ML13210A452
| ML13210A452 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/26/2013 |
| From: | Lampert M Pilgrim Watch |
| To: | Borchardt R NRC/EDO |
| References | |
| LTR-13-0641 | |
| Download: ML13210A452 (12) | |
Text
July 26, 2013 Mr. James Borchardt Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 By Mail & Email: NrcExecSec@nrc.gov FOLLOW-UP TO PRB MEETING OF JULY 19, 2013 PILGRIM WATCH 2.206 PETITION TO IMMEDIATELY SUSPEND THE OPERATING LICENSE OF PILGRIM STATION UNTIL THE PROVISIONS OF EA-12-050 AND EA-13-109 ARE FULLY IMPLEMENTED, VENTS AUGMENTED WITH FILTERS AND RUPTURE DISCS During the PRB telephone conference of July 19, 2013 the PRB requested Pilgrim Watch to provide further information regarding how long it would take to implement the Phase 1 and Phase 2 Requirement of EA-13-109, and also asked to identify issues brought forward by Pilgrim Watch that should be included in any preliminary or final PRB decision on Pilgrim Watchs 2.206 petition.
A. Implementation EA-13-109 PWs Request for Hearing (at 2) said that, Based on this new and significant information, we respectfully ask the PRB to order Pilgrim to cease operations until EA-13-109 Phase 1 and Phase 2 requirements are implemented. To be consistent, NRC should extend the Order to cease operations to other Mark I and Mark II reactors.
PWs 2.206 demonstrated that the status quo does not protect public health, safety and property; therefore it is not reasonable to delay implementation to no later than startup from the first refueling outage that begins after June 30, 2017, or June 30, 2019. PW said that
implementation in fact could happen far sooner. The further information that the PRB requested on this subject is set forth below.
- 1. A Filtered Venting Containment System is now, and for some time has been, commercially available from AREVA. AREVAs brochure1 explains that it is [e]asy to backfit in part due to compact design; and says that their extensive full system installation experience allows us to complete commissioning one and a half years from date of order. (Emphasis added)
- 2. Pilgrim was the first reactor to install a DTV system. It took approximately 18 months, not 6 years, to install the first DTV system. A Memorandum presented by David Dixon, Town of Plymouth Nuclear Matters Committee to both the Plymouth Selectmen, 07.06.90 and Massachusetts Joint Committee on Energy, 02.27.90 (attached) says that on September, 1987.
Installation of the DTVS vent line is occurring. (Item 8) and on January 1989. The DTVS was made operational. (Item 16)
- 3. Given all the industrys experience with DTV systems over the past 25 years, there is no reason to expect that a second vent could not be installed at Pilgrim in less than 18 months.
Neither is there any reason that such a vent could not be installed simultaneously with the 1
installation of a Filtered Venting Containment system, and that both jobs could not be completed in a year and a half.
- 4. The history of previous time-lines for installations shows that the Filtered Venting Containment System and second vent can easily installed in far less than six years. For example:
Pilgrim received its Special Permit from the Town of Plymouth in 1967 and became operational in 1972; in other words the site was prepared and reactor constructed in less than five years. In the 1990s, the major reactor modification was the alternate decay heat removal system. It took 2-4 years. In the 2000s, the reactor vessel head replacement modification became widespread, taking 2 to 4 years. More recently, the NRC issued three orders in March 2012 for Fukushima modifications with a requirement they be installed no later than end of year 2016 -- a four year deadline.
- 5. PW expects that the core problem is that the NRC's implementation schedule is driven by utility refueling outage schedules by allowing licensees to wait one outage to take measurements and then wait another outage to finally install the vent. There is no basis to build this schedule around outage schedules. It simply requires a shutdown at any time to take measurements and another shut down to install.
- 6. The likely true explanation for the Orders implementation schedule, as PW explained during the conference call, is that NRC wants to delay installation because the cost to install vents would cause shutdowns of plants like Fitzpatrick, VY and Pilgrim. These reactors are in financial trouble because of low prices in their respective deregulated energy markets and the NRC does not want to push some of these reactors into closure. The message to us is that reactor profits from delay mean more than public safety. If NRC wants to prove us wrong, as we sincerely hope, and satisfy its AEA obligations to protect public health and safety then it will 3
require installation in one to one and a half years. Absent the full implementation of filtered and passive wetwell and drywell vents, there is no reasonable assurance; NRC knows this. PWs petition provided 14 direct quotes from the actual orders, EA-12-050 and EA-13-109, that public health and safety are not protected today.
- 7. Starting essentially from scratch, the U.S. built the massive machine needed to win, and won World War II in 4 years. During that period a huge number of battleships and airplanes were built. It took only 16 month to build the Pentagon.
- 8. Any contention that 6 years is needed to install a vent or a filtered vent system is laughable. We recognize that some reactor owners do not want to spend any money. They should be given a choice - either complete installation within 18-24 months, or .permanently cease operations and begin decommissioning within two years.
B. Request Decision Include Discussion of the Following During the PRB teleconference, PW said that any Preliminary and Final Decision should discuss and resolve the following issues.
- 1. Public Health & Safety:
- a. Whether the NRC has a statutory obligation to protect public health and safety.
- b. Whether any of the fourteen (14) quotes from the EA-12-050 and EA-13-109 in PWs petition acknowledging that the status quo does not protect public health and safety were accurate quotes, and whether any of the quotes are themselves in any way inaccurate.
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- c. Whether the NRC Commission assessment that the status quo does not protect public health and safety are incorrect; and if the Commission is incorrect, why.
- d. Whether the AEA requirement to protect public safety means that such protection must be provided now and on an ongoing basis, or whether that protection only has to be provided sometime in the future such as six years later; if the latter, please explain why.
- e. Whether NRCs obligation to protect public health and safety, that the Commission itself acknowledged is not provided now, necessarily includes: (i) requiring mitigation, known to be necessary, so that the reactor would not explode, breach its walls as occurred at Fukushima; (ii) filters so that radiation in excess of allowable limits is not released offsite ;
and (iii) rupture discs on vents to assure that they are passive and will operate absent human intervention.
- f. Eric Leeds introductory letter to licensees accompanying the EA-13-109 said:
NRC staff has determined that continued operation does not pose an imminent risk to public health and safety; however the additional requirements outlined in EA-13-109 are necessary in light of insights gained from the events at Fukushima Daiichi. (pg., 2 letter)
Imminent is defined in the Free Dictionary as About to occur; impending; the Oxford Dictionary defines imminent as about to happen." As used in Mr. Leeds letter, does the word imminent have any different meaning, and if so what is that meaning.
Is the Commissions statement that the status quo does not protect public health and safety correct, or is Eric Leeds statement that continued operation does not pose a risk that is likely to occur at any moment to public health and safety correct. It seems clear that both cannot be right.
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- 2. Filtering The Order also discusses NRCs process for further action on filtering. It says issues relating to filtering will be addressed through the rulemaking process. (EA 109, 5) To understand whether rulemaking is a viable option, petitioners need to know (i) the NRCs complete track record for granting, or not granting, the full substance sought in any rulemaking petition; and (ii) the range of time it has taken NRC to issue a full decision on a rulemaking petition.
- 3. Rupture Discs PWs petition asked that NRC require rupture discs on the vents to make them passive - in order to provide assurance that they would open as needed. The Order itself explains their importance. Attachment 2 in EA-13-109 says that, HCVS Functional Requirements at 1.1.1 The HCVS shall be designed to minimize the reliance on operator actions.
Petitioners request some clarity as to what minimize means. Does it mean the same as Dictionary.com reduce to the smallest possible amount or degree? In the Commissions view, how would a rupture disc in fact minimize the reliance on operator actions?
With reference to Fukushima, the Order itself says:
In particular the operators were unable to successfully operate the containment venting system. These problems with venting the containmentscontributed to thehydrogen explosions that destroyed the reactor buildingsthe loss of various barriers led to the release of radioactive materials that further hampered operator efforts to arrest the accident. (EA-13-109, 2)
Without rupture discs, please explain how this Commissions lesson learned from Fukushima would be satisfied.
We thank you for your attention and we look forward to reading the preliminary and final decisions and any further discussion with you on this matter.
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Respectfully, Mary Lampert Pilgrim Watch, director 148 Washington Street Duxbury, MA 02332 Tel. 781.934.0389 Email: mary.lampert@comcast.net 7
ATTACHMENT Cover to Time Line Document 8
9 10 11 Remsburg, Kristy From: Mary Lampert <mary.lampert@comcast.net>
Sent: Friday, July 26, 2013 12:07 PM To: NRCExecSec Resource Cc: Guzman, Richard
Subject:
PW 2.206 EA-13-109 Follow-Up (07.19.13) PRB 07.26.13 Attachments: PW 2 206 EA-13-109 FOLLOW-UP (07.19.13) PRB 07.26.13 .pdf Hello:
Please find Pilgrim Watchs Follow-Up To PRB Meeting Of July 19, 2013-Pilgrim Watch 2.206 Petition To Immediately Suspend The Operating License Of Pilgrim Station Until The Provisions Of EA-12-050 And EA-13-109 Are Fully Implemented, Vents Augmented With Filters And Rupture Discs.
If you have any difficulty in downloading the attached document, please call Mary Lampert at 781-934-0389.
Please provide notice that the attachment was received and docketed by return email.
Thank you and enjoy the week-end.
Mary 1