ML19276G640
| ML19276G640 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/22/1979 |
| From: | Studds G HOUSE OF REP. |
| To: | Hendrie J NRC COMMISSION (OCM) |
| Shared Package | |
| ML19261E444 | List: |
| References | |
| NUDOCS 7908010204 | |
| Download: ML19276G640 (8) | |
Text
.
ia.'ae m'.u GERRY E. STUDDs GREATER NEW storono 1Stu Di.esicv. M.ss.caewstvts Post Onscs D sen.aeses N
...ns u..
m.
.m.
....-.o.
" " '*'* ".*."."', *.";'c "O*~
- COngrC66 0f fIJC ElliitCD 6IafC6
],[',
m-= ' "
,, o w.
Mouse of Repregentatibes c..-......>
--tm.
x
. M..
-.u n masf;ington, D.C.
20515
. " ' * " " ^ ' ' " ^ ' " ' ' ^ ' ' *
- M EMCH ANT M ARIf 44 AND FISMERIES
- SAPC AND ISLANOS EN ' " "
- N" CMasm u AN
.--,3,=,~g,7= -
rehruary 22, 1979
...m
Dear Mr. Hendrie:
A number of my constituents have contacted me regarding recent g
statements by the Union of Concerned Scientists (UCS) about the y
safety of the Pilgrim I nuclear power plant in Plymouth, i..
-=
The UCS has stated that although the Nuclear Regulatory Commis-sion' found the fire ' protection system at Pilgrim I to be in-adequate, no immediate improvements were required because the 1975 Reactor Safety Study, known as the Rasmussen Report, con-cluded tnat there was little chance a dangerous fire would occur at a nuclear plant.
Now that the conclusions of the Rasmussen Report are being seriously questioned by the NRC, the UCS sug-gests that nuclear power plants which have inadequate fire pro-L..
tection systems should stop operating until improvements have been made.
3 t..
I am enclosing a copy of a statement which I have received from the UCS, I would appreciate it if you would share with me your reaction to the points made therein, especially those relating to the safety of Pilgrim I in Plymouth.
Thank you for your cooperation in this.atter.
I look forward to hearing from you.
.e Si rel J
Gerry E.
StUdds i:
Honorable Joseph M. Hendrie, Chai san Nuclear Regulatory Commission 1717 H Street, N. W.
Washington, D.
C.
20555 Enclosure 7908010 M I
t
,s'"
25
~
- UNION OF CONCERNED SCIENTISTS
.THREE SERIOUS SAFETY HAZARDS WHICH THE NRC HAS NOT ACTED UPON BECAUSE OF PAST NRC RELIANCE ON THE RASMUSSEN REPORT 1.
Safety System Electrical Cables Will Fail in Fire.
Fire is an event expected to occur at a nuclear power plant.
NRC and its consultant agree a fire could disable all the safety systems designed to protect the public.
The cables controlling the safety systems are so highly flamable and located so closely together, a single fire would destroy them all.
(See Attachment 1. )
2.
Safety System Equipment Cannot Withstand Accident it is Designed to Control.
The key safety equipment either has been shown in tests to be unable to withstand an accident or has been tested using worthless testi.
Key safety equipment designed to protect the public against a catastrophic accident will itself be destroyed by that accident.
(See Attachment'2.)
3.
Catastrophic Accidents for Which There is No Protection Required.
For years, the AEC/NRC has refused to require protection for the public against catastrophic accidents on the sole basis that it believed they were of low probability.
This is in direct contrast to the safety philosophy in West Germany, where all protection within the state of the art must be provided without regard to the probability of the accident.
(See Attachment 3.)
e
=
}
SAFETY SYSTEM ELECTRICAL CADLES WILL FAIL IN FIRE Inadequate fire protection in nuclear plants can have catas-Since the Browns Ferry plant fire in 1975, the trophic c'.ects.
NRC has completed a review of fire protection of only 28 operating plants (as of July 6, 1978).
Of those, the NRC determined that there are 12 plants now operating where a fire could destroy all the cables controlling the multiple systems intended to prevent a reactor meltdown.
These plants are:
Brunswick Units 1 and 2 (Southport,, N. C. )
Haddam Neck (lladdam Neck, Conn. )
Oconee Units 1, 2 and 3 (Seneca, S. C.)
' Pilgrim Unit 1 (Plymouth, Mass.)
Rancho Seco (Clay Scation, Calif.)
H.
B. Robinson Unit 2 (Hartsville, S. C.)
Three Mile Island Units 1 and 2 (Middletot rn, Penn.)
Trojan (Prescott, Oregon)
(See Enclosure 1.)
Fire tests sponsored by NRC at Sandia Laboratories in 1977 and at Underwriters Laboratories in September 1978 showed that standards do not provide adequate plant designs meeting current protection against fire.
The NRC's fire protection consultant, Gage-Babcock, also agrees that fire protection is inadequate'in many existing plants.
(See Enclosure 2).
The NRC staff has determined that improvements in fire protection must be implemented, i.e.,..the NRC has determined that "such action will provide The standards were adopted in 1975 and were not applied to p1Lnts
. licensed earlier which have more extreme fire hazards,
'm--
substantial, additional protection which is required for the and safety..'."
(10 CFR Part 50, Section 50.109, public heaint.
Nevertheless, the NRC is allowing these plants to Backfitting.)
(at least until the end of 1980 ini some continue to operate because the Reactor Safety Study said that the proba-instances)
The Commission adopted bility of occurrence of a fire is low.
this Reactor Safety Study finding and stated:
"A probabilistic assessme.t of public safety or risk in quantitative terms is given in the Reactor Safety Study [UASII-14 00).
As the result of a calculation based on the Browns Ferry fire, the study concludes that the. potential for a significant release of radioactivity from such a fire is about 20% of that calculated from all other causes analyzed."
13, 1978, (Commission Memorandum and Order, April page 37.)
With the NRC's withdrawal of the Rasmussen Report as a docu-suitable for regulatory decisions, the commission may find
- nent it necessary to order the shutdown of the nuclear plants until it can establish the technical basis, if any,'for allowing resumption of operation without posing a serious threat to public health and safety.
e S
a
~,
T
.*y_.
- 4 Sae s.
SAFETY SYSTEM EQUIPMENT CAUNOT WITHSTAND j
ACCIDENT IT IS DESIGNED TO CONTROL e
Many safety components needed to protect the public in the event of an accident are located inside the reactor containment i
building.
If these safety systems do not work correctly, a catastrophic accident may occur.
During an accident, this safety equipment is exposed to a severe environment, i.e., very hot steam, high temperatures, high pressures, and high radiation lev'els.
NRC regul*ations require that the safety equipment be tested in a simulated accident environment to prove its capability of operation in a real accident.
However, in many cases tests have not been done.
In other ipstances, the tests were performed according to an industry testing program which, in the words of a senior NRC official, is " worthless" as a basis for determining whether critical safety equipment will operate following a nuclear plant accident.
All plants which were licensed prior to 1974 were licensed on the basis of this worthless standard.
This defective equipment was discovered as a result of the Union of Concerned Scientists' Petition to the NRC of November 1977.
Defective equip-ment was found installed in an absolute minimum of six operating plants including,the following:
D.
C. Cook Unit 1 (Bridgman, Michigan)
,$ Pilgrim Unit 1 (Plymouth, Massachusetts)
Browns Ferry Unit 3 (Decatur, Alabama) lladdam Necx (Itaddam Neck, Connecticut)
Yankee Rowe (Rowe, Massachusetts)
Ginna (Ontario, New York)
- See Enclosure 3.
.-;4 '
Despite.the replacement of specific identified defective equipment, no overall assessment of the remaining equipment in these and other plants has yet been completed.
The NRC's position is that "the likelihood of a major accident reunirinh the per-formance of this equipment is very low."
(Staff Memorandum for the Commission, December 15, 1977, page 36 Appendix B.)
With the Commission's repudiation of the Rasmussen Report, the Com-mission may have to order the shutdown of many nuclear plants to determine what, if any, technical basis exists for allowing resumption of operation.
O e
e O
e e
l-l 9
CATASTROPHIC ACCIDENTS FOR WHICH THERE IS NO PROTECTION REQUIRED For years, the NRC ha's labeled certain accidents as " Class 9,"
i.e., accidents whose probability of o;rurrence[ were deemed so' low as to be " incredible."
Two important points should be made about these accidents.
First, they can have catastrophic consequences, Second, because they were thought to be of low probability, HRC has no requirement to include any protection against the catastrophic consequences of such accidents.
Attempts by concerned citizens to voice concerns about the need' for protection *against accidents such as cracks in reactor vessels were dismissed out-of-hand.
With the NRC repudiation of the quantitative probabilities set forth in the Reactor Safety Study, the Commission must reassess all plant" to determine what accident scenarios were not examined and determine what additional safety features must be added to adequately protect the health and safety of the public.
- Concern is not limited to plants licensed af ter issuance of'the Reactor Safety Study.
The situation is identical to that pre-ceeding the study when agency officials wrote the following:
Associating technically defensible probabilities with Class 9 accidents [a major accident involving large radiation releases) is not possible at this time.
To develop a basis for this is, and has been, the subject of much discussion among the top Regulatory Staff and the Commission.
It will, in my opinipn, require a very substantial technical effort over a-considerable length of time.
(Peter Morris, " Federal Agency Comments on Ac'cident Analysis," AEC internal memorandum, April, 1972.)
~2-Dr. Stephen H. Hanauer, Technical Advisor to the wrote a set of Director of Regulation at the time, notes on the RSS proposal in March of 1972 that All summed up the pr'e-RSS predicament of the AEC..
that could be done in justifying the licenring ' '
nuclear plants while the RSS was " perking along" was just to " wave arms and talk loud."
(Stdphen II.
" Notes on MIT Study Proposal," AEC internal
- Hanauer, memorandum, March 22, 1972.)
e
\\
e O
e e
e O
4 e