ML111530345

Declaration of Dr. Gordon R. Thompson in Support of Commonwealth of Massachusetts' Contention and Related Petitions and Motions

ML111530345
Person / Time
Site:	Pilgrim
Issue date:	06/01/2011
From:	Thompson G Institute for Resource & Security Studies, State of MA, Office of the Attorney General
To:	NRC/OCM
SECY RAS
Shared Package
ML111530338	List: ML111530339 ML111530340 ML111530341 ML111530342 ML111530343 ML111530344 ML111530345
References
50-293-LR, ASLBP 06-848-02-LR, RAS 20414
Download: ML111530345 (5)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OR BEFORE THE COMMISSION In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application June 1, 2011 DECLARATION OF DR. GORDON R. THOMPSON IN SUPPORT OF COMMONWEALTH OF MASSACHUSETTS CONTENTION AND RELATED PETITIONS AND MOTIONS I, Gordon R. Thompson, declare as follows:

1. I am the executive director of the Institute for Resource and Security Studies (IRSS), a nonprofit, tax-exempt corporation based in Massachusetts. Our office is located at 27 Ellsworth Avenue, Cambridge, MA 02139. IRSS was founded in 1984 to conduct technical and policy analysis and public education, with the objective of promoting peace and international security, efficient use of natural resources, and protection of the environment. I am also a senior research scientist at the George Perkins Marsh Institute, Clark University, Worcester, Massachusetts.

2. In support of the Commonwealth of Massachusetts request for the admission of a new contention in this proceeding, I have prepared a report entitled New and Significant Information From the Fukushima Daiichi Accident in the Context of Future Operation of the Pilgrim Nuclear Power Plant (1 June 2011) (Report). Previously, in this proceeding, I prepared a report entitled Risks and Risk-Reducing Options Associated with Pool Storage of Spent Nuclear Fuel at the Pilgrim and Vermont Yankee Nuclear Power Plants (25 May 2006) (2006 Report). The analysis and conclusions in my Report are consistent with the analysis and conclusions in my 2006 Report.

3. I am an expert in the area of technical safety, security, and environmental analysis related to nuclear facilities. My Curriculum Vitae is provided here as an attachment.

4. I am familiar with environmental analyses by the U.S. Nuclear Regulatory Commission (NRC) and Entergy Nuclear Operations, Inc. (Entergy) that apply to the Pilgrim Nuclear Power Plant (NPP). These documents are listed in my Report or my 2006 Report.

5. I received an undergraduate education in science and mechanical engineering at the

2 University of New South Wales, in Australia. Subsequently, I pursued graduate studies at Oxford University and received from that institution a Doctorate of Philosophy in mathematics in 1973, for analyses of plasmas undergoing thermonuclear fusion. During my graduate studies I was associated with the fusion research program of the UK Atomic Energy Authority. My undergraduate and graduate work provided me with a rigorous education in the methodologies and disciplines of science, mathematics, and engineering.

6. Since 1977, a significant part of my work has consisted of technical analyses of safety, security and environmental issues related to nuclear facilities. These analyses have been sponsored by a variety of nongovernmental organizations and local, state and national governments, predominantly in North America and western Europe. Drawing upon these analyses, I have provided expert testimony in legal and regulatory proceedings, and have served on committees advising US and UK government agencies. To illustrate my expertise, I provide more detailed information on my experience below.

7. I have conducted, directed, and/or participated in a number of studies that evaluated aspects of the design and operation of nuclear power plants with respect to severe accident probabilities and consequences. These include general studies and studies of individual plants. For instance, with respect to general studies, in 1986, I participated in the preparation of a study by the Union of Concerned Scientists of the potential for escape of radioactive material during a reactor core-melt accident (Sholly and Thompson 1986). In the late 1980s, I was part of a team of four scientists who prepared a comprehensive critique of the state of the art of probabilistic risk assessment (PRA) for Greenpeace International (Hirsch et al, 1989). I published two other articles on the relevance of PRA to emergency planning in a book entitled Preparing for Nuclear Power Plant Accidents (Golding, et al., 1995). All of these studies required me to be highly familiar with the design and operation of nuclear power plants, as well as the characteristics of probabilistic risk assessment.

8. I have also done considerable work on the risks posed by individual nuclear facilities.

In addition to performing the studies described elsewhere in this Declaration, I have studied the risks posed by the Seabrook and Harris plants (U.S.), the La Hague facility (France), and the Darlington and Pickering Stations (Canada). All of these studies required me to become familiar with the relevant details of the design and operation of the facilities involved.

9. To a significant degree, my work has been accepted or adopted by the governmental agencies involved. During the period 1978-1979, for example, I served on an international review group commissioned by the government of Lower Saxony (a state in Germany) to evaluate a proposal for a nuclear fuel cycle center at Gorleben. I led the subgroup that examined accident and security risks and alternative options with lower risk. One of the risk issues that I identified and analyzed was the potential for an exothermic reaction of fuel cladding in a high-density fuel pool if water is lost. I identified partial loss of water as a more severe condition than total loss of water. I identified and described alternative fuel storage options with lower risk. The Lower Saxony government accepted my findings and ruled that high-density pool storage was not an acceptable option at Gorleben. As a direct result, policy throughout Germany has

3 been to use dry storage, rather than high-density pool storage, for away-from-reactor storage of spent fuel.

10. My work has also influenced decision making by safety officials in the U.S.

Department of Energy (DOE). During the period 1986-1991, I was commissioned by environmental groups to assess the safety of the military production reactors at the Savannah River Site, and to identify and assess alternative options for the production of tritium for the US nuclear arsenal. Initially, much of the relevant information was classified or otherwise inaccessible to members of the public such as myself.

Nevertheless, I addressed safety issues through analyses that were recognized as accurate by nuclear safety officials at DOE. I eventually concluded that the Savannah River reactors could not meet the safety objectives set for them by DOE. DOE subsequently reached the same conclusion. The current national policy for tritium production is to employ commercial reactors, an option that I had concluded was technically attractive but problematic from the perspective of nuclear weapons proliferation.

11. In 1977, and again during the period 1996-2000, I examined the safety of nuclear fuel reprocessing and liquid high-level waste management facilities at the Sellafield site in the UK. My investigation in the latter period was supported by a consortium of local governments in Ireland and the UK, and my findings were presented at briefings in the UK and Irish parliaments. I identified safety issues that were not addressed in any publicly available literature about the Sellafield site. As a direct result of my investigation, the UK Nuclear Installations Inspectorate (NII) required the operator of the Sellafield site to conduct extensive safety analyses. These analyses confirmed the significance of the safety issues that I identified, and the NII imposed a schedule for run-down of the Sellafield inventory of liquid high-level waste.

11. In 2000, the NRC Staff accepted my view that older fuel in a spent-fuel pool is more vulnerable to ignition in a state of partial drainage than in a state of total drainage, because convective heat transfer is suppressed by the presence of residual water at the base of the fuel assemblies. Although the NRC Staff previously ignored or disparaged my opinion, the Staff eventually confirmed the validity of my expert opinion on the matter.

12. The factual statements in my Report are true and correct to the best of my knowledge and the statements of opinion therein are based on my best professional judgment.

13. I am prepared to testify as an expert witness on behalf of the Commonwealth of Massachusetts with respect to the facts and opinions set forth in my Report.

14. My Report addresses the relevance to the Pilgrim re-licensing decision of new and significant information emerging from the radiological accident involving four nuclear power plants (NPPs) on the Fukushima Daiichi (Number 1) site in Japan. That accident began in March 2011 and is ongoing. Publicly available information about the accident in English language - and probably in Japanese as well - has been emerging constantly since the accident began, but is incomplete and inconsistent at this time. Additional information about the causes and effects of the Fukushima accident is likely to become available over the coming months. While consideration of the implications of the

4 Fukushima accident would be most effectively done if the NRC awaited a more complete investigation of the accident, I believe that sufficient information exists now to reach significant conclusions about the current inadequacy of the NRCs environmental analyses in addressing the implications of the Fukushima accident. Therefore, I believe the Commonwealths contention is timely.

15. I also believe the Commonwealths contention addresses exceptionally grave environmental issues, for three reasons. First, the Fukushima accident shows that a severe reactor and/or spent-fuel-pool accident is significantly more likely than estimated or assumed in the NRCs current environmental analyses for the Pilgrim NPP. Second, the experience of the Fukushima accident shows that the accident mitigation measures relied on by the NRC are grossly inadequate to prevent the type of catastrophic damage at Pilgrim that has occurred at Fukushima. Finally, the Fukushima accident shows how corrosive and dangerous is the high level of secrecy that the NRC has maintained with respect to accident mitigation measures, thereby contributing to the use of ineffective measures at Fukushima. Accident mitigation measures (excluding the most site-specific details) should be subject to public scrutiny in an environmental review process, in order to ensure that they will not be relied on unless they are sufficiently rigorous.

16. As discussed in my Report at Section VI, I believe that a materially different result would be likely if the NRC were to thoroughly consider the implications of the Fukushima accident in its environmental analyses for the Pilgrim NPP. In particular, I believe that the NRC would consider a much broader and more rigorous array of severe accident mitigation alternatives (SAMAs) than have been previously considered, including systems for hydrogen control, containment venting, and replacement of high-density spent fuel storage racks with low-density, open-frame racks. Also, in view of the high risk of a radioactive release at Pilgrim, any accident-mitigation measure or SAMA that is credited for the future licensed operation of the Pilgrim NPP should be incorporated in the plants design basis.

17. As discussed in my Report, I believe that many of the implications of the Fukushima accident for the Pilgrim NPP license renewal proceeding are site-specific. My opinion is based on several factors. First, the analyses of core-melt accident risks and SAMAs that the licensee and the NRC have prepared for the Pilgrim NPP are specific to that facility.

Second, the spent-fuel storage risks discussed in my Report are integrally related to the core-melt accident risks that are already discussed in the existing SAMA analysis.

Finally, the mitigation measures that the NRC relies on to mitigate reactor and spent-fuel-storage risks have been separately devised and reviewed for the Pilgrim NPP and therefore are not generic. The Fukushima accident has raised significant questions about the effectiveness of these mitigation measures, and therefore it would be appropriate to re-evaluate them on a plant-specific basis. This is especially true with respect to the analysis of spent fuel pool storage risks and associated mitigative measures, because the NRC has relied on the plant-specific application of extensive damage mitigation guidelines (EDMGs) to conclude that the environmental impacts of high-density pool storage of spent fuel are insignificant. Similar EDMGs were demonstrated to be inadequate to mitigate the effects of the Fukushima accident. Therefore, I conclude that it is necessary and appropriate for the Commonwealth to seek a plant-specific waiver of the spent fuel pool exclusion regulations.

5 I declare, under penalty of perjury, that the foregoing facts provided in my Declaration are true and correct to the best of my knowledge and belief, and that the opinions expressed herein are based on my best professional judgment.

Executed on 1 June 2011.

Gordon R. Thompson