ML052790463
| ML052790463 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/12/2004 |
| From: | Lochbaum D Union of Concerned Scientists |
| To: | Miller H NRC Region 1 |
| References | |
| FOIA/PA-2004-0369 | |
| Download: ML052790463 (4) | |
Text
- A W
- 7fH Citizens and Scientists for Environmental Solutions
-r c
March 122004
.41 gyA.
Mr. Hubert J. Miller, Regional Administrator 7
United States Nuclear Regulatony Commission Region I pf f A F.
475 Allendale Road King of Prussia, PA 19406-1415
SUBJECT:
EXPLANATION OF REGULATORY REVIEW PROCESS OF PROPOSED POWER UPRATE AT VERMONT YANE Dear Mr. Miller.
During the Region I breakout session conducted on Friday, March 12, 2004, at the Nuclear Regldory Commission's Regulatory Information Conference, you committed to providing the public vA a description of the review process for the proposed power upvate at Vermont Yankee (VY) during the upcoming annual assessment meeting. You indicated that this public discussion might also be supplemented by a meeting arranged by Tad Marsh of the NRC's Office of Nuclear Reactor Regulation.
As an advocate of an Independent Safety Assessment (ISA) being conducted at VY before any operation above the currently licensed power level, I am very interested in hearing this description. You may not be aware that prior to joining UCS in October 1996, 1 was on the power uprate project for the two boiling water reactors at the Susquehanna Steam Electric Station between 1990 and 1992. Among my tasis on that project were the design reviews for the condensate, feedwater, liquid radwaste, spent fuel pool cooling, turbine building ventilation, containment atmosphere dilution, and river water makeup system I also worked on the Salem H restart project in 1996. Amcing my tasks on that project were vertical slice inspections of the spent fuel pit cooling and safety injection systems. As you are probably aware, sine joining UCS I was appointed by the NRC to the Federal Advisory Committee Act panel established to evaluate the pilot program for the revised reactor oversight process and have been invited numerous times by the Commission to present our views on the efficacy of the agency's reactor oversight process.
My experience leads me to believe that an Independent Safety Assessment is the best regulatory tod the NRC has to ensure that Vermont Yankee can operate safely at the proposed uprated power levels. More to the point, I firmly believe that safety cannot be adequitely assured by the NRC wthout an Independent Safety Assessment. I will detail the primary reasons for my position with the hope that Region I orNRR will address them, should you disagree, in the upcoming public meeting(s).
- 1. Unlike many other Region I reactors (Pilgrim, Peach Bottom Units 2 and 3, Calvert CifsM Units 1 and 2, Nine Mile Point Unit 1, Millstone Units 2 and 3, Indian Point Unit 3,FtzPatrick. and Salem Units 1 and 2), Vermont Yankee has not undergone a rigorous system review in the past twenty years. From my onsite experience at Salem Unit 2 and knowledge of comarable efforts at the other reactor I know that the safety-elated systems at these reactors were subjected to extensive, multi-faceted reviews that identified literally thousands of design, maintenance, and operations problems. Vermont Yankee is more likely to have undetected system problems than these other Region I reactors because it has not had such extensive 'find and fix" efforts.
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entries considered to be significant" and that "All of the events that the BWROG classified as significant were caused by vibrations except one." (Source: Slide 10 of the BWROG's Match 4, 2004, presentation).
Of the 11 BWRs reporting data, there were 11 significant events caused by vibration at the extended power uprate conditions. This experience does not suggest that Vermont Yankec is 100 percent likely to also encounter a significant event caused by vibration after extended power uprate, but it also does not provide any basis to conclude that such an event will be unlikely. The fact that BWR after BWR encounters the very same problem - namely, significant events caused by vibration - is prima fade evidence that neither the industry nor the NRC really understands what is causing these significant failures and how to prevent them fr1m recurring.
Furthermore, the NRC's review process for extended power uprate licensing amendments ignores its own regulatory guidance. For example, Paul Blanch discovered that in November 2003, the NRC staff issued Revision 3 to Regulatory Guide 1.82, "Waler Sources for LonTerm Recirculation Cooling Following a Loss-of-Coolant Accident." The guidance applicable to boiling water reactors begins on page 1.82-7 of this recently revised regulatory guide. The following page contains this paragraph Predicted performance of the ECC [emergency core cooling] and the containment heat removal punps should be independent of the cakulated Increases In containment pressure caused by postulated LOCAs in order to ensure reliable operation snder a variety of possible accident conditions. For example, (fproper operation of the ECYS or the containment heat removal system depends on containmentpressure above a fcrled minimum amoun, operation of these systems at a contabiment pressure less than this amount (resultingo for example. from Impaired containment Integrity or operation tf the containment heat removal systems at too high a rate) could signlfcant*y ffect theability of the system to accomplish Its safety function. However, for some operating reactors, credit for containment accident pressure may be necessary This should be minimed to the extentpossible.
Regulatory Guide 1.82 does not absolutely preclude taking credit for containment pressure during an accident. But the NRC's safety evaluation report for extended power uprate at the Brunswick nuclear plant, which took credit for containment pressu, failed to discuss Regulatory Guide 1.82 and how credit for containment re as being "minimized to dte extent possible."
Thus, using an impaired power uprat license amendment review process and an impaired reactor oversight process at a nuclear plant that has never had rigorous system reviews is not likely to assure adequate safety levels at the uprated power level. It might ultimately find Se problemns, such as when big pieces of metal shake loose and break as at Quad Cities or when gaping haees are finally discovered as at Davis-Besse, but that's way too late.
The regulatory tool the NRC should use - at least until it corrects all of the regulatory deficiencies that allowed it to miss so inany warning signs for so long at Davis-Besse - is the Independent Safety Assessment. If I owned Vermont Yankee, rd welcome an Independent Sarety Assessment as a means to verify that my reactor is not likely to repeat the significant events encountered at other BWRs after extended power uprate or identify a potential problem before I have to shut down and fix it a la Quad Cities. If I lived around Vermont Yankee, rd welcome an Independent Safety Assessment because rd
'On Mard 11, 2004, Entergy held a press conference at Vermont Yankee dring which they had the audacityof claiming
- r. Blanch did not know thec ai regulations Since Etr's license amedment request forextended power upate t Vermont Yankee fae to dscuss Regulatory Guide 1.82 at al wh the current revision arits previous Incarnations. Mr. Blanch should not be faulted for lack of knowledge about NRC's regulations.
March 12,2004
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want the NRC's best regulatory tool instead of a patchwork array of impaired tools. If I regulated Vermont Yankee, rd be picking team members for the Independent Safety Assessment.
I look forward to Region I's presentation on why using an impaired power uprate license amendment review process and an impaired reactor oversight process at a nuclear plant that has never had rigorous system reviews is adequate. I hope that your presentation will address my three concerns. If so, rll gladly consider the information provided by the NRC and re-consider my position on the need for an Independent Safety Assessment at Vermont Yankee prior to operation at extended power uprate conditions.
Sincerely,
<Original signed by>
David Lochbaum Nuclear Safety Engineer Washington Office March 12,2404
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