ML20033D372
| ML20033D372 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 11/18/1981 |
| From: | Malsch M NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML18058B973 | List: |
| References | |
| FOIA-92-436, TASK-AIA, TASK-SE 2.206, SECY-81-658, NUDOCS 8201110348 | |
| Download: ML20033D372 (8) | |
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7 November 18, 1981 i
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.SECY-81-658 r,
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ADJUDICATORY ISSUE (Affirmation) r For:
The Commissioners From:
Martin G. Malsch Deputy General Counsel 3
Subject:
REVIEW OF DIRECTOR'S DECISION ON 2.206 PETITION (FLORIDA POWER AND LIGHT s a
COMPANY)
Facility:
Turkey Point Plant, Unit 4
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Purpose:
Review Time Expires:
November 30, 1981-.
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Discussion:
By letter to the, Commission dated,
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September 11, 1981, the' Center for Nuclear Responsibility (CNR) requested.
that the following actions be taken with respect to Turkey Point Unit #4:
(1) that the plant be shut down immediately for a steam generator inspection; (2).
that the NRC conduct a license review in I
light of concerns about steam generator tube integrity and pressure vessel
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integrity; and (3) that the unit's license be suspended until Florida Power
& Light demonstrates that the steel
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shattered by thermal shock in1theHevent-l of high' pressure injection emergencyr
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cooling.
This' letter.was referred to the Director, NRR, as a.2.206fpetition.;
On November 5,- 1981 the. Director denied 7
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the petition.
DD 81-21.
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denial, however,.it immediately notified the Commission,._both by letter and by-phone, that-it had never intended-for.
its letter to be treatedLas-a 2.206 petition, that its letter-had'been sent solely from a sense:of' concern about' conditions at: Turkey Point.-- CNR; maintains that if'it had desired to file-a.2.206 petitionigit would have acquired.
7; counsel and. proceeded more formally, i
denominating its petition as such and
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.i setting forth:a'much moraidetailed-~
factual analysis.- CNR is'very' concerned that the' formal treatment its letter has recei'ved will' prejudice'it-if'it'later~
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decides'itLis necessary.to file an
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' actual 2.206; petition.
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3 ec',L Recommendations:
Martin G. Malsch Deputy General Counsel Attachments:
- 1. CNR letter
- 2. Director's decision
- 3. Subsequent CNR letter
- 4. Proposed Order Comissioners' coments or consent should be provided directly to the Office of the Secretary by c.o.b. Monday, november 30, 1981.
Comission Staff Office coments, if any, should be submitted to the Comissioners NLT November 23, 1981, with an information copy to the If the paper is of such a nature that it Office of the Secretary.
requires additional time for analytical review and comment, the Comissioners and the Secretariat should be apprise.d of when coments may be expected.
This paper is tentatively scheduled for affirmation at an open meeting during the week of December 7, 1981. Please refer to the appropriate weekly Commission schedule, when published, for a specific date and time.
DISTRIBUTION Comiss1oners Comission Staff Offices Secretariat
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\\J CENTER FOR NUCLEAR RESPONSIBILITY U.S. Nuclear Regulatory Cornission 1717 H Street, N.W. lith Floor Washington, J.C. 20555 4-lbnzio' J. Palladino, Chairman Victor Gilinsky, Comissioner Peter A. Bradford, Comissioner John F, Ahearne, Comisssioner i
September 11,1981 Gentlemn:
I write to you out of concern about Turkey Point nuclear unit #4, aM what appears to be the HEC's lack of concern as to the increasingly severe safety problems plaguing this unit. Areas of imediate' concern to myself and other Miami residents living near this reactor unit are:
- 1. Turkey Point Unit f4 is one of eight nuclear reactor units that the NEC has namd whose steel pressure vessel may be vulnerable to cracking or shattering caused by themal shock in the event of an accicent that requires high pressure injection energency cooling.
- 2. Turkey Point Unit.f4 is operating in an irpaired condition with nearly 25%
of its steam generator tubes plugged and remved from service.,This t.
reduction in heat transfer area could cause this unit to be more susceptible to overheating, necessitating emergency cooling.
- 3. Turkey Point init #4 is required to be shut down every six months for steam generator inspection and tube plugging in orcer to maintain safe operation of the unit. The last inspection was scheduled for July of 1981 but the NRC granted FPSL an extensian an its operating ' license allowing Unit #4 to run for two additional months. This is despite the fact that the NRC has stated in various documents t?at "we do not have an adegaate technical basis to preaict steam generator perfomance for periods longer than six rentns."
- 4. Turkey Point Unit f 4 is operating presently with steam generator tubes that may be aa the verge of leaking. The Union of Concemed Scientists' in a 1975 study on ?bclear Power Pdsks claims that if only a handfal of tubes nptured in an accident, tne emergency core cooling system would be stalled and the core could melt. Should such an accident occur aM the reactor vessel did not maintain its integrity,there would be no way
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to protect the public healta and safety of the residents of Miami.
S. Both steam generator tube integrity and p:ewure vessel uitegrity are unresolvec safety issues before the NRC.
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4 In light of these safety problems at hrkey Point Unit #4, we ask-I that the Nuclear Regulatory Comission take steps to imediately intitiate a license review of this nuclear reactor unit.
It is the responsibility of the Nuclear Regulatory Comission to protect the public health and safety, and this can only be accomplis ad if adequate safety systems exist to protect the public in case of an accident.
Turkey Point Unit #4 will continue to deteriorate, and is quickly approaching the magic number of 25% of its tubes plugged. We hope at this
- i point the NRC will derate the unit,so that it doesn't operate in an unsafe manner.
In closing, we ask that the NRC request tnat Erkey Point Unit #4 shut down imediately for its already delayed steam generator inspection.
We also ask that the NRC consider the suspenslan of the license for Wrkey Point Unit #4 until such tire as FPGL sub' nits proof ' that this reactor unit's pressure vessel would maintain its integrity in a loss of cooling accident.
As the consequences of a core melt would.be totally unacceptable to the residents of Miami, we respectfully ask that prompt action be taken on these crucial matters.
Respectfully yours, h
(EDR Joette lorion Center for fuelear Responsibility cc Marshall Grautenhuis, NRC Atomic Safety and 1.icensing Board Joe Gilliland, NRC Atlanta Attorney riartinJbdder Robert Pollard, UCS Dr. Gordon Edwards, CO R G
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION HAROLD R. DENTON, DIRECTOR In the Matter of FLORIDA POWER AND LIGHT COMPANY Docket No. 50-251 (Turkey Point Plant, Unit 4)
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DIRECTOR'S DECISION UNDER 10 C.F.R. 2.206 I
By a letter dated September 11, 1981, signed by Joette Lorion, the Center for Nuclear Responsibility (Center), which is located in South Miami, Florida, petitioned the Nuclear Regulatory Comission to take the following actions in relation to Turkey Point Plant, Unit 4 (Unit 4):
1)
Immediately order a shutdown to inspect the steam generator tubes; and 2)
Consider the suspension of the plant's operating license be-
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cause of concerns over the safety of the reactor pressure i
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The petition was referred by the Comission to the Director, Office of
. Nuclear Reactor Regulation, for action in accordance with 10 C.F.R. 2.206 of the Comission's regulations.
I.
Recuested Shutdown for Steam Generator Inspection In summary, the background of the steam generator problem is as follows:
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'In the mid-1970's, a number of nuclearL power plants,.
j including Turkey Point Plant Unit Nos. 3 and 4 began to have problems with leaking steam generator tubes'
.j due to a corrosive process called " denting."
On October 29, 1976, the' NRC staff set-forth minimum j
7 requirements to ensure that Units 3 and.4 would not. -
as a result of this-denting phenomenon, operate with q
reduced integrity of the primary system pressure boundary. Since that time the plants have operated under strict requirements imposed by the NRC staff. If-Under the terms of these requirements, Florida Power and Light-Company (FPL) has received permission for short-tenn extensions of operation i
for Unit Nos. 3 and 4 in the fonn of license amendments.
Following shut -
down, inspection and plugging of tubes; that were judged by the licensee to be in danger of leaking in the ensuing 10 months, and NRC staff analysis of the inspection and plugging, license amendments were granted to allow six months of full power equivalent operation.
Subject to operating experience which indicated that further operation j
before shutdown and inspection. would.not.enda.nger public health and j
a safety, additional extensions have. also been granted..for: totals of up
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to 10 months of full power equivalent operation between inspections.
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.f FPL reported on the last-previous inspection of Unit 4,-
which they performed in November,1980, in a letter to the Counission dated December 18, 1980. The letter also contained a
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request for continued operation of Unit 4. After reviewing'the.in.
spection results, NRC. issued Amendment 54 to License No. DPR-41
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-on January 15,1981. Amendment 54 allowed continued operation for six equivalent full:
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i jf Florida Power and Light Company (Turkey Point Plant, Unit 3), DD-80-28 j
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power months, commencing January 13, 1981.
Operation beyond the six-month period without further inspection was also anticipated and permitted in Amendment 54, but subject to the requirement that "an acceptable analysis of the susceptibility for stress corrosion cracking of tubing is submitted to explicitly justify continued operation of Unit No. 4 beyond the authorized period of operation.",2f In response to a FPL request dated May 27, 1981 for a four-month extension of operating permission, the NRC staff again reviewed the status of the steam generators in Unit 4. Based upon this re-review, an -
extension for two equivalent full power months was granted in Amendment 62, dated July 6,1981.
On July 30, 1981, FPL requested an additional two months operation for Unit 4.
Again the NRC staff reviewed the status of the steam generators and based upon this re-review, an additional extension of two-equivalent full power months was granted in Amendment 66, dated September lu,1981.
Anendment 66 allowed operation for -ten equivalent full power nonths from January 13, 1981.
An important factor underlying the decision to grant the extensions authorized by Amendment 62 and 66 has been the continued essentially leak-free operation of the steam generators throughout the period in question.
Host recently, on October 19,1981 FPL has shut down Unit 4 and commenced an inspection of the steam generators. Thus, the request in the 2/
Facility Operating License No. DPR-41, as amended by Amendment 54, piragraph D(1).
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l petitio'n for a snutdow: to inspect the steam generators is now moot.
i II.
Petitioner's Allegations concerning Steam Generator Safety _
The Center in its petition makes a number of allegations concerning the safety of the steam generators in Unit No. 4.
The first is that Unit 4 is operating with "nearly 25 percent of its steam generator tubes plugged and removed from service. This t
reduction in heat transfer area could cause this unit to be more susceptible to overheating, necessitating emergency cooling." The Center also states that the steam generator tubes will continue to deteriorate.
FPL sought by application dated ~ April 29, 1980, to operate Unit 4 with 25 percent of steam generator tubes plugged. The staff concluded that operation of Turkey Point Unit No. 4 with up to 25 percent of the tubes plugged is acceptable 3/ and issued Amendment 50 to the license, dated May 15, 1980, which permitted operation with 25 percent of the tubes plugged. A total of 23.8 percent of the tubes were plugged prior to Amendment 54 and the recently concluded period
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of operation. f/
Subsequent safety analysis by the staff of FPL's application for A endment dated March 5,1981, showed that operation with 28 percent of the tubes plugged is acceptable.
Operation with this level of tube plugging was pemitted in Amendment 60, dated June 23, 1981, t
3/ Safety Evaluation by the Office of Nuclear Reactor Regulation Related to knendments 57 and 50 to Facility Operating Licenses
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(May 15,1980).
4/ Safsty Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 54 to Facility Operating License No.
DPR-41, page 4 (January 15,1981).
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, The safety analysis supporting Amendment 60 does not imply that plugging of more than 28 percent of the tubes would be unsafe; the analysis was performed at the 28 percent level because it is expected that the 28 percent limit will be fully sufficient to allow plugging of all tubes which the current inspection of Unit 4 will show might be susceptible to leaking in the foreseeable future. 5/ The plugging is, and has been, cafried out by the licensee as a prophylactic program, and it has been successful in preventin'g leakage since mid-1978. y The Center in its letter quotes the NRC to the effect that, "We do not have an adequate technical basis to predict steam generator performance for periods longer than six months." While the author of the letter does not identify the source of the quotation, a virtually b
identical statement was made in N.R.C., Safety Evaluation by the Office of Nuclear Reactor Reculation Related to Amendment No. 52 to Facility Operatino License No. DPR-31. JJ The latter statement, however, continues,
... and that our consideration of extended operation beyond six (6) months would depend upon the operating experience at this and similarly y
Safety Evaluation by the Office of Nuclear Reactor Regulation Relating to Amendment No. 68 to Facility Operating License No. DPR-31 and Amend-ment No. 60 to Facility Operating License No. DPR-41 (June 23,1981).
It is expected that approximately 2 percent additional plugging will be required in Unit 4 beyond the current 23.8 percent.
6/
Safety Evaluation by the Office of Nuclear Reactor Regulation Relating to Amendment No. 66 to Facility Operating License No. DPR-41 (September 10,1981).
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,7f Unit 3 has the same design steam generator as Unit 4 with substantially similar degradation experience.
This last quotation refhects the consistent policy of the degraded units."
Commission in relation to Turkey Point Units Nos. 3 and 4.
Thus statements concerning six-month maximum prediction period, such as the one quoted by the j
Center, must be taken in context.
In context, it is clear the six-month initial period of operation after an inspection of steam generators may be followed by extensions, provided the technical basis supplied by the licensee, i
and the relevant operating experience, justify the extensions. This course of action has been followed in relation to Turkey Po'nt Units No. 3 and 4 since 1977 8/ and satisfactorily protects the public health and safety.
The Center further asserts that the " steam generator tubes Cof Unit 43 may be on the verge of leaking"; and that, according to a 1975 study by the Union of Concerned Scientists (study not further identified in the Center's letter), rupture of "a handful of tubes" would result in a core melt, with very serious public safety results.
The Staff, based on its studies, does not anticipate that a " handful of tubes" will rupturN (" handful" is un'd'efined in the ' petition), or that such~ an
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event, if it should occur, would cause a core melt. Neither does the petitioner advance any factual basis for anticipating such events.
Isolated breaks of single tubes which could be described by the word " rupture" have occurred in steam generators similar to those of Unit 4.
In these instances, however, the reactors have been shut down in an orderly fashion.
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Florida Power and Light Company (Turkey Point Plant. Unit 3) DD-80-28, 12 NRi386 (1980).
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As indicated above, the steam generator tubes of Unit 4 are being regularly.
monitored. Moreover, the license for Unit 4 requires a cold shutdown if leakage i
exceeds the prescribed limit of 0.3 gpm per steam generator. 9/ Staff is of the view that the 0.3 gpm leakage limit, and actions required should this rate be exceeded (along with the monitoring previously described), are fully adequate to protect the health,And safety of the pubife.10/
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Finally, the Center asserts in its letter that steam generator tube integrity is an unresolved safety issue.
While it is true that the problem of steam generator tube integrity is not fully resolved, the problem has re-ceived careful ongoing review and analysis, as described above. Accordingly, and in view of the history of the steam generators of Unit 4, further action by NRC regarding Unit 4's steam generators is unnecessary at this time. The procedures and safeguards instituted in relation to that problem are sufficient to safeguard the public health and safety.11/
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Facility Operating License No. DPR-41, as amended, paragraph D(2).
i 10L/ Safety Evaluations, footnotes 3 and 5, supra.
l 11/ NRC Regulatory Guide 1.83 contains the standard procedures for inspecting steam generators, which standards are considered adequate
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r by NRC for protecting the public health and safety. The procedures i
which have been developed for Turkey point and inserted in Unit 4's operating license as mandatory requirements are significantly more rigorous than the procedures in Regulatory Guide 1.83, and therefore provide an additional margin of safety.
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III. Recuested Action With Reference to Reactor Pressure Yessel The Center asserts that Turkey Point Unit No. 4 is one of a number of nuclear power plants Nhose steel pressure vessel nay be vulnerable to cracking or shattering caused by themal shock in the event of an accident that requires high pressure injection emergency cooling." The petition further cites pressure vessel safety as an unresolved safety issue.
During the past few conths the subject of reactor pressure vessel thermal shock has received increased attention by the NRC staff and industry representatives. The NRC staff has recently evaluated (1) the types of transients or accidents that could lead to overcooling of the reactor system; (2) experience to date with transients that have occurred in U.S. pressurized water reactors; (3) the probability that i
such overcooling events will occur; and (4) the capability of reactor
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vessels to withstand these transients.
As a result of its evaluations to date, the staff has concluded that the probability of a severe overcooling transient is relatively low.
For Babcock & Wilcox designed reactors this probability is estimated to be about 10-3 per reactor per year, e.nd for Westinghouse and Combustion
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Engineering designed reactors, it is lwer, perhaps by an order of magnitude. The staff has also concluded that, based on present irradia-tion lev {1s at operating reactors, reactor vessel failure from such an
i event in the near term is unlikely. Therefore, no immediate licensing action i
is required for operating reactors including Unit 4.12/
However, the staff believes that additional action should be taken to resolve the long-term problem. Toward this end, the staff, tne Pressurized Water Reactor (PWR) owners' group, and PWR vendors are working together to determine the scope of the generic pressure vessel problem.
In addition, plants with the nast limiting condition (in tenns of assured period of continued safe operation) in each vendor's group have been selected for individual study.
Unit 4 having been selected as one of the plants for plant-specific study, a letter dated August 21, 1981, was sent to require the licensee in accordance with 10 C.F.R. 50.54(f) of the Commission's regulations to submit information for review.
Based upon the generic and plant-specific t
studies and reviews, NRC will take titely action in relation to the reactor vessel problem.
IV. Recuest for " License Review" The letter from the Center also asked:
that the Nuclear Regulatory Commission take steps to immediately initiate a license review of this nuclear reactor unit Cunit 4?.
It is the responsibility.of s
the Nuclear Regulatory Commission to protect the public health and safety, and this can only be accorr plished if adequate safety systems exist to protect the public in case of an accident.... We hope at l
this point the NRC will derate the unit, so that it doesn't operate in an unsafe manner.
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Requests for a " license review" and to "derate the unit" appear to be synonbnomous with the request that.the NRC consider the suspen-sion of the*.1teense of Unit 4 Other than the assertions which have y Preliminary Assessment of Thennal Shock to pWR Reactor Pressure Vessels, SECY 81-Z85 (May 4,1951).
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l been discussed above concerning the steam generators and reactor vessel, the -
t petitioner advances no facts that relate to possible safety inadequacies.
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Conclusion i
Based on the foregoing discussion, I have detemined that the petitioner's request for an order to shut down the Turkey Point Plant Unit 4 to inspect steam generator tubes should be and is hereby denied.
Further, based upon the staff analyses of the Reactor Vessel question, I have also concluded that the petitioner's request for consideration of suspension of the license
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of Turkey Point Unit No. 4 should also be denied.
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A copy of this decision will be placed in the Commission's f
Public Document Room at 1717 H Street, N.W., Washington, D.C. 20555 and the local public document room for the Turkey Point Plant located at the Environmental Urban Affairs Library, Florida International
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University, Miami, Florida 33199. A copy of this decision will also j
be filed with the Office of the Secretary of the Commission for its I
review in accordance with 10 C.F.R. 2.206(c) of the Comission's regulations.
r FOR THE NUCLEAR REGULATORY COMMISSION w
Harold R. Denton, Director Office of Nuclear Reactor Regulation l
Dated at Bethesda, Maryland this 5th. day of November, 1981.
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- Certified Mail: Return Receipt Requested Mr, Harold R. Denton Of fice of Nucicar Reacter Regulation (8.S. Nuclear Regulatory Comission
' *a s hin e, con. D.C. 20555
Dear Mr. tenton,
This is in response to your letter to me and Director's recision Undcr 10 CFR 2.206 dated November 5,1981.
Please be advised that my letter of Septe=ber 11,1981, on behalf of the Center for Nuclear Responsibility and concerning steam generator tube integrity and pressure vessel eebrittlement in Turkey Foint Unit #4, was not a formal petition under 10 CFR 2.206 of the Com:nission's Regulations.
The Septe=ber 11th letter v'as merely advisory and intended to bring to your attention potential safety and legal proble=s associated with the continued operation of this severely degraded nuclear unit.
It was never my inte.ntion, nor that of the Center for Nuclear Responsibility, that this letter be treated as a for=al ler.al petition in accordance with 10 CFR 2.206 of the Co=ission's Regulations. -
Should the Center for Nuclear Responsibility decide to initiate a formal petition for consideration of license review or possible shutdown of Turkey Point Nuclear.1?nic #4, our petition will be labled a petition in accordance with the rules of practice under 10 CFR 2.206 of the Co:.J.ssion's Regulations and will have representatien of counsel.
Respectfully yours,
$ 0 Ltit S W O n Joette Lorion Research Director CNR
Enclosure:
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Letter Sept. 11,1981 0 \\ S
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