ML20069J253
| ML20069J253 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/02/1994 |
| From: | Sullivan J ALABAMA, STATE OF |
| To: | Selin I, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20069J233 | List: |
| References | |
| NUDOCS 9406140272 | |
| Download: ML20069J253 (6) | |
Text
a STATE OF ALAOAMA
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MONTGOMERY. ALABAMA 361010991 fs JIM SULLIVAN PRESIDENT W ALLACE TIDMORE JAN COOK. Associate COMMisS#0NER SECRETARY CHARLES B MARTIN. Associate couw ssioNER May 2,1994 The lionorable Ivan Selin Chairman Nuclear Regulatory Commission Washington, D.C. 20555
Dear Chairman Selin:
As President of the Alabama Public Service Commission (PSC), and a member of the National Association Of Regulatory Commissioners (NARUC) Committee on Electricity and its Subcommittee on Nuclear Issues - Waste Disposal, I would like to offer comment on a recent letter that I received from Governor Jim Folsom's office, with the Governor's request that we respond.
The letter in reference is from David A. Lochbaum and Donald C. Prevatte, and expresses their concerns regarding a safety hazard involving the design of the Susquehanna Steam Electric Station, and thirty five other similarly designed plants (Attch.1). Alabama has three of these units at TVA's Browns Ferry Nuclear Plant near Athens, Alabama.
While the PSC has no jurisdiction over the operation of the TVA units in question, as a concerned citizen and elected representative of the people of the State of Alabama, I must ask if the grave concerns, as stated by Messrs. Lochbaum and Prevatte, are warranted. If these concerns are warranted, what action has, or will the NRC take to address these concerns to insure the safety of the environment and public located near these units.
I appreciate the cooperation of the NRC in this matter, and I look forward to receiving your answer to these concerns.
Sincer j
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David A. Lochbaum Donald C. Prevatte N
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Watchung, NJ 07060 Fogelsville, PA 18051 L
(908) 754-3577 (215) 398-9277
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Governor Guy IIunt State llouse Montgomery, AL 36130 0086%
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Dea t:
In November 1992, the undersigned (engineers with 37 years combined experience in the nuclear power industry) reported to the United States Nuclear Regulatory Commission (NRC) a substantial safety hazard in the Susquehanna Steam Electric Station, a 2-unit nuclear power plant located in northeastern Pennsylvania / Because of design denciencies, the potential exists for meltdown of irradiated nuclear fuel outside containment and the failure of emergency systems in the plant for the design basis accident. The consequences of such an accident would be deaths, injuries, and massive contamination of the surrounding countryside. We are also concerned with the approximately thirty five other nuclear units in the United States which have a similar design as the Susquehanna plant.
Subsequent evaluations by the plant's owners and the NRC have confirmed our concerns, and the NRC confirmed that these design deficiencies were the result of the owners having failed to meet numerous regulatory requirements at the time the plant was licensed - requirements which are still not being met. However, the NRC has failed to require the owners to correct the discrepancies in the Susquehanna plant or any of the other plants. Additionally, the NRC has demonstrated an attitude of complacency and even reluctance in resolving these concerns. Moreover, the NRC recently ruled that since the failures to comply with the regulations had not been identified by the owners or the NRC at the time of licensing, the requirement to comply was not within the plant's licensing basis, thus paving the way for more delays and the eventual dismissal of these discrepancies as insignificant, as they have done in several recent similar cases.
We believe that without outside intervention, the NRC will continue on their current path, and therefore, we have contacted the Chairmen of three Congressional Subcommittees with NRC oversight responsibilities, Senator Joseph Lieberman, Congressman Richard Izhman, and Congressman Phillip Sharp. We also feel responsible for informing officials in those states in which the other thirty five high risk nuclear units are located so that they may also pursue all available means to resolve these concems. That is the reason for this letter. In Alabama, there are three nuclear units of similar design - those at the Browns Ferry Nuclear Plant near Athens.
Enclosed is a white paper which provides more details of these concems. If after reading this you have any questions or comments, please do not hesitate to contact us at any.ime.
We appreciate very much your attention in this matter, and we look forward to a safe resolution.
Sincerely, 9
y Ok0 5-QQg David A. Lochbaum Donald C. Prevatte
Substantial Nuclear Safety llazard
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Loss of Spent Fuel Pool Cooling A substantial nuclear safety hazard has been identified at the Susquehanna Steam Electric Station (SSES), a two-unit nuclear power plant located in Luzerne County, Pennsylvania about 30 miles southwest of Wilkes Barre.
i ne plant is owned by the Pennsylvania Power & Light Company (PP&L) and others. His hazard was identified to PP&L more than two years ago and to the U. S. Nuclear Regulatory Commission (NRC) approximately a year and a half ago. To date, this hazard has not been properly addressed by either PP&L or the NRC.
The level of hazard is such that were an accident to occur at Susquehanna similar to the nree Mile Island accicent, the probability is very high that there would be numerous deaths and injuries and that the surrounding countryside would become uninhabitable for decades; in other words, an accident of Chernobyl proponions, ne purpose of this paper is to explain the basic elements of this extremely complex technical issue, as well as the applicable regulatory requirements which have not been compl_ icd with by PP&L or the NRC.
Each unit in the Susquehanna plant contains a General Electric Boiling Water Reactor. Nuclear fuel is contained in reactor vessels which are housed within primary containments constructed of steel and reinforced concrete. Secondary containments (also called reactor buildings) surround these primary containments, as well as the spent fuel pools which are located on a sefueling floor common to both units (see Figure i for a simplified arrangement drawing). Most of the plant's emergency systems as well as the systems for cooling the spent fuel pools are also located inside the secondary containments.
ne spent fuel pools are used for storing the extremely radioactive spent fuel when it is removed from the reactors after this fuel can no longer produce power. The water in the pools serves two functions: First, it provides shielding from the radioactivity to allow the spent fuel to be handled by the operators using remote handling equipment. Second, the water serves as the medium to transpon heat away from the spent fuel to the atmosphere by way of the Fuel Pool Ceoling System and the Cooling Towers.
Federal regulations require nuc! car facilities to be designed to prevent undue risk to the health and safety of the operators and the general public, even under the worst credible accident conditions. One of the accidents for which the facility must be designed is the " design basis loss-of-coolant-accident" (DBA LOCA). This is a sudden and complete break of the largest diameter pipe connected to the reactor vessel. If such a break were to occur, high pressure water and steam (approximately 1,000 pounds per square inch and 550*F) would be released into the primary containment, and numerous emergency systems would be automatically started to l
provide replacement cooling water to the reactor vessel and to contain the radioactive materials which could bc
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released from the reactor.
One of the regulations which mandates the margins of safety for such an accident is Regulatory Guide 1.3 (the requirements of this " Guide" are mandatory). This document specifies that a substantial degree of nuclear fuel l
failure must be assumed in designing for the accident, and it also specifies the primary containment leakage rate which must be assumed. nese required assumptions are consistent with the actual conditions which were experienced in the Three Mile Island accident. When analyses are performed using these assumptions, they reveal that for such an accident, the radiation levels inside the normally accessible reactor building would be so high as to prohibit safe operator entry.
t The same accident signals which automatically stan the emergency systems also turn off the electrical power to l
the Fuel Pool Cooling System. Thus, the accident results in the loss of cooling for the spent fuel pool. In order to restart the Fuel Pool Cooling System, operators must enter the reactor building. Ilowever, as i
described above, radiation levels would prohibit safe entry. Therefore, the system cannot be restaned.
If cooling is not restored, the water in the spent fuel pool will eventually boil. The time to boiling is dependent
-l on the number of spent fuel bundles stored in the pool and the length of time since they were removed from the l
reactor. This time could be in as little as 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> for design fuel pool loading conditions, or as much as 55
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.i Substantial Nuclear Safety llazard Loss of Spent Fuel Pool Cooling hours for the current loading of the Unit I fuel pool. if the fuel pool boils, its water will rapidly evaporate, and replacement water must be provided if it is not, within a sbon time the extremely radioactive spent fuel bundles, which are normally covered with water, will be uncovered. Ilowever, the valves which must be opened to provide this replacement water are also within the inaccessible reactor building. Therefore, the replacement water cannot be provided.
ne consequences of uncovering the spent fuel would be cat 2. strophic. First, onsite and offsite radiation would soar to extremely high levels - so high as to prevent any funber intervention by the operators. Nothing could be done at this point to reverse the course of the accident. Without the cooling effect of the boiling water, the spent fuel in the pool would meltdown, and massive amounts of airborne radioactivity would be released outside the primary containment.
Even if early in the accident the operators would reson to the heroics of entering the reactor building to restart the Fuel Pool Cooling System, the system is not designed to operate in the extreme temperature, humidity, and radiation conditions which would be present. Therefore, the system could be assumed to fail. And since it does not possess the redundant design features present in emergency systems, any failure would cause a complete loss of fuel pool cooling capability.
Additionally, even if the Fuel Pool Cooling System could be restarted and no failures occurred, the plant Emergency Procedures have required the operators to disconnect power to the system at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> into the accident.
PP&L and the NRC have contended that another system, the Residual lieat Removal (R11R) System, could be operated to cool the spent fuel pool. But analyses and tests by PP&L have demonstrated that this system cannot cool the fuel pool under accident conditions. Additionally, esen if it could, its valves are also in the inaccessible reactor building. Furthermore, attempted operation in this manner would transpon highly radioactive accident water to the fuel pool, significantly increasing the operator and public radiation exposures.
Even if replacement water could be provided to prevent the spent fuel from being uncovered, the temperature
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and humidity conditions which would be generated in the reactor building due to the boiling would cause the emergency systems to fail since none of them have been designed for these conditions. Reir failure would cause additional meltdown of the fuel in the reactor and also failure of the primary and secondary containment.
Additionally, the condensation from the pool would cause flooding of the reactor building basement where the cmergency pumps are located, thereby causing their failure if they had not already failed due to the environmental conditions.
This scenario is not science fiction. Following the Three Mile Island accident in March 1979, the containment could not be entered for nearly a year due to the radiation. But the Three Mile Island spent fuel pool was never in jeopardy because it was outside the reactor building where it was not affected by the accident, and the operators had unimpeded access. If such an accident were to occur at Susquehanna, the results would be disastrous.
And the concern is not confined to Susquehanna. Approximately one third of the 109 nuclear power plants in the United States are of similar design. Many of these plant are expanding the spent fuel pool capacities, which willincrease the risk.
Even though these concerns were reported to the NRC a year and a half ago, to date, they have not required any action at Susquehanna or any other plant. Additionally, the NRC recently ruled that even though regulations have existed since long before Susquehanna was licensed which required plants to be designed for these eventualities, since neither PP&L nor the NRC identified these concerns at the time of licensing, the requirement to consider them now is outside the licensing basis for the plant.
i April 5,1994 Page 2 of 4 1
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Substantial Nuclear Safety Hazard Loss of Spent Fuel Pool Cooling This ruling goes beyond the absurd and typiGes recent NRC responses to significant safety issues having generic industry wide implications. Here seems to be a great reluctance in the NRC to make any ruling which has the i
potential to cost money for the industry, regardless of the law or the risk. The NRC's ruling not only defies common sense, it violates the laws contained in 10CFR$0.100,10CFR50 Appendix A, NUREG-0737, various Regulatory Guides, and numerous precedents established with this and other licensees, all of which have been repeatedly brought to the attention of the NRC. It also paves the way for the NRC to bury this concern in the bureaucratic morass of the backfit rules contained in 10CFR50.109.
I 7he NRC's recent track record in similar cases has been abominable, e.g. the Thermo Lag issue, the BWR Water level Instrument issue, and numerous other issues which were resolved only after public outcry forced the NRC to do their jobs. This issue is such a case, but with potentia!!y much more catastrophic consequences.
This is why the NRC and the plants with this design flaw must be compelled to comply with the law and resolve I
these concerns without further delay.
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w David A. Lochbaum g Donald C. Prevatte 80 Tuttle Road 7924 Woodsbluff Run Watchung, NJ 07060 Fogelsville, PA 18051 908 754-3577 215 398 9277 i
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April 5,1994 Page 3 of 4
22 G2 Refueling Floor Unit 1 Unit 2 Unit 1 Spent Spent Unit 2 Reactor Building Fuel Fuel Reactor Building Pool Pool v.
Unit 1 Unit 2 Primary Primary M
8 Containment Containment P
Simplified side view of the Susquehanna Steam Electric Station showing the arrangement of the containment structures.
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