From Bhalchandra Vaida To Joseph Pechacek: Fitzpatrick .
Gray, MelFrom:Sent:To:Cc:Subject:Attachments:Vaidya, BhalchandraThursday, March 15, 2012 11:42 AMPechacek, Joseph; licfitz@entergy.com; mcolomb@entergy.comRussell, Andrea; Wilson, George; Gray, MelFitzPatrick Emergency Enforcement Petition (10 CFR 4A0320.pdfJoe, and Mike,The purpose of this e-mail is to inform you that pursuant to 10 CFR 2.206, the U.S. Nuclear Regulatory Commission(NRC) has received a Emergency Enforcement Petition dated March 9, 2012, requesting immediate enforcement actionagainst James A. FitzPatrick Nuclear Power Plant.The petition is being added in the NRC Agencywide Documents and Management System with Accession No.ML12074A032. It will be available as a "Publicly Available" Document on the NRC's Public Server soon.The attached file is provided for your convenience.The NRC staff's guidance for the disposition of 2.206 petition requests is in Management Directive 8.11, which is publiclyavailable.Bhalchandra K. VaidyaLicensing Project ManagerNRC/NRR/DORL/LPL1-1I(301)-415-3308 (0)bhalchandra.vaidvae.nrc.aov1"fhI.
EDO Principal CorrespondenceDUE:FROM:ControlEDO CONTROL: G20120172DOC DT: 03/09/12FINAL REPLY:04/12/12Paul GunterBeyond NuclearTO:Borchardt,EDO**FOR SIGNATURE OFLeeds,GRN**NRRROUTING:DESC:2.206 - Fitzpatric Emergency Enforcement Petitions(EDATS: OEDO-2012-0147)DATE:CRC NO:03/13/12ASSIGNED TO:CONTACT:LeedsNRRSPECIAL INSTRUCTIONS OR REMARKS:Please see originator's email and address hisconcerns about submitting 2.206 CDean, RIBurns, OGCMensah, NRRBanic, NRRRussell, NRRScott, OGCBowman, OEDO
EDATS Number: OEDO-2012-0147Source: OEDOGeneral InformationAssigned To: NRROther Assignees:OEDO Due Date: 4/12/2012 11:00 PMSECY Due Date: NONESubject: 2.206 - Fitzpatrick Emergency Enforcement PetitionsDescription:CC Routing: Regioni; OGC; Tanya.Mensah@nrc.gov; Merrilee.Banic@nrc.gov; S Accession Numbers - Incoming: NONEResponse/Package: NONEOteInoratoCross Reference Number: G20120172Related Task:File Routing: EDATSStaff Initiated: NORecurring Item: NOAgency Lesson Learned: NOOEDO Monthly Report Item: NOProcess InformationAction Type: 2.206 ReviewSignature Level: NRRPriority: MediumnSensitivity: NoneUr gency: NOApproval Level: No Approval RequiredOEDO Concurrence: NOOCM Concurrence: NOOCA Concurrence: NOSpecial Instructions: Please see originator's email and address his concerns about submitting 2.206 petitions.Doumn IfraionOriginator Name: Paul GunterOriginating Organization: Beyond NuclearAddressee: R. W. Borchardt, EDOIncoming Task Received: E-mailDate of Incoming: 3/10/2012Document Received by OEDO Date: 3/13/2012Date Response Requested by Originator: NONEPage 1 of I
Beyond Nuclear.---The Alliance for a Green Economy-Center for Health, Environment & Justice--Citizens' EnvironmentalCoalition---Peace Action New York State---CNY Citizens' AwarenessNetwork---Syracuse Peace Council---Peace Action Central New YorkMarch 9, 2012Mr. Bill BorchardtExecutive Director for OperationsU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001By Email: MSHD.Resourcef.nrc.qovMr. Borchardt:Beyond Nuclear, The Alliance for a Green Economy, Center for Health,Environment & Justice, Citizens' Environmental Coalition, Peace Action New YorkState, CNY Citizens' Awareness Network, Syracuse Peace Council and Peace ActionCentral New York, hereafter referred to as "the joint petitioners," submit the followingemergency enforcement petition as provided by Section 2.206 of Title 10 of the Code ofFederal Regulation (10 CFR 2.206).The joint petitioners are requesting the following emergency enforcement actionwith regard to the undue risk to the public health and safety caused by the continuedpower operation of Entergy Nuclear Operation's James A. FitzPatrick nuclear powerplant in Scriba, New York.------. Is/s.-.------------Is/-! --- --------------------------------------Paul Gunter, DirectorReactor Oversight ProjectJessica Azulay Chasnoff, OrganizerAlliance for a Green EconomyBeyond Nuclear2013 E. Genesee St.6930 Carroll Avenue Suite 400Takoma Park, MD 20912301-270-2209Pau lbeyondn uclear.orgSyracuse, NY 13210EDO -- G20120172
-Is/------------Anne Rabe, Campaign CoordinatorCenter for Health, Environment & Justice1265 Maple Hill Rd.Castleton, NY 12033-/sl/-----------Alicia Godsberg, Executive DirectorPeace Action New York StateChurch St. StationP.O. Box 3357New York, NY 10008-3357-/s/---------------Jessica Maxwell, StaffSyracuse Peace Council2013 E. Genesee St.Syracuse, NY ra Warren, Executive DirectorCitizens' Environmental Coalition33 Central Ave.Albany, NY 12210--------Is/----------Tim Judson, PresidentCNY Citizens' Awareness Network2013 E. Genesee St.Syracuse, NY 13210---- -------------------/-------------------Diane Swords, Co-ChairPeace Action Central New York2013 E. Genesee St.Syracuse, NY 13210[ATTACHMENT]2
BEYOND NUCLEAR AND THE ALLIANCE FOR A GREEN ECONOMY PETTITIONTO THE UNITED STATES NUCLEAR REGULATORY COMMISSIONREQUESTING EMERGENCY ENFORCEMENT ACTION PER 10 CFR 2.206FOR THE FITZPATRICK NUCLEAR POWER PLANT, OSWEGO, NEW YORKMARCH 9, 2012INTRODUCTIONBeyond Nuclear1 and The Alliance for a Green Economy,2 which includes theCenter for Health, Environment & Justice, Citizens' Environmental Coalition, PeaceAction New York State, CNY Citizens' Awareness Network, Syracuse Peace Counciland Peace Action Central New York, hereafter referred to as "the joint petitioners",request that the United States Nuclear Regulatory Commission (NRC) immediatelysuspend all power operations at the James A. FitzPatrick nuclear power plant inOswego, New York pending emergency enforcement actions as provided in this petitionby federal law (10 CFR 2.206).'The joint petitioners' request is based on the significant fact that the operator ofthe FitzPatrick nuclear power plant, a General Electric Mark I Boiling Water Reactor(Mark I), refused to voluntarily install the Direct Torus Vent System (DTVS) on reactor'scontainment system also known as the "hardened vent" as requested by the NRC inBeyond Nuclear is a 501(c)3 organization based in Takoma Park, MD http://www.beyondnuclear.org2 Alliance for a Green Economy is a New York State-based organization, whose members include Center for Health,Environment & Justice, the Citizens' Environmental Coalition, Peace Action New York State, Peace Action CNY, theCNY chapter of Citizens Awareness Network, and the Syracuse Peace Council.3 Chapter 10 Code of Federal Regulation Part 2.206 partOO2/partOO20206.html3
Generic Letter 89-16, "Installation of the Hardened Wetwell Vent," issued on September1, 1989.4The "hardened vent" was recommended by the NRC in order to close outoutstanding and unresolved severe accident issues in the GE Mark I boiling waterreactor as the result of the inherently unreliable pressure suppression containmentsystem. Generic Letter 89-16 (GL 89-16) requested that all GE Mark I operatorsvoluntarily make "modificationsthat substantiallyenhance the plants' capabilityto bothprevent and mitigate the consequences of serious accidents.'"5 These enhancedcapabilities covered by GL 89-16 included the installation of a "reliablehardened ventsystem."4 The operators of FitzPatrick Mark I Boiling Water Reactor refused to makemodifications to its Mark I containment. Instead, the FitzPatrick operators rely upon theanalyzed capability of a ductwork venting system for low pressure venting ofcontainment that pre-existed to the GL 89-16 request. The pre-existing containmentvent is intended for such purposes as purging the Mark I pressure suppressioncontainment for worker access during routine maintenance, repair and refueling. It wasnot designed with the intention to be used as a severe accident mitigation system.Furthermore, FitzPatrick is publicly identified as the "one exception" among the23 Mark I reactors in the United States to not voluntarily install the Direct Torus VentSystem (DTVS) also known as the "hardened wetwell vent" and the "hardened vent."4"Installation of the Hardened Wetwell Vent," Generic Letter 89-16, US NRC, September 1, t2206 -vent.pdfIbid, GL 89-16, p. 16 lbid, GL 89-16, p. 14
The modifications requested by NRC for installation of the Direct Torus Vent Systemwere intended to protect and preserve containment integrity of the Mark I pressuresuppression containment system in the event of a severe nuclear accident.7Petitioner, Beyond Nuclear, has previously filed an emergency enforcementpetition with the NRC on April 13, 2011 that separately challenges the adequacy andreliability of the installation of the experimental Direct Torus Vent System or "hardenedvent" as installed on these other Mark I containments. 8 The DTVS includes an 8"hardened steel line that by-passes the Standby Gas Treatment System (the radiationfiltration component in the nuclear power plants off-gas release system to theenvironment). The "hardened vent" by-pass line was installed for the purpose ofavoiding back pressure that could lead to the rupture and failure of the vent pathanywhere along the path to the 300-foot tall off gas vent stack release point. The DirectTorus Vent System as also installed on the GE Mark I units at Fukushima Daiichidramatically failed to mitigate the nuclear accidents following the prolonged StationBlack Out event that began on March 11, 2011. On December 13, 2011, the Office ofNuclear Reactor Regulation of the NRC formally decided to "ACCEPT" portions of theBeyond Nuclear April 13, 2011 emergency enforcement petition for further review by the7 "Safety Evaluation Report (SER) by the Office of Nuclear Reactor Regulation, Power Authority of the State of NewYork, Hardened Wetwell Vent Capability, James A. Fitzpatrick Nuclear Power Plant," US NRC, September 28, 1992,Purpose, paign/fof/vent/fof fitz 09281992-nrc-ser-approves-no-dtvs-highli.ht.pdf8 Suspension of operations at GE Mark I Boiling Water Reactors, Beyond Nuclear Emergency Enforcement Petition(10 CFR 2.206), April 13, 2011, ign/ nk-1-2206/bn2206 Pe bwr 04132011.pdfJune 8, 2011 supplement, www.beyondnuclear.orq/storage/mark-1 -campaiqn/mk-1 2206/bn 2206 qe bwr comb 06082011 sup file.pdf5
agency including the petitioner's requested action for the revocation of NRC priorapproval of installation of the DTVS or hardened vent for these Mark I units. 9However, in the matter of this emergency enforcement petition, the jointpetitioners assert that the FitzPatrick operator uniquely did not install the DTVS. Thejoint petitioners do not seek or request that FitzPatrick operators now install the DTVSas it is demonstrated to have experienced multiple failures to mitigate the severenuclear accidents at Fukushima Daiichi. The joint petitioners instead request that theFitzpatrick operating license be immediately suspended as the result of the undue riskto the public health and safety presented by the operator's reliance on non-conservativeand wrong assumptions that went into the analysis of the capability of FitzPatrick's preexisting ductwork containment vent system. The risks and uncertainty presented byFitzPatrick assumptions and decisions as regard NRC Generic Letter 89-16 asassociated with the day-to-day operations of this nuclear power plant now constitute anundue risk to public health and safety. The joint petitioners request that the suspensionof the operating license be in effect pending final resolution of a public challenge to theadequacy of the pre-existing vent line in light of the Fukushima Daiichi nuclear accident.JOINT PETITIONERS REQUEST THE IMMEDIATE SUSPENSION OFTHE FITZPATRICK OPERATING LICENSEIn full light of the demonstrated multiple failures of the GE Mark I containmentand hardened venting systems at the Fukushima Daiichi nuclear power station in the9 Letter from Eric Leeds, NRR, NRC to Paul Gunter, Beyond Nuclear, December 13, campaign/mk-I.-2206/fofnrc fdd 1213201113 ML11339A078pdf6
days following the March 11, 2011 Station Black Out (SBO) event, the joint petitionersseek the prompt and immediate suspension of Fitzpatrick operations because;1) the GE Mark I Boiling Water Reactor pressure suppression containmentsystem is identified as inherently unreliable and likely to fail during a severeaccident due to the containment's small volumetric capacity;2) the capability of FitzPatrick's pre-existing containment vent as approved forsevere accident mitigation is not a fully 'hardened vent' system asrecommended by NRC Generic Letter 89-16 and therefore presents greaterand undue risk to public health and safety in the event of a severe accidentfrom the current day-to-day operations than previously analyzed andassumed;3) the capability of FitzPatrick's pre-existing containment vent as approved reliesupon non-conservative and faulty assumptions including the assumption thatthere are "no likely ignition sources" along the pre-existing containment ventline during a Station Black Out event that would increase the risk of thedetonation of hydrogen gas generated during a severe accident that mightrequire opening the pre-existing vent line and would instead threatencontainment integrity. Such faulty assumptions place a non-conservative andundue risk on the public's health and safety in the event of a severe accidentduring the current day-to-day operation;4) the capability of Fitzpatrick's pre-existing containment vent system uniquelyallows for a severe nuclear accident to be released at ground level with7
unanalyzed and unacceptable radiation dose consequences which presentsan undue risk to public health and safety in the adjacent communities andbeyond;5) the Fukushima Daiichi nuclear catastrophe dramatically and exponentiallychances the FitzPatrick cost-benefit analyses as used to justify reliance on apre-existing containment vent system that now represents a greater andundue risk to public health and safety;6) the continued day-to-day reliance upon the significantly flawed pre-existingcontainment vent system as would be relied upon to mitigate a severeaccident at the FitzPatrick Mark I reactor presents an undue risk to the publichealth and safety while industry and NRC deliberate over unresolved issuesassociated with the unreliable Mark I containment and experimental criteriafor a renewed attempt to establish a "reliable hardened vent." Industry and theNRC could be engaged for many more years than is currently intended perOrder still pending from NRC Near-Term Task Force Recommendation 5.1.107) the identified containment vulnerability, the non-conservative if not falseassumption of "no likely ignition sources" in the pre-existing vent line and theunacceptable consequences of failure of the FitzPatrick pre-existingcontainment vent place both greater uncertainty and undue risk on publichealth and safety and not reasonably justified by arbitrarily assigning a lowprobability of the occurrence of a severe accident.10 "Recommendations for Enhancing Reactor Safety in the 21't Century: The Near-Term Task Force Review of theFukushima Daiichi Accident," US NRC, July 12, 2011, p. 41,http://pbadupws.nrc.gov/docs MLllI/ML111861807pdf.8
REQUESTED EMERGENCY ENFORCEMENT ACTIONSAs a result of the Fukushima Daiichi nuclear accident involving the five (5)General Electric Mark I Boiling Water Reactors (Mark I) and multiple failures of both theMark I pressure suppression containments and the Direct Torus Vent System or"hardened vent" at four (4) units beginning on March 11, 2011, the Petitioners requestthat the NRC immediately suspend the FitzPatrick operating license and that the reactorunit be placed into cold shutdown until the following emergency enforcement actions areenacted, completed, reviewed and approved by the NRC and informed by independentscientific analysis;1) Entergy Nuclear Operations' Fitzpatrick nuclear power plant shall be subject topublic hearings with full hearing rights on the continued operation of the Mark IBWR and the adequacy and capability of a pre-existing containment vent whichis not a fully hardened vent line as recommended by NRC Generic Letter 89-16.As such, the FitzPatrick operator uniquely did not make containmentmodifications and did not install the Direct Torus Vent System or DTVS,otherwise known as "the hardened vent," as requested by NRC Generic Letter89-16 and as installed on every other GE Mark I in the US;2) Entergy Nuclear Operations shall publicly document for independent review itspost-Fukushima re-analyses for the reliability and capability of the FitzPatrickpre-existing containment vent system as previously identified as "an acceptabledeviation" from NRC Generic Letter 89-16 which recommended the installation of9
the Direct Torus Vent System and as outlined in the NRC Safety EvaluationReport dated September 28, 1992.11 The publicly documented post-Fukushimaanalysis shall include the reassessment of all assumptions regarding thecapability and reliability of the pre-existing containment venting and specificallyaddress non-conservative assumptions regarding;a) the FitzPatrick cost-benefit analysis used to justify not installing a fullyhardened vent system and;b) "unlikely ignition points" as claimed in the FitzPatrick pre-existing ventline system that would otherwise present increased risks andconsequences associated with the detonation of hydrogen gas generatedduring a severe accident.BACKGROUND AND ARGUMENTThe General Electric Mark I Boiling Water Reactor's pressure suppression containmentsystem is documented to be vulnerable to failure during a severe accident due tocontainment melt through, over-pressurization and hydrogen gas generation andexplosion as the result of a severe accident. 12 This is in large part due to the Mark Ipressure suppression containment system's relatively small size, volumetrically, whichis one-sixth ( 1 / 6 th) that of the large dry containment systems for the Pressurized WaterReactors. As a result of design vulnerability to severe accidents, the NRC and theNRC SER for Fitzpatrick, p 2 of 8 aign/fof/vent/fofritz 09281992-nrc-ser-approves-no-dtvs.pdf12Beyond Nuclear emergency enforcement petition, April 13, 2011, n/mk-1-2206/bn 2206 ge bwr 041320111.pdf10
industry collaborated to design and voluntarily install the Direct Torus Vent System(DT-VS) or "hardened wetwell vent" to provide control room operators with a "lastresort"option during a severe accident challenge to deliberately and temporarily defeatcontainment through a hardened venting system retrofitted to the wetwell component ofthe GE Mark I pressure suppression system to save it from permanent rupture and thecatastrophic release of radiation. 1 3On September 1, 1989, the NRC sent to all Mark I operators including the NewYork Power Authority (NYPA) Generic Letter 89-16, "Subject: Installation of a HardenedWetwell Vent (GL 89-16).014 GL 89-16 requests that all Mark I operators voluntarily tomodify the pressure suppression containment systems by installing the Direct TorusVent System "to reduce the vulnerability of the BWR Mark I containments to severeaccidents.1 5 The generic letter further states, "Specifically, the Commission hasdirected the' staff to approve installationof a hardened vent under the provisions of 10CFR 50.59 for licensees, who on their own initiative, elect to incorporatethis plantimprovement."16 The NRC communication then explicitly identifies, "Continuedrelianceon pre-existing capability (non-pressure-bearingvent path) which may jeopardize13"Filtered Venting Consideratio
beyond nuclear and the alliance for a green economy pettition to the united states nuclear regulatory commission requesting emergency enforcement action per 10 cfr 2.206 for the fitzpatrick nuclear power plant, oswego, new york march 9, 2012 introduction beyond nuclear1 and the alliance for a green economy,2 which includes the
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