures to its workforce.
Mr. Malone confessed to you that Exelon experienced an "unacceptable" number of fuel failures that caused them to replace 233 defective fuel assemblies at Quad Cities Unit 1.
Curiously, the Reactor Coolant System Activity performance indicator (PI) submitted by Exelon for Quad Cities Unit I at least looked acceptable:
I
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-ruel-I nnuzzszuuI-ommission->u.aoc-Page 2 Reactor Coolant System Activity Exelon did not provide the E i i i 8 E Ei i
_NRC withanycomments accompanying this PI. One might have expected-unacceptable conditions warranting the replacement of 233 defective fuel assemblies might have been reflected in this PI or in the
--comments" field for this PI.
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5U >N-b IrM Data presented to you during the February 24L briefing indicates that 20 to 25 percent of the reactors in the United States are operating with defective fuel. The Commission briefing reflects the response undertaken by the industry and the NRC staff to this problem. Yet the Reactor Coolant System Activity PI has never been greater than Green.
Never.
In our view as public safety advocates the function of the fuel rod cladding clearly has not only an operational role but clear safety functions to include providing the first barrier for retention of fission products and providing structural integrity to ensure effective cooling of the reactor core geometry. As the principle barrier in a multi-barrier system, degradation of fuel cladding constitutes erosion in the agency's defense-in-depth philosophy and practice.
The question comes up as to whether this same number of fuel cladding defects experienced at Quad Cities 1 was acceptable or unacceptable under the current NRC oversight process? If it was acceptable, please explain why?
With regard to the oversight of operational environment impact on the overall fuel performance cycle, at what point in the SDP is fuel cladding failure during reactor operation which adversely affects overall fuel performance such that the agency issues a RED as an "Unacceptable Performance Band"?
Mr. Malone, Exelon, on Slide 39 of his presentation to the Commission reports "Dose increases not significant." The transcript of the briefing will indicate that Commissioner Merrifield questioned if Quad Cities was also the industry leader for worker radiation exposures during this same time frame and answered in the affirmative. Why should the public not view this as a significant disconnect in agency and industry's portrayal of this issue as an economic issue versus a safety matter?
Is the Reactor Coolant System Activity PI an effective metric if it has failed to track conditions deemed "unacceptable" by the industry?
III We greatly appreciate your attention to responding to this issue.
lie Lunamp - t-Uel-Li I -U22b32UUb-~o~mmission-bL)P.doc Panre 3q I Paul Gunter, Director Reactor Watchdog Project Nuclear Infonnation and Resource Service 1424 16' Street NW Suite 404 Washington, DC 20036 Tel. 202 328 0002 www.nirs.org David Lochbaum Senior Nuclear Safety Engineer Union of Concemed Scientists 1707 H St Suite 600 Washington, DC 200 202 331 5430 www.usaucs.org
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aeieclive Tuel From:
"Paul Gunterm <pgunter@nirs.org>
To:
<SECY nrc.gov>
Date:
2/28/05 4:29PM
Subject:
Letter to Chairman & Commissioners re: SDP & defective fuel Paae 1 1
II I
- Hello, Please find attached a joint letter from Nuclear Information and Resource Service and Union of Concerned Scientists addressed to the Chairman and Commissioners in request of a response to follow-up questions from the Commission Briefing of Fuel Performance February 24, 2005.
The attached letter is being posted through regular mail as well.
Thank you, Paul Gunter, Director Reactor Watchdog Project Nuclear Information and Resource Service 1424 16th Street NW Suite 404 Washington, DC 20036 Tel. 202 328 0002 CC:
CLochbaum/ David" <dlochbaum @
ucsusa.org>
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NIRS-UCS letter 02282005 corrected 3/1/05 1:03PM "Paul Gunter" <pgunter@nirs.org>
pgunter@nirs.org Recipients nrc.gov owf5_po.OWFN_DO SECY (SECY)
Post Office owf5_po.OWFN_DO Route nrc.gov Files Size Date & Time MESSAGE 500 03/01/05 01:03PM TEXT.htm 3101 Fuel-LTR-02282005-Commission-SDP-corrected.doc Mime.822 79861 54272 Options Expiration Date:
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