ML20033F436
| ML20033F436 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/06/1990 |
| From: | Licciardo R NRC |
| To: | Murley T, Taylor J Office of Nuclear Reactor Regulation, NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20033F435 | List: |
| References | |
| NUDOCS 9003210031 | |
| Download: ML20033F436 (3) | |
Text
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March 6, 1990 b akg 4
MEMORANDUM.FOR: James M. Taylor
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Executive Director for Operations Thomas E. Murley, Director Office of Nuclear Reactor Regulation FROM:
Robert B. A. Licciardo
SUBJECT:
COMMENTS BY ROBERT B. A. LICCIARDO ON THE REPORTS BY THE INDEPENDENT REVIEW COMMITTEE FOR THE DPO, AND THE STANDING REVIEW PANEL FOR THE DPV
References:
(1) Memorandum from Thomas E. Murley to Robert B. A.
Licciardo dated August 31, 1989,
Subject:
Differing Professional View (DPV) Regarding 42" Purge and Exhaust Valves at-Zion 1/2) An Independent, Outside, Qualified Review (2) Memorandum from J. M. Taylor to Robert B. A. Licciardo dated January 2, 1990.
Subject:
Disposition of 1
Differing Professional Opinion (DPO) Regarding 42" Purge and Exhaust Yalves at Zion 1/2) An Independent.
Outside Qualified Review (3) Memorandum from Robert B. A. Licciardo to F. J. Miraglia dated July 20, 1989
Subject:
Differing Professional View (DPV) Concerning Containment Isolation Yalves at Zion, with Enclosure entitled "An Evaluation of the Criterion for the Calculation of Offsite Doses Deriving from Open Containment Purge Valves During a LOCA at Zion Units 1/2 dated July 20, 1989 a Safety Evaluation Report (SER)y, Director of NRR, the writer submitted By memorandum to Thomas E. Murle and Differing Professional View (DPV) concerning a proposal by management to issue a TS amendment allowing the containment purge isolation valves at Zion 11.2 to remain open during power operation.
This DPV was accepted by Dr. T. E. Murley, Director, Office of Nuclear Reactor Regulation for review by a Standing Review Panel from which Dr. Murley finally issued action reouirements to a) effectively review all new and advanced fuels for the possibility of a rupture during the blowdown phase of a LOCA, and b) to revise the Standard Review Plan to clarify the relationship between DNBR and fuel failure (Ref. 1). This review however continued to recomend the issuance of the management SER pemitting the large containment isolation valves to remain open at power. As a consequence the writer submitted a Differing Professional Opinion (DPO) to James Taylor, Executive Director for Operations (EDO), dated October 19, 1989 to require 900 4too3t 9o9,q He nueCK. CSmcg
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that these valves remain closed under these conditions. The EDO appointed an Independent Review Committee the input from which the EDO finally issued recommendations on January 2, 1990, (Ref. 2).
The writer's coments on the reviews by the Panel and the Comittee are presented in the Enclosure, entitled "Sumary Evaluation b Licciardo of Response to his Differing Professional View (y Robert B. A.DPV) and Differ Professional Opinion (DPO) concerning (a) Zion 1/2 Containment Purge Isolation Valves, and (b)-Nethodology Used for Calculating Offsite Doses." This evaluation represents the first written opportunity the writer has had to contribute further to this problem, based upon his review of the substantial-references and comments made available to the writer by the review Panel and Committee. This sumary addresses the outstanding issues only, and in terms of the five recommendations made by the Independent Review Comittee for the DPO.
l The writer's evaluation concludes that the Zion reactor with a licensed 1-maximum power rating for LOCA calculations of 17.9 kw/ft and fuel designed to L
be at a clad pressure of 1400 to 1700 psig at normal full power conditions, gives calculated temperatures over the first seven seconds of a LOCA blowdown, of 1500 1700*F, and " evaluated" pressure differences across the clad which l
would result in fuel clad ruptures.
Furthermore, the overwhelming importance l
of fuel clad failure, both by DNBR infringement and related loss of hermeticity, and clad rupture, and it's related fission product release to offsite dose during the blowdown phase of a LOCA provides no. margin for any uncertainty about surety of containment to prevent it's release to the environment. The writer proposes that for Zion their is a sufficient probability that fuel clad failure will occur to the extent necessary to justify his primary position that the containment purge valves should thereby-remain closed in operational Modes 1 (power), 2 (startup), 3 (hot standby), and 4 (hot shutdown).
Furthermore it has been confirmed by detailed reference that the Zion facility was designed and licensed so that the containment purge valves are to remain closed in Modes 1, 2, 3, and 4 and that for plant operation at 100% rated power, provision has already been made for access to containment, and those other features of plant operations, being currently proposed as a reason to amend this requirement at an unacceptable risk to Public Health and Safety.
L These comments are provided as constructive contributions to the real problem of reaching a decision at this time, in respect of closure of the containment purge valves at Zion 182 during power operation and in other Modes 2, 3, and 4
.Further in view of the fact that management has previously been unable to close this issue out since the comencement of operations at the Zion facility in 1973, and the fact that the writer has pressed this issue to at c
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last obtain a recognition of the principal issues present and their importance to safety I trust we can now complete this particular action and t.
achieve a legal and formal closure to what is a continuing violation of the Analysis of Record for the Facility and related Regulatory Requirements.
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The writer wishes to take this~ opportunity to thank all parties concerned for the resources which have been applied to this effort and the substantial material it.ade available to the writer through the related critiques and references.
(64l 1hk' Robert B. A. Licciardo Registered Professional Engineer, California Nuclear Engineering License No. NU001056 Mechanical Engineering License No. M0lS380
Enclosure:
As stated cc w/ enclosure:
D. Ross J. Murphy L. Soffer F. Miraglia E. Rossi F. Congel N. Lauben H. Smith
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