ML20090J562

Marked-up Petition for Emergency Relief Re Primary Containment Leak Rate.Annual Integrated Leak Rate Testing Followed Unapproved ANS Proposed Std

ML20090J562
Person / Time
Site:	LaSalle, 05000000
Issue date:	11/29/1983
From:	Gogol E AFFILIATION NOT ASSIGNED
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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ML20090J550	List: ML20090J560 ML20090J562
References
FOIA-84-51 NUDOCS 8405220608
Download: ML20090J562 (4)

Text

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E_N F File pfj f PETITION FOR ENERGENCY RELIEF RE: Primary Containment Leak Rate at LaSalle Units 1 and 2 00CKETS NO. 50-373 and 50-374 Hpnorable James Keppler -

Director, Regian 3 U.S. Nuclear 4.egulatory Connission 199 Rooseve'd. Road --

Glen Ellyn IL 60137 ' *

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Dear Mr. Keppler:

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I am writing to notify you of an extremely serious and unsafe condition which. ,'

now exists at LaSalle Unit I 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 mandated 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 whatever that the containment leak rate is within the required limit.

8esides being a clear and present danger, this situation represents a gross violation of the requirements of the Atomic Energy Act and 10 CFR Part 50.

Description of the situation:

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1. There are severe errors defects, and loopholes 1n "American National Standard N45.4-1972 Leakage Rate Testing of Containment Structures for Nuclear Reactors", which Appendix J.of 10 CFR Part 50 requires that containment leak rate tests be conducted in accordance with. As a result, .

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 'l document " ANSI /ANS-56.8-1981: American National Standard Containment .

. System Testing Requirements", which the American Nuclear Society is -

proposing as a standard to replace the N45.4 standard, and which was  ?

basically followed during the 1982 LaSalle test.

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- ' November 29, 1983

. Honorable James Keppler Page 2

3. The defects in these documents include:

a. The equation used to calculate the containment air mass at any given

time is wrona. This error is the result of an obvious and glaring mistake made during the derivation of this equation. This error was

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o.3, A j A b b. A lack of any prohibition on a wide variety of ways in which the

! A O'#gg final calculated leak rate may be fudged.

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To sum up, the ILRT methodology now in use offers no guarantee that actual I leak rates are acceptably low. We simply do not know 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 reactor containment leak rates be demonstrated to be within certain values for a reactor to obtain and keep an operating license.

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Idvember 29, 1983 Honorable James Keppler l Page 3 I l

Specific problems with LaSalle Unit 1 ILRT:

In July of this year, I filed with the NRC a Freedom of Infor.mation Act Request (F01A-83-384), asking for copies of any and all documents in the NRC's possession regarding Integrated Leak Rate Testing at the LaSalle 1 and 2 and 0.C. Cook 1 and 2 reactors, including any and all information on flaws or errors in these tests. The NRC responded, after 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 j these materials for review to Dr. Zinovy Reytblatt, a specialist on  ;

containment leak rate testing. l Dr. Reytblatt informs me that these materials, which pertain to .the spring 1982 ILRT conducted at LaSalle 1, are: g4// 4

a. insufficient to justify the reported leak rate;  !

b. insufficient to prove that the kind of unjustifiable fudging of the data A i described above was not done: and.

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c. insufficient to permit a mdaningful review of this test. /4 !4 4 "' " .

' y ;ff do A * " 6 ' --f Necessary dat'a not provided include: gyT4W/ 6 .

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Precise location of temperature and pressure instruments; Compartment subvolume recalculations;

,f-a 7' g gy/s , Individual sensor weighting factors. It appears that the testing W, g /,v organizationsimplyusedpemperatureaveragingoverindividual compartments'] yrs , par s po W., *

d. Individual temperature sensor readings;

/^*y/,gs e. Back-up pressure gauge readings; and g/, f. Containment ventilation and cooling conditions in effect during the Si test.

No complete review can be done without such information.

There is strong evidence,-however, that the real leak rate may be in excess of the reported value simply because the local temperature range within the fu ( containment during the test was at times greater than 40 degrees F. Another p ga dverse factor is a possibility of actual weighting factors being in' excess of

.1, which violates even the faulty standard.

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7 A g 7 cases illegible.::r'In addition, the materials received were fragmentary, disordered, anl i

In conclusion, there appears to be no justifi. cation for the conclusion that l

LaSalle Unit l's containment leak rate is within acceptable limits. It

-appears that the NRC has never received from Commonwealth Edison any materials which can justify any such conclusion.

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. $ ember 29,1983 I

, Honorable James Keppler Page 4 l

t Relief reauested:

I therefore request that you immediately order:

1. that LaSalle Unit 1 be placed in cold shutdown until Commonwealth 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 computer media containing such supporting materials (including material relating to points a-f above) pertaining to LaSalle Units 1 and 2 and Byron Units 1 and 2, including such documents or media which contain the actual raw test data; ,

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

4. that the NRC 1mmediately commence.its own review of these tests; and .f ' ,

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5. that Commonwealth Edison be ordered to conduct no further Integrated Leak 2 -N Rate Testing until all errors and defects in the test methodology.have .

been corrected. -

The public interest, as well as 10 CFR Part 50, demands that this extremely serious situation be corrected. I shall expect to hear from you immediately.

Sincerely, .

,h_ .  ?

Edward M. Gogol cc. Congressman Sidney Yates

References:

1. See pages 33-34 of:

8NWL-1028, UC-80, Reactor Technology: Air leakage Rate Studies on the C.S.E. Containment Vessel, by M.E. Witherspoon and G.J. Rogers, Reactor Engineering Department, Physics and Engineering Division, Battelle Memorial Institute, Pacific Northwest Laboratories.

. September 1969.

2. Report 0183: Critiaue of Containment System Test Requirements By Z. Reytblatt, Extran Inc., P08 2849, Chicago IL 60690 1

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