ML20069A706

Submits Susquehanna Steam Electric Station Units 1 & 2 Loss of Spent Fuel Pool Cooling Licensing Basis

ML20069A706
Person / Time
Site:	Susquehanna
Issue date:	05/16/1994
From:	Lochbaum D, Prevatte D AFFILIATION NOT ASSIGNED
To:	Larkins J Advisory Committee on Reactor Safeguards
References
ACRS-GENERAL, GL-91-18, IEB-94-001, IEB-94-1, NUDOCS 9405260125
Download: ML20069A706 (3)

Text

• I May 16,1994 David A. IAchbaum Donald C. Prevatte

. 80 Tuttle Road 7924 Woodsbluff Run Watchung, NJ 07060 Fogelsville, PA 18051 (908) 754-3577 (215) 398-9277 Dr. John T. l arkins, Executive Director United States Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards Washington, DC 20555 SUluECT: SUSQUEIIANNA STEAM ELECTRIC STATION UNITS 1 AND 2 LOSS OF SPENT FUEL POOL COOLING LICENSING llASIS

Dear Dr.1.arkins:

On May 6,1994, the NRC staff made a presentation to the Advisory Committee on Reactor Safeguards (ACRS) on the substantial safety hazard the undersigned identified in the design of the Susquehanna Steam Electric Station (SSES) and submitted to the NRC in a 10CFR21 report dated November 27,1992. The NRC presentation relied extensively on two positions with which we strorgly disagree - first, that the loss of spent fuel pool cooling following a Design Dases less-of-Coolant Accident (DIIA LOCA) is outside the SSES current licensing basis, and second, that the probability is so low as to permit the concerns to be dismissed as having negligible safety significance.

In a letter dated March 21,1994 (attached), we identined numerous links between the loss of spent fuel pool cooling and the DBA LOCA event. A loss of spent fuel pool cooling at the SSES is a direct and immediate consequence of a LOCA event. Since it was clearly apparent from their presentation to the ACRS that the NRC staff had not properly considered these links, we requested in a letter dated May 10,1994 (attached) that the NRC staff formdly address each one of the links. In this letter, we also brought to the NRC Project Manager's attention the determination in NRC Bulletin 94 01 dated April 14, 1994 that a related event at the Dresden Unit i facility resulted in ' compliance backfits' for eight licensees.

The NRC staff's probability arguments are weak, and we were encouraged by the ACRS' challenges of these NRC staff arguments. These probability arguments also conflict with the position taken by the NRC staff in NRC Generic I etter 91-18. This NRC position explicitly forbid use of probabilities when making operability determinations. In essence, that is precisely what the NRC staff is attempting to do when they examine spent fuel pool cooling following a DBA LOCA event at SSES.

The ACRS should also be aware that Mr. William Russell of the NRC's Office of Nuclear Reactor Regulation recently denied a 2.206 petition filed by Mr. Paul M. liianch on the spent fuel pool cooling concerns tolely on the basis of a probability argument. For some reason, the distribution for this denial included several hundred individuah.

Please do not hesitate to contact us if we can provide any assistance to the ACRS on this matter.

Sincerely,

_ h0 v l 0I s" ,

David A. ochbaum g onaldD C. Prevatte i O 9405260125 940516 hl PDR ADOCK 05000010 O PDR lb i Gl r

.jh' , h&

, 1 Attachments: 1) letter dated March 21,1994 from David A. Lochbaum and Donald C. Prevatte to Joseph W. Shea, ' Comments on SSES Loss of Spent Fuel Pool Cooling Licensing Basis *

2) Ixtrer dated May 10, 1994 from David A. Lochbaum and Donald C. Prevatte to Joseph W. Shea, 'SSES Loss of Spent Fuel Pool Cooling Licensing Basis'

3) letter dated March 16,1994 from Joseph W. Shea to David A. lechbaum and Donald C. Prentte, " Spent Fuel Pool Cooling issue' Distribution: (without attachments)

United States Nuclear Regulatory Commission At'.ention: Document Control Clerk Mail Station PI 137 Washington, DC 20555 Director, Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 Mr. Richard Clark Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 Mr. Thomas T. Martin Regional Administrator, Region i United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Richard A. Matakas United States Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 1415 Mr. Exo Norton Assistant inspector General United States Nuclear Regulatory Commission Washington, DC 20555 Mr. Ivan Selin Chainnan l United States Nuclear Regulatory Commission l Washington, DC 20555 j Mr. Robert J. Summers United States Nuclear Regulatory Commission 475 Allendale Road )

King of Prussia, PA 19406-1415  ;

l l

• I Mr. David Williams ,

Inspector General

-f Uni,ted States Nuclear Regulatory Commission

. Washington, DC 20555 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P.O. Box 2063 Harrisburg. PA 17120 The Honorable Joseph I. Lieberman Chairman, Senate Environment and Public Works Committee, Subcommittee of Clean Air and Nuclear Regulation SD-458 Washington, DC 20510 The lionorable Richard H. Lehman Chairman, llouse Natural Resources Committee, Subcommittee on Energy and Mineral Resources 818 O'Neill Building 300 New Jersey Avenue, S.E.

Washington, DC 20515 The lionorable Philip R. Sharp Chairman, Ilouse Energy and Commerce Cornmittee, Subcommittee on Energy and Power 331 Ford Building 2"' and D Streets, S.W.

Washington, DC 20515 Ms. Joanne Royce Government Accountability Project 8101" Street NE, Suite 630 Washington, DC 20002-3633 Mr. Robert D. Pollard Union of Concerned Scientists 1616 P Street NW Washington, DC 20036 Mr. Paul M. Blanch 135 liyde Road West llartford, CT 06117 i I

I

-!