ML13162A630

from Robert Dennig to Andrea Russellaction for Your Review/Comment

ML13162A630
Person / Time
Site:	FitzPatrick
Issue date:	03/22/2012
From:	Dennig R L Office of Nuclear Reactor Regulation
To:	Brice Bickett, Doerflein L T, Eul R C, Fretz R J, Jennerich M K, Monninger J D, Morgan-Butler K R, Russell A P, Safford C M, Ulses A P, Bhalchandra Vaidya Office of Nuclear Reactor Regulation, NRC Region 1
References
2.206, FOIA/PA-2013-0010, G20120172, TAC ME8199
Download: ML13162A630 (5)

Text

Doerflein, LawrenceFrom:Sent:To:

Subject:

Attachments:Dennig, RobertThursday, March 22, 2012 9:06 AMRussell, Andrea; Bickett, Brice; Doerfleir.Lawrence; Jennerich, Matthew; Ulses, Anthony;MorganButler, Kimyata; Fretz, Robert; (b)(7)(c) Safford, Carrie; Monninger, John;Eul, Ryan; Vaidya, BhalchandraRE: Action: For your Review/Comment: Bruce Boger E-mail for Immediate Action Only:FitzPatrick 2.206: G20120172 (Gunter et. al.) (TAC ME8189)G20120172 FitzPatrick BBemaildrft Immediate Request 3 22 12 RD Comments.docxMy two cents.From: Russell, AndreaSent: Thursday, March 22, 2012 7:09 AMTo: Bickett, Brice; Doerflein, Lawrence; Jennerich, Matthew; Dennig, Robert; Ulses, Anthony; MorganButler, Kimyata;Fretz, Robert;E: (bL(7)(C) ,.afford, Carrie; Monninger, John; Eul, Ryan; Vaidya, Bhalchandra

Subject:

Action: For your Review/Comment: Bruce Boger E-mail for Immediate Action Only: FitzPatrick 2,206:G20120172 (Gunter et. al.) (TAC ME8189)Good moming,Please see the attached draft e-mail for Samson to send to Bruce. Please respond by noon today if you haveany edits.Please let me know if you have any questions.Thanks,Andrea2.206 CoordinatorC/131 (b)(5)PETITION:http.//portal`nrc`gqov/edo/nrr/dp~r/Lists/2206%2/Petition%20Assiqnments/Attachments/35/Fitzpatrick%20G'20120172.pdfSUMMARY OF REQUEST:The joint petitioners request that the FitzPatrick operating license be immediately suspended asthe result of the undue risk to the public health and safety presented by the operator's relianceon non-conservative and wrong assumptions that went into the analysis of the capability ofFitzPatrick's pre-existing ductwork containment vent system. The joint petitioners state that therisks and uncertainty presented by FitzPatrick's assumptions and decisions, in regard to NRCGeneric Letter 89-16, as associated with the day-to-day operations of this nuclear power plantnow constitute an undue risk to public health and safety. The joint petitioners request that thesuspension of the operating license be in effect pending final resolution of a public challenge tothe adequacy of the pre-existing vent line in light of the Fukushima Daiichi nuclear accident.The joint petitioners do not seek or request that FitzPatrick operators now install the DirectTorus Vent System (DTVS) as it is demonstrated to have experienced multiple failures tomitigate the severe nuclear accidents at Fukushima Daiichi.The joint petitioners are requesting that the NRC take action to suspend the FitzPatrickoperating license immediately until the following emergency enforcement actions are enacted,completed, reviewed and approved by the NRC and informed by independent scientific analysis:

1 ) Entergy Nuclear Operations FitzPatrick nuclear power plant shall be subject to publichearings with full hearing rights on the continued operation of the Mark I BWR and theadequacy and capability of a pre-existing containment vent which is not a fully hardenedvent line as recommended by NRC Generic Letter 89-16. As such, the FitzPatrickoperator uniquely did not make containment modifications and did not install the DTVS,otherwise known as "the hardened vent," as requested by NRC Generic Letter 89-16and as installed on every other GE Mark I in the US;2) Entergy Nuclear Operations shall publicly document for independent review its post-Fukushima re-analyses for the reliability and capability of the FitzPatrick pre-existingcontainment vent system as previously identified as "an acceptable deviation" from NRCGeneric Letter 89-16 which recommended the installation of the Direct Torus VentSystem and as outlined in the NRC Safety Evaluation Report dated September 28,1992. The publicly documented post-Fukushima analysis shall include thereassessment of all assumptions regarding the capability and reliability of the pre-existing containment venting and specifically address non-conservative assumptionsregarding:a) the FitzPatrick cost-benefit analysis used to justify not installing a fully hardened ventsystem and;b) "unlikely ignition points" as claimed in the FitzPatrick pre-existing vent line systemthat would otherwise present increased risks and consequences associated with thedetonation of hydrogen gas generated during a severe accident.BASIS FOR THE REQUEST:As a basis for the request, the joint petitioners state that in light of the multiple failures of the GEMark I containment and hardened vent systems at the Fukushima Daiichi nuclear power stationin the days following the March 11, 2011, station black out event, the joint petitions seek theprompt and immediate suspension of the FitzPatrick operations because:* The GE Mark I BWR pressure suppression containment system is identified asinherently unreliable and likely to fail during a severe accident." The capability of FitzPatrick's pre-existing containment vent as approved for severeaccident mitigation is not a fully "hardened vent" system.* The capability of FitzPatrick's pre-existing containment vent as approved relies uponnon-conservative and faulty assumptions." The capability of FitzPatrick's pre-existing containment vent system uniquely allows for asevere nuclear accident to be released at ground level." The Fukushima Daiichi nuclear catastrophe dramatically and exponentially changes theFitzPatrick cost-benefit analyses.* The continued day-to-day reliance upon the significantly flawed pre-existing containmentvent system as would be relied upon to mitigate a severe accident at the FitzPatrickMark I reactor presents an undue risk to the public health and safety." The identified containment vulnerability, the non-conservative if not false assumption of"no likely ignition sources" in the pre-existing vent line and the unacceptableconsequences of failure of the FitzPatrick pre-existing containment vent place bothgreater uncertainty and undue risk on public health and safety and are not reasonably justified by arbitrarily assigning a low probability of the occurrence of a severe accident .(b)(5)

PRB MEMBERS & ADVISORSSamson LeeBhalchandra VaidyaAnthony UlsesRobert DennigRobert FretzJohn MonningerAndrea RussellKim MorganButlerBrice BickettMathew JennerichLawrence DoerfleinCarrie SaffordRyan Eul(PRB Chair -Deputy Director, NRR, Division of Risk Assessment)(Petition Manager -NRR, Division of Operating Reactor Licensing)(Branch Chief -NRR, Division of Safety Systems, Reactor SystemsBranch)(Branch Chief -NRR, Division of Safety Systems, Containment andVentilation Branch)(Senior Project Manager -NRR, Japan Lessons Learned ProjectDirectorate, Projects Management Branch)(Associate Director -NRR, Japan Lessons Learned Project Directorate)(Agency 2.206 Coordinator -NRR, Division of Policy and Rulemaking)(Branch Chief(A) -NRR, Division of Policy and Rulemaking, GenericCommunications Branch)(Senior Project Manager -Region 1, Branch 2, Division of ReactorProjects)(Project Engineer -Region 1, Branch 2, Division of Reactor Projects)(Branch Chief -Region 1, Branch 2, Division of Reactor Safety)(Deputy Assistant General Counsel Materials Litigation andEnforcement -Office of General Counsel)(Enforcement Specialist -Office of Enforcement)* .- .1l, l(b)(5)