ML14198A141
| ML14198A141 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Monticello, Dresden, Peach Bottom, Browns Ferry, Nine Mile Point, Fermi, Oyster Creek, Hope Creek, Cooper, Pilgrim, Brunswick, Vermont Yankee, Duane Arnold, Quad Cities, FitzPatrick, LaSalle |
| Issue date: | 10/27/2014 |
| From: | Marilyn Evans Division of Operating Reactor Licensing |
| To: | Gunter P Beyond Nuclear |
| Lingam S | |
| Shared Package | |
| ML14198A098 | List: |
| References | |
| 2.206, EDATS: OEDO-2011-0269, G20110262 | |
| Download: ML14198A141 (29) | |
Text
Mr. Paul Gunter, Director Reactor Oversight Project Beyond Nuclear 6930 Carroll Avenue Suite 400 Takoma Park, MD 20912
Dear Mr. Gunter:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 27, 2014 The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Beyond Nuclear petition dated April 13, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11104A058), submitted by you along with Mr. Kevin Kamps of Beyond Nuclear. By letter dated December 13, 2011 (ADAMS Accession No. ML11339A078),
the NRC accepted part of the Beyond Nuclear petition because it met the criteria for review.
The agency stated that the aspects of the Beyond Nuclear petition that were accepted are also the subject of the Near-Term Task Force review of insights from the Fukushima Dai-ichi accident, "Recommendations for Enhancing Reactor Safety in the 21st Century" (ADAMS Accession No. ML112510264) and ongoing NRC review. The agency rejected the remaining issues because each issue was already reviewed, evaluated, and resolved by the NRC. As part of the Petition Review Board's final recommendation, both accepted and rejected issues were summarized in a table that was enclosed in the letter dated December 13, 2011. After careful review, NRC staff concluded that one of the rejected issues (Issue No. 1 C of the table) associated with containment failure during severe accident should have been accepted. The resolution for this issue is included in this response. A copy of the modified table is attached to this letter (Enclosure 1 ). The NRC staff's proposed director's decision under Title 10 of the Code of Federal Regulations (1 0 CFR) 2.206, "Requests for Action under This Subpart," for the accepted issues is also enclosed (Enclosure 2).
I request that you provide comments to me on any part of the decision that you believe is in error, or any issues in the petition that, in your opinion, have not been addressed. This letter is also distributed to the licensees, and the licensees can provide any comments on the decision to the NRC staff. The NRC staff will then review any comments provided by you and the licensees and consider them in the final version of the director's decision, with no further opportunity to comment.
Please provide your comments within 30 days from the date of this letter. The petition manager, Mr. Siva Lingam, can be reached at 301-415-1564.
Docket Nos. 50-259, 50-260, 50-296, 50-325, 50-324, 50-298, 50-237, 50-249, 50-331' 50-321' 50-366, 50-341' 50-354, 50-333, 50-263, 50-220, 50-219, 50-277, 50-278, 50-293, 50-254, 50-265, and 50-271
Enclosures:
- 1. Summary Table of Petitioner's Concerns
- 2. Proposed Director's Decision Sincerely, Michele G. Evans, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
- 3. Licensees-Mark I Boiling Water Reactors cc:
Kevin Kamps, Beyond Nuclear (w/ enclosures) 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 Licensees-Mark I BWRs (w/ enclosures)
Listserv (w/o enclosures)
TABLE SUMMARIZING EACH ISSUE FOR 2.206 CRITERIA No.
Issue Does this meet criteria Does this meet criteria for Recommendation for acceptance?
rejection?
- 1) A.
Fundamentally flawed combination of Yes.
REJECT free standing steel primary containments The Nuclear Regulatory I
for the pressure suppression Commission (NRC) addressed containment systems. So many different and resolved the Mark I combinations of conditions and events containment structural integrity can create a steam or hydrogen concerns through NUREG 0474, explosion that will fail the containment.
"A Technical Update on Pressure Rapid quenching such as the seawater Suppression Type Containments injections at Fukushima could contribute in Use in U.S. Light Water Reactor to a hydrogen explosion due to rapid Nuclear Power Plants," and oxidation of metals in the fuel. In case of NUREG 0661, "Safety Evaluation an accident, the uplift forces on the torus Report, Mark I Containment Long-of early Mark I containments would have Term Program."
destroyed the containment. Further, the control rods enter through the holes in the bottom of the reactor vessel, and in case of a melted core that occurred at Fukushima, the melted core material can directly leak in to the containment floor.
This is another flaw in the Mark I containment design.
- 1) B.
Spent fuel pools (SPFs) elevated to the Yes.
ACCEPT top of the reactor building outside and This meets the criteria above the rated containment structure for review as it pertains without safety-related backup electric to the events in Japan power systems to cool high-density and recent Browns storage of nuclear waste in the event of Ferry partial loss of loss of grid power.
offsite power (LOOP).
Provide emergency makeup water L____ __
No.
Issue Does this meet criteria Does this meet criteria for Recommendation for acceptance?
rejection?
reliable source.
Install additional instrumentation (water level, temperature, and radiation monitoring) on all Mark I storage pools.
- 1) C.
Substandard Mark I pressure
[Yes.
[¥e&
[REJECT suppression containment system This meets the criteria N~G aEIEiresseEI aREI resel11eEI tl=le ACCEPT]
vulnerable to early failure under severe for review as it pertains Marl~ I eeRtaiRFReRt stn:leh:lral accident conditions including over-to the events in Japan.]
iRtegrity eeReems tl=!reugl=l pressurization.
NbJ~eGs Q474 aREI Qee~.]
- 1) D.
Reactor design has now dramatically Yes.
ACCEPT failed in Japan to reliably and adequately This meets the criteria mitigate and contain significant and for review as it pertains mounting radiological releases to the to the events in Japan.
atmosphere, groundwater and the ocean from multiple severe accidents in multiple General Electric (GE) boiling water reactor (BWR) Mark I units.
There certainly is so much at stake and the seismic issues need to be studied because there is a great deal of seismic activity around Augusta, Georgia; the Vogtle nuclear plant; and Charleston, South Carolina.
Yes.
ACCEPT
- 1) E.
Failure of the Mark I containment even This meets the criteria with the hardened vent system at for review as it pertains Fukushima Dai-ichi demonstrates the to the events in Japan.
inadequacy in design to mitigate and contain a severe accident resulting from No.
Issue Does this meet criteria Does this meet criteria for Recommendation for acceptance?
rejection?
longer station blackout.
NRC should order the Tennessee Valley Authority (TVA) to evaluate pressure suppression containment venting to determine whether the Browns Ferry Nuclear Plant should be allowed to continue operation.
- 2)
Immediately suspend operating licenses Yes.
REJECT of all GE BWRs Mark I Units pending full
[This ARy] request for additional NRC review with independent expert action by NRC does not involve and public participation from affected any enforcement action, and emergency planning zone communities.
therefore, does not fall under the 10 CFR 2.206 review process.
- 3) a.
Conduct public meetings within each of Yes.
REJECT the 1 0-mile emergency planning zone for
[This ARy] request for additional each GE BWR site for the purpose of action by NRC does not involve receiving public comment and any enforcement action, and independent expert testimony regarding therefore, does not fall under the the reliability of hardened vent system or 10 CFR 2.206 review process.
direct torus vent system.
- 3) b.
Immediately revoke prior preapproval of "Yes" for investigating ACCEPT the hardened vent system or direct torus reliability of direct torus vent system at each GE BWR Mark I vent system, and "No" unit under the provisions of for immediate action.
1 0 CFR 50.59.
This meets the criteria for review as it pertains to the events in Japan.
No.
Issue Does this meet criteria Does this meet criteria for Recommendation for acceptance?
rejection?
- 3) c.
Immediately issue Confirmatory Action "Yes" for investigating ACCEPT Orders to all GE BWR Mark I units to backup electrical power, promptly install safety-related backup and "No" for immediate electrical power (Class 1 E) and action.
additional backup direct current battery This meets the criteria system to ensure reliable supply of for review as it pertains power for the spent fuel pool cooling to the events in Japan system.
and recent Browns Ferry partial LOOP.
- 4)
An accidental or intentional airline crash Yes.
REJECT into the currently unprotected spent fuel NRC has addressed and resolved pool areas of these reactors has the this concern after 9/11 events potential to sever cooling water piping or through major actions such as institute other dangerous disruptive mitigating strategies.
events at reactors which would be similar to a tsunami or an earthquake in Japan.
- 5)
Illinois reactors are operating on river Yes.
ACCEPT flood plains and the current situation in This meets the criteria Missouri and Nebraska speaks volumes for review based on as to what this means in terms of ongoing NRC flooding.
investigation and events in Japan.
- 6)
Dr. Kennedy states that "critical failure Yes.
REJECT modes for gross structural failure of the NUREGs 1488 and 1738 pool is out of plain [8Reef shear] failure sufficiently addressed and of pool floor slab.
resolved the concerns raised by the copetitioner.
- 7)
Provide an expedited hardened (dry Yes.
ACCEPT cask) onsite storage by emptying the This meets the criteria No.
Issue Does this meet criteria Does this meet criteria for Recommendation for acceptance?
rejection?
SFPs and converting the irradiated for review based on nuclear fuel that is more than 5 years ongoing NRC cooled to dry casks. At Fukushima, investigation and events three reactor systems were blown out in Japan.
and caused exposure of the fuel in the SFPs directly to the atmosphere.
NRC should order TVA to eliminate the existing unsafe irradiated fuel storage system at Browns Ferry and move the fuel to hardened storage in concrete structures.
- 8)
The NRC should immediately [roll bask Yes.
REJECT rescind] power [uprates at reactors that The Commission approved the have] received the containment accident CAP credit on March 15, 2011 pressure (CAP) credit.
(ADAMS Accession Nos.
- 9)
NRC should issue an order to TVA to Yes.
REJECT inspect control rod blades at Browns This is handled by inspection and Ferry Nuclear Plant.
10 CFR 21 process.
1 0)
The intense rainfall accompanying the Yes.
ACCEPT hurricane thoroughly saturated the This meets the criteria ground around Vermont Yankee, which for review based on has aggravated the existing problem of ongoing NRC reactors' underground safety-related investigation.
electrical cables which were never designed to withstand wet or underwater conditions. NRC is aware of this problem. To my knowledge, no remedial action or even a complete inspection of No.
Issue Does this meet criteria Does this meet criteria for Recommendation for acceptance?
rejection?
every inch of such cables has been undertaken or is even being contemplated.
- 11)
Radioactive water containing tritium was Yes.
REJECT leaking from under one of the buildings This is followed by [the NRC's at Hatch nuclear plant. Officials Region II] Office. The licensee discovered tritium in two test wells about (Hatch) issued a 10 CFR 50.72 25 feet below ground. The leak was report (ADAMS Accession No.
large enough to raise the water table in ML11308A668), notified NRC and the wells at least 5 feet. The levels of the Georgia's Department of tritium shot the concentration in the Natural Resources. In this report, drinking water up to 200 times the limit the licensee stated, "No tritium set by EPA.
levels above background have been detected or migrated outside the area where the two sample points are located." NRC inspection report dated October 28, 2011 (ADAMS Accession No. ML113010464),
addressed this issue, and the corrective actions by the licensee.
In summary, the licensee identified the leak, capped the underground pipe, and will route the new pipe above the ground.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION Jennifer L. Uhle, Deputy Director Proposed DD In the Matter of All General Electric Mark I Boiling Water Reactors Operating Licensees PROPOSED DIRECTOR'S DECISION UNDER 10 CFR 2.206 I.
Introduction On April 13, 2011, Mr. Paul Gunter along with Mr. Kevin Kamps of Beyond Nuclear (the petitioner) submitted a petition under Title 10, "Energy," of the Code of Federal Regulations (1 0 CFR) 2.206, "Requests for Action under This Subpart," to the Executive Director for Operations of the U.S. Nuclear Regulatory Commission (NRC or Commission) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML11104A058).
The petitioner requested that the NRC order the immediate suspension of the operating licenses of all General Electric (GE) boiling water reactors (BWRs) that use the Mark I primary containment system. The petitioner cited the Fukushima Dai-ichi accident in Japan as the rationale for and basis of the petition.
On April 19, 2011, the NRC acknowledged receipt of your April 13, 2011, petition. The NRC Petition Review Board (PRB) determined that your request for immediate action is a general assertion without supporting facts. The PRB did not identify a significant safety concern from the information provided that would warrant the NRC to order the immediate suspension of the operating licenses of all GE BWRs with Mark I containments. On April 21, 2011, the NRC informed you of the PRB's decision about the immediate action (ADAMS Accession No. ML11140A078). Subsequently, more than 10,000 copetitioners joined, supporting your petition. Some of the copetitioners provided supplemental information.
On August 16, 2011, the NRC informed you of the PRB's initial recommendations to accept your petition for review in part (ADAMS Accession No. ML112340018). The NRC received from you and copetitioners information on numerous and diverse issues that were not raised in your April 13, 2011, letter or during a public meeting held on October 7, 2011.
On December 13, 2011, the NRC informed you of the PRB's final recommendations, accepting parts of your petition for review, and rejecting the remaining parts of your petition (ADAMS Accession No. ML11339A077). Based on the NRC's timeline related to its Fukushima lessons-learned review, and because many of your items accepted for review pertained to the Fukushima review, the NRC's review of your petition took longer than the standard of 120 days for reaching a decision on the petition.
II.
Discussion This section includes both the petitioner's requests and the NRC's decisions. The NRC did not issue orders within 90 days of the petition, as the petitioner had requested, because we determined that the continued operation of operating reactors did not pose an imminent risk to public health and safety. The NRC also will not be issuing orders in the future based on the petition. The NRC will not be issuing orders because, as we explain below, each of the petitioner's requests has been addressed through other actions.
Request 1 (Issue No. 1 B of the Table): Spent fuel pools (SFPs) elevated to the top of the reactor building outside and above the rated containment structure without safety-related backup electric power systems to cool high-density storage of nuclear waste in the event of loss of grid power.
Provide emergency makeup water reliable source.
Install additional instrumentation (water level, temperature, and radiation monitoring) on all Mark I storage pools.
NRC decision: The NRC addressed the petitioner's requests through Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," issued March 12, 2012 (ADAMS Accession No. ML12054A736).
This order imposes requirements to maintain or restore SFP cooling capability. This strategy provides makeup water independent of offsite power and the normal emergency alternating current (ac) power sources (e.g., installed emergency diesel generators).
Regarding additional instrumentation for all Mark I spent fuel storage pools, the NRC has addressed this request through Order EA-12-051, "Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," issued on March 12, 2012 (ADAMS Accession No. ML12056A044).
In addition, the petitioner's requests are being addressed through rulemaking (mitigation of beyond design basis events rulemaking, NRC-2011-0299). The rulemaking makes generically applicable the requirements of the mitigation strategies order, giving consideration to lessons learned and feedback from implementation of the order's requirements.
Request 2 (Issue No. 1C of the Table): Substandard Mark I pressure suppression containment system vulnerable to early failure under severe accident conditions including over-pressurization.
NRC decision: In 1972, Dr. S. H. Hanauer, Technical Advisor to the NRC's Executive Director for Operations, wrote a memorandum that raised several questions on the viability of pressure suppression containment concepts. As a result of these concerns, NRC published NUREG-0474, "A Technical Update on Pressure Suppression Type Containments in Use in U.S. Light Water Reactor Nuclear Power Plants." In Enclosure A of this NUREG, a response to each concern of Dr. Hanauer's memorandum of September 20, 1972, was provided. In this NUREG, NRC has concluded that licensed Mark I BWR facilities can continue to operate safely, pending completion of the comprehensive Long-Term Program (LTP) evaluation.
The L TP was associated with the suppression pool hydrodynamic loads in BWR facilities with the Mark I containment design. In NUREG-0661, "Safety Evaluation Report, Mark I Containment Long-Term Program," NRC described the generic techniques for the definition of suppression pool hydrodynamic loads in a Mark I system and the related structural acceptance criteria. In the report, NRC staff concluded that "the proposed structural acceptance criteria are consistent with the requirements of the applicable codes and standards and, in conjunction with the structural analysis techniques, will provide an adequate basis for establishing the margins of safety in the containment design." All GE Mark I BWRs were evaluated for the above hydrodynamic loads, and appropriate modifications, if required, were made to maintain the containment structural integrity (Order by NRC to each licensee on January 13, 1981, to evaluate hydrodynamic loads, and the licensee reflected this in Final Safety Analysis Report Section 3.8 after completing the evaluation/implementation).
The NRC finds that existing containment vent systems at BWRs with Mark I containments should remain in service to provide a capability to vent the containment under most circumstances, until licensees install enhanced venting systems. The NRC addressed this request through Order EA-12-050, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," issued on March 12, 2012 (ADAMS Accession No. ML12054A694), and superseded by a modified Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable for Operation under Severe Accident Conditions" (ADAMS Accession No. ML13143A334), issued on June 6, 2013. This order further enhances the reliability of the containment vent system, thereby protecting the containment during severe accident conditions Request 3 (Issue No. 1 D of the Table): Reactor design in Japan has now dramatically failed to reliably and adequately mitigate and contain significant and mounting radiological releases to the atmosphere, ground water, and the ocean from multiple severe accidents in multiple GE BWR Mark I units.
There certainly is much at stake and the seismic issues need to be studied because there is a great deal of seismic activity around Augusta, GA; the Vogtle nuclear plant; and Charleston, SC.
NRC decision: The NRC staff continues to conclude that the GE Mark I BWRs have been designed, built, and operated to safely withstand earthquakes likely to occur in their region and that the plants meet their current licensing basis. As part of the NRC post-Fukushima lessons-learned activities, the NRC is requiring all licensees to reevaluate seismic hazards at their sites. To this end, on March 12, 2012, the NRC issued a request for information under 10 CFR 50.54(f) (ADAMS Accession No. ML12053A340). Site seismic hazard reevaluation findings by the licensees in the central and eastern United States were submitted in March 2014, and are currently under NRC review. The NRC will take appropriate actions to ensure the continuous safe operation of all the plants including Vogtle.
In addition, the Commission issued Order EA-12-049 (station blackout mitigation strategies), which requires mitigation strategies to protect against, among many other hazards, postulated seismic events. Such actions significantly enhance the margins of safety to the effects of extreme natural phenomena at commercial operating reactors in the United States.
Request 4 (Issue No. 1 E of the Table): Failure of the Mark I containment even with the hardened vent system at Fukushima Dai-ichi demonstrates the inadequacy in design to mitigate and contain a severe accident resulting from longer station blackout.
NRC decision: The Commission issued Order EA-12-049, which requires mitigation strategies to protect against, among many other hazards, an extended station blackout. Such actions significantly enhance the margins of safety to the effects of extreme natural phenomena at commercial operating reactors in the United States.
This order requires a three-phase approach for mitigating beyond-design-basis external events. The initial phase requires the use of installed equipment and resources to maintain or restore core cooling, containment, and SFP cooling capabilities. The transition phase requires providing sufficient, portable, onsite equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from offsite. The final phase requires obtaining sufficient offsite resources to sustain those functions indefinitely. Order EA-12-049 requires the licensee to meet the following:
(1) Licensees or construction permit (CP) holders shall develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and SFP cooling capabilities following a beyond-design-basis external event.
(2) These strategies must be capable of mitigating a simultaneous loss of all ac power and loss of normal access to the ultimate heat sink and have adequate capacity to address challenges to core cooling, containment, and SFP cooling capabilities at all units on a site subject to this order.
(3) Licensees or CP holders must provide reasonable protection for the associated equipment from external events. Such protection must demonstrate that there is adequate capacity to address challenges to core cooling, containment, and SFP cooling capabilities at all units on a site subject to this order.
(4) Licensees or CP holders must be capable of implementing the strategies in all modes.
(5) Full compliance shall include procedures, guidance, and training, as well as the acquisition, staging, or installation of equipment needed for the strategies.
The NRC addressed the petitioner's containment venting request through Order EA-12-050, "Order To Modify Licenses with Regard to Reliable Hardened Containment Vents,"
issued on March 12, 2012 (ADAMS Accession No. ML12054A694), and superseded by a modified Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable for Operation Under Severe Accident Conditions" (ADAMS Accession No. ML13143A334), issued on June 6, 2013.
Order EA-13-109 requires the licensees of BWRs with Mark I and Mark II containments to design and install a venting system that provides venting capability from the wetwell during severe accident conditions. Severe accident conditions include the elevated temperatures, pressures, radiation levels, and combustible gas concentrations, such as hydrogen and carbon monoxide, associated with accidents involving extensive core damage, including accidents involving a breach of the reactor vessel by molten core debris. Furthermore, the licensees of BWRs with Mark I and Mark II containments shall either (1) design and install a venting system that provides venting capability from the drywell under severe accident conditions, or (2) develop and implement a reliable containment venting strategy that makes it unlikely that a licensee would need to vent from the containment drywell during severe accident conditions.
Request 5 (Issue No. 3b of the Table): Immediately revoke prior preapproval of the hardened vent system or direct torus vent system at each GE BWR Mark I unit under the provisions of 10 CFR 50.59, "Changes, Tests, and Experiments."
NRC decision: The NRC finds that existing containment vent systems at BWRs with Mark I containments should remain in service to provide a capability to vent the containment under most circumstances, until licensees install enhanced venting systems. The NRC addressed this request through Order EA-12-050, "Order to Modify Licenses with Regard to Reliable Hardened Containment Vents," issued on March 12, 2012 (ADAMS Accession No. ML12054A694), and superseded by a modified Order EA-13-1 09, "Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable for Operation under Severe Accident Conditions" (ADAMS Accession No. ML13143A334), issued on June 6, 2013. The NRC summarizes the pertinent requirements in these orders above, in response to the petitioner's Request 4.
Request 6 (Issue No. 3c of the Table): Immediately issue confirmatory action orders to all GE BWR Mark I units to promptly install safety-related backup electrical power (Class 1 E) and additional backup direct current battery system to ensure reliable supply of power for the SFP cooling system.
NRC decision: The NRC has addressed this request through Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," issued March 12, 2012 (ADAMS Accession No. ML12054A736). This order imposes requirements to maintain or restore SFP cooling capability. This strategy provides makeup water independent of offsite power, normal emergency ac power sources (e.g., installed emergency diesel generators), or normal direct current power sources. This request is also being addressed through rulemaking (mitigation of beyond design basis events rulemaking, NRC-2011-0299). The rulemaking is making generically applicable the requirements of the mitigation strategies order, giving consideration to lessons learned and feedback from implementation of the order's requirements.
Request 7 (Issue No.5 of the Table): Illinois reactors are operating on river flood plains and the current situation in Missouri and Nebraska speaks volumes as to what this means in terms of flooding.
NRC decision: The NRC staff continues to conclude that the GE Mark I BWRs have been designed, built, and operated to safely withstand flooding likely to occur at each site and meet their current licensing basis. Accordingly, the NRC has decided not to issue orders on flooding at this time. The NRC is instead addressing this issue through a 10 CFR 50.54(f) letter titled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)
Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from The Fukushima Dai-ichi Accident" (ADAMS Accession No. ML12056A046), issued on March 12, 2012.
The reasons for this decision are set forth in the following documents. On September 9, 2011, the NRC staff provided SECY-11-0124, "Recommended Actions to Be Taken without Delay from the Near-Term Task Force Report," to the Commission (ADAMS Accession No. ML11245A158). The document identified those actions from the Near-Term Task Force Report that should be taken without unnecessary delay. As part of the staff requirements memo for SECY 0124 (ADAMS Accession No. ML112911571) (October 18, 2011 ), the Commission approved the staff's proposed actions, including the development of three information requests under 10 CFR 50.54(f). The information collected will be used to support the NRC staff's evaluation of whether further regulatory action is needed regarding revisions to the existing flooding licensing basis for each plant.
Request 8 (Issue No.7 of the Table): Provide an expedited hardened {dry cask) onsite storage by emptying the SFPs and converting the irradiated nuclear fuel that is more than 5 years cooled to dry casks. At Fukushima, three reactor systems were blown out and caused exposure of the fuel in the SFPs directly to the atmosphere.
The NRC should order TVA to eliminate the existing unsafe irradiated fuel storage system at Browns Ferry and move the fuel to hardened storage in concrete structures.
NRC decision: Contrary to the petitioner's statement, the SFPs at Fukushima Dai-ichi were found to be structurally intact following the accident and the fuel was still under water, that is, not exposed to the atmosphere.
The NRC would further note that all operating U.S. nuclear power plants store some spent nuclear fuel in "spent fuel pools." These pools are made of reinforced concrete several feet thick, with steel liners. The water is typically about 40 feet (12 meters) deep, and serves both to shield the radiation and cool the spent fuel assemblies.
As the pools near capacity, licensees move some of the older spent fuel into "dry cask" storage. Fuel is typically cooled at least 5 years in the pool before transfer to casks. The NRC has authorized transfer as early as 3 years; the industry norm is about 10 years.
After the September 11, 2001, terrorist attacks, the NRC issued orders to plant operators requiring several measures aimed at mitigating the effects of a large fire, explosion, or accident that damages a SFP. These were meant to deal with the aftermath of a terrorist attack or plane crash; however, they would also be effective in responding to natural phenomena such as tornadoes, earthquakes or tsunami. These mitigating measures include:
- 1.
Controlling the configuration of fuel assemblies in the pool to enhance the ability to keep the fuel cool and recover from damage to the pool.
- 2.
Establishing emergency spent fuel cooling capability.
- 3.
Staging emergency response equipment nearby so it can be deployed quickly.
The NRC determined that SFPs and dry casks both provide adequate protection of the public health and safety and the environment. Therefore, there is no safety or security reason to mandate earlier transfer of fuel from pool to cask. In a staff requirements memorandum dated May 23, 2014 (ADAMS Accession No. ML14143A360), the Commission directed the NRC staff, based on the staff's recommendation, to stop working on possible regulatory actions that would require the expedited transfer of spent fuel to dry cask storage.
The GE Mark I BWRs meet their current license requirements related to spent fuel storage and inventory. Dry cask storage is in use at Browns Ferry Nuclear Plant, along with SFP storage.
In conclusion, based on the NRC's prior analyses of closely related issues, we conclude there is no need to issue an order requiring licensees to take the petitioner's requested actions.
Request 9 (Issue No. 10 of the Table): The intense rainfall accompanying the hurricane thoroughly saturated the ground around Vermont Yankee, which has aggravated the existing problem of reactors' underground safety-related electrical cables that were never designed to withstand wet or underwater conditions. The NRC is aware of this problem. To my knowledge, no remedial action or even a complete inspection of every inch of such cables has been undertaken or is even being contemplated.
NRC decision: During license renewal of the Vermont Yankee Nuclear Power Station, Entergy Nuclear Operations, Inc., (the licensee) made the following commitments related to the electrical cables as described in the safety evaluation report NUREG-1907, Supplement 2 (ADAMS Accession No. ML110770495).
Commitment 13 Implement the Non-Environmental Qualification Inaccessible Medium-Voltage Cable Program as described in License Renewal Application Section 8.1.17.
Inspections for water accumulation in manholes containing inaccessible low-voltage and medium-voltage cables with a license renewal intended function will be performed at least once every year. Additional condition-based inspections of these manholes will be performed based on: a) potentially high water table conditions, as indicated by high river level, and b) after periods of heavy rain. The inspection results are expected to indicate whether the inspection frequency should be modified.
Inaccessible low-voltage cables (400 V to 2 kilovolt [Kv]) with a license renewal intended function are included in this program. Inaccessible low-voltage cables will be tested for degradation of the cable insulation prior to the period of extended operation and at least once every six years thereafter. A proven, commercially available test will be used for detecting deterioration due to wetting of the insulation system for inaccessible low-voltage cables.
Commitment 43 Establish and implement a program that will require testing of the two 13.8 kV cables from the two Vernon Hydro Station 13.8 kV switchgear buses to the 13.8 kV/69 kV step up transformers before the period of extended operation and at least once every 6 years after the initial test.
The NRC Inspection Report 05000271/2012008 dated April20, 2012 (ADAMS Accession No. ML12103A406) discussed the implementation of Commitments 13 and 14 as noted below.
The inspectors reviewed the commitment completion review reports, manhole inspection results, and cable test results to verify that potential aging effects to inaccessible cables were being adequately managed. The inspectors reviewed tan delta and insulation resistance test results to verify that cable testing frequencies were established based on cable performance. The inspectors verified that the cable testing program included medium and low voltage cables.
The inspectors also reviewed the manhole inspection results and determined that all of the manholes had been inspected and future work orders were designed to inspect the manholes on appropriate frequencies and at least once every year. The inspectors reviewed OP-PHEN-3127, "Natural Phenomena Operating Procedure," to verify that the manholes will be inspected under conditions of high river level or after heavy rain. The inspectors also interviewed the project manager to review any operating experience or implementation issues.
Commitment 43 applied the Commitment 13 cable testing program to the cables between Vermont Yankee and the Vernon Hydro Station. The inspectors reviewed the cable testing program to ensure that the cables between Vermont Yankee and Vernon Hydro station were included in the cable testing program, the cables had been tested satisfactorily, and the cable testing frequency was set at 6 years.
Based on the above, the licensee has satisfied the commitments made during the license renewal application. The NRC finds that the licensee's existing commitments address the risks identified by the petitioner and that an order requiring additional actions is not needed at this time.
Furthermore, the NRC would note that NRC Regulatory Guide 1.218, "Condition-Monitoring Techniques for Electric Cables Used in Nuclear Power Plants," published in April 2012, provides guidelines in monitoring the performance of electric cables used in nuclear power plants.
Ill.
Conclusion The NRC has evaluated each of the petitioner's requests. For the reasons stated above, the NRC will not be issuing an order requiring the additional actions specified in the petitioner's requests.
As provided in 10 CFR 2.206(c), a copy of this director's decision will be filed with the Secretary of the Commission for the Commission to review. This decision will constitute the final action of the Commission 25 days after the date of the decision unless the Commission, on its own motion, institutes a review of the decision within that time.
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Dated at Rockville, Maryland, this t--':bay of Oc~..hli.A. ; (;1-'V uclear Regulatory Commission.
~~~
Je r L. Uhle, Deputy Director f r eactor Safety Programs Off1ce of Nuclear Reactor Regulation
OPERATING BOILING-WATER REACTOR LICENSEES WITH MARK I CONTAINMENTS Browns Ferry Nuclear Plant Tennessee Valley Authority Docket Nos. 50-259, 50-260, and 50-296 License Nos. DPR-33, DPR-52, and DPR-68 Mr. Joseph P. Grimes Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Brunswick Steam Electric Plant Duke Energy Progress, Inc.
Docket Nos. 50-325 and 50-324 License Nos. DPR-71 and DPR-62 George T. Hamrick, Vice President Brunswick Steam Electric Plant P.O. Box 10429 Southport, NC 28461 Cooper Nuclear Station Nebraska Public Power District Docket No. 50-298 License No. DPR-46 Mr. Oscar A. Limpias Vice President-Nuclear and Chief Nuclear Officer Nebraska Public Power District 72676 648A Avenue P.O. Box 98 Brownville, NE 68321 Dresden Nuclear Power Station Exelon Generation Co., LLC Docket Nos. 50-237 and 50-249 License Nos. DPR-19 and DPR-25 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 BWR-Mark I BWR-Mark I BWR-Mark I BWR-Mark I
Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Docket No. 50-331 License No. DPR-49 Mr. Rich Anderson Site Vice President NextEra Energy Duane Arnold Energy Center 3277 DAEC Road Palo, lA 52324-9785 Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Co.
Docket Nos. 50-321 and 50-366 License Nos. DPR-57 and NPF-5 Mr. David R. Vineyard Site Vice President Southern Nuclear Operating Company, Inc.
Edwin I. Hatch Nuclear Plant 11028 Hatch Parkway North Baxley, GA 31513 Fermi Detroit Edison Co.
Docket No. 50-341 License No. NPF-43 Mr. Joseph Senior Vice President and Chief Nuclear Officer Detroit Edison Company Fermi 2-210 NOC 6400 North Dixie Highway Newport, Ml 48166 Hope Creek Generating Station PSEG Nuclear, LLC Docket No. 50-354 License No. NPF-57 Mr. Thomas Joyce President and Chief Nuclear Officer PSEG Nuclear LLC - N09 P. 0. Box 236 Hancocks Bridge, NJ 08038 BWR-Mark I BWR-Mark I BWR-Mark I BWR-Mark I
James A. FitzPatrick Nuclear Power Plant Entergy Nuclear Operations, Inc.
Docket No. 50-333 License No. DPR-59 Mr. Lawrence Coyle Executive Vice President Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 31955 Jackson, MS 39286-1995 Monticello Nuclear Generating Plant Northern States Power Company Docket No. 50-263 License No. DPR-22 Mrs. Karen D. Fili Site Vice President Northern States Power Company - Minnesota Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362-9637 Nine Mile Point Nuclear Station Nine Mile Point Nuclear Station, LLC Docket No. 50-220 License No. DPR-63 Mr. Christopher Costanzo Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P. 0. Box 63 Lycoming, NY 13093 Oyster Creek Nuclear Generating Station Exelon Generation Co., LLC Docket No. 50-219 License No. DPR-16 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 BWR-Mark I BWR-Mark I BWR-Mark I BWR-Mark I
Peach Bottom Atomic Power Station Exelon Generation Co., LLC Docket Nos. 50-277 and 50-278 License Nos. DPR-44 and DPR-56 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Pilgrim Nuclear Power Station Unit No. 1 Entergy Nuclear Operations, Inc.
Docket No. 50-293 License No. DPR-35 Mr. John Dent, Jr.
Vice President and Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Quad Cities Nuclear Power Station Exelon Generation Co., LLC Docket Nos. 50-254 and 50-265 License Nos. DPR-29 and DPR-30 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Vermont Yankee Nuclear Power Station Entergy Nuclear Operations, Inc.
Docket No. 50-271 License No. DPR-28 Mr. Christopher J. Wamser Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 BWR-Mark I BWR-Mark I BWR-Mark I BWR-Mark I
Package: ML14198A098 Letter* ML14198A141* '
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NRR/D NAME MCiark WDean (JUhle for)
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