ML17157C518
| ML17157C518 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/19/1993 |
| From: | James Shea Office of Nuclear Reactor Regulation |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17157C519 | List: |
| References | |
| NUDOCS 9310250110 | |
| Download: ML17157C518 (28) | |
Text
Pocket Nos.
50-387 and 50-388
~
LICENSEE:
Pennsylvania Power and Light Company October 19, 3
FACILITY:
Susquehanna Steam Electric Station, Units 1 and 2
SUBJECT:
SUMMARY
OF MEETING ON OCTOBER 1, 1993 REGARDING SPENT FUEL POOL COOLING FOLLOWING A LOSS-OF-COOLANT ACCIDENT (LOCA)
On November 27,
- 1992, two individuals, Mr. David A. Lochbaum and Hr. Donald C.
Prevatte; who formerly had worked as contract engineers for Pennsylvania Power and Light Company (PP&L), filed a report under 10 CFR Part 21 asserting that the design of the spent fuel pool cooling system at Susquehanna, Units 1 and 2
fails to meet regulatory requirements.
The initial Part 21 report was supplemented by six additional letters.
On October 1,
1993, the NRC staff met with Hr. Lochbaum and Mr. Prevatte.
The purpose of the meeting was to afford Mr. Lochbaum and Mr. Prevatte the opportunity to personally present the technical issues in their Part 21 report to the NRC staff.
Enclosure 1 is a list of attendees, including members of the public and press representatives who attended as observers.
Enclosure 2 is a handout distributed prior to the meeting by Messrs.
Lochbaum and Prevatte and was essentially an outline of their presentation.
It contains most of the slides used during the discussion.
The meeting was transcribed, and a copy of the transcript is attached as Enclosure 3.
The transcript includes any comments or questions by observers at the end of the meeting.
The staff is reviewing the information presented by Messrs.
Lochbaum and Prevatte as well as information that has been submitted by PP&L on the issues.
/S/
Joseph W. Shea, Project Manager Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosures:
1.
List of Attendees 2.
Handout 3.
Transcript cc w/enclosures:
See next page
- w/Enclosures 1,
2 and 3
DISTRIBUTION w Enclosure 1:
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- DShum
- KEccleston LNicholson HFleishman
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Docket Nos. 50-387 and 50-388 UNITED STATES NUCLEAR REGULATORY COMMISSION" WASHINGTON, D.C. 20555-0001 October 191
>993 LICENSEE:
Pennsylvania Power and Light Company FACILITY:
Susquehanna Steam Electric Station, Units 1 and 2
SUBJECT:
SUMMARY
OF MEETING ON OCTOBER 1, 1993 REGARDING SPENT FUEL POOL COOLING FOLLOWING A LOSS-OF-COOLANT ACCIDENT (LOCA)
On November 27,
- 1992, two individuals, Mr. David A. Lochbaum and Mr. Donald C.
- Prevatte, who formerly had worked as contract engineers for Pehnsylvania Power and Light Company (PP&L), filed a report under 10 CFR Part 21 asserting that the design of the spent fuel pool cooling system at Susquehanna, Units 1 and 2
fails to meet regulatory requirements.
The initial Part 21 report was supplemented by six additional letters.
On October 1,
1993, the NRC staff met with Mr. Lochbaum and Mr. Prevatte.
The purpose of the"meeting was'to"afford Mr. Lochbaum and Mr. Prevatte the opportunity to. personally'.present thh "
technical issues.,in theip Part 21 report to the NRC staff;"" "
Enclosure 1 is a list of attendees, including IIIembers.of the public and press representatives who attended as observers.
Enclosure 2 is a handout distributed prior to the meeting by Messrs.
Lochbaum and Prevatte and was essentially an outline of their presentation." It contains most of the slides used during the discussion.
The meeting was transcribed, and a copy of the tran'script is attached as Enclosure 3.
The transcript includes any comments or questions by observers at the end of the meeting.
The staff is reviewing the information presented by Messrs.
Lochbaum and Prevatte as well as information that has e n submitted by P KL on the issues.
Enclosures:
1.
List of Attendees 2.
Handout 3.
Transcript cc w/enclosures:
See next page F
(
3 c$
I J sep W. Shea, Project Manager P oj ct Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Pennsylvania Power
& Light Company Susquehanna Steam Electric Station, Units 1
& 2 CC:
Jay Silberg, Esq.
- Shaw, Pittman, Potts
& Trowbridge 2300 N Street N.W.
Washington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. J.
M. Kenny Licensing Group Supervisor Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania l8101 Mr. Scott Barber Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsy1van)a 18603-0035 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pennsylvania 17120 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I U.S. Nuclear Regulatorp Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr.,Harold, G. Stanley Superintendent of Pl'ant
'usquehanna Steam Electric Station PennsyTv'ania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herber't D. Woodesh'ick "
Special Office of the President Pennsylvani'a Power and Light Company Rural Route 1,
Box 1797 Berwick, Pennsylvania 18603 George T. Jones Manager-Engineering Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Robert G.
Byram Senior Vice President-Nuclear Pennsylvania Power
& Light Company 2 North Ninth Street Allentown, Pennsylvania '8101 Mr. David A. Lochbaum 80 Tuttle Road Watchung, New'ersey 07060 '*
Mr. Donald C. Prevatte 7924 Woodsbluff Run Fogelsville, Pennsylvania 18051
ENCLOSURE I ATTENDANCE LIST
'eeting between NRC and Messrs. Lochbaum and Prevatte on Effects of Loss-of-Spent-Fuel-Pool Cooling at Susquehanna Steam,.Electric Station,. Units
'1 and,2 October 1, 1993 A
Jon Block Paul Gunter M. Blood Lisa Finnegan Joanne Royce James Kenny Herb Woodeshick David Ney Larry Nicholson Morton Fleishman Mark Wigfield John R. White Conrad McCracken Dick Clark Ashok Thadani Jose A. Calvo Michael L. Boyle David A. Lochbaum Donald C. Prevatte George Hubbard John Kopeck David Shum Ken Eccleston Tilda Liu New England Coalition on Nuclear Pollution Nuclear Information. 8 Resource Servide'P Allentown Morning Call Government Accountability Project Pennsylvania Power 5 Light Co.
Pennsylvania Power 8 E,ight Co'.
Pennsylvania DER/BRP NRC Region I" NRC/OCMKR Ottawa News Service NRC Region I DRP NRC/SPLB
'" " " 'P'8 NRC/DRPE/PD I-2 NRC/NRR/DSSA NRC/NRR/DRPE NRC/NRR/DRPE/PD I-2 Self Representing Self Representing NRC/DSSA/SPLB NRC/OPA NRC/NRR/DSSA/SPLB NRC/NRR/DRSS/PRPB NRC/DRPE/PDI-2
ENCLOSURE 2
October 1, 1993 Michael L. Boyle, Acting Project Director Project Directorate I-2 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555-0001 sUBJECT:
Docket Nas.
50-387 and 50-388 Presentatian to the NRC an Susquehanna Steam,...Electri.c Stati.an Design Deficiencies far Loss. of Spent puel Paal Cooling
Dear Mr. Boyle:
I We appreciate the opportunity to make.
a presentation
. on the substantial safety hazard which exists at the Susquehanna Steam Electric Station which we identified to the NRC in a 10CFR21 report dated November 27, 1992.
If there are any questions on the material we discussed in the presentation or submitted with the Part 21 report, please contact us
~
Sincerely,
~~a David A. Lochbaum 80 Tuttle Road
- Watchung, NJ 07060-.
(908) 754-3577
~Q.
g,Donald
. Prevatte 4%
'TO@C~
7924 Woodsbluff Run...
Fogelsville,.PA 18051 (215) 398-9277 Attachments:
- 1) Outline for NRC Presentatian on SSES Loss of Spent Fuel Pool Cooling Design Deficiencies (13 pages)
EDR G20020 Events (1 page) 4)
Shoreham Containment Schematic (1 page) 5)
SSES Fuel Pool Cooling Diagram (1 page) 6)
SSES Refueling Floor Plan (1 page)
Outline for NRC Presentation on SSES Loss of Spent Fuel Pool Cooling Design-Deficiencies I ~
INTRODUCTION A.
Technical Concerns 1.
Susquehanna SES has serious design defects for handling of loss of, fuel pool cooling events associated with Design Basis Loss of Coolant Accidents (DBA LOCAs).
For DBA LOCA conditions, defects can produce potentially catastrophic results:
a.
Fuel meltdown outside containment.
2 ~
- b. Failure of ~al reactor building safety systems and resultant core meltdown.
~ ~
- c. Failure of all containment systems. l'l It'I "~
- d. Offsite radiation doses thousands of times greater than 10CFR100 limits.
Very high risk accident (risk.~;.probability.x~
consequences)
- a. Probability - Same as LOCA (10~/year)-,
because it is mechanistically caused by LOCA.
b.
Consequences Much worse than analyzed LOCA. See (1) above.
3.
Because of post-DBA LOCA..radiation levels, operators are powerless to intervene.
Unable even to. monitor due to inaccessibility and/or failure of instrumentation.
4.
Most Bus have same basic design (approximately 1/3 of U.S. plants)
B.
Other Concerns
<< To be handled separate from this presentation >>
October 1, 1993 Page-1 of 13
~ Ql
~
J' Outline for NRC Presentation on SSES Loss of Spent Fuel Pool Cooling Dosign Defi.cioncios ZZ ~
OUTLZNE OP ACCZDENT SCENARZO OF CONCERN A.
B.
Licensing Basis - Includes all accidents/events described in FSAR + all mechanistic consequences.
DBA LOCA one of the accidents described in the FSAR.
C.
D.
E.
The spent fuel pool (SFP) cooling system is not designed for LOCA hydrodynamic loads and,environmental conditions.
Therefore,'t will fail mechanistically with LOCA. If it did not fail, it would be de-energized by LOCA load shed and cannot be restarted without.reactor, building entry.
If SFP cooling system fails, per the FSAR, boiling is the consequence (pool is in reactor.building)~...
Therefore, boiling of the SFP is one of the mechanistic consequences of a DBA LOCA alone.
Therefore, contrary to PPfL's claim, boiling of the SPP concurrent vith LOCA ~
vithin the SSES licensing basis.
Continuing the logic for other'accidentsw.
n F.
G.
H.
Combination accidents are also described-in
.FSAR:.
I LOCA/LOOP LOCA/LOOP/single failure LOCA/seismic event, LOCA/seismic event/single failure Any mechanistic results of these accidents.
All of these include LOCA which causes SFP boiling.
Therefore, all combination accidents also cause SPP hailing.
Therefore, all are vi.thin thelicensing hasi.s.
~
~ ', 4~
Continuing the logic for consequences:-
I. Emergency Service Water (ESW) makeup valves to fuel pool are. in reactor building.
For DBA LOCA with required Reg.
Guide 1.3 source terms, reactor building is virtually inaccessible for many days.
(Radiation levels ) 5,000 Rem/hr;,
450 Rem is lethal).
K.
L.
Therefore, ESW makeup valves cannot be opened without excessive radiation exposure.
Zf makeup vater cannot he provided, the fuel in the SPP vill he uncovered and villmelt dovn (outside primary containment).
M. Unanalyzed catastrophic results.
October 1, 1993 Page 2 of 13
Outline for NRC Presentation an SSES Loss of Spent Fuel Pool Caoling Desi.gn Deficiencies Additional consequences:
N. Safety-related equipment in reactor building is not qualified for temperatures and water collection resulting from the boiling of the spent fuel pool.
O. Therefore, safety-related equipment vi.ll fail.
P. After safety-related equipment fails, core villmeltdavn.
Q. Additional unanalyzed catastraphi.c resulti:
- 1. Failure of reactor vessel.
- 2. Failure of primary and secondary containment.
- 3. Release of radi.oactivity thousands of times greater than allowed.
R.
DBA LOCA fault tree (attached)
ZIZ PP&L's POSZTZONS A.
Before the 10CFR21 report-
- 1. The accident scenario described above was not directly addressed in the FSAR, the FSAR had been approved by the NRC, and PP&L had an unwritten "agreement" with the NRC that SFP boiling concurrent with a LOCA didn't have to be considered.
Therefore, it was not a valid concern.
- 2. Additionally, PP&L was not required to consider Reg Guide 1.3 source terms.
And even if they were considered,,
their operators could take needed..
<<heroic<< actions, and their emergency management
,organization could handle any condition even if it had not been analyzed.
B.
Since the Part 21 report-1..
PP&L still claims this accident scenario is not part of their licensing basis, therefore, they are not required to deal with it.
2.
- However, PP&L finally concedes that Reg.
Guide 1.3 source terms are applicable for operator access to the reactor building and that airborne radiation must be considered.
October 1, 1993 Page 3 of 13
Outline for NRC Presentation on SSES Loss of Spent'uel Pool Cooling Design-Deficienoies-3.
PP&L'has made numerous equipment, procedure,
- analysis, and training changes - all for a condition they maintain was of "minimal" safety significance.
4.
Even with these changes which have remedied many
- problems, PP&L is still forced to admit that numerous shortcomings and equipment failures remain for this accident scenario.
Examples:
a.
Failure of safety-related equipment.
They finally: admit> to faX'lure of a core spray'pump and other unspecified safety-related equipment.
b.
Reg Guide 1.97 - Qualification of safety-related instrumentation.
They finally admit that fue1 pool monitoring instrumentation's not accessible.
5.
Even with these changes and failures, they still contend there is not now and never"was-any problem
- And, PP&L is asking the'NRC to accept these positions.
ZV, POZNTS OP CONTENTZON AND OTHER VZOLATZONS AND PAZLUREB A.
Specific Points of Contention:
1.
Claim -
Fuel pool instrumentation is seismically qualified.
Reality Instrumentation is only seismically
- mounted, not seismically qualified.
Instrumentation 'is also-not -qualified for LOCA or for boiling fuel pool environments.
2.
Claim -
Fuel pool instrumentation is 1E qualified.
Reality It can-be powered-from lE source, but the circuitry is non-1E and the instruments themselves are not 1E qualified.
- In 1984,
- 1988, and 1992, PP&L's Nuclear Safety Assurance Group recommended that instrumentation be upgraded.
Still has not been.
October 1,
1993 Page 4 of 13
Outline for NRC Presentation on SSES Loss of spent Fuel Pool cooling Design Deficiencies 3.
Claim-Standby Gas Treatment System (SGTS) is qualified for boiling fuel pool condi tions.
Reality-Equipment in the SGTS rooms is not qualified for temperature generated by boiling fidel pool (identified by Bechtel in 1980).
{}uestionable ability to handle volumes of.condensate that will be..-
generated.
Before Part 21 report,.fire.dampers in the SGTS ducts closed at 165oF.
- Boiling fuel pool generates
=185oF.
4.
Claim-Reality-Reactor building HVAC recirculation system can be isolated to prevent the boiling fuel pool heat and moisture from reaching the safety-related equipment in the..
reactor bui lding.
This would be an unanalyzed condition.
Recirculation-. is required for mixing of the reactor building atmosphere for temperature control and for dilution of primary containment leakage.
5.
Claim-Reality-I'mergency procedures/training at time of Part 21 report addressed boiling pool; changes are gust enhancements.
Procedures/training at that time did-not address this scenario.
Current changes address this scenario for first time.
Procedure at time of our Part 21 report caused fuel pool cooling failure by de-energizing non-1E power to the reactor building.
-,--Procedure was changed in. 1988 to add-step to de-energize non-1E power.
This change created an unreviewed safety question, but was not reported by PPEL.
October 1, 1993 Page-5 of 13
Outline for MRC Presentation on SSES Loss of Spent Fuel Pool Cooling Design Deficiencies 6.
Claim The design basis source term required by Reg Guide 2..3 is a "severe accident",
i.e., outside their design/licensing bases.
Reality-Reg Guide 1.3 source terms are within their design/licensing bases as ~ea~
indicated in NRC Standard Review Plan 15 ' I "Severe accident" is only properly applied to accidents which are actually, outside licensing basis, such as ATWS.
7.
Claim-Reality-ESP makeup valves may, be operated within the 5 Rem exposure limit.
PP&L time-motion study determined one trip to the ESW valves, resulted. in. 4.2. Rems exposure.
- To prevent overflowing the=SFP,
.ESW makeup is specified to be in batch mode.
Therefore, each batch exposes operator and HP tech to an entire accident dose.
8.
Claim-Reality-Flood water from boiling pool can be sent to radwaste.
ll Sump pumps aren't 1E powered or seismically or environmentallyqualified.
Operators don't have access due to radiation levels.
Radwaste isn't 1E powered or seismically qualified.
- Radwaste isn't designed to handle accident water volumes or content.
- This would constitute breach of secondary containment.
- No place to release or store the accident water once it is processed.
October 1, 1993 Page 6 of 13
Outline for NRC Presentation on 88ES Loss of Spent Fuel Pool Cooling Design Deficiencies 9.
Claim Reality Fai?ure of -core spray. pump. due to flooding is acceptable because there is another pump to handle cooldovn..*
No failure of safety-related equipment due to inadequacies in the design is acceptable.
- With only one pump, single failure leaves no pumps for cooldown.
With actual volumes of water that will be generated, the watertight door to the second core spray room will fail causing loss of the second pump also.
- 10. Claim g
'- I I
RHR could be used in the fuel pool cooling assist mode.
Reality Critical manual valves are inaccessible post-LOCA due to radiation:levels.
- PP&L's own analysis shoved RHR pumps had insufficient NPSH in this mode.
- PP&L's preop tests confirmed RHR pumps could not deliver required flow.
In the time required to align RHR for SFP cooling, the.SFP temperature vill exceed 1254F, further reducing available NPSH.
1 The spray pond (UHS) does not have sufficient cooling capacity-for fuel pool heat load in addition to LOCA and shutdown;.
(elaborate, based on numerous if's)
- Single failure cannot be tolerated in this mode.
Not all of involved piping is seismically qualified.
Critical RHR valves were removed from the ISI program.
- This mode would contaminate the fuel pool with accident water - an unanalyzed condition.
October 1, 1993 Page 7 of 13
Outline for NRC Presentation on SSES Loss of Spent Puel Pool Cooling Design Deficiencies ll. Claim -
MOP can last only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />'.
Reality Reg.
Guide 1.137 requires emergency diesel generators have minimum of 7 days fuel supply.
Turkey Point had LOOP that lasted six and one half days.
Credible long-term LOOP mechanisms:
Natural events, operator error and sabotage.
B.
Other Violations and Failures 1.
Even with above described 'safety-related equipment failures documented by PP&L, PP&L has not made any 10CFR50.72/50.73 reports (violation of 10CFR50.9).
~I a
~ ~ 'I 2.
Fuel pool instrumentation.,isnot envi.ronmentally qualified for LOCA or boiling'pool (violation of 10CFR50.49, 10CFR50 App. A GDC 63, and Reg Guides 1.13, 1.89 and 1.97).
3.
The following safety-related room coolers are not designed for latent heat cooling and will potentially fail upon SFP boiling with the resultant failure of safety-related equipment they serve (violation of 10CFR50.49, 10CFR 50 App.
A GDC 4, and
- 10CFR50, Appendix B, Criterion IZZ, Design Control):
Core spray pump rooms RHR pump rooms HPCI pump room RCZC pump room Emergency switchgear and load center rooms 4.'he safety related HVAC ductwork is not designed to handle condensation; will produce unanalyzed leaks and/or will fail due to condensate accumulation or blockage of flow path (violation of 10CFR50, Appendix B, Cri.terion IZZ, Design Control).
5.
>>Draft>> analyses for this scenario not, reviewed and approved (violation of 10CFR50, Appendix Bf
,Criterion ZZI, Design Control).
October 1, 1993 Page 8 of 13
Vo Outline for NRC presentation on SSES Loss of Spent Fuel Pool Cooling Design Deficiencies QUALIFICATIONS OP PERSONS MAKING PART 21 REPORT A. Don Prevatte's Education and Experience
- Bachelor of Science in Mechanical Engineering
- Officer in engineering consulting company
- Over 22 years commercial nuclear power experience in design, startup, and management
- 13 years experience with BWRs
- 9 years experience with PP&L 4 years performing NRC inspections (more than 30 inspections at more than 25 plants) 2 1/2 years as design engineer on SSES Power Uprate Project
- 2 years as A/E discipline manager B. Dave Lochbaum's Education and Experience
- Bachelor of Science in Nuclear Engineering Over 14 years commercial nuclear power experience in
- startup, operations, licensing and engineering
- 7 years as reactor engineer 3 years as BWR STA
- Experience with all BWR containment types
- 1 year as Reactor Engineering Supervisor and STA Supervisor 1 year as BWR..licensing engineer 2 years as design engineer on SSES Power Uprate Project 1 year as design engineer on DBD project and handling design do'cument open items VI~
HISTORY OP THIS CONCERN A. Prevatte prepared updated reactor building heat load calculation to account for higher loads resulting from power uprate.
B. Lochbaum performed technical review of updated reactor building heat load calculation.
C. Discovered and reported to PP&L supervision in March, 1992 that original and updated calculation non-conservatively neglected any mode of spent fuel pool cooling and the latent heat load from boiling spent fuel pool(s)
(As much as 26.4 million BTU/hr added vs. 5.2 million BTU/hr for all other heat loads combined.).
D. Updated calculation revised to assume FPCCS operation in non-LOOP case'nd RHR FPC Assist operation in LOOP case.
October 1, 1993 Page 9 of 13
Outline for NRC Presentation on SSES Loss of Spent Fuel Pool Cooling Design Deficiencies E. Research to support FPCCS and RHR FPC Assist assumptions determined that boiling spent fuel pool could result from DBA LOCA but was not covered by calculation.
Prevatte and Lochbaum would not sign calculation because it was not bounding.
EDR G20020 was generated in April 1992 on loss of fuel pool cooling concerns to allow calculation to be issued.
F.
The PP&L EDR process repeatedly failed to completely and adequately evaluate the EDR concerns; G.
PP&L management failed to properly determine operability and reportability for concerns.
H.
On November 17, 1992 PP&L submitted report under 10CFR50.9, failing to properly report under 10CFR50.72 and 50.73.
I. When it was apparent PP&L would not make complete and accurate report, Lochbaum and Prevatte made 10CFR21 report on November 27, 1992.
'L VIZ~
REASONS
%E MADE 10CPR21 REPORT'.
A high risk accident.
B. Serious generic implications of the concerns.
C. Ethical responsibility.
D. Legal obligation under 10CFR21.
E.
To bring regulatory attention to PP&L culture adverse to nuclear safety.
F. What's in it for us.
o,Ridicule.
o Loss of contract.
o Embarrassment and strain in personal relationships with co-workers, family, neighbors.
o Untold expenditure of personal time, effort, and money in discouraging, one-sided battle.
o Career suicide, label as troublemaker, non-team player (Nobody likes alligators).
October 1, 1993 Page 10 of 13
Outline for NRC Presentation on SSES Loss of Spent, Puel Pool Cooling Design Deficiencies VZZZ~
WHY %E KN0% %E ARE RZGHT A.
WPPSS 2 made 10CFR50.72 and 50.73 report on same concerns in April and May, 1993.
B.
GE issued warning letter to all domestic BWRs on this concern in March, 1993.
C. Four independent PP&L engineering evaluations agreed with the essences of our technical assessments.
D.
We spent two years before the discovery thoroughly researching the systems involved.
After the discovery, we concentrated our research on the concerns.
All research confirmed discovery.
PP&L also thoroughly researched.
PP&L made discoveries which resolved two of the original nine concerns, but could not resolve the remaining seven.
E.
PP&L has made and is making extensive modifications to plant hardware, procedures,
- training, and analyses to cope with a problem with "minimal" safety significance.
(Modifications aren't adequate and would not have been done without the impetus of our Part 21 report.)
F. Seabrook Station incorporated history of this case into their GET training as an example of how not to handle safety issues.
G. Massachusetts Assistant Attorney General had an independent consultant evaluate concerns for applicability to Pilgrim.
Consultant concluded that the Part 21 concerns were valid.
H. Neither GE nor Bechtel has supplied PP&L with adequate justification for the SSES design at the time of the Part 21 report.
I.
We both have extensive, diverse BWR experience.
October 1, 1993 Page 11 of 13
t ~
1 Outline for NRC presentation on SSES Loss of Spent Fuel Pool Cooling Design Deficiencies 1X.
WHAT SHOULD BE DONE NOW2 WHAT DO WE WANT NRC TO DO2 A. Perform thorough review of current Susquehanna condition vs. regulatory requirements.
o Qualification/accessibility of SFP instruments and system controls.
o Investigate operability of RHR FPC assist mode.
- Availability for all accident scenarios including single failure in RHR and support systems.
h
- NPSH available vs. required.
- Contamination of SFP with accident water and resultant offsite
& control room doses vs.
allowables.
Spray pond heat load capacity.
(LOCA+safe shutdown+fuel pools beyond design basis)
- Failure of non-seismic piping in RHR suction path from fuel pool.
o Mods to ESW and/or RHR valves.
o Mods to HVAC systems.
o Changes to emergency procedures and training.
o Analyses that have been produced or updated.
B. Determine the generic impact of this discovery on other
e'.
Determine Susquehanna condition at time of Part 21 report (not today) vs. regulatory requirements.
D. Investigate PP&L's actual response to our discovery, before Part 21 report.
Did they do the right thing2 E. Investigate counter-to-safety management attitudes at PP&L.
F. Bring issues to closure as soon as practicable.
October 1, 1993 Page 12 of 13
Outline for NRC Presentation on SSEB Loss of Spent Fuel Pool Cooling Design Deficiencies G. Don't take our positions at face value; don't take PP&L's positions at face value. If you look at the facts, we'e confident our conclusions vill be supported.
1.
A DBA LOCA results in a boiling spent fuel pool.
- 2. The inability to provide makeup to a boiling spent fuel pool results in the meltdown of irradiated fuel outside primary containment.
3 ~
A boiling spent fuel pool results in the failure of safety-related equipment in the reactor building and loss of secondary containment.
- 4. Loss of safety-related equipment results in the meltdovn of reactor core, failure of the reactor vessel and failure of the primary containment.
- 5. All of the above result in radiological consequences to the public thousands of times greater than allowed by 10CFR100.
6.
PP&L did not and still is not satisfying their legal and ethical obligations.
October 1,
1993 Page 13 of 13
DBA LOCA Event Loss of Fuel Pool Cooling from Auto Load Shed Logic Reactor Bldg Accessible?
Yes Non-Class 1E Pover Available?
No Yes No FPCCS
& SV Piping Intact?
Yes No FPCCS
Yes Initiate FPCCS Using Affected Unit's FPCCS Restore FPC No RHR Loop Available?
Yes No No RHR FPC Components Operable?
Yes Adequate NPSH for RHR Pump?
Yes No Yes RHRSV/UHS Capacity Available?
Yes Accident Source Term Present?
No Initiate RHR FPC Assist Using Affected Unit's RHR FPC Cannot Be Restored Using Affecte4 Uniti8 SpsteIhs Restore FPC
(B)
Non-Class LE Pover Available?
No Yes Fuel Pools Crosstied?
No Yes FPCCS Capacity Available?
Yes Initiate,,FPQQS Using Adjacent Unit's FPCCS Restore FPC No No No No No-Reactor Bldg Accessible?
Yes RHR Loop Available?
Yes RHR FPC Components Operable?
Yes Adequate NPSH for RHR Pump?
Yes RHRSW/UHS Capacity Available?
Yes Initiate RHR FPC Assist Using Adjacent Unit's RHR FPC Cannot Be Restored Using Adjacent Unit's Systems Restore FPC (C)
(C)
Boiling Spent Fuel Pool Reactor Bldg Accessible?
Yes FPCCS Piping Intact?
Yes No No
) (D)
Close RHR/FPCCS Boundary Valve R
E P
E Open ESW Makeup Valves on Affected Unit Obtain Desired SFP Level-Close ESW Makeup Valves SGTS Designed for Temperature 6 Moisture?
Yes No SGTS Components Eg'd for Boiling Condi tions?
Yes No Loss of Secondary Containment Room Coolers Designed For Latent Heat?
No Yes Switchgear Room Coolers Designed for Latent Heat?
Yes Flooding ControlledP Yes No No Loss of ECCS Pumps Loss of Containment Cooling Maintain SFP Level With Affected Unit's ESW System Core Meltdown
(D)
Boiling Spent Fuel Pool I
R E
p A
T I
Open ESW Makeup Valves on Adjacent Unit Fuel Pools Crosstied?
Yes No Yes.
FPCCS Piping intact?
No (E)
Obtain Desired SFP Level Close ESW Makeup Valves SGTS Designed f'r Temperature
& Moisture?
Yes SGTS Components Zg'd for Boiling Conditions?
Yes No No Loss of Secondary Containment Room Coolers Designed For Latent Heat?
No Yes Svitchgear Room Coolers Designed for Latent Ze~
Yes Flooding Controlled?'es No No Loss of ECCS Pumps Loss of Containment Cooling Core Meltdown Maintain SFP Level With Adjacent Unit's ESW System
Boiling Spent Fuel Pool Without Makeup Uncovery/Damage of Irradiated Fuel Outside Primary Containment
5 12 19 26 6
13 20 27 I
2 7
8 9
14 IS 16 21 22 23 28 29 30 February T
W T
2 9
16 23 3
10 17 24 4
5 6
11 12 13 18 19 20 25 26 27 I
8 IS 22 29 2
9 16 23 30 March T
W T
3 4
5 Io II 12 17 18 19 24 25 26 3l S
M April T
W T
5 12 19 26 6
13 20 27 I
2 7
8 9
14 IS 16 21 22 23 28 29 30 Ma T
W T 3
10 17 24 31 4
11 18 25 5
6 7
12 13 14 19 20 21 26 27 28 January M
T W
I 3
lo 17 24 31 7
14 21 28 6
13 20 27 3
10 17 24 I
8 15 22 29 4
Il 18 25 I
8 IS 22 7
14 21 28 4ll 18 25 2
9 16 23 30 March 19 PP&l. Supcnisor Ntnilinlof (.'onccrns by Memo A ril 16 EDR G20020 Written by Imhbaum 20 EDR G20020 Signcd by I'P&l.Supervisor 23 PP&LEDMGiSupervisor Dctermmcs FDR G2002011as "Noapparent impact on plant. 1)IID Issue" June 1 1 EDR Engine'I'elis l~ichbaum Issues Itave Nn Safety Significance 18 InitialMeeting on EDR G20020 Concerns 22 Memo from Prevatte & Iachbaum to FDR tinginccr Jul I EDR Scn~ning Workshcct Drafted by PP&I.
8 Meeting on EDR G20020at Susquehanna-Prevat tc &Iochbaum Denied Attendance 10 Prcvat tc &IAx:hbaum Discuss (concerns with PP&L Supervisor, Engineering Projixts EDR GW20 Validated IS Large Meeting on EDR G20020in Allentown 17 Lochbaum Given 2 Weeks Notice 23 Lochbaurn Rcqucsts Meeting with EDMG Supervisor 27 Meeting with Lochbaum Cancelled - Not Rcsched ukd 29 I:Oopm Prcvattc &IAichbaum Meet with PP&L Engineering Mgr 2:30pm Iuchbaum Meeting with PP&L Nuclear Safety Manager 31 Lochbaum's final Dayat PP&I.
Au ust 18 PP&LSupenksor, Engineering Projects Reports NRC Ilas Approved SS ffS Design Se tember 1992 October 9 Prcvat tc &IAichbaum Meet with PP& .-
ll lltimat 14 Pl'&I.Manager of lhiginccting Lstablishes Task Fiirce 20 PP&I. Manager of Nuclear Regulatory Affairs Report 29 PP &I. Fnginccring Repon on Fuel Pool
(.ooling Event November 2 DeadlineSet for PP&l.tolti1iort Issucor Justify Prcvat tc & Iaichbaum NotifyPP&I.'that l)ccision on NRC Rctxirt WillAwait I'P&I:s I.ER 3 PP&l. Arranges Tclcmin with lax:hbaum on Issue 17 I'P&t.Submits Voluntary!.t!R tinder 10(:FRS0.9 27 Prcvattc &lxichhaum Submit loci 1(21 Rcport 5
12 19 26 2
9 16 23 a
13 20 27 4
II 18 25 I
8 15 22 29 July M
'I'
'I' 13 20 27 I
2 7
8 9
14 IS I6 2l 22 23 28 29 30 August T
W T
3 10 17 24 31 4
5 6
11 12 13 18 19 20 25 26 27 7
14 21 28 I
2 3
8 9
Io 15 16 17 22 23 24 29 30 5
12 19 26 October T
W T
I 7
8 13 14 15 20 21 22 27 28 29 M
2 9
16 23 30 November T
W T
3 4
5 IO I I 12 17 18 19 24 25 26 September M
T W
T I'
3 4
10 I I 17 18 24 25 31 I
S 1
7 8
14 15 21 22 28 29 S
4 5
II l2 18 19 25 26 I'
2 3
9 10 16 17 23 24 30 31 F
S 6
7 13 14 20 21 27 28 7
14 21 28 I
8 IS 22 29 S
M Junc T
W T 2'
4 9
Io 11 16 17 18 23 24 25 30 5
12 19 26 6
13 20 I Concerns Validatixt by Indcpcndent PP&L Engineer 9 PP&LManager ofNuclear Safely Conlirms
. Problems October 6 EDR G2tto20 Scrccning Completed - No Silfclyimpact 6
13 20 27 7
14 21 28 Dcccmbcr T
W T
I 2
3 8
9 Io 15 16 17 22 23 24 29 30 31 F
S 4
5 I I 12 18 19 25 26 EDR G20(QO Events 8/4/1993
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