ML13126A406
| ML13126A406 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/06/2013 |
| From: | Gundersen A Fairewinds Associates |
| To: | NRC/SECY |
| SECY RAS | |
| References | |
| License Renewal, RAS 24489, 50-327-LR, 50-328-LR, NRC-2013-0037 | |
| Download: ML13126A406 (12) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE SECRETARY In the Matter of Tennessee Valley Authority Sequoyah Nuclear Plant Units 1 and 2 Docket Nos. 50
-327 and 50
-328 License Nos. DPR
-77 and DPR
-79 NRC-2013-0037 EXPERT WITNESS REPORT OF ARNOLD GUNDERSEN TO SUPPORT THE PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING BY THE BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE, BELLEFONTE EFFICIENCY AND SUSTAINABILITY TEAM, AND MOTHERS AGAINST TENNESSEE RIVER RADIATION I, Arnold Gundersen, declare as follows:
- 1. My name is Arnold Gundersen. I am sui juris. I am over the age of 18
-years-old. 2. The Blue Ridge Environmental Defense League (BREDL), Bellefonte Efficiency And Sustainability Team, and Mothers Against Tennessee River Radiation have retained Fairewinds Associates, Inc to issue an expert report in support of the Parties Petition For Leave To Intervene And Request For Hearing. I have specifically been retained to examine the Aging Management Program at the Tennessee Valley Authority Sequoya Nuclear Power Plant as it relates to its ice containment system.
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Page 2 of 12 3. I earned my Bachelor Degree in Nuclear Engineering from Rensselaer Polytechnic Institute (RPI) cum laude. I earned my Master Degree in Nuclear Engineering from RPI via an Atomic Energy Commission Fellowship. Cooling tower operation and cooling tower plume theory were my area of study for my Masters Degree.
- 4. I began my career as a reactor operator and instructor in 1971 and progressed to the position of Senior Vice President for a nuclear licensee prior to becoming a nuclear engineering consultant and expert witness. My Curriculum Vitae is Attachment 1.
- 5. I have testified as a n expert witness to the Nuclear Regulatory Commission (NRC) Atomic Safety and Licensing Board (ASLB) and Advisory Committee on Reactor Safeguards (ACRS), in Federal Court, the State of Vermont Public Service Board, the State of Vermont Environmental Court, and the Florida Public Service Commission.
- 6. I am an author of the first edition of the Department of Energy (DOE) Decommissioning Handbook.
- 7. I have more than 40
-years of professional nuclear experience including and not limited to: Cooling Tower Operation, Cooling Tower Plumes, Consumptive Water Loss, Nuclear Plant Operation, Nuclear Management, Nuclear Safety Assessments, Reliability Engineering, In
-service Inspection, Criticality Analysis, Licensing, Engineering Management, Thermohydraulics, Radioactive Waste Processes, Decommissioning, Waste Disposal, Structural Engineering Assessments, Nuclear Fuel Rack Design and Manufacturing, Nuclear Equipment Design and Manufacturing, Prudency Defense, Employee Awareness Programs, Public Relations, Contract Administration, Technical Patents, Archival Storage and Document Control, Source Term Reconstruction, Dose Assessment, Whistleblower Protection, and NRC Regulations and Enforcement.
- 8. I am employed as the chief engineer for Fairewinds Associates, Inc, an expert witness and paralegal services firm specializing in nuclear engineering, nuclear operations, and nuclear safety analysis and assessment.
Page 3 of 12 9. My declaration is intended to examine the Aging Management Program at the Tennessee Valley Authority Sequoya Nuclear Power Plant as it relates to its ice containment system.
Background
- 10. The last line of defense to prevent the release of radiation from a design basis nuclear loss
-of-coolant-accident (LOCA) is the nuclear containment that surrounds the nuclear reactor and the nuclear fuel. The nuclear containment is normally a passive structure, simply designed to absorb the energy of hot steam if a pipe inside containment were to rupture.
- 11. The containment at the Sequoya Nuclear Power Plant in Tennessee has a unique containment design called an Ice Condenser (IC). Of the 103 currently operating nuclear reactors in the United States , only 9% of the operating reactors , including the two at Sequoya
, have been built with this unique design.
- 12. The Ice Condenser (IC) design is considered unique for two reasons:
12.1. Most nuclear reactor Containments are passive with no moving parts. The IC C ontainment has internal active components including doors and hinges that must operate correctly during an accident in order to channel the hot steam through large baskets containing ice that in theory cool the steam and prevent Containment failure.
12.2. The IC Containment design is very small in comparison to other Containments housing similar sized reactors. Rather than rely upon a large volume of space within the Containment to reduce steam pressure in the event of a design basis accident, the IC Containment design relies upon ice to melt the steam.
Page 4 of 12 13. In Information Notice 2004
-09, Corrosion of Steel Containment and Containment Liner , the NRC has identified that all types of reactor containments have a history of significant containment integrity problems
.1 14. Fairewinds Associates, Inc has briefed the NRCs Advisory Committee on Reactor Safeguards (ACRS) and written extensively on the history of containment failures in United States reactors in Nuclear Containment Failures 2 and Post Accident AP1000 Containment Leakage
- 3. 15. The IC Containment design has numerous critical design defects of which the NRC is already aware, including and not limited to
- 15.1. First, that ice condenser plants are substantially more sensitive to early containment failure than those at PWRs with large dry or sub-atmospheric containments.
Assessment of the DCH Issue for Plants with Ice Condenser Containments
- Consistent with perceptions of the technical community, this study shows that ice condenser plants are substantially more sensitive to early containment failure than PWRs with large dry or subatmospheric containments. A plant-specific evaluation of the containment event tree showed that all plants, except McGuire, have an early failure probability within the range 0.35% to 5.8% for full power internal events.4 [Emphasis Added]
15.2. Second, because actual operational experience has shown that some of the original design assumptions are faulty, the ice condenser is subjected to significant maintenance and operational challenges.
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$1 Corrosion of Steel Containment and Containment Liner, April 2004 http://www.nrc.gov/reading
-rm/doc-collections/gen
-comm/info-notices/2004/in200409.pdf 2 Nuclear Containment Failures, December 2, 2010 http://fairewinds.org/sites/fairewinds.org/files/reports/Fairewinds%20AP1000%20Supplemental%20Report%2012-21-2010_0.pdf 3 Post Accident AP1000 Containment Leakage, April 21, 2010 http://fairewinds.org/sites/fairewinds.org/files/reports/AP1000_Containment_Leakage_Report_Gundersen__Hausler__4 2010.pdf.pdf 4 Assessment of the DCH Issue for Plants with Ice Condenser Containments, September 1999, Page iii http://pbadupws.nrc.gov/docs/ML0037/ML003712849.pdf
Page 5 of 12 Topical Report ICUG
-001, Rev.
2.0-2: The design of the ice condenser system constantly challenges industry initiative, given that operational experience has rewritten some of the original assumptions regarding ice bed behavior. While the ice condenser itself appears passive, sublimation, frost build
-up, and a saturated environment all take their toll over the course of an operational cycle. Ice bed maintenance processes contribute further; the use of vibrators and thermal drills to replenish sublimated ice baskets creates an outfall of ice/water, which, while expected, tends to make other maintenance
-related activities more time-consuming.
5 15.3. Third, the design is not single
-failure proof. For a design basis LOCA accident, industry data appears to show that there would be insufficient ti me available for the operators to respond to a loss of containment spray before the ice melted and could no longer cool the reactor.
Response to Request for Additional Information, NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors
- The Westinghouse ice condenser containment plants are especially sensitive to the single failure of the operating spray pump once ice condenser heat removal capability is exhausted. The sensitivity is driven by containment size, lower containment design pressure, and available containment heat removal systems.
For a large
-break LOCA, preliminary evaluations indicate that insufficient time would be available for the operator to respond to the loss of the operating containment spray following the exhaustion of heat removal capability by the ice condenser system.6 15.4. Fourth, industry evaluat ed data shows that a core damage event would most likely result in a hydrogen explosion, like one that occurred at Fukushima Daiichi, and render the Containment unable to perform its function of containing radiation in the event of an accident.
(Discussed) Hydrogen Igniter Backup Power Generic Safety Issue
-189 (Inspection Procedure 35007)
- An evaluation was performed for the
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$5 Application of the Active Ice Mass Management Concept to the Ice Condenser Ice Mass Technical Specification:
Topical Report ICUG
-001, Rev. 2.0
-2, May 2003, ML032340563, page O-2. 6 Response to Request for Additional Information, NRC Bulletin 2003
-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors, June 2005, Page 1 http://pbadupws.nrc.gov/docs/ML0516/ML051660328.pdf
Page 6 of 12 potential of early failure of containment during very low probability events involving damage to the reactor core as discussed in NUREG/CR-6427, Assessment of the Direct Containment Heat Issue for Plants with Ice Condenser Containments. The results of the evaluation revealed an early containment failure probability of ice condenser containments, dominated by hydrogen combustion following core damage events.
7 15.5. Fifth, in addition to the aforementioned design and operational defects , the IC Containment design has a long history of repeated containment inspection failures associated with its unique design.
These inspection failures include, and are not limited to the following Nuclear Power Plants (NPP)
- 15.5.1. The McGuire NPP in Huntersville, North Carolina The Nuclear Regulatory Commission staff will hold a pre
-decisional enforcement conference with Duke Power Company on Wednesday, October 1, to discuss apparent violations of NRC regulations involving ice condenser doors at the McGuire nuclear power plant near Huntersville, North Carolina. The apparent violations involve the companys failure to ensure that ice condenser inlet doors on Unit 2 would be able to open if needed and a failure to perform adequate corrective actions based on industry experience and operational events at McGuire.
8 15.5.2. The DC Cook NPP in Bridgeman, Michigan In February and March of 1998, at the D. C. Cook Nuclear Power Plant, the licensee identified corrosion (pitting) of the containment liner at the moisture barrier seal areas of both units. At Unit 1, the licensee identified more than 60 areas in which the thickness (1 cm [3/8 inch] nominally) of the steel liner plate had been reduced below the minimum design thickness value of (0.6 cm [0.25 inch]).
9 15.5.3. The Catawba NPP in York, South Carolina NRC officials said the apparent violations include the potential inoperability of the Unit 2 ice condenser doors due to ice buildup, the failure to promptly identify and correct ice condenser blockage and damaged ice containers in both units, the failure to perform adequate $$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$$
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$7 (Discussed) Hydrogen Igniter Backup Power Generic Safety Issue
-189 (Inspection Procedure 35007) December 2012, Page 13 http://pbadupws.nrc.gov/docs/ML1235/ML12356A073.pdf 8 NRC Staff to hold conference with Duke Power Company to discuss apparent violations at McGuire Nuclear Plant, September 1997, page 1.
http://pbadupws.nrc.gov/docs/ML0037/ML003706619.pdf 9 May 1998, DC Cook, Corrosion of Steel Containment and Containment Liner, April 2004, page 3.
http://www.nrc.gov/readin g-rm/doc-collections/gen
-comm/info-notices/2004/in200409.pdf
Page 7 of 12 inspections for foreign debris in the ice condensers, and the failure to properly install ice condenser components as designed.
10 Containment Contention #1
- Aging Management Plans Lacking
- 16. The data reviewed by Fairewinds Associates shows that t he NRC is clearly aware of the existing design flaws and inspection failures at IC Containment NPPs throughout the United States
- 17. For more than 15
-years, the industry has known that Aging Management Programs on IC Containments are inadequate according to the Sandia National Laboratories Report entitled Analyses Of Containment Structures With Corrosion Damage
- 11. In the subsection entitled, Analyses Of A Typical PWR Ice Condenser Containment, the report states that:
É In actual containments, the region around the ice basket has a high potential for corrosion, but the status is unknown because the 12area is inaccessible for inspections.
É The containment was modeled to determine failure level and location under several different degraded conditions.
É Corrosion near the top of the ice basket, with a 10% through the thickness corroded area of 1.09 m high by 0.91 m circumferentially. In operational containments, this area is susceptible to corrosion, but is inaccessible and does not get inspected. Analyses show this is the area of highest strains on an uncorroded containment, and the expected failure location.
ÉCONCLUSIONS É However, if a narrow band of corrosion occurred in the vertical direction on a cylindrical containment, the reduction in capacity would be more severe. This is because internal pressure causes a larger membrane force in the hoop direction than in the vertical direction. In the corrosion that was modeled around the ice basket
, failure occurred through large plastic strains that grew circumferentially. The geometry of the structure caused large membrane hoop strains in the thinned area, and the structure expanded in the radial direction. Therefore, any
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$10 NRC staff sets enforcement conference with Duke Energy to discuss apparent violations at Catawba Nuclear Station , July 1999, page 1. http://pbadupws.nrc.gov/docs/ML0036/ML003696909.pdf 11 Analyses Of Containment Structures With Corrosion Damage, Jeffery L. Cherry, Sandia National Laboratories, SAND96
-0004C http://www.osti.gov/energycitations/servlets/purl/441095
-JUcbqP/webviewable/441095.pdf
Page 8 of 12 amount of corrosion near the ice basket high strain region degraded the load-carrying capacity.
- 18. Given the critical safety importance of single-failure proof operation of the Sequoya IC Containment coupled with the long history of IC Containment design flaws and failures, the Sequoya A ging Management P lan (AMP) should have specific action plans in place to address these aforementioned Containment design and operational flaws. 19. Fairewinds thorough review of the proposed License Renewal Application for the Sequoya reactors was unable to find any Sequoya
-specific Aging Management Plans (AMPs) addressing I C Containment aging phenomena know n to have already occurred and postulated to occur in the future.
- 20. Due to the lack of a Sequoya
-specific AMP focused on the design and operational flaws already known and proven to exist in Ice Condenser Containments, the NRC should reject TVAs requested license extension for the two Sequoya reactors until adequate AMPs that address significant component aging management points in question have been addressed, reviewed, and put in place
. 21. Without an application addressing the known AMP points in question and design and operational flaws, the TVA application for a license extension is incomplete and wholly inadequate. Containment Contention #2
- Severe Accident Mitigation Analysis Lacking
- 22. Actual events at the Fukushima Daiichi NPPs in Japan have proven that Nuclear Power Containment s can fail during a LOCA and leak significant radiation into the environment
. Three of the Containments at the Fukushima Daiichi site failed causing extensive amounts of radiation to leak into the surrounding environment.
- 23. Less than two weeks before the Fukushima Daiichi accident, the NRC staff informed the Advisory Committee on Reactor Safeguards (ACRS) that during a design basis Page 9 of 12 accident the NRC Édoes assume that the containment is leaktight.
13 Now that it has been proven wrong, the Nuclear Regulatory Commission (NRC) staff has not remedied its error and corrected its myth and mistaken assumption that a nuclear containment building will not leak.
- 24. The NRC staff decision to promulgate such a technical misconception in order to facilitate relicensing and operation of flawed Containments by the nuclear industry reminds one of an ostrich sticking its head in the sand so that it will not see any sign of danger. 25. Not only does TVAs Sequoya L icense Renewal Application claim that its Containment is designed to withstand a design basis accident (DBA) at either Sequoya NPP without leaking , the application also states that its Containment is specifically able to withstand severe accident forces beyond it s original DBA. 26. Accidents that exceed the DBA , like the one that occurred in three reactors at Fukushima Daiichi site, are termed s evere accidents by the NRC and the nuclear industry. TVAs application for license extension at the two Sequoya NPPs clai ms that for even severe accidents
, like the ones that occurred at Fukushima Daiichi, the Sequoya Containment would retain all its radioactive fission products. Specifically, the TVA license extension application , Sequoyah Nuclear Plant Applicants Environmental Report Operating License Renewal Stage states: The reactor containment is designed to adequately retain these fission products under the most severe accident conditions.
14 [Emphasis added
] 27. TVA has therefore claimed in its Sequoya NPP License Rene wal Application that the IC Containment has the ability to withstand not simply design
-basis events, but also severe accidents. Fairewinds has been unable to locate any analysis within the License Extension application to support this claim.
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$13 ACRS Transcript, February 2011 , Page 69, http://pbadupws.nrc.gov/docs/ML1104/ML110480828.pdf 14 Sequoyah Nuclear Plant Applicants Environmental Report Operating License Renewal Stage
, TVA 2011p, Section 1.2.2.2, page 3-2. http://pbadupws.nrc.gov/docs/ML1302/ML13024A007.pdf
Page 10 of 12 28. Therefore, the NRC must reject TVAs Application for a License Renewal at the Sequoya NPP due to the lack of supporting documentation providing an analysis detailing TVAs assumptions proving that the Sequoya IC Containment can withstand severe accidents without leaking. 29. Furthermore , a Severe Accident Mitigation Analysis (SAMA) must include details with the exact sequences of events showing TVAs proof that the Sequoya Ice Condenser Containment will in fact withstand a severe accident without leaking any radiation. Containment Contention 3
- Accuracy of Information Is Compromised
- 30. The I ce Condenser Containment design has been shown to be less robust than other containments in the United States, and given that the Sequoya design is less robust than other Containment designs, it is imperative that the personnel who work on the flawed IC Containment design do so in a manner guaranteeing that they are free from harassment.
- 31. It is disturbing and a detriment to the safe operation of the Sequoya NPP, that the Tennessee Valley Authority has along history of discrimination and retaliation against nuclear whistleblowers that have worked on design and operation of the Sequoya Ice Condenser Containment. 32. These whistleblower concerns have spanned more than 10-years, and are continuing to occur as recent ly as May 2013, the date of this expert report. The following two examples are illustrative of the ongoing safety concern retaliation: Two critical issues that should be taken into account by the NRC in deciding whether to take escalated enforcement action against TVA (1) the continuing harassment of Mr. Overall for reporting of problems with the ice condenser system internally within TVA and externally, including actions so severe that they drove him off the job site; and
Page 11 of 12 (2) TVA's practices regarding managers who were found to have discriminated and retaliated against nuclear whistleblowers by the Department of Labor in the past.
15 33. TVA Sequoyah, Watts Bar nuclear plants among top 5 in internal complaints, say regulators Associated Press: May 3, 2013 CHATTANOOGA, Tenn.
Ñ The Nuclear Regulatory Commission tracking of whistleblower complaints at nuclear plants lists both of TVAs plants in Tennessee among the top five. The Chattanooga Times Free Press (http://bit.ly/120KQv8) reported the Tennessee Valley Authoritys Browns Ferry Nuclear Plant in northern Alabama also had several internal complaints. The NRC report showed there were 21 complaints against Watts Bar, 19 on Sequoyah and 16 at Browns Ferry in 2012.
16 34. In my opinion, the NRC should reject the Sequoya License Renewal Application until such time as the accuracy of the data therein can be independently assessed especially in light of the whistleblower complaints that date back more than a decade and have specifically targeted personnel responsible for the Sequoya IC Containment design. 35. Furthermore, it is even more alarming that TVAs Sequoya Units should have a decade long history of whistleblower complaints and safety concerns, and it is abysmal that three TVA nuclear reactor sites totaling seven separate nuclear power reactors top the US list for the most whistleblower complaints. 36. Given the thousands of TVA employees coupled with the extraordinarily large number of TVA personnel who have been harassed and intimidated for bringing forward legitimate safety and public health concerns, the veracity of TVAs License Renewal Application process is in doubt
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$15 Apparent violations of employee discrimination requirements (U.S. Department of Labor Case No. 1997
-ERA-0053), July 2001, page 1.
http://pbadupws.nrc.gov/docs/ML0123/ML012320261.pdf 16 TVA Sequoyah, Watts Bar nuclear plants among top 5 in internal complaints, say regulators Associated Press: May 3, 2013, http://www.washingtonpost.com/local/tva
-sequoyah-watts-bar-nuclear-plants-among-top-5-in-internal-complaints
-say-regulators/2013/05/03/3fc6ad36
-b405-11e2-9fb1-62de9581c946_story.html
Page 12 of 12 Conclusion
- 37. First, the TVA License Extension Application for the Sequoya Reactors Ice Condenser Containments lacks acceptable Aging Management Plans to adequately maintain critical components of the Ice Condenser Containment for the next 20
-years. 38. Second, TVAs long standing breakdown in dealing with the mismanagement of its whistleblower complaints is a reflection of the corporations lack of integrity and insufficient adherence to regulatory statutes that demand nuclear power owners put safety first. Given these ongoing systemic problems the accuracy and validity of the Licensees Application cannot be assured and therefore should be rejected.
- 39. Finally , TVA claims that the Sequoya Ice Condenser Containments can withstand severe accidents without leaking radiation into the environment. Therefore, the NRC must reject TVAs Application for a License Extension at the Sequoya NPP due to the lack of supporting documentation providing the analysis detailing TVAs assumptions that prove that indeed the Sequoya IC Containment can withstand severe accidents without leaking.
In conclusion, a Severe Accident Mitigation Analysis (SAMA) must include details with the exact sequences of events showing TVAs proof that the Sequoya Ice Condenser Containment will in fact withstand a severe accident without leaking any radiation.
End Attachments:
Attachment 1 Curriculum Vitae I declare under penalty of perjury that the foregoing is true and correct.
Executed this 6 th day, May 2013 at Burlington, Vermont.
__________/s/_____________________
Arnold Gundersen, MSNE, RSO Chief Engineer, Fairewinds Associates, Inc