ML18016A907

Discusses 990122 Ltr from DA Lochbaum Re Opposition to Proposed Wet Storage Capacity Expansion by CP&L at Shearon Harris Plant

ML18016A907
Person / Time
Site:	Harris
Issue date:	03/11/1999
From:	Singh K HOLTEC INTERNATIONAL
To:	Shirley Ann Jackson, The Chairman NRC COMMISSION (OCM)
Shared Package
ML18016A906	List: ML18016A907
References
NUDOCS 9904190145
Download: ML18016A907 (6)

Text

Holtec Center, 555 Lincoln Drive West, Marlton, Nj 08053 Telephone (609) 797-0900 Fax (609) 797-0909 March 11, 1999 The Honorable Dr. Shirley A. Jackson Chairman, U.S. Nuclear Regulatory Commission White Flint Building 11555 Rockville Pike Rockville, MD20852

Subject:

January 22, 1999 Letter from David A. Lochbaum, Union of Concerned Scientists, to Chairman Shirley A. Jackson ct al.

Dear Chairman:

I read Mr. Lochbaum's letter dated January 22, 1999 addressed to you and other Commissioners on the matter of his opposition to the proposed wet storage capacity expansion by the Carolina Power Ec, Light Company (CPAL) at its Shearon Harris Plant.

Mr. Lochbaum's letter, written on the Union of Concerned Scientists'tationary, misconstrues a fundamental notion of science probability to deliver an acerbic attack on the,USNRC and CPAL...,

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• CPkL.posited.and.the USNRC agreed that'the probability of a" &el handlin'g ac'cident would not:be significantly incieased upon expansion of the in-pool spent fuel storage capacity ifall parameters (equipment, operator experience, procedures, quality assurance, etc.) remained unaltered. CPSs proposition is founded on the very fundamentals of the notion of statistics. Probability, as defined in the theory of random phenomena, is a dimensionless quantity: The probability function does not change unless the variables attendant to it are altered.

Mr. Lochbaum confuses probability with the numerical expectation of a fuel handling event. CPErL and the USNRC understand the axiomatic fact'that the potential for a probabilistic event occurring will increase as the number of activities increases. However, two times an infinitesimal quantity is still infinitesimal. A survey of nuclear plants by our company in 1996 had concluded that the probability of a fuel handling accident occurring in a spent fuel pool is less than what we routinely consider as negligible. Our research showed that there have been only approximately thirty spent fuel handling events in commercial spent fuel pools after more than tens of thousands of assembly movements through,1984; There was no breaching of the fuel cladding or releases of radioactive gases. or. solids;,with the exception of,.a momentary airborne release from an assembly that.was struck..It, should. also be, noted that the existing considerations for, fuel handling accidents are based upon the 40-year plant license duration, not the number'of spent fuel

.assemblies in the pool or how many times they are handled. Furthermore, ifos, were to

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Holtec Center, 555 Lincoln Drive West, Marlton, Nj 08053 Telephone (609) 797-0900 Fax (609) 797-0909 The Honorable Shirley A. Jackson U.S. Nuclear Regulatory Commission March 11, 1999 Page 2 postulate an accidental fuel misplacement or even a fuel drop event, the consequences have been demonstrated under the existing design bases of plants to pose no practical threat to the plant personnel or the general public.

As you know, the risk from damaged spent fuel has been shown to be only a small fraction of the risk fiom core-melt accidents.

Mr. Lochbaum ought to know that commercial nuclear plants are engineered with multiple layers of safety. The spent fuel pool is one of the most robust and safe means to store radioactive materials devised by man. The historical facts attest to the performance of spent fuel pools. Consider the following facts based on over 9,000 plant-years of worldwide wet storage experience:

~ There has never been a case of loss of shielding to the stored fuel in any fuel pool anywhere.

~ There has never been a nuclear'riticality accident in any pool anywhere.

~ There has never been a significant release of radioactivity to the environment due to malfunction of a fuel pool.

Spent fuel pools, fiom a purely technical standpoint, are a fortress of safety with huge, some would say, unseemly, large margins against all potential dysfunction scenarios.

CP&L's Shearon Hams pool is even more conservatively engineered than most other pools. From a purely technical standpoint, the Harris pool system is a particularly poor target for advancing an intervenor's dogma.

"Concerned scientists" with legitimate concern about matters of nuclear safety would preserve their scientific legitimacy only ifthey restrain their overzealous colleagues from using bogus science in the service of the anti-nuclear priesthood.

Flimsy arguments and exaggerations do succeed in convening ASLB hearings, but accomplish little of constructive value. Because of the status of-my company as the nation's pre-eminent supplier of wet storage technology, I have had the tedious task of explaining, fiom the expert witness's chair over the past two decades, the bedrock of safety undergirding the in-pool storage technology to intervenors across the nation. I have

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Holtec Center, 555 Lincoln Drive West, Marlton, Nj 08053 Telephone (609) 797-0900 Fax (609) 797-0909 The Honorable Shirley A. Jackson U.S. Nuclear Regulatory Commission March 11, 1999 Page 3 found that the power of logic and rational suasion always triumphs ov'er inflammatory rhetoric and sweeping allegations.

Despite Mr. Lochbaum's disclaimer, legal intervention in the CPAL's project is already reported to have ensued. This intervention is reminiscent of the National Sierra Club's all-out effort against Diablo Canyon in 1987, and a local group's claims against St. Lucie Unit 1 in 1990. The outcome in both cases was foreordained. Indeed, many of the allegations in the Harris intervention are a rehash of those previously debated and resolved in favor of the utilities. However, many of the same issues will be debated all over again for Shearon Harris. The people in the surrounding community, however, will have an opportunity to learn first-hand how exceedingly safe their plant's fuel storage system really is, which is the only salutary result from a protracted contest between the utility and its recalcitrant opposition.

Sincerely,

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K.P. Singh, Ph.D., PE President and CEO Holtec International KPS:nlm cc (via fax): Mr. Steven Edwards, Carolina Power Ec Light Company

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