ML071640348

Y020070131 - Estimated Time It May Take for 7 Inches of PWR Upper Head Steel to Dissolve

ML071640348
Person / Time
Site:	Davis Besse
Issue date:	05/22/2007
From:	Tom Gurdziel - No Known Affiliation
To:	Reyes L NRC/EDO
orenak, Michael, NRR/DCI/CPTB, 415-3229
Shared Package
ML071790106	List: ML071640348 ML071790100
References
FOIA/PA-2007-0299, LTR-07-0399, TAC MD5759, Y020070131
Download: ML071640348 (4)

Text

Original Due Date: 06/29/2007 Ticket Number: 020070131 Document Date: 05/22/2007 NRR Received Date: 06/11/2007 From: TACs:

Tom Gurdziel MD5759

• • YELLOW**

Luis Reyes For Signature of: Routing:

Jack Grobe Dyer Wiggins Mithcell Boger

==

Description:==

Grobe Concerns the Estimated Time it May Take for 7 inches of PWR Upper Head NRR Mailro-om Steel to Dissolve Assigned To:

Contact:

DCI EVANS, MICHELE G Special Instructions:

Prepare short letter acknowledging his views and describing our current approach.

. OF1FICE OF THIE SECRETARY

,ý,To CORRESPONDENCE CONTROL Ti~ICET Date Prinled: Jut 06, 2007 14:01I PAPER NUMIB ER: LTIR- 07 -0399 L ING DATE: 06/06/2007 ACTION OFFICE: EDO EDO DEDMAS AUTHOR: G-Urdziel DEDR DEDIA AFFILIATION:

ADDRESSEE: Mr. LLuis Reyes

SUBJECT:

Concerns the estimated time it may take for 7 inches of PWR Upper head steel to dissolve ACTION: Appric~priate DISTRIBUTION:

LETTER DATE: 0 5/ 22/2100 7 ACKNOWLEDGED No SPECIAL HANDLING:

NOTES:

FILE LOCATION: ADAMVS DATE DUE: DATE SIGNED:

1~'

I-Ir IVA A .~ * /7.

9 Twin Orchard Drive Oswego, NY 13126 May 22, 2007 Mr. Luis A. Reyes Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Mr. Luis A. Reyes:

Th~e purpose of this letter is to suggest to you a path of lower risk. Recently there has come to the public's knowledge a startling new estimate of the time it may take for 7 inches of PWR upper head steel to dissolve. Using a "The Plain Dealer" May 15, 2007 article by Patrick O'Donnell, that time is about 4 months.

When I was on "C" Shift, (a US commnercial nuclear plant operating crew), we told our operators to believe their instruments. Just because you are seeing something you are not used to seeing, or don't want to see doesn't mean you can safely ignore it. You would need to prove that instrument wrong before disregarding it.

Well, that's pretty simple, isn't it? And I think it is a relatively low risk path to follow. I mention it because I believe it is NOT the path the NRC is presently following with the Exponent reports. They present information the industry, or, in my opinion, the NRC, does not want to believe.

What the NRC appears to be doing is to allowing time to pass while asking the people whose explanations they find suspect to provide more explanations. Considering the especially short period of time in question, I consider this a very high risk path.

Here is what I suggest as a lower risk path. Since, as I understand it, the quick failure requires some conditions from the original Davis-Besse root cause AND an additional, hard to identifyr flaw that allows the erosion/dissolving to speed up, and since this can happen in 4 months, I would think that asking all PWAR owners with Alloy 600 steel upper reactor heads.to inspect on a 4 month interval is prudent if they cannot prove that they have none of those hard to detect flaws.

As you can see, what I am suggesting is that you consider the report as accurate until you-.

or the industry proves it is not.

Perhaps though, you are seeing some proof already. If the report is accurate, wouldn't it be plausible to expect that FirstEnergy would have already made plans to extend the FLUS system from the present Davis-Besse reactor vessel cylinder and lower hcad to include the upper head as well? (I believe that their (present) reactor upper head #2 is made of the same material as was their reactor upper head #1.)

I don't need a reply.

Thank you, Torn Gurdziel