ML20247N753
| ML20247N753 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Hatch, Monticello, Dresden, Peach Bottom, Browns Ferry, Nine Mile Point, Perry, Fermi, Oyster Creek, Hope Creek, Grand Gulf, Cooper, Pilgrim, Susquehanna, Columbia, Brunswick, Limerick, River Bend, Vermont Yankee, Duane Arnold, Clinton, Quad Cities, Big Rock Point, FitzPatrick, LaSalle, 05000000, Shoreham |
| Issue date: | 07/28/1988 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| FRN-54FR30905, RULE-PRM-50-53 PRM-50-53, NUDOCS 8908030142 | |
| Download: ML20247N753 (10) | |
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JUL 2 6 sse 3 UNITEDr$TATES OF AMERICA NUCLEAR kEQULATORY CCMM18810N
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Before the Director, Office of Wuclear Reactor R tion M* * :
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En the Mattar of 305T0N EDISDN CO. (Pilgrim Nuclear Power
- Station, Docket No.80-253) i CAROLINA 70h'ER & LIGHT CO. (Brunswick Station, Units 1 and 2,
Docket Nos. 50-324 and 50-325)
CLEVELAND ELECTRIC ILLUM1NATING COMPANY, ET AL. (Perry Muclear l
Fower Plar.ti Unit 1, Docket No. 50-440)
COMMONWEALTH EDISON CO. (Dresden Nuclear Power Plant, Unite 2
and 3, Dockst Nos. 50-237 and 50-249):
(Quad Cities Muclear Power Plant, Units i and 2, Docket Nos.
50-254 and 50-385):
(Lasalle County station, Unita 1 and 3, Docket Nos. 50-373 and 50-374) 1 r.
f C' CONSUMERS 70WER CO. (Big Rock toiatt, Dochit No.56-155)
DETROIT EDIHOH Co. (rerai Unit 2, Docket No. 50-341 GEORGIA POWER Co. (Hatch Nuclear Power Plant, Units 1
and 3,
Docket No. 160-321 and 50-368)
GULT STATES, UTILITIES CO.
(River Bend
- Station, Docket No.
50-458) 2LLIN015 P0h'ER CO. (Clinton Nuclear Power
- Plant, Docket No.
- r. 50-451)
~
ECMA ELECTR ;C LIGHT & POWER CO.
(Duane Arnold Nuclear Power ot No.80-331) g Plant, Dock
/CENERAL PUS 11C UTILITIES (Oyster Creek
- Station, Docket No.
50-219) a N
LONG. ISLAND LIGHTING CO. (Shdreham Nuclear Power Plant, Docket h
No.80-323)
[oh M!ss!551PPI POWER & LIGHT CO.
(Grand Gulf Nuclear
- 8tation, Docket No. 150-415) og4 No. M, /0 NEBRASKA PUllLIC 70MER DISTRICT (Cooper
- station, cocket
/
50-258) l' MIAGARA MOXAWK POWER CORP. (Nine Mile Point, Unite i
and 2,
(
j ls j
WORTHEAST U1'1LITIES (Millstone Unit 1, Docket No. 50-245)
NORTHERN STATES POWER CO.
(Monticello Nuclear Power Plant,
~
Docket No.1 0-263)
PEWNEYLVRNIL POWER &
LIGHT CO.
(Susquehanna steam Electric Station, Untts 1 and 2, Docket No. 50-387 and $0 388)
PHILADELPHIA ELECTRIC CO. (Peach Bottom Nuclear Station, Units 2 and 3 Dooket Nos.
50-277 and 50-278);
(Limerick Nuclear Power Planti Unit 1, Docket No. 50-352) 70WER RUTHOLITY OF THE STATE OF NEW YORE (James R.
Fitspatrick.
Station, Docket No. 50-333)
PUBLIC'8ERVLCE ELECTRIC OAS CO.
(Hope Creek Generating Station, Dodkat No. 50-354)
TENNESSEE VLLLEY AUTHORITY (Browns Ferry Nuclear Station, Units 1, 2, and 24 Docket Nos. 50-259, 50-260, and 50-296)
VERMONT YANTEE NUCLEAR POWER CORP.
(Vermont Yankee Nuclear power Planti Docket No. 50-271)
WASHINGTON PUBLIC POWER SUPPLY SYSTEM (WNF Unit 1, Docket No.
50-397)
PETITION UNDER 10 CFR 2.206 REQUESTING NRC ACTION T.0 RIVLEVE UNDUE RISK POSED SY S0ILING WATER RZACTOR THERMAL-H*iDAAULIC INSTABILITY 3.
INTRODUCTION Purouant to 10 CFR 2.206, the Ohio Citisans for Responsible
- Energy, Inc.
(80CRE*)
hereby petitions
- the
- Director, Office of Nuclesr Reactor Regulation, to take immediate action to relieve undue risks to the public health ahd safety posed by <the thermal-hydraulic instability of boiling water reactors, as revealed by the power oscillation event at Lacalle Unit 2 on March,9, 1988.
2=
1
II.
DESCRIPTION OF PETITIONER i
Petiti oner DCR2 is a
- private, nonprofit corporation
~
organized u sder the laws of the State of Ohio.
OCRE apacialises La research and advocacy on issues of nuclear reactor saf ety and has as its goal the promotion and
{
application of the highest standards of safety to such facilities.
211.
GROUND 1 FOR RELIEF A.
Signific,Lnce of ths,Lafa11e=2 Ever.t on March 3,
- 1988, while operating at 844
- power, the LaSalle" Unit 2 reactor underwent a dual recirculation pump trip on a fa.se low level transient signal caused by a technician!s 1
valving erroa in the reactor pressure vessel level sensing Lines. Resu11&nt natural circulation operation at the unchanged
~ 991 flow con 4rol line yielded power oscillations, which went on ainutes until thetreactor automatically scrammed on for several l APRM high flux (Litt).
It is estimated that local neutron flus variations an large as 3004 occurred (see Attachment it.
The plant" operauers, rather than scramming; the
- reactor, were instead trying to restart the recirculation pumps.
Nad they succeeded in restarting the pumps, it is likely that the event' 3
t i
~
would have worsene'd due to the insertion of additional reactivity.
The event is described further in Attachment 1, an article appe dingintheJuly4, 1988 issue of Inside NRc, Information Notice 88-39: Attachment 3, Su11stin 88-07; and Attachment 4, June 8,1988 Namorandum for Thomas E.
Murley and Eric 3.
- Seckjord, Offices of Nuclear Reactor Regulation and Research, from Edward L.
- Jordan, Office for Analysis and Evaluation of operational Data, and the enclosed
" AEOD Special' Report, AECD/8803.
Attachments 1 through d clearly indicate that the LaSalle ev.ent has sa.rious safeq' implications for all boiling wat,e'r l
~
Power oscillations were not predicted to
- occur at l
reactors.
Lasa11er the calculated decay ratio for LaSalle was 0.6.
In fact, LaSalle was considered to be one of the most stable BWRs l
in the ' country (Attwhment 1).
Other
- SWRs, with higher calculated d ecay ratios, are even more susceptible to power oscillations when operated in unstable regions.
For
- example, the calculated decay ratio (or the Ferry Nuclear Power plant i's 0.98 (Update d safety Analysis Report, p. 4.4-13).
The NRC has concluded that the decay, ratio determined by Aicensing
. calculations is not a reliable indicator of core stability.
The 3 ttachments state that there is a question of compliance t'ith General Design criterion 12 of Appendix A to 10 CFR part 80; GDC 12 require 4 that,the reactor core and
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associated c colant, control, and protection systems be designed so as to asi ure that power oscillations which can, result in
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4
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conditions exceeding specified acceptable fuel design limits are not Possible or can be reliably detected and suppressed.
The La6a11e event clearly demonstrates that the design and analyses of the reactor cannot be relied upon to ensure that esci11ations are not possible.
It also showed defio'iencies in operator training to detect and suppres. esci11ations.
General s
Electric's g utdance in SIL 380 Revision 1
La inadequate to ensure comp liance with ODC 12 (Attachment 4).
Plant instrumentation may not detect power oscillations.
APRM instruments typically show large noise f1*uctuations.
If
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out-of-phase oscillations occurred, the average signal to the #
APRM trip ft netion would be below the trip level, even though local oscillations could be large enough to cause fuel damage.
The LaSalle oscillations were also too fast to be accurately esasured by instrumentation,n available to the operators (Attach'ments i and 4).
The At0D recome. ends that in the
- interia, SWR licensees
~
ehould be rt quired to develop procedures to avoid unstable operation (Lttachment 4, AEOD Special Report at 7-8).
AEOD also recomends that the WRC re-evaluate the resolution of
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Generic Isstes 5-19, Thermal;Mydraulic stability, and B-59, N-1 Loop OperatLon, in SWRs and
- pWRs, and the ATWS mitigation measure of tripping the recirculation pumps (see 10 CFR 50.62 (c) (5) !
B.
The NRC Mas Failed to Take Appropriate Regulatory Action e
.'s -
s I
i
)
P The AEOD rer.irt has thoroughly documented the serious implications et the Lasalle event and has made some specific recommendations to the Offices of NRR and RES.
,Unfortunately, it appears uhat AE00's advice has fallen on deaf ears.
The NRt: issued Bulletin 88-07 on June 15, 1988.
After pointing out the significant generic. implications of the tasalle event, the NRC outlines three ' requested" actions for SWR licenset.s and announces its intent to pursue the remaining issues with the BWR owners Group.
The requested actions include ensuring that licensed operators and Shift Technical Advisors aro " thoroughly briefed" regarding the LaSalle event 4
j within 15 dtys of receipt of the bulletin, and, within 60 days, verifying the adequacy of procedures and training programs to assure awareness of (a) plant conditions which can result in power oscill ations: (b) actions which can be taken to avoid J
such plant a onditions; (c) how to recognise t.he ons'at of power oscillations and (d) action,s which can be taken in response to power oscill ations.
3WR licensees are also requested to verify
~
the adequacy of the instrumentation which is relisti upon by the operators.
The licensees then have an additional 30 days a completion of t' ese actions to confirm by letter following tt p
that they ha va been completed.
the evaluation of the adequacy of procedure s, training programs, and instrumentation is not to be submitted to the NRC, nor made available to the public, but it is rather to be kept on file at the plant site, for a period
-s-
~
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i of at least two years.
The specific recommendations made by AtoD are not required or even mentioned.
Given the grave implications of the LaSalle
- event, as thoroughly d ocumented in the AE0D report, the actions requested in the sulletin are insufficient.
The NRC aust take aggressive enforcement action to ensure the health and safety of the public.
Because it is probable that most, if not all, twRs are l
in a state of noncompliance with ODC 12, the
- Director, NRR should'immediately take the actions outlined below..
(
IV.
RELIEF REQUESTED
(
A.
The Director, NRR, should issue an order requiring all CeneralElecI tric BWR licensass to place their reactors in cold l
shutdown until permission to restart is
- given, based on completion and implementation of actions 3, C, and D below.
3.
The Dire ctor, NRR, should tesue an order requiring all General Electric BWR licensees to develop and implement l
l l
l procedures to (a) immediately insert control rods to below t.he 80% rod line following reduction or loss of recirculation flow or other traneients which re,sult in entry into potentially unstable regions of the power / flow
- saps (b) increase rec'irculation flow during routine reactor htartups and ir. sert some control rods prior to reducing recirculation flow below 50% during asutdowns to avoid operation in potentially unstablef e
p
=7-a
]
%.','-l areas of tho powerlflow maps (e) immediately scram the reactor
~
if (a) or (b) above are not successful in preventing and suppressing'esci11ations.
The licensees shall submit these procedures <;o the NRC for review 4.nd approval.
)
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C.
The Diractor, NRR, should issue an order requiring all General Electric LWR licensees to demonstrate that all licensed operators aad Shift Technical Advisors na've been trained to these procedures.
Additionally, the order should require SWR.
~
licensees to ensure that all licensed operators and shift Technical Advisors have received' training in and~
have f
exhibitse, through testing and examination, documented understanding of the nature and dangers of power oscillations, the thersa.1< hydraulic conditions causing power oscillations, how such coaditions can be avoided, how power oscillations can be
- detected, and the need to promptly terminate power oscillation i through scramming the reactor.
The licensees shall suba Lt evidence that the above measures have been
)
completed, Lncluding the content of training programs and the testing and examinations, to the NRC for review and
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results of approval.
I 3.
The Dir4ctor, NRR, should issue an order requiring all General El ectric SWR licensees to.
demonstrate that instruments cion readily available to tsontrol room operators is capable of detecting and alerting the operators to power
.g.
l 3
f oscillations, including out-of-phase er. asymastrical power oscillations.
The licensees shall' submit evidence
/
demonstrating that their instrumentation asets these i
- r. requirements to the NRC for review and approval.
The Director, NRR, should issue an order requiring General E.
31ectrie 3
licensees to develop simulator,s capable of I
modeling power oscillations such as those occurring at LaSalle and also out-of-phase or asymmetrical power esci11ations.
(the licensees, Genera,1 Elastric, or the SWR Owners Group may develop one such simulator and send operators from their facilitie's Sor training on it.)
After this simulator is l
developed arid built, all SWR licensees must include simulator The training on power esci11ations to.' all licensed operators.
and the NRC should evaluate the espabily ies of the simulator adequacy of the training on it.
F.
The Director, NRR, should issue an order to all General 1
all Electric BW3 licensees requiring them to report to the NRC past incider to in which the, recirculation pumps have tripped off, and the causative eventiand
- results, and all incidents i
involving power escillationey The WhC's order should e,stablish reporting seguirements for all future incidents of
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recirculatica pump trip and/or power opcil,1ations.
5-59 The C,omnission should reopen Generic Issues 3-19, and 4.
9
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.i..
and the A NI rulemaking.
The ATWS resolution should depend or,
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measures other than tripping the recirculation pumps to rapidly reduce reac civity, suc'h as an a'utomatic, high-capacity standby liquid cent rol systee. The commission should also. reconsider the use of t.he End-of= Cycle Recirculation pump Trip on 3Was.
The Directo r, NRR, should issue an order requiring all General.
Electric SWA licensees within 30 days to submit to 'the NRC for review and approval a justification for continued operation in light of th Ls unresolved matter and the reopened generic issues and RsWS r alemaking.
Any licenses failing to submit an f
appropriate. justification for continued operation shall have its facility operating license suspended until this issue is resolved.
=
R.
The Dirictor, NRR, should issue an order requiging all General Ele:tric SWR licensees within one year to submit a
~
report.to the NRC for review and approval demonstrating complianceitith ODC 12.
Any licenses failing to es'tablish compliance' tith GDC 12 shall have its facility, operating license rev oked.
=
s
. Respectfully submitted, l+rY.fbR Susan L. Riatt OCRE Representative 4275 Nunson Road Mentor, ON 44066
- (216) 254=3158 nRsnan. C. W t.3/ft?
10- :
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