ML13120A611
| ML13120A611 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 05/28/2013 |
| From: | Magwood W NRC/OCM |
| To: | Pierman B - No Known Affiliation |
| Patty Bubar | |
| Shared Package | |
| ML13142A424 | List: |
| References | |
| G20130287 | |
| Download: ML13120A611 (8) | |
Text
May 28, 2013 Ms. Bette Pierman 2033 Paw Paw Avenue Benton Harbor, MI 49022
Dear Ms Pierman,
I very much appreciated your time and the engaged conversation during the meeting on March 25 at the Beach Haven Event Center in South Haven Michigan. As promised, I am responding to your letter dated March 25, 2013, which expressed concerns regarding the safe operation of Palisades. A record of these and other questions from local citizens, as well as my responses, is documented in the Nuclear Regulatory Commissions (NRC) Agencywide Documents Access and Management System No. ML13142A424. The discussion with you and the other participants was very helpful to me as I continue to consider public concerns about nuclear safety.
You raised issues regarding the tritium leaks, effluent monitoring capability, low Lake Michigan water levels, and fire protection lack of compliance. In the enclosure, I have provided specific responses to the items you provided to me.
The NRC maintains safety as our top priority to ensure the protection of our citizens and the environment. I and all my colleagues at the agency are firmly dedicated to ensuring the safe operation of nuclear power plants and to protecting public health and safety.
Thank you for sharing your views and insights. If you have any additional questions, dont hesitate to contact me at 301-415-8430.
Sincerely,
/RA/
William D. Magwood, IV
Enclosure:
Responses to Questions
May 28, 2013 Ms. Bette Pierman 2033 Paw Paw Avenue Benton Harbor, MI 49022
Dear Ms Pierman,
I very much appreciated your time and the engaged conversation during the meeting on March 25 at the Beach Haven Event Center in South Haven Michigan. As promised, I am responding to your letter dated March 25, 2013, which expressed concerns regarding the safe operation of Palisades. A record of these and other questions from local citizens, as well as my responses, is documented in the Nuclear Regulatory Commissions (NRC) Agencywide Documents Access and Management System No. ML13142A424. The discussion with you and the other participants was very helpful to me as I continue to consider public concerns about nuclear safety.
You raised issues regarding the tritium leaks, effluent monitoring capability, low Lake Michigan water levels, and fire protection lack of compliance. In the enclosure, I have provided specific responses to the items you provided to me.
The NRC maintains safety as our top priority to ensure the protection of our citizens and the environment. I and all my colleagues at the agency are firmly dedicated to ensuring the safe operation of nuclear power plants and to protecting public health and safety.
Thank you for sharing your views and insights. If you have any additional questions, dont hesitate to contact me at 301-415-8430.
Sincerely,
/RA/
William D. Magwood, IV
Enclosure:
Responses to Questions The correspondence addresses policy issues previously resolved by the Commission, transmits factual information, or restates Commission policy.
Distribution:
SECY ADAMS Package Number: ML13142A424 Ticket Number: G20130287 OFFICE RIII RIII RIII EDO OCM NAME SShah:dtp JGiessner KOBrien RWBorchardt WDMagwood (via email) (MJohnson for)
DATE 05/01/13 05/01/13 05/07/13 05/13/13 05/28/13 OFFICIAL RECORD COPY
Response to Questions Raised in Letter Sent to the NRC by Ms. Bette Pierman In your letter you raised questions in a number of areas. I would like to take this opportunity to provide answers to your questions, which were:
- 1. If the Tritium release to the environment-first detected in a monitoring well in December 2007-is still occurring, why has the leak not been stopped? What steps have been taken to clean up the site and remove the Tritium contamination?
The Palisades licensee first installed tritium monitoring wells during late 2007. In December 2007, tritium activity of approximately 22000 pico Curies per liter was discovered in one of the western-most (lake side) wells. State and local governmental officials were contacted with the results and an NRC event notification was made (EN43832, public http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2007/20071211en.html). Since 2007, Palisades utilized multiple methods to identify the underground source of leakage. Consequently, Palisades has made repairs and improvements to existing tanks, replaced several sections of underground piping, inserted a sleeve into underground piping, or permanently sealed off connections between higher activity piping systems in the plant and piping that may have leaks in an effort to eliminate leakage causing the elevated tritium values. Flaws were observed in some of the piping that was replaced that would allow leakage. The licensee continued to monitor the wells after pipe replacements. Several leaks have been repaired in an area along some underground piping between liquid storage tanks on the western perimeter of the site heading eastward back towards the auxiliary building. Monitoring of the wells continues showing leakage. The area where the suspected leakage still exists is along the aforementioned underground piping run, approximately 100-200 yards east of the shoreline. Groundwater flow is generally east-to-west, so activity seen in the wells ultimately makes its way to Lake Michigan. Monitoring wells of interest on site (i.e., wells that have shown elevated tritium levels) get sampled every month, while other wells get sampled at least once per quarter. The levels of tritium which are seen and which continue to be monitored are below Environmental Protection Agency (EPA) established limits and do not pose a threat to public health and safety. The South Haven drinking water, whose source is Lake Michigan, is tested monthly and continues to show no detectable activity. The residential area of Palisades Park, south of plant, is seasonally tested and no detectable activity has been discovered thus far. There is no evidence from the monitored wells on site that tritium activity is migrating to the northern, eastern, or southern boundaries. Please note that once the leaks cease, tritium will continue to be detected due to its half-life of 12.3 years.
The NRC has an extensive regulatory framework designed to ensure all nuclear power plants, including Palisades, are operated safely. The regulatory framework is designed to ensure the NRC takes actions before public health and safety is affected. Whenever it is necessary, the NRC will take, action against power plants to ensure the health and safety of members of the public are protected. The regulatory framework associated with radioactive effluents includes: (1) regulations; (2) requirements and licensing conditions; (3) onsite inspections; and (4) reports. The NRC has multiple thresholds for radionuclides in groundwater as part of a defense in depth framework designed to Enclosure
protect public health and safety. This regulatory framework includes reporting levels, design objective, and safety limits. The EPA has established standards for drinking water in the Safe Drinking Water Act to ensure drinking water is safe to drink.
In addition to the regulatory limits described above, the NRC has a Policy Statement on safety goals which broadly defines acceptable levels of radiological risk. The NRC Policy Statement is described in the Federal Register (51 Federal Register 30028). The goals outlined in the policy statement indicate the NRC will provide a level of protection from the consequences of nuclear power plant operation such that individuals bear no significant additional risk to life or health. Additionally, societal risks should be comparable to or less than the risks of generating electricity by viable competing technologies and should not be a significant addition to other societal risks.
Information about all liquid releases from Palisades, including leaks and spills, are reported to the NRC in the licensees Annual Radioactive Effluent Release Reports.
These annual effluent reports are available on the NRCs web site (http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/pali.html).
The NRC requires the plant to monitor leaks from various systems, especially those that are significant to plant safety. Per Title 10 Code of Federal Regulations (CFR) 50.9, Completeness and Accuracy of Information, licensees are required to provide complete and accurate information to the NRC. Details related to leaks inside nuclear plants that are considered risk and safety significant are documented in NRC inspection reports.
The leaks that are not considered risk and safety significant are not documented. The NRC requires leaks released outside of the plant to be reported in publicly available annual effluent and the environmental monitoring reports. The following link to the NRC Website contains an alphabetical listing of all nuclear plants in the United States with an associated link to inspection reports issued from early 2000:
http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/listofrpts_body.html. NRC's inspection reports and other documents can be accessed through ADAMS at:
http://www.nrc.gov/reading-rm/adams.html.
The NRC also maintains a list of reactor sites where tritium has been detected in ground moisture or groundwater. The list may be found on NRCs public web site (http://www.nrc.gov/reactors/operating/ops-experience/tritium/sites-grndwtr-contam.html). Palisades also provided additional information on historical radioactive leaks and spills in a Groundwater Questionnaire. That document can be found on same NRC public web page where the annual reports are located. The NRC posts this information on NRCs public web site so that the public can be informed of the radioactive effluents from commercial nuclear power plants.
The NRC routinely conducts inspections of the Palisades site to ensure radioactive effluents from the Palisades site meet federal regulations. These NRC inspection reports are publicly available in NRCs agency wide document access management system (ADAMS) on the NRC public web site.
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The recent reports related to radionuclide sampling and reporting and their frequency can be viewed at: http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/pali.html.
Inspection of the above documents reveals that Palisades has experienced some leaks of radioactive materials onto soil at the Palisades site. As a result, tritium has been identified in groundwater on the Palisades site. The information indicates that tritium released to offsite areas has not resulted in tritium concentrations in excess of standards established by the EPA in the Safe Drinking Water Act. In fact, there were no detectable amounts of radioactivity in drinking water. This includes Lake Michigan, which is the source of water for South Haven. Additionally, none of the radioactive releases from the Palisades site have exceeded any of the NRCs regulatory limits for radioactive effluents.
Therefore, the NRC is confident these leaks do not represent a hazard to public health and safety.
- 2. How is the Tritium plume being monitored? How far from Lake Michigan is it at this time? What steps are being taken to prevent it from reaching and contaminating Lake Michigan and other area watersheds?
Since 2007, Palisades utilized multiple methods to identify the underground source of leakage. The licensee is monitoring wells for tritium levels. Wells of interest (i.e., wells that have shown elevated tritium levels) get sampled every month, while other wells get sampled at least once per quarter. The area where the suspected leakage still exists is along the aforementioned underground piping run, approximately 100-200 yards east of the shoreline. Groundwater flow is generally east-to-west, so activity seen in the wells ultimately makes its way to Lake Michigan. The levels of tritium, which are detected and continue to be monitored, are below EPA established limits and do not pose a threat to public health and safety. The South Haven drinking water supply is tested monthly and continues to show no detectable activity. The southern residential area of Palisades Park is seasonally tested and no detectable activity has been discovered thus far. There is no evidence from the monitored wells on site that tritium activity is migrating to the northern, eastern, or southern boundaries. All radioactive effluents must be monitored or accounted for to ensure they remain below the federal limits. All releases of radioactive effluents have been well below federal limits.
- 3. When Entergy and NRC resident inspectors discovered the leak, did they notify the area governments i.e., South Haven and Covert City Councils and the local township boards so that they could more closely monitor the drinking water being drawn from Lake Michigan? What about those governments further south where drinking water also comes from the lake?
The licensee notified the state and local governmental officials with the results of the tritium leak and made an NRC event notification (EN43832 located at http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2007/20071211en.html). The authorities notified included Van Buren County commissioners, Covert Township, South Haven Township, South Haven city, Van Buren County Emergency Planning Office and the Michigan Department of Environmental Quality. All drinking water samples have shown no detectable radioactivity. Therefore, the NRC is confident these leaks do not represent a hazard to public health and safety.
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- 4. Regarding the failed Effluent Monitoring System Inoperability, why was this deemed an acceptable occurrence for a monitor to be out-of-service for greater than 30 days? It is particularly disturbing that the high range noble gas monitor was out of service for a total of 142 days in 2010. How can the public be assured of safe plant operation when they learn of instances like these? How does anyone know what they may have been exposed to during this time?
Information related to Palisades effluent radiation monitors that have been out of service for greater that 30 days is in the licensees Annual Radioactive Effluent Release Reports. These annual effluent reports are available on the NRCs web site (http://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/pali.html).
Specifically, the Palisades 2010 Annual Effluent report states in section 5 for Effluent Monitoring System Inoperability that The effluent monitors that were out of service for greater than 30 days were RIA-2323, B steam generator main steam line monitor, was out of service from March 28, 2010, to July 26, 2010, (120 days). RIA-2327, high range noble gas monitor, was out of service from July 4, 2010, to December 15, 2010, (142 days).
Compensatory actions are put in place when one monitor is out of service to ensure adequate monitoring of all offsite releases is always present. This ensures there is no threat to public health and safety, since monitoring capability does exist through redundant monitors or compensatory actions. These compensatory actions assure accurate release information is available to prevent unmonitored releases (it should be noted during plant operation, the releases are extremely low and would be imperceptible to background radiation). When RIA-2323 and RIA-2327 were out of service compensatory actions were put in place. Although the steam line monitor and the high range noble gas monitor were out of service for a period of time in 2010, other monitors/compensatory actions were in place to ensure there was adequate effluent monitoring. The resident inspectors verified that the licensee established compensatory actions and alternate radiation monitors were available to ensure that all offsite releases were monitored. Based on the above review, the resident inspectors found no safety significant violations. The NRC inspectors who specialize in health physics will review this issue in more detail during a follow-up inspection during this year.
The NRC reviews the compensatory actions for radiation monitors that are out of service. We not only inspect effluent radiation monitors, but also radiation monitors used in other applications such as the emergency plan, on-site laboratory analyses equipment, area radiation monitors, and radiation monitoring equipment used to assess occupational and public radiation exposures. The NRC performs these inspections once every two years. The inspections include, but are not limited to review and walk down of area and effluent radiation monitors, their testing and calibrations, review of procedures that govern operation of these instruments, review of portable survey instruments and post-accident monitoring instrumentation and review for anomalous results or other indications of instrument performance problems.
In addition to radiation monitors, the NRC inspectors review the licensees effluent program. These inspections include, but are not limited to determination if any of the newly contaminated systems have an unmonitored effluent discharge path to the 4
environment and whether the associated effluents were reported to the NRC, review of groundwater monitoring results, walk down of selected components of the gaseous and liquid discharge systems, walk down of filtered ventilation systems and verification that adequate controls have been implemented to ensure representative samples are obtained. In addition, we also verify that effluent discharges made with inoperable (declared out-of-service) effluent radiation monitors had controls in-place to ensure compensatory sampling is performed consistent with required controls that are adequate to prevent the release of unmonitored liquid and gaseous effluents and review whether the facility is routinely relying on the use of compensatory sampling in lieu of adequate system maintenance.
In summary, the NRC ensured compensatory actions were in place for the radiation monitors. Additional, detailed reviews will occur this year. The NRC monitors the operations at power plants on a daily basis to ensure the health and safety of the public, and the environment, are protected.
- 5. What are the risks related to low Lake Michigan Water Level? In the event of a super storm hitting the shores of the greatest freshwater, inland lake system in the world, how are you going to prevent the nuclear waste storage casks and reactor from ending up in the lake contaminating the source of drinking water for untold millions of people? What is the plan? (Yes, we have 25 foot plus waves on Lake Michigan, and we have not experienced a super storm yet.)
Overall, the NRC Staff evaluated the impact of record low Lake Michigan levels and determined there was no current safety issue. There is adequate water to support cooling of safety related equipment with several feet of margin. That being said, the Staff agrees it is important to look strategically at possible risks with low Lake Michigan levels. Starting in the fall of 2012 and continuing today, NRC experts in headquarters and the Region have been discussing issues with the US Army Corps of Engineers (USACE) and the National Oceanic and Atmospheric Administration, Great Lakes Environmental Research laboratory (NOAA/GLERL). These groups are responsible for water management of the Great Lakes and conducting research on the Great Lakes dynamic ecosystems, including the varying levels in response to changing climate. In addition to phone discussions, the NRC Staff met with these experts in February 2013 to discuss future collaboration. In March 2013, an information exchange occurred between members of the NRC, NOAA, USACE, the Canadian Nuclear Safety Commission (CNSC), and the International Joint Commission (IJC). The NRC will continue to assess conditions in Lake Michigan with assistance of our federal partners as needed.
The Palisades nuclear plant is designed for a seiche height of 594.1. This number is conservative in comparison to the current low lake levels (576-577) and a design basis seiche of about 11 feet. The plant is protected against flooding up to 594.4 in buildings where safety-related equipment is located. The independent spent fuel storage location pad height (bottom level of pad) is 625.2. This height is approximately 50 feet from the current lake height. A storm surge of about 100 feet (waves are measured crest to trough so with 50 feet from the still lake level reaching the cask, would require a wave two times that for a total wave height), conservatively assuming no shoreline was present to cause the waves to break, would be needed to reach the bottom of the cask.
The highest wave ever seen is about 25ft. Also, the spent fuel storage casks are approximately 16 feet in height. The casks themselves are designed to withstand water currents up to 25 feet per second while being fully immersed before they would begin to 5
slide on the pad. At lower water levels, they are designed to withstand currents of much higher speeds before they begin sliding from the spent fuel storage pad. Therefore, it is not plausible a wave will impact the casks.
- 6. Reiterating the comment in this LTE, if our bone-dry forests catch fire, the concrete nuclear plants wont burn, but the power lines will melt, and the plants will be forced to deal with hot reactors and nowhere to unload the reactors power. What plans are in place at Palisades to deal with this scenario and when has it been tested?
If offsite power is lost, the two on-site emergency diesel generators will automatically start and supply power to the safety pumps which deliver water to the reactor. The emergency diesel generators provide backup power in the event of loss of off-site power, or loss of power to the associated safety buses. The on-site power systems are designed and tested to full capacity, and are available to ensure the plant can be safely shutdown and maintained shut down for extended periods.
- 7. What plans are in place at Palisades to deal with the fluctuating lake levels and how those levels will impact the plant safe operation on a daily basis and in the event of a super storm?
Lake Michigan levels do not change rapidly (levels have never varied by more than one foot per month), but weather events can cause rapid, short-term changes (winds, storms, seiche). The level of Lake Michigan is relatively stable (the difference between all-time high to all-time low is only ~ 6 feet). Storm surges are possible and the plant is designed to withstand large storm surges. During actual storms, onsite resident inspectors look at safety equipment and systems connected to the Lake to ensure there is no adverse impact. In fact, during Super-storm Sandy that occurred in October 2012, resident inspectors reviewed key systems and the shoreline; and determined there was no impact to plant safety.
In addition, Palisades has both normal and emergency procedures to deal with fluctuating lake levels. The existing procedures prescribe required actions for low/high levels, flooding, etc., to ensure the plant is safe. Finally as part of post-Fukushima lessons learned, all operating nuclear power plants will perform flooding hazard characterization reviews and safety walk downs. There are currently no safety concerns regarding the plants ability to manage fluctuating Lake Michigan levels. If an issue is found, the NRC would ensure the site take appropriate action.
- 8. What measures are in place to ensure that the storage casks will not end up in Lake Michigan with the potential for major contamination in the event of an unprecedented super storm?
The storage casks are not impacted by Lake Michigan waves with the closest storage pad 50 feet higher and set back from the beach. In addition to possible waves, the casks have been evaluated for potential seismic forces. The evaluation for these casks determined that the casks will not tip over. Therefore, there is no plausible scenario where the cask would tip over or move to Lake Michigan causing a release of radiation.
The NRC has concluded the casks are in a safe location. If new evidence suggests this 6
could occur and cause the cask to tip over, the Agency has processes in place to take prompt action to ensure plant safety.
- 9. After reviewing the FEMA After Action Reports and Communications Re: Specific Emergency Exercises at http://www.nrc.gov/about-nrc/emerg-preparedness/related-information/fema-after-action-reports.html, I could not understand why there have not been any reports for Palisades since 2004. In light of the relicensing approval in 2007, how could the NRC make an informed decision without this information?
Thank you for your feedback regarding the unavailability of FEMA reports since 2004.
We apologize for any inconvenience this may have caused you. These exercises, assessments and the follow-on reports were actually completed, but were not uploaded and made public. The Staff has updated these reports and it can be accessed at http://www.nrc.gov/about-nrc/emerg-preparedness/related-information/fema-after-action-reports.html. The relevant ADAMS accession numbers are ML13100A201, ML13099A161, ML13099A162 and ML101830320.
- 10. Where does Entergy stand with the enforcement of the new fire rules at Palisades? Have they been given a waiver and deadline extension by NRC until 2016?
Palisades Nuclear Plant submitted a license amendment request (LAR) to transition their fire protection program to NFPA 805 on December 12, 2012. The LAR is currently under staff review. Palisades was granted enforcement discretion for the transition and LAR review period. During this period the NRC continues to conduct regularly scheduled inspections through the Reactor Oversight Process (ROP). Until Palisades transitions to NFPA 805, they must continue to meet their licensing basis under 10 CFR 50.48(b),
Fire Protection, and only have enforcement discretion for fire protection non-compliances that: the NFPA 805 transition identifies; are entered into their corrective action program; have compensatory measures in place; are not willful; are not of high safety significance; and would not have been found by routine surveillance activities.
The enforcement discretion will end with the disposition of the LAR when the license is amended, denied, or rescinded. The disposition of the LAR is expected to be completed by December 2014 by the NRC. In the interim, the licensee has established necessary compensatory actions until any required modifications are installed and the transition to NFPA 805 is completed.
- 11. If Palisades is not enrolled in the new fire program, what interim steps are in place to protect the reactors while they work on their new fire plans?
Palisades has submitted a request to move to the new program. The licensee has established a number of compensatory actions to ensure that defense-in-depth is maintained and safe reactor shutdown can be achieved, until any required modifications are installed and the transition to NFPA 805 is completed. Compensatory actions include training for fire brigade and control room staff, procedure reviews, use of fire watches, additional tours by qualified personnel, detailed planning in risk significant areas, additional briefings and control of plant activities to ensure protection from fire.
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- 12. When was the last fire inspection conducted by the NRC staff, and what were the 3 to 5 areas for scrutiny at the inspection? Are they conducting these inspections every 3 years or more often in the case of Palisades safety record?
The NRC inspection program is structured such that the resident inspectors will check multiple areas important to safety each quarter with regards to fire protection.
Inspectors also observe at least one fire brigade drill each year. Quarterly fire inspections are documented in the integrated inspection report (http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/listofrpts_body.html#pali). Additionally, every 3 years, fire protection specialists perform detailed reviews of fire areas deemed risk significant per the criteria outlined in the inspection procedure. Per the inspection procedure, once every 3 years, an NRC inspection team is required to select three to five risk-significant fire areas or zones (depending on the teams makeup, scope, and resources) and conduct risk-informed inspections of selected aspects of the licensees fire protection program. These inspections make up our baseline inspection program.
There are no additional inspections planned. The team may adjust the number of fire areas inspected during the inspection based on the complexity of issues. The initial selection of areas to be inspected is based on inputs from a senior reactor analyst (SRA), a fire protection specialist and an electrical engineer. For each area, the selection process will consider but will not be limited to the following:
- A review of the fire hazard analyses.
- Potential ignition sources.
- The configuration and characteristics of combustible materials.
- Routing of circuits important to accomplish and maintain safe shutdown condition.
- The licensees fire protection and firefighting capability.
- The licensees use of operator manual actions.
The fire protection inspection is focused on post-fire safe shutdown capability and alternative or dedicated shutdown capability, as applicable.
The areas inspected last year by the NRC triennial fire protection inspection team were:
- Control Room.
- An electrical penetration room, (i.e. a place where many cables enter containment and where a remote shutdown station is located).
- The service water intake structure (houses safety-related service water pumps and all in-plant fire pumps).
The link to the inspection report is provided under Palisades report number 2012008:
http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/listofrpts_body.html#pali 8