ML061220542
| ML061220542 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/04/2006 |
| From: | - No Known Affiliation |
| To: | Coward D Office of Nuclear Reactor Regulation, St. Lucie County, FL |
| References | |
| LTR-06-0213 | |
| Download: ML061220542 (7) | |
Text
OFFICE OF TIHE SECRETARY CORRESPONDENCE CONTROL TICKET Date Printed: May 01, 2006 12:33 PAPER NUMBER:
ACTION OFFICE:
LTR-06-0213 EDO LOGGING DATE: 05/01/2006 Sosclef, IYSs
.1 AUTHOR:
AFFILIATION:
ADDRESSEE:
SUBJECT:
ACTION:
DISTRIBUTION:
DT CT FL Doug Coward Appeal to protect the community...FPL Appropriate Chairman, Comrs S'.v ED()
l DEDMRS DEI)R DEDIA AO f \\ t vgs I LETTER DATE:
ACKNOWLEDGED SPECIAL HANDLING:
04/04/2006 No NOTES:
Oh%
FILE LOCATION:
ADAMS DATE DUE:
DATE SIGNED:
April 4, 2006 Commissioner Doug Coward Chairman, District 2 St. Lucie County 2300 Virginia Avenue Fort Pierce, FL 34982
Subject:
Appeal to Protect Our Community
Dear Commissioner Coward:
I am a semi-retired engineer with long years of experience in the nuclear power industry. I make my home in South Florida. I am not an FPL em-loyee but I do a fair amount of contract work for them. As a result, I am quite familiar with FPL's plans to store spent fuel at its plant sites, including at Plant St. Lucie.
I am aware that FPL will use the technology that is called "dry storage". The dry storage technology involves storing fuel in welded containers that are stored outdoors in thick concrete or steel housings. The housing confines the huge quantities of radiation coming out of the container, which is why we engineers call it the "biological shield". Storage is outdoors.
I am not against dry technology per se, there are some safe ones out there. My problem is with the particular technology that FPL has selected to use in my backyard. I am concerned because I know that the technology FPL has decided to use is old and downright dangerous. I dlo not mean to sound like an alarmist, but I am alarmed, and I believe that you would be as well if you took a little time to familiarize yourself with some basic facts about the storage technology that FPL would like to install in our midst.
This technology is owned by a French-government owned company called Areva. The technology is called NUHOMS, an illustration of which I attach to this letter. (These sketches are from Areva subsidiary TN£'s filings to the NRC; they are available in the public domain.
I will share with you only some of the obvious facts about NUHOMS that one does not have to be an engineer to understand. I know a whole lot:
more, :out what I present to you in this letter should be enough to cause you to either move out of the county or force FPL to use a better and safer technology.
Please check out the cylindrical container in figure #1. This contai:aer holds the reactor fuel. I reckon a typical container loaded with fuel will pack about five to ten million curies of radioactivity.
It is also very heavy because it is filled with uranium -
it weighs over forty tons!
A direst sighting of a loaded container will, of course, kill any human being instantly. For this reason Areva encloses the container :n a rectangular housing made of concrete that you can see in the cutaway in figure #1. They call it the "NUHOMS" storage module. The concrete wall and roof provide the radiation protection to people and livestock
'~Page 2of 6 near the container. (The concrete walls have ventilation openings through which radiation leaks out, but it is not enough to cause significant radiation damage to people.) Now, look how this 40-ton uranium-filled container is supported in the NUHOMS storage module: It simply lies horizontally on its side on two rails. The container is not even fastened to the rails! Further, these rails are held up in the air- (yes, in the salt air) on a few upright square tubes made of ordina::y steel (noted as Canister Support Structure in Areva's figure
- 1 attached). Yes, sir, this 40-ton cylinder filled with the nastiest.
of man-made stuff rests -
six feet up in the air -
on a set of steel tubes. These structural tubes will support the weight of the forty-ton-plus canister year-in/year-out completely out of sight of FPL's plant staff because the tubes are not visible or accessible. The NUHOMS is designed for the salt air to enter the inside of the concre:e structure, where the container is resting, sweep past the vertical support tubes and then the container overhead to remove the heat thaat is constantly produced by the contents inside the container.
How lo:ng do you think the steel tubes will last before they turn into rust! 'r reckon they will last long enough for the big wigs of FPL to get their golden parachutes. When the tubes cannot hold the weight of:
the container the container will come crashing down to the concrete surface below. I do not know whether the container is strong enough t:o remain intact after falling for six feet. But imagine dozens of these cylinders crashing to the ground at. Port St. Lucie! Imagine the catastrophe. It does not take a rocket scientist to know how corrosive salt air is. Salt air even attacks stainless steel. Here is our own FPL, hoisting 40,-ton containers on tube steel columns that are bound to deteriorate in the salt air environment, sight unseen. Should I be outraged! Should you be outraged!
The NR-is supposed to have a law called "Part 21". If any company knows of a defect in its product that is being used at a nuke, it is supposed to notify the NRC. Well, Areva knows that it has installed dozens of these containers around.the country. The square'tube structure may.be rusting away at any of these plants, completely undetected (because.the outside of the tubes is not visible, and the inside of the tubes is completely unseeable).You would think that Areva would admit to the defect in the NUHOMS design and make.changes before a tube structure collapses somewhere. I have not heard a peep.
In. my view, the French company's action (rather, lack of action) is a direct violation of the'law (Part 21) and a shameful neglect of responsibility.
What I mentioned above is a no-brainer technical point. Let me exposes.
another no-brainer about this NUHOMS technology.
FPL's men will push this 40-ton container on the rails by using a large "hydraulic ram" (seen in sketch #2). To make sure that the cylindrical surface of the container does not bind on the rail's surface, they will make sure that the rails are greased and are installed in a perfectly horizontal configuration. I am sure they will get the containers pushed in without irradiating their workers: Areva claims extensive operating experience in doing this sort of a risky operation. The only problem is how will they get the container out oE NUHOMS after the rails and the container havc been weathered by marine air and the settlement of the ground below has occurred (does the
Page 3 of 6 ground settle under heavy load!) under the weight of the 40-ton-plus container and its concrete housing has made the rails out-of-flat and out-of-horizontal. To dismantle the storage facility at the end of its life, you must be able to pull the container out of the NUHOM concrete housing.
If you cannot pull the containers out then you are flat out of luck:
you cannot take the container out to Yucca or anywhere: the site will become a permanent graveyard for the nuclear fuel. It will become a waste clump full of hundreds of millions of curies of radioactivity that takes over a million years to die down. Port St. Lucie will become the long-term repository and we, our children, and grandchildren will.be its reluctant neighbors. I do not want our lovely St. Lucie County to join the ranks of places like Middletown, Pennsylvania, which has never recovered from the blow delivered to it by Three Mile Island accident almost 30 years ago.
In fact:, you should know that the storage facility that the Department of Energy is planning to build in Nevada will not use the NUHOMS design because, among other concerns, DOE is concerned about the feasibility of removing the container after some period of storage due to settlement.(They are planning to use the vertical storage technology instead; there are several available on the market).
Think about it: the DOE does not even consider NUHOMS to be fit for use in a dry desert away from population centers, but our FPL has no concern placing them right in the midst of us in the humid, salt laden air of Florida! Go figure.
Another point of information -
the NUHOMS module is not even made by
- pouring concrete, like a concrete building..It is made by pre-cast concrete blocks trucked to the site and assembled by bolting the blocks together. It is not even anchored to the concrete floor it will sit on; it just lays there.
I am not a structural engineer but I know that a rectangular box made by field assembling precast concrete blocks may not be the safest kind of housing enclosure for deadly nuclear fuel in a terrorist attack situation. I have heard that the USNRC simulated an airplane attack on NUHOMS on the computer. The industry scuttlebutt is that the NUHOMS.
concre,-e enclosure falls apart and the container is:breached under a Boeing airplane strike. The NRCwseems to be unwilling to publish their findings in detail because (I think) it would cause panic in the communities where NUHOMS is presently installed. To prevent panic, the NRC is allowing this downright unsafe dry storage technology to be used near our homes.
The sad fact is that if I know, then FPL's executives must also know that NiHOMS is a sitting duck in the face of a crashing aircraft.
I have heard guys at FPL say that they selected NUHOMS because it looks like a low-rise townhome. They say that the people -
all of us -
wilL find a module that resembles a home to be more salable to us! They must think we are so technically ignorant that camouflaging nuclear waste in townhomes -
engineered to collapse on their own due to corrosion and totally unfit in the September 11 world -
will fool us.
Page 4 of 6 Let us show the big shots in Juno that we are not so ignorant after all.
Maybe you and the other commissioners can ask FPL some pointed questions to smoke them out, such as:
- 1.
Was FPL aware of the risk of corrosion failure of the steel structure that supports the fuel container when it selected NUHOMS? If so, what did it do to eliminate the risk?
- 2.
Was FPL aware of the risk of settlement of the ground below the NUHOMS module? What did FPL do to ensure that the containers can be safely pulled out after years of storage in open air so that Port St.
Lucie does not become a waste dump?
- 3.
Does DOE's decision to not use NUHOMS technology at the Yucca site bother FPL? If not, why not?
A4.
Has FPL verified from the NRC that the NUHOMS module will continue to serve as a secure biological shield after an airplane strike? And the container will not fall to the ground or develop a leak?
- 5.
Can FPL share the information from its files on other technologies that it considered in its bid evaluations and its safety reasons for not selecting them?,
- 6.
Are FPL's executives who manage FPL's nuclear plants willing to testify that they have not received favors (golf trips, ski trips, etc.) Erom the seller (Areva) in the year before selecting Areva's technology?
I suspect that you will watch FPL squirm but I also doubt that they will give you a straight.answer.
I am writing this letter anonymously because I make.my living as a contraztor to FPL; coming out in the open will definitely put me out of work!-. By sharing the facts with you, I have done my civic duty while preserving my means of earning a living.
I hope that you and your associates in the position of authority wilL verify the facts that I have presented in this letter and act to save all of us from a huge blunder by FPL. I surely:hope that you would not let the utility "contribute" their way out of this blunder to get the permits they need to give us the nuclear graveyard.-.
Yours faithfully, DT cc:
Commissioner Paula Lewis Commissioner Frannie Hutchinson Commissioner Chris Craft County Administrator Douglas Anderson Environmental Resources Director Vanessa Bessey Assistant County Attorney Katherine McKenzie-Smith
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SASEIAT APPROACH SLA JDRY SHIELDED CANISlER (STORED POSITION)
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- AND POSITIONING SYSTEM Figure 1.1.2 NUHOMS System Comnonents. Structures, and Transfer Enuipment.
Elevation View NIH1-003 Rovision 5 1.1-6 August 2000 l