ML111530448

Watch Request for Hearing on a New Contention Regarding Inadequacy of Environmental Report, Post Fukushima

ML111530448
Person / Time
Site:	Pilgrim
Issue date:	06/01/2011
From:	Lambert M Pilgrim Watch
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML111530440	List: ML111530441 ML111530442 ML111530443 ML111530444 ML111530445 ML111530446 ML111530447 ML111530448 ML111530449
References
RAS 20407, 50-293-LR, ASLBP 06-848-02-LR
Download: ML111530448 (35)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Docket # 50-293-LR Entergy Corporation Pilgrim Nuclear Power Station License Renewal Application June 1, 2011 PILGRIM WATCH REQUEST FOR HEARING ON A NEW CONTENTION REGARDING INADEQUCY OF ENVIRONMENTAL REPORT, POST FUKUSHIMA In accordance with 10 C.F.R § 2.309 (c)(1) Pilgrim Watch files a new Request for Hearing. The contention reads:

Based on new and significant information from Fukushima, the Environmental Report is inadequate post Fukushima Daiichi. Entergys SAMA analysis ignores new and significant issues raised by Fukushima regarding the probability of both containment failure, and subsequent larger off-site consequences due to failure of the direct torus vent (DTV) to operate.

In its SAMA analysis for PNPS, Entergy followed conventional NRC practice and assumed very low probabilities, not only that any accident would occur at all, but also that in the event of an accident there would not be:

(i) Pressure-build up within the containment; (ii) A significant delay in even attempting to vent the containment because of operator error;

(iii) Failure/Inoperability of the Direct Torus Vent; and (iv) Catastrophic failure of the containment.

The NRC years ago recognized that Mark I failure within the first few hours following core melt would appear rather likely;" a 90% likelihood of containment failure.

The events at Fukushima showed that there is an equally high likelihood that the supposed fix, the DTV, will fail also. Three direct torus vents should have opened, one at each of the three Fukushima Mark I reactors. All three failed to do so; and, as expected, all three containments failed.

Entergys prior SAMA analysis, based on hopeful, purely theoretical facts was plainly inadequate. It must be required to conduct a new analysis - based on what Fukushima has taught about reality.

I. INTRODUCTION In the license renewal process, the Applicant is required under 10 CFR

§51(c)(ii)(L) to perform a severe mitigation analysis if they had not previously done so. The purpose of a SAMA review is to ensure that any plant changes that have a potential for significantly improving severe accident safety performance are identified and addressed.

Post Fukushima Daiichi, it plainly is necessary to redo Pilgrims SAMA analysis to take into account new and significant information learned from Fukushima regarding the probability of containment failure in the event of an accident and the concomitant probability of a significantly larger volume of off-site radiological releases.

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II. THE CONTENTION IS WITHIN THE SCOPE OF THESE PROCEEDINGS This contention addresses a defect or dispute regarding the Applicants SAMA which is a Category 2 issue, and thus is within the scope of this proceeding.

The NRC must consider new and significant information arising from the accident at Fukushima before relicensing Pilgrim NPS whether or not that information ultimately leads to modification of licensing requirements. Regardless of its eventual assessment of the significance of the information, the [agency] ha[s] a duty to take a hard look at the proferred evidence. Marsh v Oregon Natural Resources Council, 490 U.S. 360, 385 (1989) (emphasis added)

The fundamental purpose of the National Environmental Policy Act, NEPA, 42 USC § 4332, is to help public officials make decisions that are based on understanding of environmental consequences, and take decisions that protect, restore and enhance the environment. 40 CFR § 1500.1(c) (Emphasis added).

In its application for license renewal of Pilgrim, Entergy was required under 10 CFR § 51 to provide an analysis of the impacts on the environment that could result if it is allowed to continue beyond its initial license; and the environmental impacts that must be considered in its EIS include those which are reasonably foreseeable and have catastrophic consequences, even if their probability of occurrence is low. 40 CFR

§1502.22(b)(1). The fact that the likelihood of an impact may not be easily quantifiable is not an excuse for failing to address it in an EIS. NRC regulations require that to the extent that there are important qualitative considerations or factors that cannot be quantified, these considerations or factors will be discussed in qualitative terms. 10 CFR§51.71.

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The ASLB must consider issues raised by Fukushima prior to relicensing Pilgrim because the Fukushima events plainly show that, even if they are not yet all conclusively understood, the environmental impacts of the NRC relicensing Pilgrim may affect the quality of the human environment in a significant manner or to a significant extent not already considered. Marsh at 374; see also Marsh at 372-373 The ASLB properly cannot rely upon Entergys 2006 SAMA analysis and ignore new and significant information. NEPA requires an agency to consider the environmental impacts before decisions are made to ensure that important effects will not be overlooked or underestimated only to be discovered after resources have been committed or the die otherwise cast. Robertson v Methow Valley Citizens Council, 490 U.S. 332,349 (1989)

This new contention seeks compliance with NEPA and is based on the Applicants Environmental Report (ER). 10 CFR§2.309(f)(2).

III. THE ISSUE RAISED IN THE CONTENTION IS MATERIAL The issue raised in th[is new] contention is material to the findings the NRC must make to support the action that is involved in the proceeding. 10 CFR§2.309(f)(iv) In considering the license renewal for Millstone Nuclear Power Station, the ASLB stated that

[w]here a contention alleges a deficiency or error in the application, the deficiency or error must have some independent health and safety significance. In the Matter of Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Units 2 and 3) Docket Nos. 50-336-LR, 50-423-LR ASLBP No. 04-824-01-LR July 28, 2004, p. 7. See Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP- 98-7,47 NRC 142, 179-80 (1998),

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affd in part, CLI-98-13, 48 NRC 26 (1998). The deficiency highlighted in this contention has enormous independent health and safety significance.

IV. THERE IS A SUBSTANTIAL BASIS FOR THE CONTENTION Assumptions made in Entergys SAMA analysis now have to be questioned. This contention focuses on new and significant information regarding the increased probability of a severe accident and larger offsite consequences, both justifying additional mitigation.

NEW AND SIGNIFICANT INFORMATION REGARDING THE PROBABILITY OF A SEVERE ACCIDENT

1. Direct Torus Vent Did Not Prevent Containment Failure

a.

Introduction:

Pilgrim is the same design as the failed Fukushima reactors - all are GE, Mark I, BWRs. Almost forty years ago, the NRC identified a serious design flaw in these reactors - in certain accident scenarios the containment would fail in the event of pressure build up.

A supposed fix was recommended, and put into place - a direct torus vent (DTV) to relieve pressure in order to save the containment by releasing unfiltered material directly into the air. Pilgrim assumed that the DTV would work, and that theoretical assumption was the underpinning of its assumed probabilities in accident sequences. The use of the direct torus vent 5

as a means of containment heat removal has been shown to have a major impact upon the results of Class II accident sequences. 1 But this major impact was shown only by theoretical analysis. The only real tests of the DTV - Unit 1, Unit 2, and Unit 3 at Fukushima, March 2011 - all failed. Three out of three failures is not a good score.

The new and significant information concerning the likely failure of the DTV to prevent containment failure that now must be considered in Pilgrims SAMA analysis includes:

(1) Properly trained operators decided not to open the DTV when they should have because they feared the effects offsite of significant unfiltered releases; (2) When the operators finally decided to open the DTV, they were unable to do so; (3) The failure of the DTV to vent led to containment failure/explosions that resulted in significant ongoing offsite consequences.

Prior to Fukushima, concerns regarding the operational safety of the DTV focused simply on accidental releases - measures to assure no single operator error in valve operation could activate the DTV and mistakenly release unfiltered radiation into the environment. Now, after the DTVs first and only real test, it is clear that what is most important is not a theoretical mistaken release; rather the new and significant issue is the likelihood that the DTV simply wont work when release is required to save the containment.

1 Pilgrim Nuclear Power Station Individual Plant Examination for Internal Events Per GL-88-20, Volume 1, Prepared for Boston Edison Co., September 1992, pg, 5.0-13 (Exh.,1) 6

b. History: GE Mark I BWR Lack Containment Integrity during a Nuclear Accident The DTV is designed to relieve high pressure generated during a severe accident, and to avoid containment failure/explosions, a particular problem for this type of reactor design. 2 The lack of containment integrity of the GE Mark I was recognized as early as 1972. Dr. Stephen Hanauer, an Atomic Energy Commission safety official recommended that the Mark 1 pressure suppression system be discontinued and any further designs not be accepted for construction permits. Hanauer's boss, Joseph Hendrie (later an NRC Commissioner) essentially agreed with Hanauer, but denied the recommendation on the grounds that it could mean the end the nuclear power industry in the U.S. 3 In 1976, three General Electric nuclear engineers publicly resigned citing dangerous shortcomings in the GE design. 4 An NRC analysis of the potential failure of the Mark I under accident conditions concluded in a 1985 report that, Mark I failure within the first few hours following core melt would appear rather likely."

In 1986, Harold Denton, then the NRC's top safety official, told an industry trade group that, "The Mark I containment, especially being smaller with lower design pressure, in spite of 2

U.S. Reactor Owners See Retrofits to Avoid Blasts, Bloomberg, Mehul Srivastava, Jim Polson and Rachel Layne -

May 19, 2011 (Exh.,2) 3 Copies of the three original AEC memos, including Hendrie's, November 11, 1971: outlines problems with the design and pressure suppression system containment; September 20, 1972 : memo from Steven Hanauer recommends that U.S. stop licensing reactors using pressure suppression system; September 25, 1972: memo from Joseph Hendrie (top safety official at AEC) agrees with recommendation but rejects it saying it "could well mean the end of nuclear power..." (Exh.,3) 4 Faulty hydrogen vents at Fukushima Daiichi spell trouble for US nuclear plants as well, Bellona, Charles Digges May 18, 2011 http://www.bellona.org/articles/articles_2011/fautly_hydrogen_vents (Exh., 4) 7

the suppression pool, if you look at the WASH 1400 safety study, you'll find something like a 90% probability of that containment failing. 5" Fukushima proved that these estimates (NRC - likely containment failure; its top safety official - a 90 percent probability) - were about right.

To protect the Mark I containment from a likely total rupture, NRC advised venting high pressure built up. As a result, an industry workgroup designed and installed the "direct torus vent system" at all Mark I reactors, beginning with Pilgrim. However the NRC recognized that the vent was not full-proof. During some ATWS (anticipated transient without scram) events, the pressure in the containment will rapidly increase. Venting pressure could be reached in a matter of minutes rather than hours. Therefore venting may not prevent containment failure because of the high containment pressurization rate but it was thought it would provide additional time to scram the reactor and delay the core melt 6.

Operated from the control room, the DTV is a reinforced pipe installed in the torus and designed to release radioactive high pressure steam generated in a severe accident by allowing unfiltered radioactive release directly to the atmosphere through the vent stack. Reactor operators have the option whether to open the vent in order to, what was believed pre-Fukushima, "save the containment," or when to keep it closed in order not to unnecessarily expose the public and the environment to unknown amounts of harmful radiation.

5 Reactor design in Japan has long been questioned, NYT, March 15, 2011, Tom Zeller referencing Denton Urges UNRC to Settle Doubts About Mark I Containment, Inside NRC, McGraw-Hill,Vol. 8, No. 12, June 9, 1986.

6 Chairman Kenneth M. Carr, Responses to Concerns raised by W.R. Griffin, June 21, 1990, Enclosure 2, Response to Question 2, page 5 (Exh.,5) 8

As a result of GE's design deficiency, the original design for a passive containment system was compromised in favor of a system that relied entirely on human control, despite all the associated risks of error and technical failure.

The design was further compromised by the NRCs now highly-questionable decision not to require that any release be filtered. Over thirty years ago, the Three Mile Island Lessons Learned Task Force recommended that the NRC solicit comments on the issues and specific facts relating to the consideration of controlled filtered venting..., and that a decision on whether and how to proceed with this specific requirement within one year.... 7 The NRC never bothered to follow its Task Forces recommendation. 8 The absence of a filter the DTV had significant negative unintended consequences at Fukushima, and this must be factored in here. The New York Times reported that, Government officials have also suggested that one of the primary causes of the explosions was a several-hour delay in a decision to use the vents, as Tokyo Electric managers agonized over whether to resort to emergency measures that would allow a substantial amount of radioactive materials to escape into the air 9.

No rational SAMA could provide any excuse for not requiring filtering the DTV.

7 From the Bulletin Archives: Containment of a reactor meltdown, From the Bulletin Archives: Containment of a reactor meltdown, by Frank von Hippel, 16 March 2011. The original article authored by Jan Beyea and Frank von Hippel appeared in the September 1982 issue of the Bulletin (Exh., 6) 8 Entergys estimate of the cost of filtering the DTV at Pilgrim is $3 million (LRA, Appendix E, Table E.2-1, pgs.,

E.2-15, E,2-24,; Table E.2.2, pgs., E.2-45, E.2-47CITE); peanut when compared to the damage from an unfiltered release, to say nothing of the costs of a containment failure occasioned by an intentional decision not to vent.

9 Hidden Dangers: Japanese Officials Ignored or Concealed Dangers, NYT, Hiroko Tabuchi reported from Tokyo, Keith Bradsher from Hong Kong, and Matthew L. Wald from Washington, May 17, 2011.Exh., 7 9

c. DTV Failure The DTV design failed three times at Fukushima, in its first real test. The New York Times reported that, The failure of the vents calls into question the safety of similar nuclear power plants in the United States and Japan. After the venting failed at the Fukushima plant, the hydrogen gas fueled explosions that spewed radioactive materials into the atmosphere, reaching levels about 10 percent of estimated emissions at Chernobyl, according to Japans nuclear regulatory agency. 10 The following diagram illustrates what went wrong with the DTV in Japan and could occur at Pilgrim.

11 As reported by the NYT and others, the causes of the explosions and containment failure were both human and technological.

10 Ibid 11 The Importance of Venting, When a Reactor Threatens to Blow Its Stack, Matthew L. Wald, May 19, 2011, http://green.blogs.nytimes.com/2011/05/19/the-importance-of-venting-when-a-reactor-threatens-to-blow-its-stack, Exh., 8 10

One of the primary causes of the explosions was a several-hour delay in a decision to use the vents. Tokyo managers agonized over whether to resort to emergency measures that would allow a substantial amount of radioactive materials to escape into the air. 12 The second major cause was technological; even when Tokyo Electric got around to trying to open the DTV, it could not do so. All of the reasons that the DTVs failed are still being determined. Several things, however, are clear:

Fukushima had vent, but system failed reported (May 18, 2011) 13 a cascading series of complications once the order to vent was issued:

The venting system is designed to be operated from the control room, but operators attempts to turn it on failed, most likely because the power to open the critical valve was out. The valves are designed to open manually, but by the time, workers found radiation levels near the venting system at Reactor No 1 were already too high to approach, according to Tokyo Electrics records At reactor No. 2, workers tried to manually open the safety valves, but pressure did not fall inside the reactor At reactor No.3, workers tried sever times to manually open the valve, but it kept closing, the records say. The results of the failed venting were disastrous.

Both Tokyo Electric documents and interviews with experts provide comprehensive evidence that mechanical failures and design flaws in the venting system were a major cause of the DTV failure and containment failure. 14 12 Had the DTV been filtered, as it clearly should have been, it seems clear that Tokyo Electric would have at least tried to open them when they should have, long before the containment failed. Whether their efforts would have been successful, however, is a different matter 13 Fukushima had new vents, but the system failed, May 18, 2011, http://joewein.net/blog/2011/05/18/fukushima-had-new-vents-but-system-failed/ (Exh., 9) 14 Ibid 11

The New York Times reported that 15: five years before the DTVs at the Fukushima Daiichi nuclear plant were disabled by the accident the DTVs were supposed to handle, engineers at a reactor in Minnesota warned American regulators about the very problem. One of the engineers, Anthony Sarrack, notified staff members at the NRC that the design of venting systems was seriously flawed at his reactor and others in the United States similar to the ones in Japan. He later left the industry in frustration because managers and regulators did not agree. As Mr.

Sarrack said, and Fukushima proved, the vents, which are supposed to relieve pressure at crippled plants and keep containment structures intact, should not be dependent on electric power and workers ability to operate critical valves because power might be cut in an emergency and workers might be incapacitated.

And, according to the NYT article, NRC is considering lessons learned about the DTV and making the vents more passive but the staff had not yet chosen a way to do that.

Once again, and only after the event, the NRC is apparently considering a solution that it previously incorrectly rejected. Mr. Sarrack recommended rupture disks, relatively thin sheets of steel that break and allows venting without any operator command or moving parts when the pressure reaches a specified level. But the NRC gave into those in the industry that argued that if a disk is used that there would be a way to close the vent once pressure is relieved in order to hold in radioactive materials. Rather than requiring that such a way be provided, the NRC again saved the industry money, and effectively forgot that the major problem that needed to be faced was containment failure. And, once 15 U.S. Was Warned on Vents before Failure at Japans Plant, NYT, Matthew Wald, May 18, 2011 (Exh., 10) 12

again, if the NRC had required a filtered vent, the problem of clos[ing] the vent once pressure is relieved would largely alleviate continued release of radioactive materials.

A rational SAMA would require both filtering and redesign of the DTV venting system.

d. Pilgrims DTV- how it works Pilgrims DTV is described in Boston Edisons Initial Assessment of Pilgrim Safety Enhancement, Section 3.2, Installation of DTVS (Exh.,11) Attachment to BECO letter 88-126, Section 3.2 Revision 1 Installation of a Direct Torus Vent System (DTVS) pages 14,-19B, Rev.

1 (7/25/88) (Exh., 12)

The Initial Assessment says:

Pilgrims DTVs provides a direct vent path from the torus air space to the main stack, in parallel with and bypassing the Standby Gas Treatment System (SGTS).

The DTVS provides a new 8 line branching off the existing torus purge exhaust line between the containment isolation valves (outside containment) with a reconnection to the existing torus purge exhaust line downstream of the SGTS. The new torus vent line is also provided with its own containment isolation valve and rupture disc, set to relieve at 30 psig.

The following diagram, that shows the branch line with its own containment isolation valve 5025 and Rupture Disc, is included in the attachment to BECOs letter. It will be noted that the Rupture Disc is downstream of valves AO-5042B and AO-5025, and that both of these values 13

are normally closed and are designed to be opened either remotely from the control room or manually. 16 The accompanying discussion in the BECO letter attachment says, among other things:

• The vent line provides a direct vent path from the torus to the main stack bypassing the SBGTS. The bypass is an 8 line (hatched line in diagram) -the upstream end is connected to the pipe between the primary containment isolation valves AO-5042 A

& B. The downstream end of the bypass is connected to the 20 main stack line downstream of the SBGTS valves AON-108 and AON-112.

• An 8 butterfly valve (AO-5025), which can be remotely operated from the control room, is added downstream of 8 valve AO-5052B. This valve acts as the primary containment outboard isolation valve for the DTV line. Test connections are provided upstream and downstream of AO-5025.

16 Some initial reports indicated that the Fukushima DTV did not include updates that were present in US Mark I Reactors such as that at PNPS. Those reports were apparently not correct. Pilgrim Watchs understanding is that the Fukushima DTVs had been upgraded, and are essentially the same as that at PNPS (Exh. 12) 14

• AO-5042B was replaced in 1988 with a DC solenoid valve (powered from essential 125 volt DC) so that it would operate without dependence on AC power. AO-5025 is also provided with a DC solenoid powered from a redundant 125 volt DC source.

Both valves are normally closed and are closed in a fail-safe position. One inch nitrogen lines are added to provide nitrogen to valves AO-5042B and AO-5025.

• Valve AO-5025 is controlled by a remote manual key-locked control switch. During normal operation, power to AO-5025 DC solenoid will also be disabled by removal of fuses in the wiring to the solenoid valve to assure it cannot be inadvertently opened.

The 7/25/88 document said that an additional fuse will be installed to power valve status indication for AO-5025 in the main control room.

• A rupture disc is included in the piping to provide a second leakage barrier. It is designed to open below containment design pressure, but will remain intact up to pressures equal to or greater than those which cause automatic containment isolation during accident conditions.

See also, Chairman Kenneth M. Carr, Responses to Concerns raised by W.R. Griffin, June 21, 1990, Enclosure 2 Possibility Of A Vacuum Breaker Remaining Open (Q.2 Response, pp.,2-3, 5)

(Exh.,13)

• Each penetration consists of a vacuum breaker and an air operated butterfly valve in series. During normal operation, valves are closed; the vacuum breaker is maintained closed by the weight of the disc, and the butterfly valve is maintained closed by positive actuator air pressure.

• Therefore, during the entire positive pressure profile of the event, the penetration has two closed barriers in series. It is only during the end of the pressurization phase that the penetration is aligned into its vacuum breaker role.

Because of this double barrier protection and the fact the both valves are not expected to change position during the pressurization phase of the event, the staff has concluded that failure of the penetration as a leak tight barrier is not credible and need not be considered in design basis.

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• The fact the Pilgrim DTVS rupture disc is designed to rupture at 30 psi is not related to the NRCs recommendation that specified the venting pressure at the containment design pressure. The set pressure for the rupture disc does not control the venting pressure because there are two closed isolation valves in the flow path.

• These two valves are normally closed and will open manually by the operator if venting is needed. The maximum containment pressure at which the operators are expected to open the vent valve is 56 psig (not 60 psi), which is the NRC recommendation on venting pressure.

• The rupture disc is designed to serve as an additional leakage barrier at pressures below 30 psi. It is designed to open below the containment design pressure, but will be intact up to a pressure equal or greater that those pressures that cause an automatic containment isolation during an accident conditions.

Therefore, its presence in the line can effectively eliminate the negative consequences of inadvertent actuation of the vent valves at pressures below 30 psi. The set pressure of 30 psi for the rupture disc satisfies these design objectives.

• The isolation valves, AO-5025 and AO-5042B, are designed with ac independent power supplies. These two valves are powered from essential dc power and are backed up with diverse nitrogen actuation capability. Therefore in case of an SBO event, the valves would be available for venting. The venting concept is mainly designed to slow overpressure transients of the containment.

During some ATWS (anticipated transient without scram) events, the pressure in the containment will rapidly increase. Venting pressure could be reached in a matter of minutes rather than hours. Therefore venting may not prevent containment failure because of the high containment pressurization rate but would provide additional time to scram the reactor and delay the core melt.

In other words and greatly simplified, the DTV will vent excess pressure from the containment only if normally closed valves AO-5025 and AO-5042b can be opened.

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At Fukushima, TEPO was unable to open the normally closed valves in all three DTVs, and there is no redundancy. 17 Pilgrims control room has 2 key locked switches in series that have to be opened manually when the need to use the DTV occurs. If, as happened at Fukushima, the normally-closed isolation valves cannot be opened from the control room, the next step is to try to open the isolation valves manually - but this also proved impossible at Fukushima since radiation levels were too high.

e. Pilgrims Vent System - Applicable New & Significant Safety Issues Raised at Fukushima (1) Unfiltered vent: Pilgrim and the Fukushima Units 1, 2, 3 have unfiltered vents.

Reports cited above indicated that operators postponed venting too long because they were hesitant to release a substantial amount of radioactive materials. This must be considered by Entergy. Operators cannot be trusted to make this decision. Entergy estimated that adding a filtered vent would provide $0.00 added benefit and it would cost $3,000,000 (LRA, Appendix E, pgs., E-2-15, E-2-24). We assume the estimated cost is approximately correct. The $0.00 added benefit is ludicrous.

Accidents & Estimates of Consequences Pilgrim Watch expects the Entergy will continue to fight having to filter the DTV, likely relying on yet another incorrect NRC assumption - that the suppression pool alone will scrub out and retain particulate and volatile fission products.

17 Redundancy, of course, could have been provided at both Fukushima and Pilgrim, e.g., by a parallel vent line with a 50-55 psig rupture disc followed by a normally open valve that would be closed when pressures had dropped to an accept able level, but that would have cost the industry more money.

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This hopeful assumption is simply wrong.

Dr. Frank von Hipple analyzed the NRCs largely unsupported contention and found it considerably more optimistic than estimated in the NRC's first study on the subject. WASH-1400, The Reactor Safety Study, WASH-1400 (1975). Also known as The Rasmussen Report.

Entergy may also rely on an EPRI study that resulted from a concerted industry campaign to convince both the public and government that, even in case of containment failure, the resulting release of radioactivity to the atmosphere would be much less than has always been thought. 18 EPRIs study claimed, in effect, that improved containments were not necessary, 19 again claiming that even in the event of a core meltdown accident and a containment failure, "due to the solubility of the volatile fission product compounds and the aerosol behavior mechanisms, the off-site dispersion of radioactive materials (other than gases) following a major LWR [light water reactor] accident will be small 20."

The Nuclear Regulatory Commission authorizes an effort to examine the Institute's claims as a collaborative enterprise between Commission staff members and technical experts at three major national laboratories. The teams draft report, in March of 1981 stated:

"The results of this study do not support the contention that the predicted consequences of the risk dominant accidents have been over-predicted by orders of magnitude in past studies. For 18 The electric utilities' public relations departments and the nuclear industry press sprang into action and advertised these claims with great fanfare, noting that "If findings like these are verified . . . it would go far toward deflating the doomsday predictions of anti-nuclear groups" (Quoted by von Hippel, Bulletin Atomic Scientists, Exh. 6) 19 M. Levenson and F. Rahn (Electric Power Research Institute), "Realistic Estimates of the Consequences of Nuclear Accidents," paper presented at the International Meeting of the American Nuclear Society, Washington, D.C. (Nov. 20, 1980). (Ibid) 20 John O'Neill, "Scientists Say NRC Greatly Overestimates Accident Risks," Nuclear Industry (Dec. 1980), p. 27 (Ibid) 18

example, the analysis in this report indicates that . . . 10% to 50% of the core inventory of iodine could be released to the environment. 21" Under pressure from the industry, the Commission subsequently rewrote the summary language so that it no longer appeared to be a rebuttal to the Electrical Power Research Institute report. Nevertheless, the technical conclusions remained the same.

Japan has shown that Entergys and NRC assumptions of the probability of offsite consequences are wrong. Dr. Frank von Hippel explained in a briefing to the NRC that, For accidents in which the damage is sufficient to open large pathways from the core to the containment, there will not be sufficient water available to trap the radioactive materials of concern, nor will the pathway be so torturous that a significant amount wills tick to surfaces before reaching the containment atmosphere. Similarly f the containment fails early enough, there will be insufficient time for aerosols to settle in the reactor building floor. 22 These three mechanisms are the basis for claims made by Entergy, NRC, and industry to falsely trivialize offsite consequences. Pilgrims SAMA analysis must be redone to take this new and significant information into consideration in its calculations of offsite consequences.

21 U.S. Nuclear Regulatory Commission, Technical Bases for Estimating Fission Product Behavior During LWR Accidents, NUREG-07 draft (March 6, 1981; final, June 1981). The basic points in the NRC experts' review were immediately apparent to knowledgeable readers of the Institute report. See Frank von Hippel, an invited briefing to the NRC as recorded in the transcript, "NRC Meeting on Iodine Release from Accidents and Estimates of Consequences," (Nov. 18, 1980), pp. 38-61. For accidents in which the damage is sufficient to open large pathways from the core to the containment, there will not be sufficient water available to trap the radioactive materials of concern, nor will the pathway be so tortuous that a significant amount will stick to surfaces before reaching the containment atmosphere. Similarly, if the containment fails early enough, there will be insufficient time for aerosols to settle to the reactor building floor. These three mechanisms are the basis for the claims made in the Electric Power Research Institute report 22 Bulletin of Atomic Scientists: Containment of a Reactor Meltdown, Frank von Hippel, March 15, 2011, FN 16(Exh. 6) 19

(2) Failed Valves: Pilgrims DTV isolation valves appear to be essentially the same as those that failed at Fukushima. Supposedly automatic systems do fail (as they did at Fukushima) and manual systems may also (both mechanically and because radiation is too high to permit manual operation). Why is there no redundancy?

(3) DC Batteries: Pilgrim Nuclear Power Station Individual Plant Examination For Internal Events Per Gl-88-20, Volume 1, Prepared by Boston Edison Co.,

September 1992 (Exh.,14) says that:

• [T] he direct torus vent requires both DC batteries for operation (C.2-10)

• 125VDC Bus (Battery) A This bus is required for operation of the direct torus vent. (C.2-14)

• 125VDC Bus (Battery) B This bus is also required for operation of the direct torus vent. (Ibid)

• The containment torus venting system would be unavailable if one DC division is unavailable. (C-4-8)

Again, the PNPS (and Fukushima) DTV systems fail closed, not open. Absent redundancy, if either DC division is not available to the DTVS, the venting system is unavailable, apparently because there would be no way to open the normally-closed isolation values.

f. DTVS Piping is buried - management/history degradation piping The DTVS 8 inch piping is buried underground. The piping is susceptible to corrosion, especially in Pilgrims subsurface environment. Also corrosion is a function of age and it can result from manufacturing and installation error. If the pipe corrodes to the point that it develops a hole of any size, dirt and debris are likely to enter the hole. If the 20

DTV is activated in an emergency, the dirt and debris could then be blown down the line and packed, disenabling the vent. 23 Pilgrim Watch demonstrated in PWs buried pipes and tanks contention and submerged non-environmentally qualified electric cable contention that Pilgrims subsurface environment is moist. It is basic that water and moisture are needed for external corrosion to occur [Brookhaven Report at 26]. There is no basis upon which anyone can assume that the DTV piping has not been exposed to significant moisture since it was installed in 1987.

e. Summary - Pilgrims SAMA, New Probability Calculations Required The NRC Staff told the Commissioners that it is looking at effectiveness of the containment venting strategies, 24 Pilgrim Watch petitions the Board to do likewise.

In Pilgrims ER, new and significant issues raised in Japan require Entergy to reanalyze the probability for DTV failure and subsequent containment failure/explosions.

It is not new that Pilgrims containment will not hold up if too much pressure builds up inside nor that Pilgrim like its sister Fukushima reactors installed an unfiltered vent to let radioactive gases out in an accident. What is new are two significant pieces of information.

The first is that we now know that an unfiltered vent has unintended consequences beyond poisoning unnecessarily offsite neighborhoods - it makes operators hesitant to use the vent until perhaps too late, upping the probability of containment failure/explosions.

23 Discovery from Pilgrim Watchs filings on the Aging Management Program for Buried Pipes and Tanks and Submerged Non- Environmentally Qualified Electric Cables will be applied to this contention.

24 Briefing on the Progress of the Task Force Review of the NRC Processes and Regulations Following the Events in Japan, May 12, 2011, pg., 17. http://www.nrc.gov/reading-rm/doc-collections/commission/tr/2011/20110512.pdf 21

The second is the likely failure of the DTV itself. Before Fukushima, the DTV had not been tested. At Fukushima, DTV systems failed three times - three out of three.

The final cost of the Fukushima disaster remains to be calculated, but it is clearly billions of dollars. Entergy did not properly factor either reasonable probabilities of DTV failure, or the likely cost of failure, into its SAMA. Had Entergy done so, more SAMAs (such as DTV filters and redundant vent lines) are likely to be justified and the risk for the public will be reduced significantly. Citizens should not be faced with the equivalent of having been assured that we had life boats but not told either that crewman wont launch them or that that they dont float.

It is just not Pilgrim Watch that is aware that this is an issue. Bloomberg reported that, Entergy fully expects the U.S. Nuclear Regulatory Commission to order new equipment installed and new procedures to be adopted as a result of the accident in Japan, said Jim Sheets, a spokesman for the New Orleans-based company that owns 11 reactors. Operator error or lack of power at the facility may explain why venting systems didnt work at Fukushima. There are multiple explanations for failure of venting systems in Japan to prevent hydrogen explosions, Michael Burns, another Entergy spokesman, said in an e-mailed statement yesterday. 25 25 U.S. Reactor Owners See Retrofits to Avoid Blast, Mehul Srivastava, Jim Polson and Rachel Layne, Bloomberg, May 19, 2011 (Exh., 2) 22

f. Pilgrims Application, Appendix E - DTV The Application considers in Appendix E, Table E.1-8, Core Damage Accident Sequences Plant Damage States containment venting is not available; but the only reason provided is operator failure to recognize the need to vent the torus.

Entergys SAMA does not consider what actually happened at Fukushima - operators consciously deciding not to open the DTV for fear of serious contamination offsite, or failure of the DTV itself.

2. New and Significant Information Regarding the Severity of the Accident As discussed earlier, the lack of containment integrity of the GE Mark I was recognized as early as 1972. Dr. Stephen Hanauer, an Atomic Energy Commission safety official recommended that the Mark 1 pressure suppression system be discontinued and any further designs not be accepted for construction permits. Later in 1986, Harold Denton, then the NRC's top safety official, told an industry trade group that the "Mark I containment, especially being smaller with lower design pressure, in spite of the suppression pool, if you look at the WASH 23

1400 safety study, you'll find something like a 90% probability of that containment failing. The DTVS was billed as the fix. Fukushima confirmed the high probability that the containment would fail, but it also showed that the supposed fix could fail also. The offsite consequences of containment failure would be huge. None of this was properly factored into Entergys SAMA.

V. THE CONTENTION IS TIMELY Under 10 C.F.R 2.309(c), the determination whether the filing of a contention is non-timely is based on a balancing of eight factors, the most important of which is good cause, if any, for the failure to file on time. Crow Butte Resources, Inc. (North Trend Expansion Project),

LBP-08-6, 67 NRC 241 (2008)

The factors, and how each points to the conclusion that this contention should be accepted, are set forth below.

1. Good cause, if any, for failure to file on time.

The information upon which this contention is based did not become available to the public (including Pilgrim Watch) until the New York Times published articles on Fukushima Unit 1, 2 and 3s DTVS failures, May 19, 2011.

Good cause has been consistently interpreted to mean that a proposed new contention be based on information that was not previously available, and was timely submitted in light of that new information. Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Unit 3), CLI-09-5, 69 N.R.C. 115, 125-26 (2009) citing Pacific Gas & Electric Co. (Diablo Canyon Power Plant Independent Spent Fuel Storage Installation), CLI-08-1, 67 N.R.C. 1, 6 (2008). See also, NRC Digest, Prehearing Matters, 29: Newly arising information has long been recognized as providing "good cause" for acceptance of a late contention. Consumers 24

Power Co. (Midland Plant, Units 1 and 2), LBP-82-63, 16 NRC 571, 577 (1982), citing Indiana and Michigan Electric Co. (Donald C. Cook Nuclear Plant, Units 1 and 2), CLI-72-75, 5 AEC 13, 14 (1972); Cincinnati Gas and Electric Co. (William H. Zimmer Nuclear Station), LBP 14, 11 NRC 570, 574 (1980), appeal dismissed,ALAB-595, 11 NRC 860 (1980).

Here is it clear that (1) the information is new and could not have been presented earlier, and (2) Pilgrim Watch acted promptly after learning of the new information. Texas Utilities Electric Co. (Comanche Peak Steam Electric Station, Units 1 and 2), CLI-92-12, 36 N.R.C. 62, 69-73 (1992)

2. The nature of the requestors/petitioners right under the Act to be made a party to the proceeding.

Pilgrim Watch is already a party, and thus clearly has the right under the Act to be a party to this proceeding.

3. The nature and extent of the requestors/petitioners property, financial or other interest in the proceeding.

As said in Pilgrim Watchs originally filed petition (Request For Hearing And Petition To Intervene by Pilgrim Watch -May 25, 2006. Pg.1), and as remains the case, Pilgrim Watch is a non-profit citizens organization located at 148 Washington Street, Duxbury, Massachusetts, 02332. It is represented pro se by Mary Lampert who makes her residence and place of occupation and recreation within ten (10) miles of Pilgrim Nuclear Power Station. Under 10 CFR

§ 2.309 Petitioners have standing to intervene in the license renewal proceedings of Pilgrim because they live within 10 miles of the facility. For reactor construction and licensing 25

proceedings, the NRC has recognized a presumption that people who live within close proximity of the facility (50 miles) have standing to intervene in the proceedings.

4. The possible effect of any order that may be entered in the proceeding on the requestors/petitioners interest.

Petitioners believe that if Pilgrim is allowed to operate for an additional twenty years without redoing its SAMA, that would justify the cost of taking the mitigation steps that would be required by making correct assumptions regarding both the probability of containment failure and subsequent larger offsite consequences due to failure of the DTV to operate, that there will be an unacceptable risk to the environment jeopardizing the health, safety, property and finances of Petitioners' members who live, recreate, conduct business and own property within the vicinity of the Pilgrim Nuclear Power Station. The motion thereby addresses a new and significant public safety and environmental issue.

5. The availability of other means for protecting the petitioner's interests.

None of the factors suggesting other means referred to in Sec. 2, 10.3.3.3E Factor #5 of the NRC Digest are present here. There is no state judicial forum or other NRC licensing procedure to which Pilgrim Watch can take its concerns regarding to provide the necessary reasonable assurance that public health and safety shall be protected during license renewal.

(See, Private Fuel Storage, L.L.C. (Independent Spent Fuel Storage Installation), LBP-00-23, 52 NRC 114, 121-122 (2000)). The suggestion that an organization could adequately protect its interest by submitting a limited appearance statement gives insufficient regard to the value of participational rights enjoyed by parties - including the entitlement to present evidence.

Similarly, assertions that the organization might adequately protect its interest by making 26

witnesses available to a successful petitioner or by transmitting information in its possession to appropriate State and local officials are without merit. Duke Power Co. (Amendment to Materials License SNM-1773 -- Transportation of Spent Fuel from Oconee Nuclear Station for Storage at McGuire Nuclear Station), ALAB-528, 9 NRC 146, 150 n.7 (1979). NRC Digest, Prehearing Matters, 38. And a petition under 10 C.F.R. § 2.206 for a show cause proceeding is not an adequate alternative means of protecting a late petitioner's interests.... Washington Public Power Supply System (WPPSS Nuclear Project No. 3) ALAB-747, 18 NRC 1167, 1175-1176 (1983). See Florida Power and Light Co. (Turkey Point Nuclear Generating Plant, Units 3 and 4), LBP-90-5, 31 NRC 73, 81 (1990), aff'd, ALAB-950, 33 NRC 492, 495-96 (1991). After all, despite the long history of §2.206, the number of successful petitions brought under that section is extremely small. Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Units 2 and 3), LBP-05-16, 62 NRC 56, 67 (2005) (Id.)

6. The extent to which the petitioner's interest will be represented by existing parties.

The other parties to this proceeding are Entergy and the NRC Staff. Throughout this proceeding both NRC Staff and Entergy (in concert with each other) have consistently opposed Pilgrim Watchs interests. There is no reasonable basis to expect that leopard will change its spots. The NRC has accurately recognized that, In weighing the [sixth] factor, a board will not assume that the interests of a late petitioner will be adequately represented by the NRC Staff. The general public interest, as interpreted by the Staff, may often conflict with a late petitioner's private interests or perceptions of the public interest. Washington Public Power Supply System (WPPSS Nuclear Project No. 3), ALAB-747, 27

18 NRC 1167, 1174-1175 n.22 (1983).

NRC Digest, Prehearing Matters, 35; see also NRC Practice Digest, Prehearing Matters 33:

Participation of the NRC Staff in a licensing proceeding is not equivalent to participation by a private intervenor.

The Board accurately summarized the realities in Turkey Point (NRC Practice Digest, Prehearing Matters, 34-35):

To what extent will Petitioners' interest be represented by existing parties?" must be answered, "None."

7. The extent to which petitioner's participation will broaden the issues or delay the proceeding.

The issue presented by this contention - new and significant information regarding the increased probability of a severe accident due to failure of the DTV with larger offsite consequences that would justify additional mitigation to provide the necessary reasonable assurance that public health and safety shall be protected during license renewal - The ASLB has not looked at this before.

However, this factor includes only that delay which can be attributed directly to the tardiness of the petition. Jamesport, supra, ALAB-292, 2 NRC at 631; South Carolina Electric and Gas Co. (Virgil C. Summer Nuclear Station, Unit 1), LBP-81-11, 13 NRC 420, 425 (1981).

Here, there is nothing tardy about Pilgrim Watchs petition to add this new petition. It is based on information that became public only a short time ago.

28

8. The extent to which petitioner's participation might reasonably assist in developing a sound record.

Absent Pilgrim Watchs participation, it is apparent that neither any other party nor the Board will develop any record whatever regarding the subject of this contention.

Pilgrim Watch intends principally to rely upon government and licensee documents of record, and testimony from Arnold Gundersen, nuclear engineer. His Declaration is attached.

The Petitioner satisfies 10 C.F.R 2.309(d), Standing: The Petitioner already is a party to this hearing and has satisfied the requirements.

9. Pilgrim Watchs motion shows that a materially different result would be likely had this new and significant information been available to consider initially 26. The offsite consequences, without addressing the deficiencies cited in the foregoing, would far outweigh the cost of mitigations to reduce risk of containment failure.

In its SAMA analysis for PNPS, Entergy assumed very low probabilities, not only that any accident would occur at all, but also that in the event of an accident there would not be:

pressure-build up within the containment; a significant delay in even attempting to vent the containment because of operator error; failure/inoperability of the Direct Torus Vent; and catastrophic failure of the containment and offsite consequences/costs. The NRC years ago recognized that Mark I failure within the first few hours following core melt would appear rather likely;" a 90% likelihood of containment failure.

The events at Fukushima showed that there is an equally high likelihood that the supposed fix, the DTV, will fail also. Three Direct Torus Vents should have opened, one at 26 This satisfies re-opening the record, in an abundance of caution, although we argue that is not required.

29

each of three Fukushima Mark I reactors. All three failed to do so; and, as expected, all three containments failed.

Entergys prior SAMA analysis, based on hopeful, purely theoretical facts was plainly inadequate. It must be required to conduct a new analysis - based on what Fukushima has taught about reality. And in so doing, the fixes recommended would be cost effective to reduce very significant and unnecessary risk.

PW Does Not Seek To Reopen the Record As Entergy did in opposing PWs New Contention filed November 29, 2010, Entergy (Entergy Op. 10-14) and the NRC Staff (Staff Op 4-8) and did again in their oppositions to PWs New Contention filed on Cables filed December 13, 2010, we expect once again that Entergy and NRC Staff will start any argument with this contention that PW has not met the requirements for reopening the record under 10 C.F.R. §2.236. As before, Entergy and the Staff would be wrong; and the subject is made mute anyway because Pilgrim Watch also has satisfied the criteria to reopen.

Rule 2.236 is clear. It applies to A motion to reopen a closed record. The Rule does not apply here, for a simple reason - the record in this proceeding has not been closed. The evidentiary record relating to Contention 1 was, as the Staff says, closed some time ago. But Pilgrim Watch does not seek to introduce any new evidence as to Contention 1; rather it seeks to add a new, in scope, contention to the proceeding.

The record in this proceeding (as contrasted with the record for Contention 1) unquestionably has not been closed. Further, third criteria - that a materially different result would be likely - simply would show why Rule 2.236 does not apply; the new contention does not involve any prior result.

30

In short, the record in this proceeding is open until and unless the Board and the Commission close it with respect to everything involved in this proceeding. The record before this Board remains open. There is no need to reopen it; and Sec. 2.326 is not applicable.

National Environmental Policy Act Further, National Environmental Policy Act, NEPA, 42 USC § 4332, requires that the ASLB look at new and significant information in order to help public officials make decisions that are based on understanding of environmental consequences, and take decisions that protect, restore and enhance the environment. 40 CFR § 1500.1(c) (Emphasis added)

Sua Sponte Last, this contention should be accepted even if the record had been closed. This Board has the duty to reopen sua sponte when [it] becomes aware, from any source, of a significant unresolved safety issue or of possible major changes in facts material to the resolution of major environmental issues. See NRC Practice Manual, Post Hearing Matters, 11-12. 27 VI. CONCLUSION As required by NEPA, the ASLB should consider the new and significant information arising from the Fukushima accident brought forward by Pilgrim Watch before deciding whether to approve Pilgrims Application to continue operations until 2032.

Petitioners have brought forward new and significant information from Fukushima showing that properly trained and educated operators did not open the DTVS when they should have because of their fear of the effect of large unfiltered radioactive releases on the population 27 The inclusion of this provision in Post Hearing Matters provides additional evidence that the record is not now closed and 2.236 is not applicable.

31

offsite. Delay would not have happened had the DTVS been filtered. This now-known cause of containment failure could be avoided here for $3,000,000 - the estimated cost of a filter.

Further, at Fukushima when operators finally tried to vent they were unable to do so due to power failure and later inability to manually open the DTVS because of high radiation.

Discovery developed over this proceeding is likely to point out additional mitigation.

The likely offsite costs of containment failure/hydrogen explosions would outweigh the cost of mitigation. The cost to public health and safety justify a board decision to accept this contention.

Respectfully submitted, (Electronically submitted)

Mary Lampert Pilgrim Watch, pro se 148 Washington Street Duxbury, MA 02332 Tel. 781-934-0389 Email: mary.lampert@comcast.net June 1, 2011 32

APPENDIX A AFFIDAVIT OF ARNOLD GUNDERSEN

1. I have been retained by Pilgrim Watch to provide expert services in connection with the above captioned matter, an application to add 20 years to the operating license of Pilgrim Station.

2. I have personal knowledge of the facts contained in this Declaration.

3. I have a Bachelors and a Masters Degree in Nuclear Engineering from Rensselaer Polytechnic Institute (RPI) cum laude

4. I began my career as a reactor operator and instructor in 1971 and progressed to the position of Senior Vice President for a nuclear licensee. A copy of my Curriculum Vitae is attached.

5. I have qualified as an expert witness before the NRC ASLB relating the proposed uprate at the Entergy Nuclear Vermont Yankee Nuclear Power Station and before the State of Vermont Public Service Board regarding that same matter.

6. I was an author of the first edition of the Department of Energy (DOE) Decommissioning Handbook.

7. My more than 35 years of professional nuclear experience include and are not limited to:

Nuclear Plant Operation, Nuclear Management, Nuclear Safety Assessments, Reliability Engineering, In-service Inspection, Criticality Analysis, Licensing, Engineering Management, Thermohydraulics, Radioactive Waste Processes, Decommissioning, Waste Disposal, Structural Engineering Assessments, Cooling Tower Operation, Cooling Tower Plumes, Nuclear Fuel Rack Design and Manufacturing, Nuclear Equipment Design and Manufacturing, Prudency Defense, Employee Awareness Programs, Public Relations, Contract Administration, Technical Patents, Archival Storage and Document Control.

8. My declaration is intended to support Pilgrim Watchs Request for Hearing and is specific to issues regarding the inadequacy of Pilgrims SAMA analysis. The SAMA does not consider new and significant issues raised at Fukushima regarding the lack of containment integrity of Pilgrims Mark I and demonstrated failure of the direct torus vent designed to save containment during pressure buildup.

9. I have reviewed the Request for Hearing and support its content.

10. I am qualified to testify in support of this Request for Hearing.

11. I served as an expert witness for Pilgrim Watchs motion to intervene regarding the insufficiency of the aging management plan for buried pipes/tanks; and became familiar with Pilgrim Stations subsurface environment and its effect on corrosion. This applies directly to Pilgrims buried DTV piping.

12. Also, for more than six years, I have disputed the NRC's stand that containment systems simply do not and cannot leak, in testimony and in correspondence with the NRC; events at Fukushima have proven my testimony as true.

13. The explosions at Fukushima show that Pilgrims DTV is unlikely to save Pilgrims containment and huge amounts of radiation will be released. The subsequent offsite costs incurred from such an event justify additional mitigations to reduce the risk of DTV failure and loss of containment.

Executed in Accord with 10 CFR 2.304 (d),

(Electronically signed)

Arnold Gundersen, MSNE, RO Fairewinds Associates, Inc Burlington, Vermont 05408 Tel: (802) 865 9955 Email: contact@fairewinds.com Date: June 1, 2011 34

EXHIBITS (Listing of appendices filed separately on hearing docket, June 1, 2011)

Exhibit Title 1 Pilgrim Nuclear Power Station Individual Plant Examination for Internal Events Per GL-88-20, Volume 1, Prepared for Boston Edison Co., September 1992, pg, 5.0-13 2 U.S. Reactor Owners See Retrofits to Avoid Blasts, Bloomberg, Mehul Srivastava, Jim Polson and Rachel Layne - May 19, 2011 3 September 20, 1972 : memo from Steven Hanauer recommends that U.S. stop licensing reactors using pressure suppression system; September 25, 1972: memo from Joseph Hendrie (top safety official at AEC) agrees with recommendation but rejects it saying it "could well mean the end of nuclear power..."

4 Faulty hydrogen vents at Fukushima Daiichi spell trouble for US nuclear plants as well, Bellona, Charles Digges May 18, 2011 5 Chairman Kenneth M. Carr, Responses to Concerns raised by W.R. Griffin, June 21, 1990, Enclosure 2, Response to Question 2, page 5 6 Containment of a reactor meltdown, From the Bulletin Archives: Containment of a reactor meltdown, by Frank von Hippel, 16 March 2011. The original article authored by Jan Beyea and Frank von Hippel appeared in the September 1982 issue of the Bulletin 7 Hidden Dangers: Japanese Officials Ignored or Concealed Dangers, NYT, Hiroko Tabuchi reported from Tokyo, Keith Bradsher from Hong Kong, and Matthew L. Wald from Washington, May 17, 2011.

8 Importance of Venting, When a Reactor Threatens to Blow Its Stack, Matthew L.

Wald, May 19, 2011, http://green.blogs.nytimes.com/2011/05/19/the-importance-of-venting-when-a-reactor-threatens-to-blow-its-stack, 9 Fukushima had new vents, but the system failed, May 18, 2011, http://joewein.net/blog/2011/05/18/fukushima-had-new-vents-but-system-failed/

10 U.S. Was Warned on Vents before Failure at Japans Plant, NYT, Matthew Wald, May 18, 2011 11 Boston Edisons Initial Assessment of Pilgrim Safety Enhancement, Section 3.2, Installation of DTVS 12 Attachment to BECO letter 88-126, Section 3.2 Revision 1 Installation of a Direct Torus Vent System (DTVS) pages 14,-19B, Rev. 1 (7/25/88) 35