ML13217A061

G20130561 - David Lochbaum E-mail Re Tanya Mensah, NRR, Merrilee Banic, NRR; Andrea Russell, NRR, David Pelton, NRR; Mary Spencer; OGC

ML13217A061
Person / Time
Site:	FitzPatrick
Issue date:	07/25/2013
From:	Lochbaum D Union of Concerned Scientists
To:	Borchardt R NRC/EDO
References
2.206, G20130561
Download: ML13217A061 (9)

Text

ETS JU.S.NRC Ticket No: G20130561 Nrae'ling People and thrEnvironment 3069

. ---- a

• ý ....

Assigned Office: NRR OEDO Due Date: 01/24/2014 Other Assignees: SECY Due Date:

Date Response Requested by Originator:

Other Parties: Tanya Mensah, NRR; Merrilee Banic, NRR; Andrea Russell, NRR; David Pelton, NRR; Mary Spencer; OcIC

Subject:

2.206 - Condenser Tube Degradation at James A. FitzPatrick Nuclear Power Plant

Description:

CC Routing: OGC, Regioni ADAMS Accession Numbers - Incoming: Response I Package:

• a Cross Reference No: SRM\Other: No a

Action Type: 2.206 Review OEDO Concurrence: No Signature Level: OCM Concurrence: No Special Instructions: OCA Concurrence: No

8. a X Originator Name: David Lochbaum Date of Incoming: 07/25/2013 Originator Org: Union of Concerned Document Received by OEDO Date: 07/25/2013 Scientists Addressee: R. W. Borchardt, EDO Incoming Task: E-mail OEDO POC: Dan Merzke W~OA WB~1

Boyer, Rachel From: Borchardt, Bill Sent: Thursday, July 25, 2013 11:39 AM To: Boyer, Rachel

Subject:

Fw: 2.206 Petition re: condenser tube degradation at FitzPatrick Attachments: 20130725-jaf-ucs-nrc-condenser-tube-events.pdf Bill Borchardt Via blackberry From: Dave Lochbaum <DLochbaumrucsusa.org>

To: Borchardt, Bill Cc: Dean, Bill; Thadani, Mohan; Jessica(allianceforgreeneconomy.orq <Jessica(allianceforgreeneconomy.org>; Gunter, Paul <paul@beyondnuclear.orq>; Judson.timgamail.com <Judson.timrgmail.com>; Deb katz <debbnukebusters.org>

Sent: Thu Jul 25 09:30:20 2013

Subject:

RE: 2.206 Petition re: condenser tube degradation at FitzPatrick Sorry - the petition is attached this time.

From: Dave Lochbaum Sent: Thursday, July 25, 2013 9:08 AM To: Bill.Borchardt(nrc.gov Cc: Bill. Deananrc.gov; Mohan.Thadani0nrc.gov; Jessicaaallianceforgreeneconomy.org; Gunter, Paul; Judson.tim~drgmail.com; Deb katz

Subject:

2.206 Petition re: condenser tube degradation at FitzPatrick

Dear Mr. Borchardt:

Attached is a 10 CFR 2.206 petition submitted on behalf of the Alliance for a Green Economy, Beyond Nuclear, Citizens Awareness Network, and the Union of Concerned Scientists asking that the NRC take enforcement action to require that the degrading condenser tubes at the FitzPatrick nuclear plant be replaced prior to the unit restarting from its fall 2014 refueling outage.

We not not plan to also mail in a hard copy of this electronic version, but would be glad to do so upon request.

Thanks, David Lochbaum Director, Nuclear Safety Project Union of Concerned Scientists PO Box 15316 Chattanooga, TN 37415 (423) 468-9272 office (423) 488-8318 cell dlochbaumgucsusa.org EDO -- G20130561

Union of Concerned Scientists Citizens and Scientists for Envimrnental Solutions July 25, 2013 R. William Borchardt, Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Recurring Condenser Tube Leaks and Petition Pursuant to 10 CFR §2.206 for the James A. FitzPatrick Nuclear Power Plant

Dear Mr. Borchardt:

On behalf of the Alliance for a Green Economy, Beyond Nuclear, Citizens Awareness Network, and the Union of Concerned Scientists, I respectfully submit this petition pursuant to 10 CFR

§2.206.

Each quarter, the Nuclear Regulatory Commission (NRC) staff places monthly operating data reports into the Agencywide Documents Access and Management System (ADAMS). For example, the reports for the first quarter of 2013 are in ADAMS at http://pbadupws.nrc, gov/docs/ML1312/ML13126A379.pdf. I read each of these reports and transfer items of interest into a database of events. These items include planned and unplanned reactor shut downs, reactor startups, and significant power reductions for non-routine maintenance and testing. Among the items are events when operators shut down a reactor or reduce its power level due to condenser tube leaks.

Condenser tube leaks are noteworthy for several reasons. The condenser is the normal heat sink for the heat produced by the reactor core when it is operating and when it is shut down.

Condenser tube leaks could cause the normal heat sink to become unavailable. The NRC's reactor oversight process recognizes the elevated risk associated with a reactor shut down with complications (see http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/unplanned-scrams-with-complications.html). Condenser tube leaks could cause the normal heat sink to become unavailable which in turn can complicate the operator's response to a reactor shut down.

In addition, condenser tube leaks have caused extensive damage to nuclear plant components.

UCS described a September 1972 event at Millstone Unit 1 in a post to our blog (http://allthingsnuclear.org/fission-stories-3-high-tide-in-the-reactor/). This reactor was shut down for months while workers replaced components within the reactor vessel that had been damaged by sea water leaking in through failed condenser tubes.

Over the 43 months between January 1, 2003, and March 31, 2013, the operating data reports described 57 condenser tube events at U.S. nuclear power plants - an average of slightly over 1.3 events per month across the U.S. fleet.

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July 25, 2013 Page 2 of 7 But the events are not scattered uniformly across this fleet. One reactor has experienced over 30 percent of condenser tube events in the past decade - the James A. FitzPatrick Nuclear Power Plant in your region. FitzPatrick has reported 18 condenser tube leaks. For comparison, the next highest number of events over this period is only three (a four-way tie among Comanche Peak Unit 2, Davis-Besse, Palo Verde Unit 1, and Turkey Point Unit 4).

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z LaSalle County Unit 1 t Edwin I. Hatch Unit 2' Edwin I. Hatch Unit 1K I James A. FitzPatrick Dresden Unit 2 W Catawvba Unit 2 -

Calvert Cliffs Unit 2 a Alvin W. Vogtle Unit 2 a Quad Cities Unit I a Palo Verde Unit 2 I Oyster Crook II I Comanche Peak Unit 2 Duane Arnold a Columbia Generating Station a Arkansas Nuclear One Unit 2 a a Turkey Point Unit 4 Condenser Tube Events 01-2003 to 03-2013 More troubling is the recent trend that strongly suggests the bad situation at FitzPatrick is getting worse. FitzPatrick reported three condenser tube events in 2011, nine in 2012, and four during the first three months of 2013.

July 25, 2013 Page 3 of 7 Condenser Tube Events at U.& Nudear Power Reactors January 1, 2003 to March 31, 2013 OH The oserators reduced the reactor nower levd to 50 nereent for renairs to a leskinmocondenser tube.

tot deneer tubes.

Dresden Unit2 IL r tbe leaks.

-TIZ7 14 NY 20120614 NY Ise operators reduced her"ator powerlevel to ll percenttotoubleshoot a rceireslation pump motor low oil level alm and to Fasse A. T'itrPabrick 20120401 NY Alugleoltlssgcondenser tube PaloVerde Unit 1 20120225 The operators reduced the reactor power level to 73 percent due to increased condenser conductivity caused by leaking condenser

usquchanna Unit 1 20110705 PA ubes.

.onmanheh Peak UDit 2 20110519 ~ The operators manually tripped the reactor from 97 percent power due to a condenser tube leak that caused sodium concentrations in the stesmr generator to increase.

tames A. PitzPatrick 20110506 The o r du.d the re.to wer level to 50 teoe mairn condener tub. laks.

rames A. iFiltreik 20110430 NY The o reduced thereactor pwer level to 54 perceto p a main condenser tube leak.

Beaver Valley Unit 1 20101210 PA The op raters reduced power to 82 percent for rspairs to two leaking condenser tubes.

Bukey Point Unit 4 20101209 Fl The operators tripped the reactor when a condenser tube leak caused high sodium levels in the steam generators.

Columbia Generating Station 20100603 WA The opcraters reduced the reactor power level to 55 percent for repairs to condenser tubes.

LaSalle Couty Unit 1 20100115 IL heaop tors reduced the reactor power level to 55 percent to repair acondaeser tube leak

..olumbis Generating Station 20090709 WA he operators reduced the reactor power level toS5 percent to plug a leakins condenser tube.

'urkey Point Unit 4 20090527 L The opest reduced the reactor power level so leakins condenser tubes could be identiflied and plugged.

Beaver Valley unit 1 20090416 PA h operators reduced the reactor power level to 82 percent for workers to repair a condenser tube leak.

• ud Cities Unit 2 20090416 IL The erator reduced the reactor power level soal condenser usesicould be identified and I uged.

Foames A. FittPatrjek 20090413 NY The oearsreducediltherdactor powr level to4 to akIcaking eondee tube.

Arkansas Nuclear One Unit 2 20090228 AR The oprators reduced the reactor power level to 90 percent due to a condenser tube leak NrmeMile Point Unit 1 20090225 NY The operators reduced the reactor power level to 43 percent to repair a condenser tube leak.

uad Cities Unit 1 20081031 IL The orators reduced the reactor power level to addoil to a recirealation pump motor and to repair a condenser tube.

Seabreok Unit I 2008060 NH The operators reduced the reactor powerlevel to 30 peat to repar a condenser tubeleak.

Quad Cities Unit 1 20080411 IL The operators reduced the reactor power level to 23 percent to repsir a condenser tube leak and to add oil to the recirculation pumps 1A lower motor beoing.

The operators manually teranmned the reactor when a feedwater pump tripped on low suction pressure. The operators had reduced Oyster Creek 20071219 NJ the reactor power level for maintenance on the recirculation pump motor-gcnerator sets and to repair condenser tube lcaks. A worker's error in the circulatin water lineup to the condenser caused low suction pressure for the feedwater pump.

IssuesA.Firtzpatrick 26D071003 NY Theoaronreducedtheareactor awer level to 64 P coatta reairamcondensertube lealt PaloVerde Unit 2 20070725 AZ The operators reduced the reator power level to 40 perent to resirs condenser tube leak.

Palo Vrde Unit 3 20070329 AZ The operators redueed the reactor power level to 40 percent to plug a condenser tube leak in hotwell IA.

Davis-Bcssc Unit 1 20070518 H The operators reduced the reactor power level from 100 percent to 40 percent to repair a condenser tube leak, The operators reduced the reactor power level from 40 pernm Its 20 percent for a containment ent to add oil to a reactor coolant pump, Davis-Bese Unit 1 20070323 OH The opuratorereducd the reactor power level to 47 percestto locate and plus slakin condenser tube.

Edwin 1. Hatch Unit 1 20070130 GA The operators shut down the reactor for repairs to bypass valve spargers I and 2, condenser tubes, and the condenser inlet isolation valve.

The operators reduced the reactor power level and took the generator offline at 12:45 am. The operators further reduced the reactor Calvert Cliffs Unit 2 20060128 D power level to 3 percent while workers searched for the source o fhigh conductivityin the condenser hotweli water. A condenser tube leak was identifeid and plugged in condenser waterbox 21B. The unit was connected to the electrical grid at 1:13 pm. The operators returned the reactor power level to 100 peaent at 6:45 pro.

St, Luaie Unit 2 20060120 FL c The operators manually ripped the reactor due to condenser tube leakin condenser 2B2.

Turkey Point Unit 4 20051028 Fl Wosoers identified condenser tube leaks that delayed the reactor restart.

The operators manually tripped the reactor due to indications of an cxtraction steam bellows rapture in the line to feedwate heater Alvin W. Vogtle Unit 2 20050523 GA 3C and increasing fiedwater sodium concentrations. Workers identified multiple extraction stesombellows failues and a single condenser tube rupture.

Edwin 1. Hatch Unit 2 20050523 GA The operators manually surmmned the reactor due to adverse water chemistr trends indicative of condenser tube lcakae.

Duane Arnold 20031103 IA The operators manually shut down the reactor to rpair a condenser tube leak Palo Verde Unit 1 20030327 AZ The operators manually tripped the reactor when a condenser tube leak caused secondary system sodium linits to be exceeded.

The operators manually serumamed the reactor at 2:33 sn due to high conductivity in the hotwell caused by a suspected condenser tubeleak. Workers found that a deflector plate downstream of the IE-5B low pressure fcedwater heater dump valve CV-1340 broke Duane Arnold 20030201 IA loose and punctured a condenser tube and dented several other tubes. The deflector plate failed after approximately four months of continuous use of CV-1340 instead of the drain valve for heater level control.

July 25, 2013 Page 4 of 7 The evidence strongly suggests that (a) the condenser tubes at FitzPatrick are degrading, (b) the degradation rate is accelerating, and (c) the frequency of condenser tube events is increasing.

Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50 (see http://www.nrc.gov/reading-rm/doc-collections/cfr/partO5O/partO5O-appb.html) requires that plant owners develop and maintain quality assurance programs. This regulatory requirement explicitly states:

As used in this appendix, "qualityassurance" comprises all those plannedand systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.

Sixteen condenser tube events at FitzPatrick during the 11 months from January 1, 2011 to March 31, 2013 is compelling empirical evidence that components are NOT performing satisfactorily in service. This unsatisfactory performance is made even more evident by the fact that no other nuclear power reactor in the United States is experiencing condenser tube events at even close to the frequency they are occurring at FitzPatrick.

Quite simply, the condenser tubes are wearing out at FitzPatrick. The NRC staff explained this aging phenomenon recently in their analysis of age-related incidents from licensee event reports and inspection findings between 2007 and 2011 (see http://pbadupws.nrc.gov/docs/ML1304/ML13044A469.pdf). This NRC memo contained the "bathtub curve."

Decreasing Constant Increasing I Failure Failure Failure Rate Rate Rate

.. II Rate (U "- Infant

%Mortality" I*****© (U

a-  % Failure I I (U II LL  % Failures Time

July 25, 2013 Page 5 of 7 The increasing frequency of condenser tube events at FitzPatrick constitutes irrefutable evidence that these components are in the right-hand region of the bathtub curve where wear-out failures occur at increasing rates.

Your staff concedes this point and the owner's fault. In its report dated April 23, 2013, covering the biennial problem identification and resolution inspection at FitzPatrick (see http://pbadupws.nrc.gov/docs/ML 1211/M L 12114A279.pdf), the NRC staff stated:

The [NRC] team observed that Entergy did not properly considerFitzPatrickoperating history, specifically the 4 years of outages, when projectingthe expected condenser tube life. Consequently, Entergy did not properlyplan and designfor condenser tube replacementpriorto tube leakage which has necessitatedfrequentdownpowersfor repair.Plannedcorrective actions include condenser tube sleeving during the Fall 2012 refueling outage and a complete replacementof all condenser tubes in the Fall2014 refueling outage.

The track record for plant owners making good on their plans to implement safety fixes is mixed.

When safety fixes are not implemented on schedule, the public shoulders the burden from unnecessarily elevated risk.

On July 1, 2013, the NRC issued a confirmatory order (see http://adamswebsearch2.nrc.gov/webSearch2/main.isp?AccessionNumber='ML13114A928') to the owner of the Oconee nuclear plant. This order transformed the owner's previously stated plans for implementing safety upgrades into more enforceable regulatory requirements. In other words, the NRC must now formally review and approve any delays in completing the safety upgrades. Before this order, the owner could have unilaterally deferred completion deadlines.

While perhaps not posing the same heightened risk to the public as the safety shortcomings at Oconee, condenser tube degradation at FitzPatrick poses risks to the public. The plant's owner has plans to remedy this safety problem by replacing all the tubes during a refueling outage scheduled for fall of 2014. But the owner could readily - and without NRC approval - revise its plans to correct this problem at a later date.

Therefore, we petition the NRC under Section 2.206 to 10 CFR to take enforcement action' by imposing a regulatory requirement that all the condenser tubes be replaced at FitzPatrick prior to the reactor restarting from its fall 2014 refueling outage.

The enforcement action we request is needed to protect the public from the owner opting to defer correcting this safety problem. As the NRC has explicitly noted, the owner failed to "properly plan and design for condenser tube replacement" and is experiencing abnormally high occurrences of condenser tube failures. The fall 2014 refueling outage provides the owner with sufficient time to properly plan for the replacement of the degrading tubes. Any further delays

' The form of this enforcement action is up to the NRC: it could be via an order, or by amendment of the operating license to include a license condition, or any comparable means that result in the owner having to formally obtain NRC permission before operating FitzPatrick beyond its fall 2014 refueling outage without having replaced all its condenser tubes.

July 25, 2013 Page 6 of 7 would benefit the owner at the public's expense. Because this owner is clearly at fault (as the NRC has found), it is unfair for the public to continue picking up the tab for the owner's poor performance. If the owner does not replace the tubes during its refueling outage in fall 2014, than extending the downtime of the reactor until the replacements are finally completed would more equitably share the burden between the owner (who is at fault) and the public (which has no blame in this matter).

We, the petitioners, would like to exercise our right to address the NRC staff before the Petition Review Board (PRB) meets to consider our request. We believe we have clearly articulated the enforcement action we are requesting as well as its justification, but seek the pre-PRB meeting to highlight key issues as well as answer any clarifying questions the NRC staff may ask.

Sincerely, David Lochbaum Director, Nuclear Safety Project Union of Concerned Scientists PO Box 15316 Chattanooga, TN 37415 (423) 468-9272, office (423) 488-8318, cell Co-Petitioners:

Jessica Azulay Organizer Alliance for e Green Economy 2013 E. Genesee St.

Syracuse, NY 13210 eessica(allianceforagreeneconomy.org Paul Gunter, Director Reactor Watchdog Project Beyond Nuclear 6930 Carroll Avenue, Suite 400 Takoma Park, MD 20912 301-270-2209 www.beyondnuclear.org

July 25, 2013 Page 7 of 7 Tim Judson President Citizens Awareness Network Downstate Coordinator, Alliance for a Green Economy 599 East 7 th St., #6D Brooklyn, NY 11218 315-415-3005 audson.tim(gmail.com Deb Katz Executive Director Citizens Awareness Network P.O. Box 83 Shelburne Falls, MA 01370 413-339-5781 deb@nukebusters.com