ML20083C274

Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing for Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology

ML20083C274
Person / Time
Site:	Byron, LaSalle, 05000000
Issue date:	11/29/1983
From:	Gogol E AFFILIATION NOT ASSIGNED
To:	Palladino N NRC COMMISSION (OCM)
Shared Package
ML20082Q305	List: ML20083C274 ML20083C277
References
NUDOCS 8312220267
Download: ML20083C274 (4)

Text

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• T Edward R. Gogol 154 Linden Glencoe IL 60022 (312) 835-3988 November 29, 1983 PETITION FOR EMERGENCY RELIEF RE: Primary Containment Leakage and Integrated Leak Rate Testing at all U.S. nuclear power reactors

-2, C [

3; '7 :i1 Honorable Nunzio Palladino ) 'i Chai r man U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Mr. Palladino:

I am writing to notify you of an extremely serious and unsafe condition w. '

now prevails with regard to Integrated Leak Rate Testing (ILRT) of U.S.

nuclear power reactor containments, and to request emergency action on your part to correct this situation. Besides being a clear and present danger, this situation represents a gross violation of the requirements of the Atomic Energy Act and 10 CFR Part 50.

Description of the situation:

l. There are severe errors. defects and loopholes _ in "American National Standard N45.4-1972 Leakage Rate Testi.ig of Containment Structures for Nuclear Reactors", which Appenoix J of 10 CFR Part a0 requires that containment leak rate tests be conducted in accordance with.

. 2. These errors. defects, and loopholes stand uncorrected in the' document "ANSl/ANS-56.8-1981: American National Standard Containment System Testing Requirements", which the American Nuclear Society is proposing as'a standard to replace the N45.4 standard.

3. The defects in these documents include:

a. The ecuation used to calculate the containment air mass at any civen time is wrong. This error is the result of an obvious and glaring mistate made during the derivation of this ecuation. This error was reported a's early as 1969 (see References 1 anc 2). Errors resulting from the use of the wrong equation may become significant when temperature gradients throughout a containment are not small,

b. A wide variety of ways in which the final calculated leak rate may be fudood. These include, but are not limited to:

1. unjustified discarding of the first part of the mass curve; ii. unjustified discarding of data; iii. insufficient and unjustified placement of temperature and pressure sensors; iv. use of unjustified weighting coefficients;

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i November 29l 1983 .

,e-  %-honorable Nunzio Palladino --

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v. Invalid and unjustified blockage of leakage pathways; .

, vi. invalid and unjustified use of "B" and "C" type tests as verification of overall containment leak rate; and vii. Errors in verification tests.

'c. Loose recuirements for permanent archiving of the actual raw, individeal temperature and pressure sensor readinos, as well as other essential data. If this data is not preserved, meaningful review of an ILR test is impossible .especially in light of the many 4

opportunities described above for fudging the calculated result.

4. It can be mathematically demonstrated that the errors and loopholes in the standards allow the reportino of a leak rate which may be one, or in extreme cases as much as two orders of macnitude lower than the real leak rate.

5. Integrated leak rate tests at U.S. Dower reactors have been conducted in this faulty manner since at least the 1960's.

6. This situation has persisted, and persists today, despite the fact that the Nuclear Regulatory Commission staff, the American Nuclear Society. Oak Ridae National laboratory, and Sarcent and Lundy were notified of it years 8Qo.

To sum up, the ILRT methodology now in use offers no guarantee that actual leak rates are acceptably low. We simoly do not know what the actual leak rates are. There is evidence, however, that at least one or several U.S.

containment 3 may have drastically higher leak rates than has been reported, and than the technical specifications for these plants allow.

If a Three Mile Island-type accident were to occur at a reactor with an unacceptably high containment leak rate (One that had not been detected by a faulty ILR test), radioactive contamination of the surrounding area could be The immense fission product inventory of the core would not be severe.

l contained to the degree mandated by law.

This unacceptable situation represents a fundamental violation of the requirements of 10 CFR Part 50, which requires that reactor containment leak rates be demonstrated to be within certain values for a reactor to obtain and keep an operating license.

This situation also violates the Atomic Energy Act - indirectly since it l vio'lates .10 CFR Part 50, &nd directly since the Atomic Energy Act mandates that atomic reactors may only be licensed if such licensing is consistent with protecting the public health and safety.

l' 1691a6

,, . November 29. 1983

-; ' --Nonorable Nunzio Palladino '

Page 3 .

Specific Droblems with LaSalle Unit 1 ILRT:

In July of this year, I filed with the NRC a Freedom of Information Act Request (f 0IA-83-384), asking for copies of any and all documents in the NRC's possession regarding Integrated Leak Rate Testing at the LaSalle 1 and 2 and D.C. Cook 1 and 2 reactors, including any and all flaws or errors in these tests. The NRC responded. after a very tignificant delay, by placing various documents regarding LaSalle in the LaSalle Public Document Room, at which I was able to peruse and photocopy them. I have submitted these materials for review to Dr. Zinovy Reytbla.tt, a specialist on containment leak rate testing.

Dr. Reytblatt informs me that these materials, which pertain to the spring 1982 ILRT conducted at LaSalle 1, are:

a. insufficient to justify the reported leak rate;

b. insufficient to prove that the kind of unjustifiable fudoina of the data described above was not done; and c.

insufficient to Dermit a meaninQful review of this test.

Necessary data not provided include:

a. Precise location of temperature and pressure instruments;

b. Compartment subvolume recalc'Jiations. It appears that the testing organization simply used-temperature averaging over individual comp 3rtments;

c. Individual sensor weighting factors; *

d. Individual temperature sensor readings;

e. Back-up pressure gauge readings; and

f. Contain, Tent ventilation and cooling conditions in effect during the

. test.

No complete review can be done without such information. '

There is strong evidence, however, that the real leak rate may be in excess of the reported value simply oecause the local teinperature range within the -

containment during the test was at times greater than 40 degrees F. Another adverse factor is a possibility of actual weighting factors being in excess of 0.1, which violates even the faulty standard.

In addition, the materials received were fragmentary, disordered, and in many cases illegible.

There appears, therefore, to be no justification whatever for any conclusion that LaSalle Unit l's containmsnt leak rate is within acceptable limits. It appears that the NRC has never received from Commonwealth Edison any materials which can justify any such conclusion.

1691a7

.L A 3vember 29, 1983 -

Honorable Nunzio Palladino Page 4 ,

Relief reauested: '

I therefore request that you immediately order:

1. that LaSalle Unit 1 be placed in cold shutdown until Commonwealth Edison (CECO) has provided to the NRC valid proof that its containment leak rate is within the limit mandated by law;

2. that all further construction and licensing activities on LaSalle Unit 2 and Byron Unit i be halted until CECO has provided to the NRC complete and valid proof that their containment leak rates are within the limit mandated by law; -

3. that the NRC staff immediately order CECO to submit complete ILRT reports and all supporting documentation, of the most recent ILRT's done at LaSalle Units 1 and 2, and Byron Unit 1;

4. that the NRC immediately release all such materials to me, including that described in "Necessary data not provided", points a-f above;

5. that a moratorium be placed on further Integrated leak Rate Testing until all errors and defects 'n the test methodology have been corrected;

6. that the NRC notify all U.S. reactor owners of this unsafe situation;

7. that the NRC order all U.S. reactor ownars to assemble all ILR test reports and supporting documents or computer media containing such supporting materials, including such documents or media which contain the actual raw test data; and to supply this material or copies thereof to the NRC; .

8. That the NRC commence an urgent program to promulgate a correct, . valid methodology for Integrated Leak Rate Testing; and initiate a rule-making procedure to obtain the adoption of this new methodology; and

• l 9. that the most recent ILR tests done at all U.S. reactors be reviewed immediately, and reactors ordered closed where there is not sufficient _

l evidence of containment leak rates within the legal limits.

f The public safety, as well as the law you are sworn to uphold, demands that l this extremely serious situation be corrected. I shall expect to hear from l you immediately.

Sincerely,

! Edward M. Gogol

References:

l -1. See pages 33-34 of: BNWL-1028, UC-80, Reactor Technology: Air Leakage

! Rate Studies on the C.S.E. Containment vessel, by M.E. Witherspoon and G.J. Rogers Battelle Memorial Institute

2. Report 0183: Critiude of Containment System Test Reautrements By Z. Reytblatt, Extran Inc., POB 2849, Chicago IL 60690 l 1691a8

Ed. arc M, Gogol 151 Linden

. s__

• Glencoe IL 60022 (312) 835-3988 i

November 29, 1983

, PETITION FOR EMERGENCY ret 1ET RE:

Primary Containment teakaoe and Inteerated leak Rate Testino at all i U.S. nuclear oower reactors i

Eonorable Haroic Denton Director Of fice of Nuclear Reactor Regulation L'.5. Nuclear Regulatory Lommis sion

. Washington DC 20555 Cear Mr. Denton: .

I am writing to notif y you cf an extremely ser gus and unsaf e condition which now prevails with regard to integrated Leak Rate Testir.g (ILRT) of U.S.

nuclear power reactor containments, and to request emergency action on your part to correct. this situation.

Besides being a clear and present danger, this situation representsta gross violation of the recuirements of the Atomic Energy Att and 10 CFR Part~50.

Descr*,otion of the situation:

1. There are severe errors, defects, and loocholes in "American U;tional Standard N45.4-1972, Leakage Rate Testing of Containment Structures for Nuclear Reactors", which Appendix 3 of 10 CFR Part 50 requires that containment leak rate tests be conducted in accordance with.

, 2. These errors, def ects, and locoholes stand untorrected in the ' document

' ANSI /ANS-56.8-igB1:

American National Standard Containment System Testing Requirements', which the American Nuclear Society is proposing as a standard to replace the N45.4 standard.

3. The defects in these cocuments include:

• a.

The ecuation used to calculate the containment air cassLat anv civen time is wronc. This error is the result of an obvious and glaring mistake made during the derivation of this equation. This error was reported as early as 1969 (see Ref erences 1 anc 2). Errors resulting f rom the use of the wrong ecuation ray become significant when temperature gradients throughout a containment are not small,

b. A wide variety of ways in which tpe final calculated leak rate may be fudoed. These include, but are not limitec to:

1. unjustified discarding of the first part of the mass curve; ii. (njustified discarding of data; - i iii. insuf ficient and unjustified placement of temperature and pressure sensors; iv. use of unjustified weighting coefficients; 1691a25 * ! '" A n ' u , "

DRADOCK03h00 3 PDR I Q

. hor.orable hdroib'Derdon -

,' ,- Page 2

.u- #

7 _ -

v.

Invalid and unjustified blockage of leakage pathways; Invalid and unjustified use of 'B' and 'C' type tests vi.

as verification of overall containment leak rate; and vii. Errors in verification tests. -

c.

toose recuirements for Dermanent archivine of the actual rav.

_ individual tem:erature and Dressure sensor readines, as well as other essential data. If this data is not preservec, meaningful review of

• an ILR test is impossible - especially in light cf the many cppcrtunities described above f or fudging the calculated result.

2 It, can be mathecatically di... nstrated that the errers and locoholes in the star.: ares allow the recortinc of.a___ leak rate unich ma v De one , or in extreme rate.

cases as much as two. orders cf gecnitude lower than the real leak 5.

Inteersted this faulty leak rate tests at U.S. cover reactors have _been condected in canner since at least the 1960's.

6.

This situation has persisted, and persists today, despite the fact that the Nuclear Reculatorv Commission staf f. the American Nuclear Society. Oak Eioce National laboratorv. and Sarcent anc. Lunov were notified of it years 200.

ic sua up, the ILRT methodology now in use c'f ers no guarantee ttat actual leak rates are acceptably low.

rates are. There is evidence, however, We-simolv do not irow what the aciaal leak inat at least one or several U.S.

conta'.nments may have drastically higher leak rates than has been reported, and than the technical specificatiens for these plants allow.

l l

If a Three Mile Islanc-type accident were to occur at a reactor vilth an unacceptably high containment leak rate (one that hac not been detected by a fsevere.

ault'y ILR test), radioactive contamination of the surrounding area cbuld be The immense fission product inventory of the core would not be contained to the degree mandated by law. ,

This unacceptable situation represents a fundamental" violation of the -

recuirements of 10 CFR Part 50, which recuires that reactor containment leak )

. ratesan keep beoperating demenstrated license.to be within certain values for a reactor to obtain and l

4his s'.tuation also violates the Atomic Energy Act ',ndirectly since it violates 10 CfR Part 50, and directly since the Atomic Energy Act mandates that. atomic reactors may only be licensed if such licensing is consistent with protecting the public health and safety.

1691a26

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - - - - - ^ ' - - - - - - - - - ' -

{ nt,tneer,ci, 19c3

.Ronorable Harold Denton

.+- Fr:9e 3 --

~

' Srecific o'roblems with LaSalle Unit 1 TiRT:

In July of this year, I filed with the NRC a freedom of Information Act Request (r01A-83-384), asking for copics of any anc all co: Umen;5 in the NRC's possession regarding Integrated Leak Rate Testing at the LaSalle 1 and 2 and 0.C. Cook 1 and 2 reactors, including any and all flaws or errors in these tests.

The NRC respondec, af ter a very significant delay, by placing various documents regarding 1.aSalle in the LaSalle Public Document Room, at which I was able to peruse and photocopy them.

I have submitted these caterials f or review to Dr. Zinovy Reytblatt, a specialist on containment leat rate testing.

Cr. Reytbla;t ir. forms me that thes: ete. ials, which pertair. to the sprinc 1982 ILRT r.onducted at LaSalle 1, are:

a. insufficient to iustifv the recorted leak rate; b.

insufficient to oreve that the kine of univstifiable fedeine of the data cescribed above was not done: anc

c. _insuf ficient to permit a meaninciul review of this test.

Necessary data not provided include:

a. Precise location 6T temperature anc pressure instruments;

b. Cemoartment subvolume recalculations. It appears that the testing organization simply used temperature averaging over individual compartments; .

c. Individual sensor weighting factors,

d. Individual temperature sensor readings;

e. Back-vp pressure gauge readi.ngs; and f.

Containment ventilation and cooling conditions in effect during the test.

No complete review can be done without such information. '.

There is strong evidence, however, that the real leak rate may be in excess of the reported value simply because the local temperature range within the containment during the test was at times greater than 40 degrees f. Another; adverse f attor is a . possibility of actual weighting f actors being in excess of 0.1, which violates even the f aulty standard, in addition, the materials received were f ragmentary, disordered, and in many cases illegibit.

There appears, theref ore, to be no justification whatever f or any conclusion that LaSalle Unit l's containment leak rate is within acceptable limits. It appears that the NRC has never received f rom Commonwealth Edison any materials which can justify any such conclusion.

TEGla27

. No'~ v ember 29 0 1983

~ . Hon'orable Harold Denton Page 4 Relief recuested:

I therefore request that you irnedtately order:

1.

that LaSalle Unit 1 be placed in cold shutdown until Ccmonwealth Edison (CECO) has provided to the NRC valic proof that its containment leak rate is within the limit tr.andated by law; 2.

that all further constructior,and licensing activities on LaSalle Unit 2 and Byron Unit 1 be halted until CECO has provided to the NRC complete and valid proof that their containment leak rates are within the limit cantated by law; 3.

that the NRC staf f inrnediately order CECO to sut.mit comolete ILET reports and all support'.nc cocumentation, cf the most recent ILRT's done at LaSalle Units 1 and 2, and Eyron Unit 1; 4.

that the NRC trnediately release all such t.Aterials to me, including that described in "Necessary data not provided', points a-f above; 5.

that a moratorium be-placed on further Integrated leak Rate Testing until ali errors and def ects-in the test methodology have been corretteo;

6. '

that the NRC nctify all U.S. reactor owners of this unsafe situation; 7.

~

that the NRC order all U.S. reactor owners to assemble all ILR test reports and supporting documents or computer media containing such supporting materials, including such documents or media which contain the' actual raw test data; and to sup' ply this material or copies thereof tc the NRC; 8.

That t'ie NRC 'conrnence an urgent program te promulcate a correct, salid methodology f or Integrated Leak Rate Testing; and initiate a rule ' making procedure to obtain the adoption cf this new methodology; and 9.

that the most recent lLR tests done at all 81.5. reactors. be reviewed m.

immediately, and reactors ordered closed where there is not suffic'.ent evidence of containment leak rates within the legal limits.

The public safety, as well as the law you are sworn te uphold, demands that this extrettaly serious situation be corrected. I stail expect to hear from you ir:rnediately.

S t ric e' rely

=

Edward M. Gogol

References:

1. See pages 33-34 of:

BNWL-10?8, UC-80, React or Technology: Mr leakace Rate Studies on the C.S.E. Containment Vessel, by M.E. Witherspoon and G.J. Rogers Batte11e Memorial Institute

2. Report ole 3:

Criticue of Containment System Test Recuirements By 2. Reytblatt, Extran Inc., P0B 2649, Chicago il 60690 1691a28 -

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