ML101180175

Comment (19) of David Lochbaum, on Behalf of Union of Concerned Scientists, on Petition for Rulemaking PRM-50-93, Regarding NRC Revise Its Regulations Based on Data from Multi-Rod (Assembly) Severe Fuel Damage Experiments

ML101180175
Person / Time
Site:	Crane
Issue date:	04/27/2010
From:	Lochbaum D Union of Concerned Scientists
To:	NRC/SECY/RAS
SECY RAS
References
75FR03876 00019, NRC-200909554, PRM-50-93
Download: ML101180175 (5)

Text

DOCKETED PRM-50-93 Union of Concerned Scientists USNRC Citizens and Scientists for Environmental Solutions April 27, 2010 (12:05pm)

OFFICE OF SECRETARY RULEMAKINGS AND April 27, 2010 ADJUDICATIONS STAFF Comments submitted by the Union of Concerned Scientists on the petition for rulmaking 9 q submitted by Mark Edward Leyse (Docket No. PRM-50-93; NRC-200909554)

In response to the notice published January 25, 2010, in the Federal Register (Vol. 75, No 5, pp.

3876-3877), I submit the following comments on behalf of the Union of Concerned Scientists.

It is readily apparent from the materials submitted by Mr. Leyse with his petition for rulemaking that considerable effort went into its research and preparation. UCS recognizes and appreciates the unselfish commitment to public health and safety this petition represents.

In our opinion, Mr. Leyse's petition addresses a genuine safety problem. We believe the NRC should embark on a rulemaking process based on this petition. We are confident that this process would culminate in revised regulations - perhaps not precisely the ones proposed by Mr. Leyse but ones that would adequately resolve the issues he has meticulously identified - that would better ensure safety in event of a loss of coolant accident.

To date, there has only been one loss of coolant accident of significant consequence at a nuclear power reactor licensed by the NRC - the March 1979 accident at Three Mile Island Unit 2. What deeply concerns UCS about safety analyses for postulated loss of coolant accidents is the inability to accurately explain what happened when during this past loss of coolant accident.

Many talented, capable researchers have attempted to explain what happened when the TMI-2 overheated. Their results vary widely, even when examining the same aspects of this past event.

For example, J. 0. Henrie and A. K. Postma from Rockwell Hanford Operations authored "Lessons Learned from Hydrogen Generation and Burning During the TMI-2 Event," (GEND-061, May 1987) reported results from their own and other researchers efforts to specify how much hydrogen was generated when during the accident. Figures 4-7 and 4-8 from their report are presented below. The results may all be in the same ballpark, but it is very clearly and undeniably a very large ballpark.

www.ucsusa.org Two Brattle Square. Cambridge, MA 02238.9105 ' TEL: 617.547.5552" FAX: 617.864.9405 1825 K Street Nw. Suite 800 - Washington. oC 2ooo6-i232, TEL: 202.223.6133 - FAX: 202.223.6162 2397 Shattuck Avenue - Suite 203 - Berkeley, CA 94704-"567

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The inability to explain a historical event with precision raises reasonable doubts about the ability to forecast future events with precision - in essence, the heart of Mr. Leyse's petition.

The urgency behind the need to resolve the issues raised in Mr. Leyse's petition is best demonstrated by narrowing margins to the magical 2,200'F peak cladding temperature.

Plant Name Predicted Peak Clad Temperature Source Braidwood Unit 1 - 2,161-F ML090990492 Unit 2 - 2,168-F April 9, 2009 Byron Unit 1 - 2,161 -F ML090990492 Unit 2-2,168"F April 9, 2009 Catawba Unit 1 - 2,145-F ML092180407 Unit 2 - 2,145-F August 3, 2009 Cook Unit I - 2,128-F ML092520238 Unit 2 - 2,139'F August 28, 2009 McGuire Unit 1 - 2,1450 F ML092180407 Unit 2 - 2,145-F August 3, 2009 North Anna Unit 1 - 2,131 °F ML091820272 Unit 2-2,1310 F June 30, 2009 Palo Verde Unit I - 2,152-F ML091810703 Unit 2 - 2,148-F December 22, 2009 Unit 3 - 2,148"F

April 27, 2010 Page 3 In his petition, Mr. Leyse raised valid questions about the models used to show "margin" during postulated loss of coolant accidents. Prudent protection of public health and safety warrants that his questions be answered. The NRC should answer these vital questions by pursuing the rulemaking that Mr. Leyse has proposed.

Questions were raised about the ability of o-rings to function at low temperatures before the space shuttle Challenger was launched in January 1986. About seventy seconds later, those questions were answered in about the hardest way possible.

Questions were raised about the impact of foam on the surfaces of the space shuttle Columbia during its launch. A computer model developed during the Apollo program was used and it indicated that the foam would fail the integrity of the tiles. Those undesired answers were set aside, attributed to an "out-dated" model. The Columbia's subsequent landing in Texas and Louisiana tragically re-demonstrated the need to get the right answers to all the right questions.

Questions were raised about the safety of cracked nozzles through the reactor vessel head at Davis-Besse. An order was drafted by the NRC requiring that Davis-Besse be shut down to obtain the answers to these safety questions. That order was not issued and Davis-Besse was allowed to continue to operate - the closest near-miss since the TMI-2 accident according to the NRC's accident sequence precursor program.

It was wrong that these past safety questions were not properly answered. It would be equally wrong now not to properly answer the safety questions posed by Mr. Leyse in his petition.

Sincerely, David Lochbaum Director, Nuclear Safety Project PO Box 15316 Chattanooga, TN 37415 (423) 468-9272, office

Rulemaking Comments From:

Sent:

To:

Subject:

Attachments:

Dave Lochbaum [dlochbaum@ucsusa.org]

Tuesday, April 27, 2010 7:58 AM Rulemaking Comments Docket ID NRC-2009-0554 20100427-ucs-nrc-comments-leyse-petition.pdf Good Day:

Attached are belated comments on the subject petition for rulemaking.

Thanks, David Lochbaum' Director, Nuclear Safety Project Union of Concerned Scientists PO Box 15316 Chattanooga, TN 37415 (423) 468-9272 office (423) 488-8318 cell dlochbaum(j~ucsusa.orq 1

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