ML19260A095
| ML19260A095 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/03/1977 |
| From: | Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | Gilinsky V NRC COMMISSION (OCM) |
| Shared Package | |
| ML19260A094 | List: |
| References | |
| NUDOCS 7910290714 | |
| Download: ML19260A095 (2) | |
Text
,
s.
M
[ '.'
UNION OF CONCERNED SCIENTISTS January 3, 1977 U.S. Nuclear Regulatory Cossaission DRRID)
- g, }
Cermissioner Vister-Qilimsky d
W shington, D.C. 20555 U U im u b n
=>
9 L' ear Comissiemer:
We received the emelesed document from an individual who wishes to remain amanymous. We are sending it to you in the hope that the Nuclear Regulatory Cerenission will take prompt action to protect the health and safety of the public from the known risks discussed in the document.
The docunemt terrectly indicates that the somsequences of a fuel handling accident inside the reacter sentainment building are met eensidered by the XRC 5 deciding whether a muelear power plar.t should receive a lisease. In addition, the desument indientes that Westinghouse believes that a fuel handling accident inside sentain-meat seuld result in radiatism deses to the publie in excess of 10 Cm Part 100 limits, i.e., in excess of 25 rem to the whole body and 300 rem to the thyroid.
In view of these statements, it appears that a fuel handling accident inside sentainment is an "umreviewed safety questiem" and a "significant safety hazard."
VTe recomend that the MRC review the design and precedures of each enerating zuelear newer plant to detemine whether a fuel handling accident inside sentain-ment will result in deses that "are well within the guideline values of 10 CFR Part 100," as specified in Section 15.7.h of the Standard Review Flam. Until such reviews are commleted, we believe that the NRC should issue orders to halt all refueling enerations in progress and to prohibit all future refueling opera-tiens. In addition, we believe that it is appropriate for ths NRC to initiate investigations to detemine whether Sestien 206 of the Energy Reorganization Act of 197h has been violated by individual directors er responsible effisers of Westinghouse and other firms which received the emelesed document.
We would appreciate hearing from you prematly regarding the action that NRC will take to resolve this matter. We also would like an explanation of the reasons for NRC met previously requiring analysis of a fuel handling accident inside containment and the stens that will be taken to correct this deficiency in the licensing process.
By esyy of this letter, we are also sending the enclosed document to the chaimen of the Advisory Comittee en Reacter Safeguards, the Atomic Safety ai d L4 ns 3
4/
Board Panel and the Atomie Safety and Licensing Appeal Panel.
Simeeroly,
/r Robert D. Pollard 1208 Massachusetts Avenue. Cambridge, Massachusetts 02138 Telephone (617) 547-5552 39102007/
d
[L,
~
~'
- /: ). '
~
As you are aware, a fuel handling accident in the spent fuel storage building
~~
is analyred in plant' Safety Analysis Reports.
The assumptibns utilized for this analysis are outlined in Regulatory Guide 1.25, " Assumptions Used for Evaluating the Potential Consequences of a Fuel liandling Accident in the Fuel Handling and Storage facility."
The off-site consequences of this. accident are compared to 10CfR100 limits of 300 rem to the thyroid and 25 rem whole body dose in the' Safety Analysis Reports.
In addition, the i;RC compares the resultant doses with unofficial limits of 30 rem to the thyroid and 5 rem whole body dose.
However, a fuel handling accident inside the containment is not addressed in the Safety Analysis Reports, other than indirectly in Standard Tech Specs.
W is not aware of the f;RC bases for not 5ddressing a fuel handling
- accident inside con-tainment, the bases may include:
1.
The assumption that the containment will be isolated during refueling opera tions; 2.
that the containn:ent could be isolated quickly enough to limit off-site Consequences; or 3.
that filtration capability comparable to that in fuel storage building exhausts exists in the containment purge exhaust.
These bases are similar to t' e bases used to address the fuel handling accident h
in the fuel hundling building.
Information availabic to us, including results of scoping analyses using very conservative assu stions based upon Regulatory Guide 1.25, indicates that site boundary doses in excess of exposure guidelines set forth in 10CFR100 could result from a fuel handling accident inside containment, if one assumes no credit for containment isolation, iodine filtration, or mixing within containment.
In addition to using Regulatory Guide 1.25 assumptions in'the scoping analyses, we assumed operaticn of systems which would result in the most conservative dose.
For exa".;1e, it was assured that a push-pull tycc or exhaust only sweep ventila-tion system is in operation over the refueling canal so that activity releases are routed im:ediately to the purge exhaust.
Much of the inforration required to do an evaluation for specific plants is not available to us. We do recor.nend, nowever, that you evaluate the consequences of this potential incident to assure that unacceptable doses are not a probable result.
Since the f RC regulations do not require the analysis, we do not believe this situation requires reporting to the NRC unless your engineering evaluation shotts unacccatable results.
In accomplishing the evaluation for your plant, we recctrend t".:t you use Regulatory Gaide 1.25 assumptions or other conwrvative justificele parainaters.
We also believu that ya should not (M.e credit for the function of ary system or component that is not qualified for operation during this particular incident.
For example, we think you might take credit for equip-rnent not qualified for the post accident containtaent environment but seismic qualification may very well be required.
Please feel free to contact us if further information or assistance is required.
1479 304
.