New England Coalition on Nuclear Pollution

New England Coalition
FOR IMMEDIATE RELEASE

On June 7, 2010, New England Coalition submitted a 10 CFR 2.206 petition, asking the Nuclear Regulatory Commission to lower Vermont Yankee’s licensing basis maximum fuel rod temperature, in order to provide a necessary margin of safety—to help prevent a partial or complete meltdown—in the event of a loss-of-coolant accident (LOCA).
 
In the event of a LOCA, at Vermont Yankee, the pressurized core would partly or almost completely lose water and the temperature of the Zircaloy clad fuel rods in the core would rapidly increase.  Vermont Yankee’s emergency core cooling system is designed to prevent a meltdown if there is a LOCA, by injecting water into the core to prevent the fuel rods from overheating.
 
At Vermont Yankee’s current licensed power level, in the event of a LOCA, the predicted maximum temperature the fuel rods would reach is 1960°F (the licensing basis maximum fuel rod temperature), before being quenched by water injected into the core.
 
New England Coalition has submitted its 2.206 petition, because there is a preponderance of certified experimental data that supports the need to lower Vermont Yankee’s licensing basis maximum fuel rod temperature of 1960°F by more than one hundred degrees Fahrenheit.
 
In the event of a LOCA, if the fuel rods (in a local area) were to approach current calculated maximum fuel rod temperatures, it is probable that their Zircaloy cladding would begin to rapidly oxidize, like a fire, causing a temperature excursion—termed “runaway oxidation”—that would lead to a partial or complete meltdown.  At its current licensed power level Vermont Yankee lacks a necessary margin of safety to help prevent runaway oxidation, in the event of a LOCA.
 
NRC is presently a considering an NEC 2,206 petition regarding leaking underground piping at Vermont Yankee and the adequacy of NRC oversight at the incident-ridden plant.  In addition New England Coalition is the sole intervenor in Vermont Yankee’s license renewal application, now in its 57th month of litigation.  (more)
A complete copy of the petition (90+ pages/ 1+ Mb) may be had on request.  The following is the Petition Cover Letter, which summarizes NEC’s concerns.
 

R. William Borchardt

Executive Director for Operations U.S. Nuclear Regulatory Commission Washington D.C. 20555-0001

Subject: 10 C.F.R. § 2.206 Request to Lower the Licensing Basis Peak Cladding Temperature of Vermont Yankee Nuclear Power Station (Docket-50-271) in Order to Provide a Necessary Margin of Safety—to Help Prevent a Meltdown—in the Event of a Loss-of-Coolant Accident

Dear Mr. Borchardt:

The enclosed 10 C.F.R. § 2.206 petition is submitted on behalf of New England Coalition of Brattleboro, Vermont by Mark Edward Leyse.

10 C.F.R. § 2.206(a) states that "[a]ny person may file a request to institute a proceeding pursuant to § 2.202 to modify, suspend, or revoke a license, or for any other action as may be proper."

New England Coalition requests that the United States Nuclear Regulatory Commission ("NRC") order the licensee of Vermont Yankee Nuclear Power Station ("VYNPS") to lower the licensing, basis peak cladding temperature ("LBPCT") of VYNPS in order to provide a necessary margin of safety—to help prevent a partial or complete meltdown— in the event of a loss-of-coolant accident ("LOCA"). Experimental data indicates that VYNPS's LBPCT of 1960°F' does not provide a necessary margin of safety—to help prevent a partial or complete meltdown—in the event of a LOCA. Such data indicates that VYNPS's LBPCT must be decreased to a temperature lower than 1832°F in order to provide a necessary margin of safety.

To uphold its congressional mandate to protect the lives, property, and environment of the people of Vermont and locations within proximity of VYNPS, the NRC must not allow VYNPS's LBPCT to remain at an elevated temperature that would not provide a necessary margin of safety, in the event of LOCA. If implemented, the enforcement action proposed in this petition would help improve public and plant worker safety.

New England Coalition respectfully submits that—although revisions to the 10 C.F.R. § 50.46(b)(1) peak cladding temperature limit criterion have been proposed in a rulemaking petition—this petition is separately and appropriately brought under 10 C.F.R. § 2.206, because the concerns brought forward are plant specific, brought by a local, affected party, and have immediate bearing on safety margins at VYNPS, currently operating at its maximum permissible extended power uprate level. Furthermore, the concerns raised

Entergy, "VYNPS 10 C.F.R. § 50.46(a)(3)(ii) Annual Report for 2009," January 14, 2010, located at: www.nrc.gov, Electronic Reading Room, ADAMS Documents, Accession Number: ML100260386, p. 2.
in the enclosed 10 C.F.R. § 2.206 petition are of an immediate nature that require prompt NRC review and action, which are available to the petitioners only through the 10 C.F.R. § 2.206 process.

New England Coalition looks forward to providing any additional information or clarification as may be required by your office or by a petition review board.

Respectfully submitted,

Mark Edward Leyse