ML12255A080

G20120489 Email from Bruce Boger to Lee Samson Re 2.206 Petition Initial Recommendation for Brunswick Steam Electric Plant, Units 1 and 2

ML12255A080
Person / Time
Site:	Brunswick
Issue date:	09/07/2012
From:	Boger B A Division of Operating Reactor Licensing
To:	Lee S S NRC/NRR/DRA
Saba, Farideh
References
G20120489
Download: ML12255A080 (2)

Text

From:Boger, Bruce To:Lee, Samson Cc:Banic, Merrilee; Saba, Farideh

Subject:

RE: 2.206 petition initial recommendation (G20120489)

Date:Friday, September 07, 2012 8:37:33 AMI concur with the PRB decision and next steps.

From: Lee, Samson Sent: Thursday, September 06, 2012 12:11 PM To: Boger, Bruce Cc: Banic, Merrilee; Saba, Farideh

Subject:

2.206 petition initial recommendation (G20120489)

PETITION: http://portal.nrc.gov/edo/nrr/dpr/Lists/2206%20Petition%20Assignments/Attachments/44/G20120489.pdf Bruce, The purpose of this e-mail is to inform you, as the NRR ET member with responsibility for the 2.206process, of the initial recommendation of the Petition Review Board (PRB) on the linked 2.206 petition against Brunswick Units 1 and 2 submitted by David Lochbaum et al. on July 10, 2012.

We areseeking your concurrence on our recommendation to accept the petition and to proceed with the nextsteps in the process.

Please advise at your earliest opportunity.

SUMMARY

OF REQUEST

The petitioners originally in the letter dated July 10, 2012, requested that the NRC take enforcementaction in the form of an order either modifying the Brunswick Units 1 and 2 operating licenses technical specifications (as detailed in the petition) or requiring the licensee to submit amendment requests for these licenses.

The petitioners supplemented the original request during a recordedconference call with the PRB on August 15, 2012.

BACKGROUND

The petitioners stated that the current technical specifications for the Brunswick Unit 1 and 2 reactors are based on the assumption that the sole scenario involving damage to irradiated fuel outside of the reactor vessel is that resulting from a fuel handling accident involving recently irradiated fuel (i.e., fuelthat was within a critical reactor core within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).

However, loss of water inventory fromthe spent fuel pool or sustained loss of its cooling capability can also result in damage to irradiatedfuel and the potential extent of that damage and the amount of radioactivity released from damaged fuel can be considerably larger than that resulting from a fuel handling accident. The petitioners statedthat because the probability of spent fuel pool water inventory or cooling loss is not so low as to beneglected, the technical specification provisions that currently manage the risk from a fuel handling accident must be extended to also cover other credible spent fuel pool events.

During the August 15,2012, PRB meeting, the petitioners supplemented the original petition by referring to the March 12, 2012 Orders that were issued to the plants.

Mr. Lochbaum stated that Attachment 2 of the NRCOrder EA-12-051, which involves the water level instrumentation for the spent fuel pools, does not require that the spent fuel pool water level instrumentation be operable or functional at all times whenirradiated fuel is in the spent fuel pool.

PRB INITIAL RECOMMENDATION

OnSeptemberthePRBmetandmadetheinitialrecommendationtoacceptthepetitionbecause itmeetsthecriteriaforreviewingitunderprocessanditdoesnotmeetanycriteriaforrejection underthisprocess PRB MEMBERS & ADVISORS Samson S. Lee (PRB Chair - Deputy Director - NRR, Division Of Risk Assessment)

Farideh E. Saba (Petition Manager - NRR, Division of Operating Reactor Licensing)Merrilee J. Banic (Agency 2.206 Coordinator - NRR, Division of Policy and Rulemaking)Randy A. Musser (Branch Chief, Region II, Division of Reactor Projects, Branch 4)Kent A.L. Wood (Team Leader, Spent Fuel Team - NRR, Division of Safety Systems (DSS),Reactor Systems Branch)Steven R. Jones (Senior Reactor Systems Engineer -

NRR, DSS, Balance Of Plant Branch)Harold Walker (Sr Reactor Systems Engineer

- NRR, DSS, Containment And Ventilation Branch)Kristy A. Bucholz (Reactor Systems Engineer

- NRR, DSS, Technical Specifications Branch)Rossnyev Alvarado (Electronics Engineer (Digital I&C)

- NRR, Division of EngineeringInstrumentation and Control Branch)Molly Marsh-Barkman(Legal Counsel for the PRB - Office of General Council) - AdvisorLauren R. Casey (Enforcement Specialist, Office of Enforcement) - Advisor NEXT STEPS

The next steps would be to:

Management (Bruce Boger) agreement with the PRB recommendation (via this e-mail).Inform the petitioner of the PRB recommendationsDetermine if the petitioner would like a post-PRB meeting or telecon, and make thearrangements for an acceptable date and time.