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Susquehanna - Eric Joseph Epstein'S Affirmative Duty & Obligation to Keep the Nuclear Regulatory Commission, Atomic Safety & Licensing Board Panel, Parties Informed of Significant Developments
	ML072420354
Person / Time
Site:	Susquehanna
Issue date:	08/22/2007
From:	Epstein E; - No Known Affiliation
To:	; Atomic Safety and Licensing Board Panel, NRC/SECY/RAS
	SECY RAS
References
	50-387/388, ASLBP 07-854-01-OLA-BD01, RAS 14041
	Download: ML072420354 (14)
	v • d • e

14 ~USNRC DOCKETED August 28, 2007 (3:37pm)

OFFICE OF SECRETARY August 22, 2007 RULEMAKINGS AND ADJUDICATIONS STAFF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD and the UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

PPL SUSQUEHANNA LLC ) Docket Nos. 50-387 -388 Susquehanna Steam Electric Station ) Units 1 and 2; ASLB

) No. o7-854-ol-OLA-BDo1 Office of the Secretary Mail Stop O-16 C1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Rulemaking and Adjudications Staff Eric Joseph Epstein's Affirmative Duty & Obligation to Keep the Nuclear Regulatory Commission, Atomic Safety & Licensing Board Panel, Parties Informed of Significant Developments:

Re: PPL Susquehanna LLC's Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1 & 2 Would Increase Thermal Power to 3,952 Mega-Watts Which Is 20% Above the Original Rated Thermal Power (RTP) 3,293 MWt, And Approximately 13% Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-61io and 50-388

Dear Sir or Madam:

Enclosed for filing in the above-stated matter, and consistent with Eric Joseph Epstein's affirmative duty and obligation to keep the Nuclear Regulatory Commission, Atomic Safety and Licensing Board Panel and parties advised of significant developments relevant to the proceeding, is an original and five copies of the "Potential Adverse Flow Affects From Nuclear Power Plants" and Proposed Remedies.

sspeetf I su mitted-,

Eric Jos emn, Pr0 se 41oo Hi lsdale Road Harrisburg, PA 17112 (717)-541-11O1 Phone (a~e--76 C- 6-a7 *ýe V_

PotentialAdverse Flow Affects From Nuclear Power Plants, Project # 691, ADAMS Accession No.: MLo7171 o615 Re: PPL SusquehannaLLC ProposedAmendment Requests for the SusquehannaSteam Electric Station's 1 & 2 Would Increase Thermal Power to 3,952 Mega-Watts Which Is 20%

Above the OriginalRated Thermal Power (RTP) 3,293 MWt, And Approximately 13% Above the CurrentRTP of 3,489 MWt, Docket Nos. 50-387 PLA-611o and 50-388 I. Introduction Mr. Epstein has an affirmative duty and obligation to keep the Nuclear Regulatory Commission, Atomic Safety and Licensing Board Panel and parties advised of significant developments relevant to the proceeding. (1)

II. Emerging Technical Challenge Relating to PPL Susquehanna's Proposed Uprate Enclosed is a relevant and timely communication (2) from the Nuclear Regulatory Commission (NRC) to the BWR Owners Group (BWROG) about experimental power uprates at boiling water reactors (BWRs). (3) The NRC has approved experimental power uprates (EPU) at Dresden, Quad Cities, Brunswick, Hatch, and Vermont Yankee -- and is currently recommending and reviewing an EPU for the Susquehanna Electric Steam Station (SSES).

1 Duke Power Co. (William B. McGuire Nuclear Station, Units 1 and 2),

ALAB-143, 6 AEC 623, 625-26 (1973); Georgia Power Co. (Alvin W. Vogtle Nuclear Plant Units 1 and 2) ALAB-291, 2 NRC 404, 4o8 (1975). Duke Power Co. (Catawba Nuclear Station, Units 1 and 2); ALAB-355, 4 NRC 397, 4o6 n. 26 (1976.) See also Tennessee Valley Authority (Phipps Bend Nuclear Plant, Units 1 and 2.).ALAB-752, 18 NRC 1318 (1983); Tennessee Valley Authority (Browns Ferry Nuclear Plant, Units 1, 2, and 3), ALAB-677, 15 NRC 1387, 1388 (1982.)

2 Mr. Epstein became aware of the document on August 20, 2007, but it appeared in the July 26, 2007, folder in ADAMS.

3 Please refer to Enclosure 1, from John A. Grobe, Associate Director for Engineering nd Safety Systems, Office of Nuclear Reactor Regulation.

1

Last month the NRC identified and reported (4) to the BWROG:

"The acoustic resonance phenomenon that causes adverse flow effects in nuclear power plants is highly complex and requires extensive analyses."

And, "...scale model testing (SMT) and analytical tools have not matured sufficiently to allow minimal error and uncertainty valves to be used in their application."

In short, the NRC has conceded and acknowledged to having neither an analytical nor modeling clue as to what will occur when a BWR cranks its output up, i.e., PPL Susquehanna LLC Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1 & 2 Would Increase Thermal Power to 3,952 Mega-Watts Which Is 20% Above the Original Rated Thermal Power (RTP) 3,293 MWt, And Approximately 13% Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-611o and 50-388. The NRC's current approach to "immature" and inadequate scale model testing is to conduct full-scale testing at nuclear power plants in the neighborhoods surrounding the SSES.

The second page of the NRC's letter outlines seven topics the NRC has identified as requiring further investigation. Clearly, an agency with safety as its top priority, and protection of public health as its primary mission, should require definitive answers about these "threat areas" before allowing the SSES to wander into uncharted territory. Proper protection of public health and safety dictates that the NRC do more than merely raise questions. The NRC must answer those questions at the Susquehanna Steam Electric Station to ensure safety margins are retained when boosting the reactors' output.

4 The distribution list does not include PPL Susquehanna, but it does include PPL's vendors and industry representatives e.g., EPRI and GE Energy.

There has been no information or data relating to this emerging issue presented in this case.

2

Please note that the NRC, in the second to last paragraph of " Potential Adverse Flow Affects From Nuclear Power Plants," the NRC stated, "We would appreciate receiving your comments within one month such that the NRC staff can prepare the proposed RIS in a timely manner." (5)

Certainly an uprate and license extension that will be in effect for decades can wait an additional 9o-18o days for the RIS and PPL's site-specific review. (6)

III. Proposed Remedies

1) Mr. Epstein respectfully requests that PPL's application be held in abeyance until points 1 through 3 and points 5 through 7 identified in the NRC's Communication, "Potential Adverse Flow Affects From Nuclear Power Plants,"

(Project # 691, ADAMS Accession No.: ML07171o615,) have been formally reviewed by a Regulatory Issue Summary.

2) Mr. Epstein respectfully requests that the NRC direct PPL Susquehanna to conduct a site- specific evaluation of the SSES within 90 days after the completion of the RIS, and evaluate points 1 through 3 and points 5 through 7 identified in the NRC Communication, " Potential Adverse Flow Affects From Nuclear Power Plants," (Project # 691, ADAMS Accession No.: ML07171o615).

3) Mr. Epstein respectfully requests that approval of the EPU be delayed until the RIS and NRC's review of PPL's site specific studies are completed.

5 Nearly a decade after the NRC approved power uprates at Dresden, Quad Cities, and Brunswick, and years after the steam dryer at Quad Cities shook itself apart (three times), the NRC is requesting "timely" data response.

For purposes of the request, "timely" means 90 days after the NRC issues its Regulatory Issue Summary.

6 PPL Susquehanna has applied to the Nuclear Regulatory Commission (NRC) for permission to run the Susquehanna Steam Electric Station until 2043

[Unit-i] and 2045 [Unit-2].

3

spe t mitted, ric Jo ee lh pstein, Pro se 4100 illsdale Road Harrii urg, PA 17112 I hereby certify that on August 24, 2007, a copy of Eric Joseph Epstein's Reply Petition for Leave to Intervene, Request for Hearing, and Contentions regarding the matter of the PPL Susquehanna LLC Proposed Amendment Requests for the Susquehanna Steam Electric Station's 1 & 2 Would Increase Thermal Power to 3,952 Mega-Watts Which is 20% Above the Original Rated Thermal Power (RTP) 3293 MWt, And Approximately 13% Above the Current RTP of 3,489 MWt, Docket Nos. 50-387 PLA-611o and 50-388 was sent via electronic mail, USPS and by overnight delivery with tracking numbers to:

Office of the Secretary Office of the Commission U.S. Nuclear Regulatory Commission Appellate Adjudication One White Flint North, Floor 16 US NRC - Mail Stop o-16 C1 11555 Rockville Pike Washington, DC 20555-0001 Rockville, Maryland 20852 Attn: Rulemaking and Adjudications Staff Office of the Secretary of the Commission ALJ US NRC U.S. Nuclear Regulatory Commission G. Paul Bollwerk, III, Esq.,

Mail Stop 0-16 C1 Chair Washington, D.C. 20555-0001 Mail Stop T-3 F23 Attn: Rulemaking and Adjudications Staff Washington, DC 20555-0001 US NRC Office of the General Counsel Lloyd B. Subin, Esquire Mail Stop 0-15 D21 ALJ US NRC Washington, DC 2055-0001 Dr. Richard F. Cole Mail Stop T-3 F23 Washington, DC 20555-0001 David Lewis, Esquire PPL c/o Pillsbury, Winthrop et al ALJ US NRC 2300 N. Street, NW Dr. Lester S. Rubenstein Washington, DC 20037 Mail Stop T-23 F23 Washington, D.C. 20555-0001 ALJ US NRC Dr. Lester S. Rubenstein 182o Avenida del Mundo Coronado, CA 92118 4

cc:

Paul 0. Swartz Executive Director Susquehanna River Basin Commission 1721 North Front Street Harrisburg, PA 17102-2391 Michael Brownell Chief, Water Resource Management Division Susquehanna River Basin Commission 1721 North Front Street Harrisburg, PA 17102-2391 DEP - RCSOB Paul E. Russell, Esquire Cathleen Myers, DEP PPL Electric Utilities Corporation Deputy Secretary Two North Ninth Street PO Box 2063 Allentown, PA 18101-1179 Market Street Harrisburg, PA 17105-2063 James J. McNulty, Secretary Pennsylvania Public Utility Commission Commonwealth Keystone Building 400 North Street Harrisburg, PA 17120 5

ENCLOSURE 1 July 18, 2007 Mr. Randy C. Bunt, Chair BWR Owners' Group Southern Nuclear Operating Company 40 Inverness Center Parkway/Bin B057 Birmingham, AL 35242

SUBJECT:

POTENTIAL ADVERSE FLOW EFFECTS IN NUCLEAR POWER PLANTS

Dear Mr. Bunt:

Between 2002 and 2006, the Quad Cities Nuclear Power Station, Units 1 and 2 (Quad Cities),

boiling water reactor (BWR) nuclear power plants experienced severe degradation of the steam dryers and main steam line relief valves during extended power uprate operation. To resolve this problem at Quad Cities, main steam system modifications were necessary to reduce the pressure loading on the steam dryer and vibrations in main steam line piping and components.

Further, Palo Verde Nuclear Generating Station, Unit 1, pressurized water reactor (PWR) nuclear power plant experienced damage from adverse flow effects in a shutdown cooling line resulting from acoustic resonance with subsequent plant modifications performed to address the problem. As a result of these operating experience issues, the nuclear industry and U.S.

Nuclear Regulatory Commission (NRC) staff are evaluating potential adverse flow effects from hydrodynamic loads and acoustic resonance in nuclear power plants in much more detail than in the past.

The acoustic resonance phenomenon that causes adverse flow effects in nuclear power plants is highly complex and requires extensive analyses to evaluate its potential impact on nuclear power plant structures, systems, and components over a wide frequency range. Further, scale model testing (SMT) and analytical tools have not matured sufficiently to allow minimal error and uncertainty values to be used in their application. This has resulted in the need to have significant margin available in stress analyses performed on nuclear power plant components (primarily BWR steam dryers) to account for errors and uncertainties. Consequently, applicants for power uprates, design certifications, construction permits, and operating licenses have a significant challenge in addressing potential adverse flow effects on nuclear power plant structures, systems, and components for their specific applications.

The NRC staff has updated Regulatory Guide 1.20, "Comprehensive Vibration Assessment Program for Reactor Internals During Preoperational and Initial Startup Testing," and the Standard Review Plan (SRP) in Sections 3.9.2, "Dynamic Testing and Analyses of Systems, Structures, and Components," and 3.9.5, "Reactor Pressure Vessel Internals," to incorporate lessons learned from operating experience and the review of power uprate submittals.

However, the NRC staff believes that additional generic communication would be helpful to the nuclear industry in addressing potential adverse flow effects in an adequate manner in power uprate and new reactor applications for BWRs and PWRs. Therefore, the NRC staff is considering the preparation of a Regulatory Issue Summary (RIS) to discuss the evaluation of potential adverse flow effects for power uprates and new reactors.

R. Bunt The NRC staff is considering addressing the following topics in the RIS:

1. Pressure Fluctuations and Vibration in Plant Systems (including the construction and validation of a small SMT facility, and method and approach for the measurement of plant-specific data to determine pressure fluctuations and vibration that can impact structures, systems, and components)

2. Design Load Definition for Steam Dryers (including the development of an analytical methodology to calculate fluctuating pressure loads on the steam dryer that is validated against SMT data and plant-specific instrumented steam dryers)

3. BWR Steam Dryer Stress and Limit Curves (including the performance of a finite element analysis using appropriate damping values, justification of bias error and uncertainty for each category of the stress calculation on a frequency-specific basis, and development of limit curves based on plant data accounting for bias errors and uncertainties as well as concentration and weld size factors)

4. PWR Steam Generator Stress and Design Margin (including the evaluation of the dynamic response, stress, and design margin of the internal components in steam generators)

5. Evaluation of Other Plant Components (including the evaluation of potential adverse effects from pressure fluctuations and vibration on piping and components in reactor coolant, steam, feedwater, and condensate systems, such as safety relief valves, power-operated valves, and sampling probes)

6. Power Ascension Data (including the development of power ascension procedures with limit curves and frequent data collection, walkdowns, and hold points for data evaluation and NRC staff interaction)

7. Monitoring of Potential Adverse Flow Effects (including the development of proactive methods for identifying acoustic resonance or severe hydrodynamic loading prior to component failure)

If you have any suggestions regarding these considerations, we would appreciate receiving your comments within one month such that the NRC staff can prepare the proposed RIS in a timely manner.

Please contact Kamal Manoly, Chief, Mechanical & Civil Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation, at 301-415-2765, for any additional information.

Sincerely, IRA/

John A. Grobe, Associate Director for Engineering and Safety Systems Office of Nuclear Reactor Regulation Project No. 691 cc: See next page