ML20083C277

Petition for Emergency Relief Re Primary Containment Leak Rate at Facilities.Unsafe Condition Exists Re Ability of Primary Containment to Fulfill Design Function

ML20083C277
Person / Time
Site:	Byron, LaSalle, 05000000
Issue date:	11/29/1983
From:	Gogol E AFFILIATION NOT ASSIGNED
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20082Q305	List: ML20083C274 ML20083C277
References
NUDOCS 8312220269
Download: ML20083C277 (4)

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EdwagM.Gogol l pai,4tPAL STAFF

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) Qrl l PfTITION FOR EMERGENCY RELIEF RE: Primary Containment Leak Rate at LaSalle Units 1 and 7 000KETS NO. 50-373 anc 50-)]4, .

H'onorable James Keppler Director, Region 3 -

U.S. Nuclear Regulatory Coosaission 19') Roosevelt Road Glen Ellyn IL 60137

Dear Mr. Keppler:

I 4m writing to notify you of an_ extremely serious and unsafe condition which now exists at LaSalle Unit 1 with regard to the ability of the primary containment of that reactor to fulfill its design function and provide the level of containment of reactor fission products pendated by law and the reactor's technical specifications. '

There exists strong evidence that the Integrated Leak' Rate Testing (ILRT) done at LaSalle Unit 1 in Spring.1982, provides no assurance sihatever that the containment leak rate,is within the required limit. .

Besides being a clear and 9 resent danger. this situatio represents a gross violation of the requirements of the Ato,nic Energy Act and 10 CFR Part 50.

DescriDtior, of the situation:

1. If.ere 'ere severe errors. def ects. and loopholes in "American National Standard N45.4-1972, Leakage Rate Testing of Containment Structures for huclear Reactors *, which Appendix J of 10 CFR Part 50 requires that containment leak rate tests be conducted in accor:Jance with. As a result, i ILRT's are conducted in accordance with modified versions of this standard which have not been endorsed.

2. Most of these errors, defects. and loopholes stand uncorrected in the docuruent " ANSI /ANS-56.0-1981: American National Standard Containment System Testing Requirements", which the American Nuclear Society is l proposing as a standard to replace the N45.4 standard, and which was I

basically followed during the 1982 LaSalle test.

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November 29, 1983 honorable . lames Keppler Page 2

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 gleitesy _

mistake tsade during the derivation of this equation, This error was reported as early as 1969 (see References 1 and 2). Errors resulting from the use of the wrong equation may become significant when temperature gradients throughout a containment are not small.

b. A lack of any prohibition on a wide variety of *::y: in

• t.ich the final calculated leak rate may be fudoed. These include, but are not limited to:

1. unjustified discarding of the first part of the mass curve;

11. unjustified discarding of data:

iii. insuf ficient ano unjustified placement of temperature and pressure sensors; iv. use of unjustified wighting coef ficients;

v. Invalid and unjustified blockage of leakage pathways; vi. Invalid and unjustified use of '8' and 'C' type tests as '

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

c. Loose reauirements for permanent archivinc cf the actual raw.

Individual temperature and pressure seg er readings., as well as othet essential data. If this data is not preserved, meaningful review of .

, an ILR test is impossible.- especially in light of the manf .

j opportunities described above for fudging the calculated result,

4. It can be mathematically demonstrated that' the e#rro'rs and loopholet in the standards allow the reportino of a leak rate which may be one or in ,

extreme cases as much as two orders of m6anitude lower than the real leak rate.

To sum up, the ILRT methodology now in use of fers no guarantee that actual leak rates are acceptably low. We sirnoir do not knoy what the actual leak rates are. This is precisely the case with LaSalle Unit 1.

This unacceptable situation represents a fundamental violation of the requirements of 10 CfR Part 50, which requires that reattor containment leak rates be cemonstrated to be within certain values f or a reactor to obtain and l keep an operating license.

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November- 29, 1983 Honorable James Keppler Page 3 Specific problems with LaSalie Unit 1 ILRT:

l In July of this year, I filed with the NRC a Freedom of Information Act Request (F01A-83-384), asking for copies of any and all documents in the NRC's possessior, regarding Integrated Leak Rate Testing at the LaSalle 1 and 2 and D.C. Cook 1 and 2 reactors, including any and all information on flaws or errors in these tests. The NRC responded, af ter a very significant 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 Reytblatt, 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 r'enerted leak rate;

b. insuf ficient to prove that the kind of un_ justifiable fudoino of the data

, described above was not done; and

c. insufficient to permit a meanineful review of this test.

Necessary data not provided include:

a. Precise location of temperature and pressure instruments;

b. Compartment subvolume recalcolationA;

c. Individualsensorweightingfactohp47Itappearsthatthetesting organization simply used temperature averaging over individual compartments; ,

d. Individual temperature senter readings;

e. Back-up pressure gauge readings; and f.

Containment ventilation and cooling conditions in ef fect during the, -

test.

No r,omplete review can be done without such information.

There 'is strong evidence, huwever, that the real leak rate may be in escess of the reported value simply because the local temperature range within the containment during the test was at , tikes greater than 40 degrees F. Another adverse factor is a possibility of actual weighting factors being in' excess of 0.1, which violates evan the faulty standard.

In addition, the materials received were fragmentary, disordered, and in suny cases tilegible.

In conclusion, there appears to be no justification for the conclusion that LaSalle Unit l*s containment leak rate is within acceptable limits. It appears that the NRC has never received from C6nmonktalth Edison any materials which can justify any such conclusion.

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November.29, 1-983 Honorable Janes Keppler Page 4 l

Relief reauested:

I therefore request that you immediately order:

1. that taSalle Unit 1 be placed in cold shutdown until Connonwealth Edison (CECO) can provide valid proof that its containment leak rate is within the limit mandated by law;

2. that CECO assemble and submit to the NRC all ILR test reports and supporting documents or conputer nedia r,ontaining such supporting noterials (including material re ating to points a-f above) pertaining to LaSalle Units 1 ant 7 and Byron Units 1 and 2, including such docusents or media which contain the actua) raw test data;

3. that the NRC immediately releasp copies of all this material to me so that an independent review can be Mohe;

4. that the NRC innediately commence its own review of these tests; and S. that Conmonwealth Edison be ordered to cenduct no further Integrated leak Rate Testing until all errors and defects in the test methodoiggy haye been corrected.

The public interest, as well as 10 CTR Part 50, demands that this e.afrkmely serious situation be corrected. I shall expect to hear f rom 'you 'irp4dlately.

Sincerely, Edward M..Gogol l cc. Congressman Sidney Yates '

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References:

1. See pages 33-34 of:

BNWL-1028, UC-80, Reactor Technology: Air teaksee Bate Studves on the C.S.E. Containment Vessel..'

by M.E. Witherspoon and G.J. Rogers, Reactor Engineering Departnent, Physics and Engineering Division, Battelle Nemorial Institute, Pacif tc Northwest Laboratories.

September 1969.

2. Report 0183: Criticue_9L.C.gniainment System Test RequiremenQ By Z. Reytblatt, Extran Inc., POB 2849, Chicago IL 60590 .

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/ged OCo UNITED STATES

!" .c,e j. NUCLEAR REGULATORY COMMISSION

y WASHINGTON, D. C. 20555 k.....,/ December 16, 1983 Docket Nos.

STN 50-454/455.

and 50-373/374 Mr. Edward M. Gogol 154 Linden '

Glencoe, Illinois 60022

Dear Mr. Gogol:

This letter acknowledges receipt of three Petitions for Emergency Relief submitted by you to the U. S. Nuclear Regulatory Comission on November 29, 1983. One petition was directed to the Chairman of ti;e Nuclear Regulatory Comission. The second petition was directed to the Regicnal Administrator of Region III and the third petition was directed to my office. As all petitions address substantially the 'same issue, that is, the adequacy of the containment integrated leak rate testing which has been conducted at U. S. nuclear power consolidated. And, as the issue you raise reactors, is primarilyyouronepetitions related toare thebeing 11c 'ensing of comercial nuclear reactor 4 facilities, the Office of Nuclear Reactor Regulation will provide the substantive response to all three petitions.

h.ur petitions are being treated under 10 CFR 2.206 of the Ccmission's regulations and 1ppropriate action will be taken on your petitions within a reasonable time. While your petitions seek immediate action with respect to the allegations which those petitions raise, specifically placing La Salle County Unit 1 of Commonwealth Edison Company in cold shutdown ceasing further construction and licensing activities with respect to La Salle County Unit 2 and Byron Unit 1, and shutting down reactors with insufficient evidence of adequate containment leak rate testing, I decline to take such actions based ucon the oreliminary evaluation of your petitions and other information, including a December 13,19S3 response frca Ccmonwealth Edison regarding your petitions.

You contenc that there are severe errors, defects, and loopholes in both ANS 345.4-1972 and ANSI /ANS 56.8-1981, anc that tne ILRT methocology now in use offers no guarantee that actual leak rates are acceptably low. The specific defects alleged in your petitions include:

1. The equation used to calculate the containment air mass at any i given time is wrong;

2. The final calculated leakage rate may be " fudged"; and

3. There are " loose" requirements for permanent archiving of actual raw data and other essential data.

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3 0 Mr. Edwara M.'Gogol The Commission's requirements for integrated leak rate testing (ILRT) are set out in 10 CFR 50.54(n) and Appendix J to 10 CFR S0. These requirements call for pr.eoperational and periodic leak rate testing in accordance with American National Standard N45.4-1972, " Leakage Rate Testing of Containment Structures for Nuclear Reactors." American National Standard ANSI /ANS56.8-1981, " Containment System Leakage Testing Requirements" is an industry concensus document which provides detailed guidance for performing the ILRT required by Appendix J.

With regard to Item 1, the equation presented ,in ANSI /ANS 56.8-1981 for calculating containment mass is not wrong as you allege. The manner in which the mean containment temperature is calculated for use in the equation, however, could be clarified. In this regard, ANSI /ANS 56.8-1981 does not prescribe how to calculate the mean containment temperature. Either a mass-weighted mear temperature or a volume-weighted mean temperature would be acceptable. While the use of a volume-weighted temperature is technically more correct, for reasonably well stabilized containment test conditions, as required by Appendix J, the error that could result from using the mass-weighted mean temperature is not significant. What is necessary then is assurance that the entire ILRT program is conducted to assure stable conditions ard proper evaluation of test data.

A test so conducted would not likely be flawed by the type of deficiencies you allege in the second item of your petitions, such as unjustified discarding of data or the use of unjustified weighting coefficients. The manipulation of data in the manner you suggest in the second item of your petition would be a violation cf the Commission's regulaticns. To assure compliance with the ILRT requirements, NRC inspectors generally' observe these tests and document the results of their observations. For example, the ILRT inspection for La Salle County Unit: 1 and 2 are documented in the following inspection reports:

Inspection Report 50-373/82-25 (June 9, 1982) - Unit 1 Inspection Report 50-373/82-32 (July 29, 1982) - Unit 1 Inspection Report 50-373/83-28; 50-374/83-23 (DE) (July 28, 1983) - Unit 2 Eased on these inspections, we find that the licensee's Containment Integratec Leak Rate Tests for both La Salle County Units 1 and 2 meet the current regulatory requirements centrary to the allegations in your petitiens.

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Mr. Edward M. 4o901 -

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In addition, prior to the licensing of Byron Unit 1, a similar inspection effort will be undertaken. Also, a similar effort has been undertaken each time an ILRT is performed at a licensed connercial power reactor thus providing assurance that the Commission's requirements are met.

With respect to Item 3, consistent with 10 CFR 50.34 and Criterion XVII of .

Appendix B to 10 CFR 50, licensees of commercial power reactors are required to retain records which furnish evidence of activities affecting cuality of safety-related itees including the reactor containment. Furthermore, the Technical Specifications, which form a part of the operating license for each plant, require the permanent retention of records associated with inservice inspecticrs anc tests recuired by the Technical Specifications.

The ILRT is one of those inservice inspections and tests called out in the Technical Specifications. Finally, the NRC staff has assured itself that ILRT records do in fact exist and are being so retained at La Salle County and Byron.

As you are aware from your participation, and that of Dr. Zinovy Reytblatt, in the activities of Working Group ANS-56.8 of the Standards Committee of the American Nuclear Society, efforts are underway to more clearly articulate the procedures and conditions gpverning the conduct of integrated leak rate tests.

Consequently, the participants of this group have the benefit of your concerns. These efforts could result in appropriate modifications to Appendix J to 10 CFR 50 at a fu; ore date. -

The NRC staff will continue to review your petitions, ana I will issue a formal decision with regard to them in the reasorably near future. A copy of the notice that is being filed for publication with the Office of the Federal Register is encicsed here for your information.

Sincerely, '

,s ., ,

-s q& b. / Sw Harold R. Dente , Di ector Office of Nuclear Reactor Aegulation

Enclosure:

As stated cc w/ enclosure:

Commonwealth Edison Company

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. NUCLEAR REGU'.ATORY COMMISSION REQUEST FOR ACTION UNDER 10 CFR 2.206 REGARDING ltFEGRATED CONTAINMENT LEAK RATE TESTING AT CCS"6.RCIAL NUf' EAR POWER FACILITIES Notice is hereby given that, by three petitions dated November 29, 1983, Edward M. Gogol sought emergency relief and immediate action to remedy alleged inadequacies in the conduct of integrated leak rate testing at U. S.

. nuclear power reactors, including specifically La Salle Units 1 and 2 and Byron Units l and 2. Severe errors, defects, and loopholes are alleged in the integrated leak rate testing methodology now in use. A variety of relief is reouested including placing La Salle Unit 1 in cold shutdown, ceasing further construction and licensing activities with respect to La Salle Unit 2 and Byrcr; Unit 1, and shutting down reactors with insufficient evidence of adequate containment leak rate testing. The petitions are being treated pursuant to 10 CFR 2.'206 of the Comission's regulations and, accordingly, appropriate action will be taken on these requests within a reasonable time'.

A copy of the petitions are available far inspection in the Commission's public document room, 1717 H Street, NW, Washington, DC 20555'and at the local public document-room for the La Salle Station, Units 1 and 2 at Illinois Valley Community College, Rural Route #1, Oglesby, Illinois 61348 and Byron Units 1 and 2 at Rockford Public Library, 215 N. Wymun Street, Rockford, Illinois 61101 and Byron Public Library, 218 W. Third Streets Byron, Illinois 61010.

Dated at Bethesda, Maryland, this 16th day of December 1983.

FOR THE NUCLEAR REGULATORY COMMISSION s.

i Edson G.' Case, Actino Director Office of Nuclear o.eic to r Degulaticn "2 1 3 h' 3 b '

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