ML071560488
| ML071560488 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/24/2007 |
| From: | Webster R Rutgers Environmental Law Clinic |
| To: | Conte R, Meyer G Office of Nuclear Reactor Regulation |
| References | |
| Download: ML071560488 (17) | |
Text
From:
To:
Date:
Subject:
"Richard Webster" crwebster Q kinoy.rutgers.edu>
"Glenn Meyer" cGW M Q nrc.gov>, cRJC Q nrc.gov>
05/24/2007 1 1 :06:53 AM Re: YOUR CONCERNS ON DRWYWELL SHELL THICKNESS Thanks for your e-mail. As discussed last night, since November 2006 we have been asking for the NRC's numerical estimates of the area in each drywell bay that is below 0.736 inches and for the NRC's estimate of the uncertainty of those estimates. The attached letter from March 30,2006 gives the full details of my request. If you have not performed such estimates, please let me know how NRC has confirmed compliance with the local area acceptance criterion for areas that are larger than 2 inches in diameter. I trust NRC will respond to my letter in the very near future.
One of documents I referred to last night is also attached. I will send the other by separate e-mail. They appear to indicate that AmerGen believes that there is an area of 9 square feet in Bay 1 with a representative thickness of 0.696 inches. If this is correct, we believe that would raise an operability problem because the local area acceptance criterion requires that contiguous areas thinner than 0.736 inches to be, at most, 9 square feet or less (in fact AmerGen has always applied a more stringent local area acceptance criterion and we believe that the 9 square foot formulation of the local acceptance criterion is not justified by the underlying modeling).
At this time I am neither making an allegation nor filing a 2.206 petition. I am providing these documents for your information and am asking NRC to review whether they raise a concern. As I emphasized last night, the Office of Inspection General reminded staff in 2002 that requiring absolute proof of a safety problem is an unreasonably high burden. Instead, the review should determine whether there is reasonable assurance that the areas of the drywell that are thinner than 0.736 inches are smaller than the area allowed by the appropriate local area acceptance criterion. I believe that this standard means that where there is considerable uncertainty about a key parameter, the uncertainty should be resolved in favor of safety by requiring a high degree of certainty that the parameter actually meets the requirements.
I would appreciate a written response summarizing the outcomes of your review.
Thank you for your consideration.
Richard Webster Richard Webster Staff Attorney Rutgers Environmental Law Clinic 123 Washington Street Newark, NJ 07102 Phone: 973-353-5695 Fax: 973-353-5537
CONFIDENTIAL LEGAL COMMUNICATIONNVORK PRODUCT This e-mail may contain privileged and confidential attorney-client communications and/or attorney work product. If you receive this e-mail inadvertently, please reply to the sender and delete all versions on your system.
Thank you.
Richard Webster Staff Attorney Rutgers Environmental Law Clinic 123 Washington Street Newark, NJ 07102 Phone: 973-353-5695 Fax: 973-353-5537 CONFIDENTIAL LEGAL COMMUNICATIONNVORK PRODUCT This e-mail may contain privileged and confidential attorney-client communications and/or attorney work product. If you receive this e-mail inadvertently, please reply to the sender and delete all versions on your system.
Thank you.
>>> "Richard Conte" cRJCQnrc.gov> 5/24/2007 9:32 AM >>>
Mr. Webster, last night at the Oyster Creek Annual Assessment meeting, you experessed concerns about new information you found in the hearing discovery process related to license renewal. You felt the new information is applicable to current operability issue you discussed in a March 2007 letter to us.
You inidcated last night that you would send me the new information.
For convenience could you send your March letter also. As Mr. Collins indicated we will get back to you shortly if we see any immediate safety concerns.
If will be appreciated if you can reply to all and send the information to Mr. Meyer also.
cc:
<may@ nrc.gov>
cJill.Lipoti @dep.state.nj.us>, "Debbie Mans" cDebbie.Mans @gov.state.nj.us>,
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Re: YOUR CONCERNS ON DRWYWELL SHELL THICKNESS Creation Date 05/24/2007 11:05: 15 AM From:
"Richard Webster" uwebster@kinoy.rutgers.edu>
Created By:
rwebster @kinoy.rutgers.edu Recipients nrc.gov kpl-po.KP-DO GWM (Glenn Meyer)
RJC (Richard Conte) nrc.gov TWGWP004.HQGWD001 MAY CC (Mitzi Young) gov.state.nj.us Debbie.Mans CC (Debbie Mans) dep.state.nj.us Jill.Lipoti CC Post Office kpl-po.KF-DO TWGWP004.HQGWD001 Route nrc.gov nrc.gov g0v.state.nj.w dep.state.nj.us Files Size Date & Time MESSAGE 3755 05/24/2007 11:05: 15 AM 3-30-07 Letter to NRC re thin areas.pdf 2-7-07 Estimates of thin areas.pdf Mime. 822 1961335 128722 13005 18 Options Expiration Date:
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RUTGERTENVTRONMENTAL LAW CLINIC.
123WashingtonStreet Newark, NJ 07 102-3094 Phone: (973) 353-5695 VIA E-MAIL AND US -MAIL Ms. Catherine Haney Director, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555-0001 Re-, The State University of New Jersey School of Law - Newark F~x:
(973) 353-5537 March 30,2007
Dear Ms. Haney:
On behalf of STROC, the citizens coalition including Nuclear Information and Resource Service (NIRS), Jersey Shore Nuclear Watch, Inc., Grandmothers, Mothers and More for Energy Safety, New Jersey Sierra Club, New Jersey Environmental Federation (NJEF) and New Jersey Public Merest Research Group (NJPIRG), I think you for your letter of March 16,2007. I am following ~p because, although your letter correctly states my questions, it fails to provide a complete answer.
First, I note that you state the Oyster Creek drywell shell had adequate margin against buckling in accordance with ASME code assuming a one square foot area thinner than 0.736 inches but thicker than 0.536 inches. Our calculations actually show that the area thinner than 0.736 inches in Bay 13 could be over four square feet, although the actual area is highly uncertain because the nuniber of measured points is small. To check this calculation, we would like the NRCs numerical assessment of the area in each bay that is thinner than 0.736 inches, an explanation of how those areas were derived, and a numerical estimate of the uncertainty with which those areas are known. Because it took over four months for you to respond to my previous query, I anticipate that you should have full knowledge of this issue and will be able to respond much more rapidly.
Second, we are surprised that NRC staff believes the last round of measurements showed no evidence of significant reduction in drywell thickness. In fact, AmerGen?s own statistical assessment states that the thinning observed was on average 0.02 inches, although the assessment attributed this thinning to an improvement in measurement technique, not ongoing corrosion.
Whatever the cause, this amount of thinning cannot be dismissed as insignificant. Brookhaven National Laboratories (BNL) in their review of the current licensing basis (attached to Letter from NRC to GPU, dated April 24;1992) stated there may not be adequate margin left for further corrosion... unless it is demonstrated that that removal of the sand will completely stop Carter H. Strickland, Jr., Esq.+
Acting Director Staff Attorney Staff Attorney Staff Attorney cstrlckland@klnoy.rutgsers.edu jhuff@Mnoy.rutgers.edu kshrekgast@khoy.rutgers.edu mebster@ldnoy.rutgers.edu
- Admittedh New Jersey Pursuant to 1:213(c)
Julia L. Huff, Esq.*+
Kathleen J. Shrekgast, Esq.#
Richard Webster, Esq.+
+ Also admitted in New York #Also admitted in Pennsylvania
RUTGERS ENWRONMENTAL LAW CLINIC hrther thickness reductions. Thus, any further thickness reduction beyond those observed in 1992 are cause for concern according to BNL. Furthermore, AmerGens analysis, while more optimistic, also suggests that the observed thinning is significant. AmerGens own estimates of the average thickness margins in the sandbed region contained in calculation C-1302-187-5320-024 were as low as 0.056 inches in Bay 11 before the latest results were taken. If AmerGens estimate is correct, an average reduction in thickness of 0.02 inches would mean that this margin has now reduced by around 36%. Thus, based on the analyses of BNL and AmerGen, we.do not understand how the obseryed.thinning could be termed insignificant. Please provide an explanation of NRC staffs reasoning on this point.
We trust you will understand that this matter is of the utmost importance for those who live close to the plant and in the region. We therefore respectfully request an urgent written response to this letter. Please feel free to answer these two questions separate1y;if it would enable a more rapid, response to be provided. Thank you for your consideration and we look foryard to hearing from you shortly.
Richard Webster C.C.
Donald Silverman, Esq., Counsel for AmerGen Mitzi Young, Esq., Counsel for NRC Jill Lipoti, NJ DEP Valerie Gray, Esq., Counsel for NJDEP
From:
Tamburro, Peter Sent:
To:
'So0 Bee Kok' cc:
Subject:
Attachments:
Contours.xls Wednesday, February 07,2007 0953 AM Ray, Howie; ORourke, John F.; Ouaou, Ahmed Oyster Creek Rrywell An
- Corrosion Data information and Code of Record So0 Bee Attached is an Excel spreadsheet that provides thickness information for the Drywell Vessel.
The thicknesses for the sandbed are based on a draft calculation C-130?-187-5321?-024 Revision 2.
ve the sandbed are based on the most recent ACRS presentation minus 20 mils Also, Howie Ray asked me to document the Code of Record for the Dyrwell Vessel hapter 6.2.1.I
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