ML13126A363
| ML13126A363 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/30/2013 |
| From: | Shadis R New England Coalition on Nuclear Pollution |
| To: | Macfarlane A NRC/Chairman |
| Shared Package | |
| ML13126A364 | List: |
| References | |
| CORR-13-0063, G20130352, LTR-13-0379 | |
| Download: ML13126A363 (6) | |
Text
~<U.S.NRC 1-r-ale ingl'ople and the En£ rom Ticket No: G20130352 w
Assigned Office: NMSS Other Assignees:
OEDO Due Date: 05/21/2013 SECY Due Date: 05/23/2013 Date Response Requested by Originator:
Other Parties:
Subject:
Request that Vermont Yankee be Selected as the Boiling Water Reactor (BWR) Plant if a Pilot Project is Initiated to Test Areas of Fuel Storage Remanded by the Waste Confidence Rule Task Force
==
Description:==
CC Routing: OGC, Regionl ADAMS Accession Numbers - Incoming: ML13126A363 Response / Package: ML13126A364 9
0 0
Cross Reference No: LTR-1 3-379 SRM\\Other: No I IN Action Type: Letter Signature Level: Chairman Macfarlane Special Instructions:
OEDO Concurrence: No OCM Concurrence: No OCA Concurrence: No
- 1.
RAMA-Originator Name: Raymond Shadis Originator Org: New England Coalition Addressee: Chairman Macfarlane Incoming Task: Letter Date of Incoming: 04/30/2013 Document Received by OEDO Date: 05/07/2013 OEDO POC: Yen-Ju Chen
Fri, May 3, 2013 17:09 6
Page No:
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET LTR-13-0379 PAPER NUMBER:
05/02/2013 LOGGING DATE:
ACTION OFFICE:
EDO/OGC Shadis R AUTHOR:
New England Coalition on Nuclear Pollution AFFILIATION:
ADDRESSEE:
Macfarlane A M
SUBJECT:
LTR-13-0379 - Raymond Shadis, Consultant, New England Coalition, Letter re: request that Vermont Yankee be selected as the BWR plant if a pilot project is initiated to test areas of fuel storage remanded by the Waste Confidence Rule Task Force ACTION:
RF Signature of Chairman DISTRIBUTION:
ACKNOWLEDGED:
04/30/2013 Commission Correspondence No LETTER DATE:
SPECIAL HANDLING:
NOTES:
ADAMS FILE LOCATION:
DUE DATE:
05/23/2013 DATE SIGNED:
Raymond Shadis Post Office Box 98 Edgecomb, Maine 04556 Consulting on Nuclear Policy & Environmental Issues For New England Coalition - On Nuclear Pollution April 30, 2013 Chairman Allison M. Macfarlane U.S. Nuclear Regulatory Commission Mail Stop 0-16 G 4 Washington, DC 20555-0001
Dear Chairman Macfarlane,
This letter is prompted by the anticipated draft of the new Waste Confidence Rule and by your personal interest as a geologist in seismic issues within NRC purview. In this case, I refer to seismic analysis of spent fuel pool storage risk.
Some years ago, I participated in numerous workshops and meetings at NRC, all leading to the publication of NUREG-1738 "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants." I dont know if you have read the study, so please bear with me as I go on.
Most NRC Commissioners at the time (2000-2001) hated the study because they thought it be overly conservative -in the extreme. To be fair the report was largely a compilation of existing literature, at the time conservative itself.
The report does make several interesting points regarding spent fuel pool vulnerabilities and the potential consequences of spent fuel accidents consequences that would appropriately be consulted in formulating considerations of risk within the new Waste Confidence Rule.
Hoping to attract your interest to the entire report and to the plight of my employer, New England Coalition and its members and constituents in Vermont, I have appended to this letter an excerpt of NUREG-1738 -Attachment 3 Response to Questions Concerning Spent Fuel Pool Seismic-Induced Failure Modes and Locations and the Expected Level of Collateral Damage by Robert P. Kennedy [PhD, NRC Consultant]
September 2000
2 This expert opinion in turn is largely drawn from NUREG/CR-5176, Seismic Failure and Cask Drop Analyses of the Spent Fuel Pools at Two Representative Nuclear Power Plants, 1989.
As with NUREG/CR -5176, over the years numerous NRC studies and regulatory initiatives have done pilot projects at selected representative plants. Please consider deploying such pilot projects to test those areas of fuel storage remanded by the waste confidence rule task force to the site specific category as well as such generic issues as may be identified.
If NRC should decide on a pilot project, I respectfully request that Vermont Yankee be selected as the representative BWR plant.
This selection would serve science to follow on the Vermont Yankee data considered in NUREGs 1738 and CR-5176.
Moreover Vermont Yankees selection as a representative pilot plant would to some extent serve justice as Vermont Yankees license was one of the very few renewed between issuance of the remanded Waste Confidence Rule and NRCs moratorium on new licenses and license renewal. Vermont Yankee license renewal intervenors, including the State of Vermont and New England Coalition were thus denied an opportunity to represent those concerns occupied by the 2010 waste confidence rule that my now be open to exploration.
I would be please to discuss all this further by phone or in person at your convenience.
Thank you for your kind attention, Raymond Shadis For New England Coalition 207-882-7801 207-380-5994 (c)
Scanned and Extracted from the Original by Raymond Shadis for New England Coalition U.S.NRC NUREG-1738 Spent Fuel Pool Accidents Risks at Decommissioning Nuclear Power Plants Response to Ouestions Concerning Spent Fuel Pool Seismic-Induced Failure Modes and Locations and the Expected Level of Collateral Damage By Robert P. Kennedy
[PhD, NRC Consultant]
September 2000 Ref. 1 presents seismic fragility estimates for the Vermont Yankee (BWR) and Robinson (PWR) spent fuel pools. These two fragility estimates are the only spent filel pool fragility estimates that I have seen. Therefore, my judgment is heavily based on the results presented in Ref. 1.
For Vermont Yankee (BWR), Ref. 1 states that the critical failure mode for the gross structural failure of the pool is an out-of-plane shear failure of the pool floor slab.
With this failure mode, the liner will be breached and a large crack will develop through the concrete floor slab within a distance equal to the floor slab thickness from the pool walls. Possibly the entire floor will drop out, but I think that such a gross failure is unlikely. However, the concrete crack will be sufficiently large that the water in the pool will quickly drain out.
Although not reported as the critical failure mode in Ref. 1, my judgement is that for BWR pools, it is at least equally likely that the critical failure mode will be an out-of-plane shear failure of one or more of the pool walls. With this failure mode, the liner will be breached and a major concrete crack will form along the length of the wall within a wall thickness distance from the top of the floor slab. Water will quickly drain out of the pool. However, as much as 4-feet of water depth will likely remain within the pool.
No matter which of these failure modes occur, drainage of the pool is expected to be fairly rapid. A small, but uncertain, amount of water is likely to remain in the pool with post-seismic-failure water depths ranging from essentially zero depth to about 4-feet of depth depending upon the critical failure mode.
For a 0.75g PGA scenario ground motion, I would expect less than about a 10%
chance of the spent fliel pool failing, about a 90% chance that offsite power is lost, and
more than about 50% of the CEUS buildings and bridges being unsafe for even temporary use. At this ground motion level which is within the region of ground motions that dominate the estimated seismic risk of spent filel pool failures, sufficient power, buildings housing communication systems and emergency services, and bridges will be out-of-service that emergency responses will most likely have to be ad-hoc. Specifically, for ground motion levels that correspond to spent fliel pool failure, within at least 10 miles of the plant I would expect power to have been lost and more than about 50% of the CEUS bridges and buildings (including those housing communication Systems and emergency response equipment) being unsafe for even temporary use.
- 4. Reference
- 1. Seismic Failure and Cask Drop Analyses of the Spent Fuel Pools at Two Representative Nuclear Power Plants; NUREG/CR-5176, Prepared for Nuclear Regulatory Commission, January 1989