ML18045A509
| ML18045A509 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Browns Ferry, Palisades  |
| Issue date: | 08/18/1980 |
| From: | Stephen Burns NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML18045A510 | List: |
| References | |
| ISSUANCES-CIV, NUDOCS 8008200214 | |
| Download: ML18045A509 (32) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE 8/18/80 In the Matter of
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CONSUMERS POWER COMPANY
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Docket No. 50-255 License No. DPR-20 (Civil Penalty)
(Palisades Nuclear Power Facility)
NRC STAFF'S RESPONSE UNDER ADMINISTRATIVE LAW JUDGE'S MEMORANDUM AND ORDER OF JULY 22, 1980 In his "Memorandum and Order on Licensee's Motion to Compel Discovery" of July 22, 1980, the Administrative Law Judge ordered the NRC Staff to comply with the Memorandum and Order at a time to which the parties agreed.
Memorandum and Order at 29.
Counsel for the Licensee agreed to permit the Staff until August 18, 1980, to file a response under the Memorandum and Order. This filing is intended to constitute the Staff's compliance with the Administrative Law Judge's Memorandum and Order.
In this response, the Staff first identifies the portion of the Memorandum and Order to which a response is given and, second, the Staff provides the response.
- 1.
Memorandum and Order at 19:
"As I understand the Staff's response to the motion to compel, the Staff has not withheld from disclosure any objective scientific reports. If this is not the case, the Staff is wrong."
Staff'.s Response:
The Administrative Law Judge correctly understands the Staff's position. The Staff did not intend to withhold any objective scien-tific reports concerning this civil penalty case or other enforcement cases.
Staff analyses of Consumers Power Company's estimates of potential doses resulting from the open valves at Palisades, which might be loosely termed "objective scientific reports", are identified in Item 3 of this response.
- Copies of the documents are attached to this response.
One analysis has already been provided in response to Consumers Power Company's FOIA request.
- 2.
Memorandum and Order at 23-24:
"Any document in final fonn memoralizing his [the Director of I&E's] decision not to issue a notice of violation imposing civil penalties does not fall within Exemption 5 [to the FOIA] **** [such documents] must be produced pursuant to licensee's Interrogatories 12 through 14.
"It is not clear from the record whether such ~losing memo-randa exist, or if they exist, whether the staff has already provided them* to [the] licensee under the FOIA."
Staff's Response:
The Staff has reviewed the instances identified in response to interrogatory 12 to detennine whether any "closing memoranda" existed which would reflect a detennination not to impose civil penalties.11 The Staff has not identified any such "closing memoranda" with respect to those instances. The Staff has identified two additional documents relating to the instances cited in the Staff's response to interrogatory 12:
{l} Letter to James G. Keppler, Director, AEC Region III, from
. J. S. Abel, Commonwealth Edison, dated August 21, 1974, enclosing the Semi-Annual Report for the Dresden Station for the period January 1, 1974, through June 30, 1974. This reference to the document should be included in section 7{j}
to the Staff's answer to CPC's interrogatory 12.
See NRC Staff's Supplemental Answers at 13 {April 14, 1980).
The 1/
Consumers Power Company did not request the identification or production of documents in response to interrogatories 13 and 14.
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-.. -. - - ****--- -* Staff has attached the letter fran Mr. Abel and the two pages fran the Semi-Annual Report which deal with the incident discussed in the Staff's response to the interr()(Jatory.
The remainder of the Semi-Annual Report should be available in the Commission's public document roan in the Dresden docket
{No.50-010).
{2)
Memorandum for G. C. Gower, Acting Executive Officer for Operations Support, I&E, from F. J. Long, Acting Director, Region II, dated January 11, 1980, concerning "Draft Letter of Acknowledgment to TVA Response of January 10, 1980 11 This reference to the document should be included in section 5(j) of the Staff's answer to interrogatory 12. See NRC Staff's Supplemental Answers at 10 (April 14, 1980). A copy of the memorandum and d~aft are attached to this filing.
- 3.
Memorandum and Order at 25:
11It cannot be detennined fran the papers relating to licensee's motion whether the staff has with-held documents which contain facts, calculations, and criteria, conceded by the staff to be relevant and not privileged, but which also contain infonnation revealing the deliberative processes of the Director and his advisors. If purely factual material exists in documents containing deliberative infonnation in a fonn which is severable without compromising the deliberative privilege, the staff is required to produce such documents in a sanitized fonn.
11 Staff's Response:
The Staff has identified two documents prepared by an I&E Staff member during the review process leading to the Director's deter-minations to propose and then impose civil penalties against Consumers Power Canpany.
These documents refer to the calculations and analyses made by
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~-. Consumers Power Company of the potential radiological consequences of open valves during an accident at the Palisades facility. The Staff has also identified an analysis prepared in the Office of Nuclear Reactor Regulation.
The three documents are:
(1) Infonnal Note to J. Snieze_k, l&E, from J. Stewart Bland, I&E, dated November 7, 1979, enclosing "Opened By-Pass Lines in Containment at Palisades Accident Evaluation" (6 pages); and (2)
Infonnal.Note to N. Moseley,* l&E, from J. Stewart Bland, I&E, dated December 12, 1979, enclosing nPalisades - Contaminent
[sic] Isolation Noncompliance Radiological Evaluation of Accident Doses" (5 pages).
(3) Memorandum for:
D. Ziemann, Chief, Operating Reactors Branch
- 2; Division of Operating Reactors, Office of Nuclear Reactor Regulation from G. W. Knighton, Chief Environnental Evaluation Branch, DOR, NRR concerning "Potential Radiological Consequences from Major Degradation of the Reactor Containnent (Palisades Nuclear Plant)" (Dec. 18, 1979).
The first document had already been provided to Consumers Power Company in response to its FOIA request. All three documents are attached to this filing.
To the best of its knowledgeJ the Staff has not withheld any other documents which contain facts, calculations, and criteria related to this case.
- 4.
Memorandum and Order at 27:
"CPC suggests that the staff is providing factual data (conceded by the staff to be not privi-leged) only where the factual data supports its position.
CPC Answer, p. 10, n.
However staff's responses to CPC's discovery
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- 5 requests purport to produce all relevant data not privileged.
While I do not share CPC's concern that the staff is withholding relevant factual data, to remove any doubt, the staff is directed to produce the relevant facts, calculations and criteria on which it relies and which it possesses, whether or.not the data support the staff's position in this litigation."
Staff's Response:
In the Staff's answers to Consumers Power Company's interrogatories and in the original enforcement correspondence {Mr. Stella's letters of November 9 and December 20, 1979) which initiated this proceeding,
- the Staff has identified the relevant facts, calculations and criteria on which it relies in this case.
Including the additional material submitted with this filing, the Staff has provided, to the best of its knowledge, all of the relevant factual data, calculations, and criteria which the Staff possesses and which have not previously been available t~ Consumers Power Company.
With respect to interrogatories to which the Staff opposed discovery, only interrogatories 2(b), 2(c), and 2(e) could be said to require identi-fication or production of factual material, calculations, and criteria on which the Staff relies in this case or which the Staff possesses. Although these interrogatories requested information concerning the categorization of item 1 in the Notice of Violation as a violation and as a continuing item of noncompliance, the interrogatories were cast so that they required the Staff to reveal advisory recommendations and deliberations of individual Staff members.
As the Staff stated in its answer to the licensee's motion to compel, the Staff does not object to interrogatories which ask the Staff to clarify its position in this case. If interrogatories 2(b}, 2(c}, and 2{e}
were appropriately cast such that they asked the Staff to describe its
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The Staff's position in this proceeding with respect to the matters raised in i ~terrog~tories 2(b), 2(c) 'and 2(e} is essentially as fol fows.
The noncompliances identified in item 1 of the Notice of Violation were categorized as violations in accordance with the 1974 Criteria for Deter-mining Enforcement Action and Categories of Noncompliance that have been distributed to all licensees.
The noncompliances charged in item 1 fit the 11violation 11 category of noncompliance, because they had a usubstantial potential for *** contributing to or aggravating *** an incident or occurrence
[such as] *** (b) Radiation levels in unrestricted areas which exceed 50 times the regulatory limits.n!f By Consumers Power Company's own estimates,11 the potential radiological releases under certain accident conditions could result in exposures rates of more than 100 mr/hour, which would exceed the limits for pennissible radiation levels in unrestricted areas by a factor of y
See Criteria for Detennining Enforcement Action and Categories.of Non-
~omgliance, Attachment B, at 1 (Dec. 31, 1974), guoted in Letter to R.
- Youngdahl, Consumers Power Company, from Victor Stello, Jr.,
Director, Office of Inspection and Enforcement, at 3 (Dec. 20, 1979).
See Letters to Victor Stello, Jr., from R. C. Youngdahl (Nov. 29 and Dec. 6, 1979) which reference CPC 1s estimates of potential releases.
See also 11Consumers Power Company's Response to NRC Staff Interroga-toriesand Document Requests, 11 at 6-7 (June 23, 1980}.
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See 10 CFR 20.105(b)l).
By the* same token, the noncompliances cttecJ*tn item 1 of the Notice of Violation fit subcategory (c) for a "violation":
i.e., the noncompliance has a "substantial potential for **** contributing to or aggravating *** an incident or occurrence [such as].... Release of* radio-active materials in amounts which exceed specified limits, or concentrations of radioactive materials in effluents which exceed 50 times the regulatory limits. 114/ Again, based on Consumers Power Company's own estimates of
. radi 0 l ogi cal consequeffces --under a'cci dent conditions with the val ve_s locked open, concentrations of radioactive materials in effluents would exceed 50 times the limits specified in 10 CFR Part 20.
See 10 CFR 20.106(a) and Appendix B, Table II. Because the open manual contairvnent isolation valves resulted in a breach of containment integrity under operating conditions between April 1978 and September 1979 (and had the potential for breach of containment integrity under a.ccident conditions had an accident occurred),
the noncompliances cited in Item 1 also fit subcategories (d} and (e) for a "violation" under the enforcement criteria. Thus, the noncompliances cited in item 1 of the Notice of_ Violation clearly fall within the "violation" category under existing enforcement criteria.
In view of the potentially serious consequences of the violation of containment integrity, the Director of the Office of Inspection and Enforce-ment ~elieved it appropriate to cite and fine Consumers Power Company for each day between April 11, 1978 and September 11, 1979, on which noncompli-ance with Technical Specification 3.6.la occurred.
With the manual isolation See Criteria for Determining Enforcement Action and Categories of Non-compliance, Attachment B, at 1 (Dec. 31, 1974).
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valves locked open, Consumers Power Company violated the technical specifi-cation's requirement that containment integrity be maintained on the 476 days
{by the licensee's own count) between April 1978 and September 1979 on which the Palisades reactor was not in a cold shutdown condition. Under section 234 of the Atomic Energy Act, the Commission may count each day of a continuing violation of this sort as a separate violation for purposes of computing the applicable civil penalty.
In view of the prolonged violation of contairvnent integrity at the Palisades facility, the significance of containment integrity to safe operation of power* reactors, and the potential severity of the consequences of an accident with the valves open, citation and assess-ment of civil penalities for each day of the violation is appropriate.21 21 In reply to Consumers Power Company's response to the Notices of viola-tion and Proposed Imposition of Civil Penalties, the Director wrote in his letter of December 20, 1979, enclosing the Order Imposing Civil Monetary Penalties:
"Contrary to your view we nevertheless continue to believe, as stated in my letter of November 9, that 'prolonged violation of containment integrity is a matter of very serious safety signifi-cance.' This basic fact underlies our view that this case is not properly considered 'nonnal' and that, in this particular situation, computation of the period of violation is entirely consistent with the *** Statement of Consideration [on 10 CFR 2.205] *** " Letter at 2.
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i'. Nonnan C. Moseley, Samuel E. Bryan, Leo B. Higginbotham, and Frank J.
Nolan of the Office of Inspection and Enforcement assisted in the prepara-tion of this response.
Enclosures:
Listed on next page Dated at Bethesda, Maryland this 18th day of August, 1980.
Respectfully submitted, Stephen G. Burns Counsel to NRC Staff U.S. Nuclear Regulatory Commission Washington, D. C. 20555
UNI'TED STATES OF AMERICA NUCLEAR REGULATOR'( CQM111SSION BEFORE THE. ADMINISTRATIVE LAW JUDGE In the Matter of CONSUMERS POWER COMPANY (Palisades Nuclear Power Paci1ity)
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l Docket No, 50-255 (Civil Pena1ty)
CERTIFICATE OF.SERVICE I hereby certify that copies of the NRC STAFF'S RESPONSE UNDER ADMINISTRATIVE LAW JUDGE'S MEMORANDUM AND ORDER OF JULY 22, 1980 in the above-captioned proceeding have been served on the fo11owing by depostt in the United States mail, first class, or as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 18th d~y of Al!9l.1S-t, 1980, Hon. Ivan W. Smith*
Administrative Law Judge Atomic Safety & Licensing Board U, S, Nuclear Regulatory Commission Washington, D. C, 20555 Paul Murphy, Esq.
Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, I11inois 60603 Alan Bielawski, Esq.
Michael Miller, Esq.
Isham, Lincoln & Beale One First National Plaza Suite 4200 Chicago, Illinois 60603 Judd Bacon, Esq.
212 W. Michigan Avenue Jackson, Michigan 49201 Docketing and Service Section*
U. S. Nuclear Regulatory Corrunission Washington, D. C. 20555 Atomic Safety & Licensing Board Panel*
U. S. Nuclear Regulatory Commission Washington, D, C. 20555 Atomic Safety & Licensing Appeal Panel*
U, S. Nuclear Regulatory Commission Washington, D. C. 20555 Stephen G. Bt1rns Counsel for NRC Staff
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Enc1osures:
- 1. Letter to James G. Keppler from J. S. Abel (August 21, 1974) w1th pages 17 and 18 of referenced Semi~Annual Report for Dresden Statton,
- 2.
Memorandum from G. c. Gower from f. J. Long (January 11, 1980).
- 3.
Note to J. Sniezek from J. S. Bland (November 7, 1979}.
- 4.
Note to N. Moseley from J. S. Bland (December 12, 1979).
- 5.
Memorandum to D. Ziemann from G. W~ Knighton (December 18, 1979).
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Commonwalth Edison One Ffrst Nati-Plaza, Chicago, Illinois Address Reply to: Post Office Box 767 Chicago, Illinois 60690 Mr. James G. l<eppler Regional D~rector Directorate of Regulatory Operations -
Region III U.S. Atomic Energy Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
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I Enclosure T August 21, 1974
Subject:
Dresden Station Semi-Annuai*Report,
.AEC Dkts 50-10, 50-237 and 50-249 *.
Dear Mr. Keppler:
Attached is the Semi-Anml'al Report for Dresden Station as required by the Technical Specifications for:
Units 1, 2 and 3 for the period of January 1, 1974 through June 30, 1974.
One copy of this report* is provided for yoitr use, and 39 copies are being transmitted by this letter to the Acting.Director, Directorate of Licensing.
Att.
cc.:
Mr. Edson G. Case (w/att.)
80082002.2./
Very truly you*rs, Nuclear Licensing Administrator Boiling Water Reactors
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- 4.
Surveillance All licensed required surveillance for the six month period January lD 1974.~to June _30, 1974 were satisfactorily completed.
ll1e unit was shutdown for refueling operatiohs during the entire report~ng period.
Required refueling surveillances were contin-ued.
l'bese surveillances included such major tests as the primary containment integrated *leak rate test, core spray logic and flow tests, simulated automatic actuation test of the core spray system, station battery load discharge test,. recirculation of the high pressure boron tank through the low pressure boron tank, automatic actuation test of th~ primary isolation valves, control rod drive timing and latching, ~riction and scram tests, arid the required instrument calibrations.
In addition, the inservice inspection program was satisfactorily completed as well as the other tests.
A description of the primary containment integrated leak test and inservice inspection program is given below.*
INTEGRATED PRIMARY CONTAilu"'IBNT LEAK TEST A second-primary containment *integrated leak rate test was
. perfonned during the 8th parti~l refueling outage from January 23 through January 28.
The test was conducted in accordance with Technical Specification Section 4.7.A.l.g.
l1lis section requires a primary containment integrated leak test be conducted at least three times in a ten (10) year period.
After the containment had been pressurized to 20 psig (Pa) on January 25, 1974, the conditions were* allowed to stabilize and
'leakage data was taken.
After five (5) hours of data taking, the average leakage was d.etermined to be 8.15 1./day.
Investiga-tion revealed that there was excessive leakage through an unused 2" decontamination line from the "A" cleanup system to radwaste, exiting the sphere _through penetration H-45.
fhe line was blind flanged at a spool piece connection outside the sphere in the radwaste pipeway. Additionally, leakage was noted through the secondary steam generator sample drain valve, FCV-510.
Attempts to isolate this leakage failed.
The sphere pressure was then increased to 20 psig and the test resumed.
After the leakage test was concluded, the verification test was conducted in accordance with ANSI N45.4 - 1972.
nie verification test lasted for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with the leakage calculation of.2633 +/-.034 1./day.
The verification test met the acceptability criteria of 10CFR50, Appendix J which requires the verification test results to be within 0.25 La.
Since there were two known leakage paths from the sphere during the integrated sphere test (2" decon line blind flange after installation and valve FCV-510) it was decided to do an "as found" local test on the 2" decontamination line and the seco.ndary steam generator sample drain valve, FCV-510.
After repair of the
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penetrations, a ~econ~ local test was performed and the difference subtracted from the leakage determined from the integrated leak test. The'"as fopnd" leakage t~rough the 2" decontamination line was found to be.0009 "1./day and through the secondary steam genera-tor sample drain, FCV-510,.019 "1./day.
After repairs were made to FCV-510, the calculated leakage was.0000144 "!./day.
After the 2" decontamination line was*seal welded, the calculated leakage was
- 0. 00 "1./day.
The total difference between the "as found" and the repaired leabige is.019 l/day, thereby resulting in a primary containment integrated leakage of
- 2495.+/- *.034 '1./day at a pressure of 20 psig.
The error bound of.+/- 0.034 "1./day is a 2Q-"value and by definition represents a 95l confidence level bound.
When the primary contain-ment integrated leakage is evaluated at the upper bound, the result is 0.2835 "l./day (0.2495 + 0.034).
Since the 957. confidence level upper-bound leakage (0.2835 7./day) is less than the Technical Specification 4.7.A.l.e requirement (0.30 7./day) for plant startup, the test is successful.
INSERVICE"INSPECTION PROGRAM The 1973 refueling outage inservice inspection program was completed on June 18, 1974 in accordance with Section XI of the ASME Code (1971 Summer Addenda).
During this period, approximately 220 c.omponents were examined by either volumetric, surface and/or visual methods.
Of the indications noted, none were evaluated to be of any significance.
On June 18, 1974 the reactor vessel and associated primary system pip~ng were hydrostatically tested at 1060 psig and 280°F.
At this time tw9 pin-hole leaks were detected in the same pipe section in the north steam supply line to the emergency condenser.
The defective pipe section was replaced according to code specifications and was satisfactorily hydrostatically tested at about 1600 psig.
- 5.
Results of Periodic Containment Leak Rate Tests
- 6.
.7.
Table 5 shows the results of the periodic containment leak rate
- tests performed during the period. from January l, 1974 to June 30, 1974.
Changes, Tests and Experiments Reguiring Authorization From the Comnission No changes, tests, or experiments requiring com:nission authorization were performed during the period from January 1, 1974 to June 30, 1974.
Key Changes in Plant Operatin~ Organization The following key changes in plant operating personnel occurred during the_ period from January l, 1974 to June 30, 1974.
Station Superintendent - Ben* B. Stephenson Operating Engineer - Eugene Budzichowski L__
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UNITED STATES NUCLEAR REGULATORY COMMISSION
- Enc1 osure 2,J.
REGION II 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 January 11, 1980 SSINS 50-296 1**'lr*
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}fEMORANDUM FOR:
G. C. Gower, Acting Executive Officer for Operations Support Office of Inspection and Enforcement FROM:
F. J. Lo.ng, Acting Director, Region II
SUBJECT:
DRAFT LETTER OF ACKNOWLEDGEMENT TO TVA RESPONSE OF JANUARY 10, 1980 Enclosed is a draft letter of acknowledgement to the TVA response of January 10, 1980.
Reg.ion II plans to.discuss TVA's response as part of the January 21 management meet~ng in Athens, Alabama.
Encl:
Draft Letter of Acknowledgement cc w/encl:
N. C. Moseley, ROI CONTACT:
R. H. Wessman 242-5505
~~~~*---
F. J. Long Acting Director
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ENCLOSURE DRAFT Docket Nos. 50-259/260/296 Tennessee Valley Authority Attn:
Mr. H. G. Parris Manager of Power 500A Chestnut Street Tower II Chattanooga, Tennessee 37401 Gentlemen:
Thank you for your letter of January 10, 1980, informing us of steps you have taken to correct the items of noncompliance and corrective actions pursuant to our Order concerning activities under NRC Operating License No. DPR-68 brought to your attention in our letter of January 4, 1980.
We will discuss your corrective actions at a management meeting at the Athens, Alabama City Hall on January 21, 1980.
Region II inspectors will examine your corrective actions and plans during sub-sequent inspections at Browns Ferry.
We appreciate your cooperation with us.
Sincerely, Victor Stello, Jr., Director Office of Inspection and Enforcement
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- Opened By-Pass Lines in Containment at PQ.)isades Accident Evaluation In the Licensee Event Report 79-037 update, the licensee presented the Probable Consequences (accident doses) of the open valves *as-su-tling a 42" line break
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accident. The findings were that if the charcoal absorbers are assumed to be 90% efficient for iodines, the Design Basis Accident doses would be less But if no than the 10 CFR 100 limits (i.e., less than 300 rem, thyroid).
- _...:_::_::.:..::!.::;.:..::.-::=-L..:&:.=.~=be=--:1..:. *..:..4....:t::...:i..:.:.:m.:::.:es l 0 CFR l 00.
(To ta l body doses were less than lo~; of l O CFR" l 00 for both cases.)
However, in additional internal correspondence/calculations received from the licensee, the licensee has calculated a Maximum Hypothetical Accident dose, which is roughly equivalent to what the NRC calls the Design Basis Accident/Loss of Coolant Accident.
These calculated doses were more than two
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orders of magnitude greater than 10 CFR 100 for both the thyroid and total r
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l=he-at-t-a-etr.::ent is an excerpt from the licensee correspondence and presents an overview of the dose calculations.
The following is a discussion of the calculaticns.
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- Licensee Evaluation Considering the open valves, the licensee has evaluated two separate accident conditions:
- 1.
The Maximum Hypothetical Accident (MHA} - The licensee's MHA assumed typical NRC Design Basis Accident/Loss of Coolant Accident conditions, i.e., 2 hr dose at site boundary, Reg. Guide 1.4 type source term (100% noble gases and 25% iodines}.
Crtdit is taken for the effective-ness of the containment spray system for additional idoine removal.
In determining the doses, the licensee has calculated radionuclude (mass}
leakage for the by-pass line~ being open and simply ratioed the FSAR doses, which were calculated using theOJ%/day containment leakage.
- 2.
The Design Basis Accident (DBA) - The DBA like the MHA assumes a 42" line break but, credit is taken for ECCS operation.
A 93% clad perfora-tion (FSAR) was assumed.
To arrive at doses, the licensee has rationed the Midland FSAR DBA doses since the Palisades FSAR did not calculate DBA doses.
NRC Evaluation A typical NRC type accident evaluation would be similar to the licensee's MHA *evaluation.
Thestype calculation is used to demonstrate compliance with r:-.*0 the 10 CFR* siting criteria. This MHA corresponds to the NRC Design Basis
- '* -*--** ***-* !,..~.,-. *.:.:.. ** :....... ' **.. :,.;... ;.:.:.*.... 1*.**........:.......
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- 3 Accident/Loss of Coolant Accident except that containment is assumed to be isolated with o.1fJ% leakage per day, not an opened valve as existed at Palisades and assumed in the licensees MHA calculation. This type accident dose calculation is the one of importance in determining compliance with the regulations (10 CFR 100).
The licensee's OBA presents more realistic accident consequences, i.e., assumes ECCS operation.
However, this type dose is not referenced in any regulations. Appendix K to 10 CFR 50 addresses ECCS operation but does not address accident doses.
kthcih'~
k\\{~c)(\\; b,,~\\v~~
2-lJr
- rriici:i c t
2-hr MHA Dose DBA Dose 10CFRlOO lOCFli Li""i~~
To~nl Body (Skin)
Thyroid (Rem) 194,ooo 417 (0% charcoal efficiency) (O~ charcoal efficiency) 19,400 41.7 (90% charcoal efficiency)
{9u~ charcoal efficiency MHA ANALYSIS Total Body MHA skin dose - 2 hr given:
10.3% massloss in 2 hr through 3 11 line*
given:
FSAR Sec. l~ - 0.1% rnass/day =(g~
- 1) (2) = 0.0083%/2hr 1
10* 3 l 236 ratio of oss = 0 _00833 =
given:
FSAR Fig 14.22.7 2 hr dose= 1.8 rem"?>-¥"
25 300 300 (1,236) (1.8 rem) = 2,200 re~
--* Thyroid MHA dose -
2 hr given:
1 min 38 se.c delay prior to hydrazine addition (VNWL 35-77) with c.urrent tank pressurization given:
Table 3 (RAE 58-77) can be modified to represent 1. 63 min time delay VS 5. 0 min of table:
Time Interval (min) 0 - 1. 63 1.63 - 16.3
- 16. 3 - 60 60 -
120 Core Iodine Leaked
@ 0.1%/day
(%.x 10-5) 2.8 11.1 14.3 12.7 40.9 Mass Fractions Leaked 3" Purge 0.1%/day*
(% x 10-5)
(% x 10-5) 16,ooo 11.3 150,000 104.
350,000 303~
530,000 417.
Ratio 1.42 x 103 1.44 x io3 1.16 x 103 1.27 x 103 0.07 1.39 0.14 Core Iodin*
(:;)
0.04 0.16 0.17 0.16 0.53
i:*
~'
r~.
i r.
!=
i r
t'
~*.
1*
1,:
I e
e From the ubove, rntio of ~hyroid do~es for 0.1%/d~ cn~e cusc is 0.53/40.9 x 10-5 = 1.30 x 103 to the 3" pl.1:"ce vc.lvc Dose vas previously analysed as 149 Rem from containment leakage (149 Rem) (1.30 x 103)
= 194,ooo Rem Because purge line leakage is through the hydrogen purge charcoal filter, dose could be up to a factor of 10 lower than this, or 19,400 Rem.
However, steam condensation within the filter could limit efficiency to an unknown degree.
LOCA Analysis -
DBA 42" break per FSAR 14.17.5 given: Accident analysed in Midland FSAR {Sec 15.6.5 and Table 15.6-10)
@ 100% fuel clad perforation. This is conservntive in relntion to Palisades FS.AR Table 14.17-4, which indicates worst case 93% per-foration:
Also includes primary coolant.
Midland Total Bo~y Skin Doses (2 hr)
=
0.00183 rem (uerf)
= 8.0 x 10~4 ratio 2.29 rem (MHA, melt) 0.213 rem (~erf)
Midland Thyroid Doses =
=
(2 hr) 98.9 rem (MH.A, melt) 2.15 x 10-3 ratio Palisades Skin of
. *_4.
Total Body= (2,200). (8.* _0 x 10
) = 1.76 rem
. _P~lisa.des Thyroid = (194,ooo} (2.15 x io-3) = 417 rem Palisades thyroid Yit:"h 90% *efficiency charcoal = (19,400) (2.15 x 10-3) = 41. 7 rem
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Palisades - Contaminent Isolation Noncompliance Radiological Evaluation of Accident Doses The licensee, Consumers Power, has displayed a total lack of understanding of the NRC regulations and the IE enforcement criteria.
- 1.
The licensee calculates what he calls Design Basis Accident (DBA) doses.
These doses were detennined for a 42" line break, taking credit for ECCS operation. Doses per this calculation are less than the 10 CFR 100 siting criteria for the total body and are either significantly above or slightly under the Part 100 thyroid dose limits depending on the credit assumed for charcoal efficiency. The attached licensee correspondence presents a table of the calculated doses.
The 90% charcoal efficiency assurred appears excessive. Other licensee correspondence support values ranging from 68% to 92% - a 62% overall effective e*fficiency is needed to achieve calculated doses less than 300 rem thyroid limits. The licensee therefore maintains that the calculated doses are less than 10 CFR 100 criteria.
This type calculation that the licensee has performed is not the type calculation that the NRC would do in determining compliance with the 10 CFR 100 siting criteria. The licensee's Maximum Hypothetical Accident (~HA) doses that are also presented but not discussed by the licensee are similar to what the NRC would calculate for a 10 CFR 100 deten:iination.
The only significant difference between this calculation and a normal Part 100 calculation is the 4 inch open line. The licensee's MHA doses are far in excess of the 25 rem, total body and 300 rem, thyroid of Part 100.
- 2.
The licensee attempts to compare his OBA doses with the IE criteria used for determining noncompliance categories.
The licensee, however, does not seem to have an appreciation for the regulatory limits that are used in the criteria. The licensee's discussion is presented on page 6 of their November 29 letter from Youngdahl to S~ello.
I have attached a copy of the applicable page from MC 0800 which addresses "Violations."
Conrnents are provided in the margin expressing why the licensee has exceeded these guidelines.
By comparison, in the licensee's discussfbn of the criteria, the limits assumed. are the 10.CFR 100 siting dose criteria. The limits that should have been used are those in 10 CFR 20.
In conclusion, the licensee has incorrectly compared calculated doses with NRC requirements and criteria in two cases:
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- a.
The comparison of what. the licensee calls a DBA with the 10 CFR 100 siting criteria. The". licensee's MHA doses should have been used.
- b.
The use of 10 CFR 100 criteria for comparison with the IE "Violation" criteria. The 10 CFR 20 radiation limits should have been used.
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r.ft._1:;ce~G..'1 - P2L-113 Dece~ter 5, ~979 COF.?.EC'I'ION TO RADIATION DOSE LSTD-1ATES
.PCST-D3A WITH CONTAII~1ENT PURGE FILTER VALv.ES OPEN.
cc TO."'~eek - Palisades DFHof!'::len - P24-115 DABixel - P24-119
?.5Dewitt - P26-117B
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consumers Power company INTI: ANAL CCRR[:SP'ONO[NCE RWS 168-79 This revision is made to RAE 74-79 end RAE 75-79 on the subject matter as a result of the discovery on November 28, 1979, that t=e system va1ves ~ere 4",
not 3". Further ref'inement bas been l!laB.e by calculating the off_:_site thyroid.
doses for each ti~e interval in RA.E 75-79 end s~;ng the results to obtain the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> dose.
The recalc'U.lated ~ass fraction 1e2king from the co~tair.Eent.during the 2-hour inte:-val resulting from this valve size change is 0.2196 versus 0.103 utilized in the previoL:S analysis.
(See MARU 63-79.)
!*~ass f'rac"t.io:i :-elease per each interval end other pc.rc..."!leters appearing in RP.E 15-79 are corrected to the follo~"ing.
COF.!:
2.8 11.l ll.3 12.7 fc:i.r~~>
?LSGELiiIB 0.1~/Day
(%xio-5)
- RATIO 37,400 310.,000 785,_ooo i,o64,ooo 21.96%
2-hr
~-~.:...a.-Dose 4690*
l.:12>000
( nl#'
... -;..,,,.-CO""":
U 1r
~
e~~icie::cy) hl,200 (90~ cha::-coal e.r.r~ c ~ e-.......,. )
11.3 3.3lx103 104 303 417 2.98xio3 2.-59xl03
- 2. 55xio3 2-hr
!>'EA-Dose *
- 3. 75*
886
( c~ che.:-ccc.~
e ~fi ci e:-;c:.r:
cc I
( 90~ c!:e.::-coc.:..
e.~.r.; c.: e.... c-.*)
1'
- JRE I
(~)
n.0927 0.331 0.381 0.324 1.129 lOC?RlOO Li:mi ts 25 300
- >o
~.A DOS:S
(;\\e?:;)
3.37xio4 l.21xio5 l.39xlo5 l.l8x105 4.12x105 NO c:-=.ARCO.:..L
(~em) 72.5 260 299 2511 886 Fraction oi' J..OC?RlOO 0.15 2.95 C.293
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en:-
fC C:'..!..RC '
7.3 26 30
£2_
86.:: i I
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\\'ioJ at ion A violation is an item of nonco~pliance of the type listed belo~~ or an item of noncompliance (1) which has caused, contributed to or aggravated an incident of the type listed below, or (2) which has a substantial potential for causing, contributing to or aggravating *such an incident or occurrence; e.g., a situation where the preventive capability or controls
- . Yere removed or otherwise not employed and created a sub-stantial potential for an incident or occurrence with actual or potential consequences of the type listed below:
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(j) f Exposure of an individual in excess of the radiation dose specified in 10 CFR 20. l,03 (b) or e>.."J'OSure of a group of individuals resulting in each individual receiving a radiation dose ~hich exceeds the limits of 10 CFR 20.101 and a total dose for the group exceeding 25 man-rems.
Radiation levels in unrestricted areas which exceed 50 times the regulatory limits.
Release of radioactive oaterials in aoounts which exceed specified"limits or concentrations of radioactive materials in effluents which exceed 50 times the regulatory limits.
Fabrication, or construction, or testing or operation of a Seismic Category I system or structure in such a manner that the safety function or integrity is lost.
Failyr~ to function ~hen requited to perform the safety function or-loss.of integrity of a Seismic Category I syste:n, or structure; or other co::ponent, system, or structure with a safety or consequences limiting function.
Exceeding a safety limit as defined in technical specifications associated ~ith facility licenses.
- Industrial sabotage of utilization or fuel facilities.
Radiation or contamination levels in excess of limits on packages or loss-of confine::ient of radioactive materials in packages offered for shipment on a common carrier.
Diversion or theft of plutonill!:l, uranium 233, or uranium enriched in the isotope U-235.
~!UF or LEHUF exceeds any applicable limit by a factor of two.
0800-2 MAR l 21975
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Docket No. 50-255 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 DEC 1 'D 1979 q
-- cu l. 11 MEMORANDUM FOR:
D. Ziemann, Chief, Operating Reactors Branch #2. DOR FROM:
G.
~J. Knighton, Chief. Environmental Evaluation Branch. DOR
SUBJECT:
POTENTIAL RADIOLOGICAL CONSEQUENCES FROM MAJOR DEGRADATION OF THE REACTOR CONTAINMENT (PALISADES NUCLEAR PLANT)
On November 9, in response to a request by G. Lainas, the Environmental Evaluation Branch oerfonned a quick evaluation of the potential radiological consequences of a design basis LOCA occurring during the time the Palisades Nuclear Plant containment building exhaust valves bypass line was inadvertently left open.
EE~ provided values for an open 3-inch bypass line which was estimated to release 11% of the containment volume fission oroduct inventory durinq the first two hours of a LOCA (See Attachment 1).
The exclusion area boundary two-hour thyroid and wh-le bodv doses were estimated to be 280,000 rem and 4,800 rem, resoectively (exceedinq 10 CFR Part 100 by factors of about 900 and 200, respectively).
An error in the compressed qas flow calculation has since been found and corrected, which chanaes these values to 240000 rem and 4,200 rem, respectively.
A documentation of EEB's calculation is-giv4n in Attachment 1. The tyroid dose calculation did not qive credit to the ourae line charcoal adsorber since the adsorption efficiency may be dearaded in a steam environment.
Since that time. EEB has performed a more accurate evaluation using the TACT comouter code to account for the depletion of fission products in the leakina containment and iodine removal bv the containment spray system.
The results~
of this evaluation are given in Attachment 2.
The latest word from IE (S. Bryan) is that the open valves were 4 inch, rather than 3 inch valves.
Assuming that this also includes a 4 inch minimum line size, the Attachment 2 doses were increased by a factor of 1.8.** The latter values were used in a presenta-:ion to Commissioners Gilinsky and Ahearne on November 20, 1979.
The Licensee Event Reoort 70-037, Revision l, dated September 28, 1979 reports the conseauences of the open valves durina a potential DBA LOCA are calculated to be small fractions of the 10 CFR Part 100 limits. with the exceotion of the two-hour thyroid dose at the nearest site boundary (factor of l.4 of 10 CFR Part 100 limits assumina 0% charcoal efficiency).
The licensee should submit to NRC the analysis of the radioiogical consequences of the desion basis LOCA with the containment buildina exhaust valves bypass line open.
The analysis assumptions should be based uoon either Regulatory Guide 1.4 or the Maximum Hypothetical Accident used in the licensee's FSAR.
CONTACT:
F. Witt, EEB/DOR 49-28066
t- --
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DEC 1 8 1979 The licensee is also reauired to evaluate and reoort the actual release of radioactivity during the period of Aoril 5, 1978 and Seotember 11. 1979, when the containment building exhaust valves bvpass line was open.
This should be included in the Semi-annual Radioactive Effluent Release Report required by Technical Soecification 6.9.3.1.
Attachments:
As stated cc:
D. Eisenhut
- S. Baker R. Silver L. Barrett W. Pasedag G. Lainas
/
._, )ifL rJyz_lt/~~-; "L~tL eor!=l W
.. :/Kn1 ghton. Ch.. :(
Environmental Evaluation Branch Division of Operating Reactors
1,.
I' ATTACHMENT 1 NOV. 10 HAND CALCUALTION OF OBA DOSES WITH OPEN THREE INCH LINE
~odel: Compressed Gas Flow Through an Orifice Cd = Discharge coefficient
= 0.5 A = Orifice area
= (3 in) 2 ( Tr//J) = 7.1 in2
- P1
= Upstream pressure
= 21 psig = 36 psia (Avg. for 0-2 hours)
Y
= Compressibiiity factor
=
.48 R
=
Gas constant
= 10.7 (psia)(ft3)/(lb-m)( 0 R)
- T1
= Upstream temperature
= 236°F = 236 + 460 = 696°R (Avg. for 0-2 hours)
Ve
= Containment volume= 1.64 x io6 ft 3
~
8.02 (0.5
)(7.1 in2)(36 psia)(.48
= 5.7 lbs/sec Density:
Steam @ 236°F 1
1 b
=
- 17.5 ftJ 0.05 lb/ft3 Air @ STP =.072 lb/ft3 Air@ 21 psig
=
.072 1 ~~ 7 - =.l7lb/ft3
.05 +.17lb/ft3
=
.22 lb/ft3
~ = 5.7 lbs/sec = 26 ft3/sec
~
.22 lb/ftJ
I
- f.
)
~.*
l In 2 hrs@ 26 ft3/sec = 187,200 ft3 of the containment atmosphere released to the environs Normal leakage:
1.872 x 105 1
- 64 X l 00 O. l~b/day 0.11 = 11%/2hrs
a*.1%/day (.2 )
24hr/day
.0083%/2 hrs 11 %/2 hrs 0083%/2 hrs
=
1325 norma 1 1 ea kage Dose@ 0.1%/day**
Dose @ 11%/2 hrs Thyroid (Rem) 182 240,000 Whole Body (Rem) 3.2 420J
- Error was found in November 9, 1979, hand calculations for the conversion of degrees Farenheit to degrees Rankine.
It has been corrected in appropriate places.
- Safety Evaluation dated December l, 1977, for Palisades.
I
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ASSUMPTIONS AND RESULTS OF STAFF 1S ANALYSIS*
OF OFFSITE DOSES FROM POSTULATED ACCIDENT AT PALISADES
- Loss of Coolant Accident with 3-Inch Bypass Line Open
- 1.
Regulatory Guide 1.4 Assumptions plus Standard Review Plan 15.6.5, Appendices A and B review procedures with specific values for key parameters noted below.
- 2.
Exclusion Area Boundary distance - 700 meters, LPZ Boundary distance
= 5000 meters.
- 3.
X/Q 1s from Figures 2(A) and 2(B) in Regulatory Guide 1.4, with a building wake factor of 2.09, where applicable:.
- 4.
- 5.
Time Period {hrs)
X/Q (sec/cubic meter}
0-2 5.5 x l o-4 0-8 6.0 x 1 o-5.
Containment leak rate= 132%/day.
Containment spray description:
Time Period (hrs) 0
.01667
.01667 -.25
.25 -
720 Spray Solution Borated water Borated water
+ >50 ppm N2H2 Canta inment Sump Water
- 6.
Containment free volume= 1.64 million cubic feet.
Location EAB LPZ Iodine Rem9val Rate (hr- )
.42 Elemental/
1.0 Particulate 1 O Elemental I 1.0 Particulate 0 Elemental/
l.O Particulate
- 7.
Volume sprayed by containment spray system - 1.48 miliion cubic feet.
8.*
Rate of air exchange between unsprayed and sprayed containment regions
= 2 unsprayed region volumes per hour.
Exclus1on Area Boundary Low Population Zone DOSES, REM Thyroid 228,900 24,980
- Analysis done using TACT III co~puter code.
Whole Body 4038 441