ML20011E952
| ML20011E952 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/19/1989 |
| From: | Licciardo R Office of Nuclear Reactor Regulation |
| To: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20011D095 | List: |
| References | |
| NUDOCS 9002230183 | |
| Download: ML20011E952 (5) | |
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October 19, 1989 f1El!0RANDUM FOR: James M. Taylor Acting Executive Director for Operations FROM:
RobertB.A.Licciardo,ReactorEngineer(Nuclear)
Plant Systems Branch Division of Systems Technology, NRR
SUBJECT:
DIFFERINGPROFESSIONALOPINION(DPO)CONCERNING ZION 1/2 CONTAINMENT ISOLATION VALVES, AND METHODOLOGY USED FOR CALCULATING OFFSITE DOSES This memorandum constitutes formal submission of a Differing Professional Opinion'(DPO) in accordance with NRC Manual Chapter 4125 and related i
Appendices, and particularly NRC Appendix 4125 C.I. 2 and 5.
1 A summary position of this DP0 is presented as an Attachment under the title:
"DifferingProfessionalOpinion(DPO)concerning(A; Zion 1and2 Containment Isolation Valves, and (B) Methodology Used for Calculating Offsite Doses."
The principal concerns of this DP0 have already been submitted and evaluated as a DPV through the office of NRR, and since the principal review function could remain in the same Office, as currently provided within H.C. 4125, the j
i writer now requests consideration by independent Outside Qualified Sources'as a Review Panel as provided by NRC 4125-032b.
l' f
Robert B. A. Licciardo J
1 Registered Professional Engineer, California lluclear Engineering License No. NU001056-Mechanical Engineering License No. M015380 Attachment and Related
~l Enclosures as' Listed:
I cc w/ Attachment and
Enclosures:
T. Murley l
tHPSmith cc w/ Attachment and w/o
Enclosures:
J. Sniezek F. - liiraglia E. Rossi F. Congel 9002230103 900131B PDR ADOCK 0D000295 d
Attachment e
9 DIFFERING PROFESSIONAL OPINION (DP0)
CONCERNING (A) ZIONS 1 AND 2 CONTAINMENT ISOLATION VALVES, AN (B) METHODOLOGY ' SED FOR CALCULATING 0FFSITE DOSES J
This'DP0 relates to the operation of Zions 1 and 2 and in particular the conclusion by the NRR staff to issue Technical Specifications (TSs) enabling fullpower operation of the facility with the 42" containment isolation valves (CIVs) open to a limited position of 50, and capable of isolation within seven (7) seconds of the commencement of a LOCA.
In his Safety Evaluation (Encl. 1) of this proposal by the licensee, the writer concluded that:
The 42" valves at Zion should remain closed in Modes 1, 2, 3, and 4 because the consequences of the offsite dose to thyroid (from iodine) dur-ing a LOCA is unacceptably high; whole body dose has not been evaluated.
The least value for offsite dose to the thyroid which may be pro;osed within the existing licensing basis (requiremente,) is 64,000 rem.
The conventional treatment of BTP CSB 6-4 which assumas that fuel failure does not occur over the first 5-15 seconds after a LOCA and thereby that only RCS operating inventory of fission products is released to the con-tainment, and then to the environment, cannot in general be sustained against thermal hydraulic analyses for containment response, and licensing basis requirements (including criteria) for the calculation for, and the ore
-ace of, fuel failure, and the quantification and treatment of the r,
<g source terms.
The star-
. rejected (by Encl. 2) the writers SER, and in doing so, con-cluded that:
l
" Based on.the above evaluation. the staff concludes that the proposed [by the licensee] changes to the Zion Units 1 and 2 Technical Specifications for limitation on purge and vent valve operation above cold shutdown are more restrictive than current TSs and consistent with the commitments identified in the staff SER On the same subject.
Therefore, the staff finds the proposed changes acceptable."
This matter was submitted to the Office of Nuclear Reactor Regulation (NRR) as a Differing Professional View (DPV) on May 11, 1989 (Encl. 3), a clarification was provided by the writer on July 20, 1989 (Encl. 4), and the Director of the Office has provided his disposition by recent memo of September 13, 1989 (Encl. 6).
-The purpose of this document is to present a Differing Professional Opinion (D.P.0) concerning the DPV conclusions proposed by NRR, and particularly that:
1
Attachment I
l (a) The staff should not issue its evaluation of the proposed Zion Technical Specifications.
(b) That Licensing Action be taken to close the 42" CIVs at Zion until
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this issue is resolved.
This action is required be taken by the NRC in conformance with its Regulatory responsibilities, as the current allowable method of operation with fully open 42" CIVs represents an Unreviewed Safety Question for the Zion Facility and is thereby in violation of 10 CFR 50.59(a)(1)(iii).
The current Licensing B& sis for this facility as recorded in the FSAR (Encl. 5) t and the Analyses of Record show these valves are to be closed during Power Operation and that no Safety Evaluation Report has ever been issued to ci.*nge that Regulatory requirement.
Also, therefore, that the current T.S. Ollowing their operation fully open at an angle of 90', is faulted by t
not conMrming to the requirements of 10 CFR 50.36 and must therefore be withcrawn.
And therefore, that the staffs SER premised upon the validity of the existing TS is thereby itself invalid and faulted.
The full set of documentation arising from the writer's DN is contained within Enclosure 4, and is broadly categorized as:
(a) The original summary submittal of the writer under Enclosure 1 of this DPO, and a related clarification for the DPV oversight committee under Enclosure 4.
(b) Responses by RES and DST staff through the Director, DST, A. C.
Thadani, to F. J. Miraglia, Associate Director for Inspection and Enforcement, and then to T. F. Murley, Director NRR (contained within Enclosure 6 to this DPO).
The DPV process does not provide for a timely review and response by the initial submitter of a DPV, to the detailed arguments of the staff in its understandings, representations, conclusions, and recommendations in respect of the that D.P.V.
The writer did request, and T. Murley did providt, limited time for discussion on certain general conclusions submitted by the staff.
Since the conclusion of the D.P.V, the writer has had the opportunity of a detailed review and evaluation of a minimum set of the submittals by staff and management, and has concluded that for many valid technical and regulatory reasons, these submittals cannot substantiate a departure from the writer's overall evaluation of the excessive consequential risk to Public Health and Safety in the proposed adoption of managements conclusion to permit operation with the 42" CiVs open to 50':
Summarily, the writer croposes that:
The staff's evaluation of the
,(
writer's DPV manifests in substantive areas, fundamental errors, neglect
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and omissions in represanting the writers position and in the interpreta-l tion of significant experimental data.
It also manifests a fundamental lack of understanding of the existing Licensing Dasis relationship between DNBR, specified fuel acceptable design limits, and fuel failure; and the significance of fission product release on fuel failure, and the need to l
provide conservatively designed multiple barriers between the fission 2
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Attachment
. o I
product and the external environment to reduce offsite doses from catas-trophic to acceptable levels for even small percentages of fuel failure.
Further, that incorrect Licensing Basis data has been used, together with comprehensive Non-l.icensing Basis data including information in Draft form asofAugust1,1989,andprivatesubmittalsbyWestinghousefW)onthe subject, to ultimately propose Acceptable Levels of safety.
Mso, that staff and management has not addressed the use of non-conservative interpretations of licensing basis requirements and the use of Non-Licensing Basis data, against the calculated catastrophic offsite doses of over i
200 times 10 CFR 100.11 Allowable Values as detailed in his D.P.V submittal.
All the above, leads to incorrect and invalid conclusions which are seriously flawed in respect of conformance to Regulatory requirements for Acceptable Limits for Public Health and Safety and which could result in potentially catastrophic offsite dose consequences for one of the three facilities in the USA with highest population at risk.
Given recognition of this D.P.0, the writer is prepared to fully detail the above elements to facilitate resolution of this issue.
Finally, one of the most disquieting feature of the staffs response is that, whereas the staff proposes that open 42" CIVs during power operation are neces-sary to relieve excess pressure and high levels of radioactivity inside contain-ment, to enable personnel access to perform maintenance while and at power, not one member of the staff has disclosed that systems for this purpose have already been incorporated into the design for normal operation of all W containments, and with a fully isolated containment (Encl. 5).
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Robert B. A. Licciardo Registered Professional Engineer, California Nuclear Engineering License No. NU001056 Mechanical Engineering License No. M015380 3
Attachment LIST OF ENCLOSURES (1) Proposed Memo to D. Muller, Director PD 11-2 f rom (R. Lit "-:rdo through)
Jared S. Wermeil, Acting Chief P.S.B., on the
Subject:
.:stsite Radio-i logical Consequence of LOCA During Containment Put-ge Proposed in T.S.
Changes for Zion 1 and 2; dated May 11, 1989.
(2) Memo to D. Muller, Director PD III-2, from (J. Kodrick through) J. S.
.l Werreil, Acting Chief PSB, on tht-
Subject:
Proposed T.S. Changes on Purge / Vent Operation; dated May 10, 1989.
F (3) Memo to Thomas E. Murley from Robert B. A. Licciardo dated May 11, 1989 I
on the
Subject:
Differing Professional View Concerning a) Issuance of l
SER to Zion 1/2 allowing full power operation with open 42" containment isolation valves b) Methodology used for calculating related offsite doses.
(4) Memo to F. J. Miralgia, Associate Director for Inspection and Enforcement, from Robert B. A. Licciardo, on the
Subject:
Differing Professional View t
(DPV) Concerning Containment Isolation valves At Lion; dated Juty 20, 1989.
t (5) Commonwealth Edison:
Zion; Updated Final Safety Analysis Report, Vol. 4, Sections 9.10.1.1, 9.10.1.2.1, 9.10.3.1, 9.10.3.2, 9.10.3.3.1, 9.10.3.3.2, and 9.10.3.3.7.
(6) Memo to Robert B. A. Licciardo from T. E. Murley, Director, NRR, on the
Subject:
Differing Professional View (DPV); dated September 13, 1989.
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