ML19309B036
| ML19309B036 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/03/1977 |
| From: | Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | Gilinsky V NRC COMMISSION (OCM) |
| Shared Package | |
| ML19309B034 | List: |
| References | |
| NUDOCS 8004020512 | |
| Download: ML19309B036 (2) | |
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'd UNION OF CONCERNED SCIEHTISTS d
January 33 1977 N
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D Ce missioner vieter Giu msky v
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H U.S. Nuolear Regulatory Cessaission Washingten, D.C. 20555 gg7 T
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Dear Comissiemer We rossired the emelesed document from an individual who wishes to rammin We are sending it to yru is the hope that b Nuclear Regulatory amegueus.
Comission will take prompt action to protest the health and safety of the publis from the kaews risks discussed in the document.
The desunsat eerracth inlicates that the seassquences of a fuel handling accident h
inside the reacter saataimmast 1r ilding are met seasidered by the XRC in deciding whether a r.nelaar power plant should receive a liesass. In additism, the desument indisates that Westinghouse believes that a fuel handI'ag accident inside sentain-naat seuld result in radiatism deses to the ra511e in excess of 10 CF2 Pa:t 2CO limits, i.e., in excess of 25 rem to % whole body and 300 ram to the thyrsid.
i; In view of these state =ents, it a2 pears that a fuel handling accider.t inside containment is am *uareviewed safety questism" and a "significant safety hazard."
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We resemend that the NRC review the design and yresedures of each operating zuclear power plant to detemine whet..ser a fuel handling accident insiis sentein-nsat will result in deses that "are vall withix the guidelius values of 10 C7R Until Part 100," as specified im Section 15.7.h of the Standard Review Plan.
such reviews are so-:31sted, we believe that the KEC should issue orders to halt all refurling operations in progress and to prchibit all future refueling opera-tiens. In addibu, we believe that it is appropriate for the liRC to initiate invsr.tigations to dstormine whether Sectiem 206 of the Energy Reerganize.tica Ast of 197h has beer. violated iry individual directors or responsible efficers of Westinghouse and other fims which reesired the enclosed docunext.
Ve would anrasciate hearint: fr:m you pramatly regarding the action the.t ERC will take to rotelvo this matter. We alt,e would like ar. calematien of the reasons fer MRC met previously requiring r.malysis of a fuel handling accident incide containment and the steis that will be ts.kon to correct this deficiency in the licensing process.
By eepy of this letter, we rre c.lco sending the onclosed document to the chairmen of the Advisory Co:=ittes er. Ecacter Safer;uards, the Atomic Safety and licensing Beard Panel and the Atomic Safety and Licensing Appeal Panol.
Sincoroly, gg 4
Robert D. Pellard 1208 Massachusetts Avenuo. Cambridge, Massachusetts 02138. Telephone (617) 547-5552 R00LD2n A/[
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As you are aware, a fcel handling accident in the spent fuel storage buildt:g tr analyicd in plant' Safety Analysts Reco-ts.
The cssumptitns utilized f;r this analysis are outilned in ?cgulatory Guide 1.25. " Assumptions Used for Evaluating the Potential Conscouences of a feel Handling Accident in the Fool' Handling and Storage Facility."
The off-site consequences of this.ac:ident are compared to 10CTR100 limits of 303 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
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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 fiRC bases for not addressing a fuel handling
- accident inside con-tainment, the bases may include:
'The assumption that the. containment will be isolated duEing refueling 1.
operations; 2.
that the ccntainment could be isolated quickly enough to limit off-site conseQucAces* or that filtration capability cob. parable, to(that in fuel storage building 3.
exheusts exists in the containment purge exhaust.
These bases are similar to the bases used. to address the fuel handling accident in the fuct handling building.
Information available to us. including results of scoping analyses using very conservative assur.ptions based uoon Regulatory Guide 1.25, indicates thst site
.. boundary doses in excess of exposure guidalines ret forth in 100FR100 could result from a fuel handling accident inside containment, if one assumac no credit f r contain: cent isalation, iodine filtration, or mixing within containment.
In eddition to using Regulatory Guide 1.25. assumptions in the scooing analyses, we assumed operaticn of systems which would ra: ult in the most conservative dose.
For example, it was assured that a cush-pull tyce or exhaust only sweep ventila-tion system is in ccoration over the refueling canal so that activity r21 cases are routed im:rediately to the purge exhaust.
Much of the infornation required to do an evaluation for specific plants is not ai ailable to us.
We do recor.Tcnd, nowever, that you cvaluate the consequences
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cf this potential incident to assure that unacceptable doses are not a probable result. Since the i:RC regulations do not require the analysis. v.e do not believe this situation requires reporting to the imC unless yeu engin:cring evaiention shows unacceatable results.
In accomplishing the evaluation for your ciant, we recc. Tend t tat you use Regulatory Guide 1.25 assumptions or other conservative justifiable paramaters.
He also believe that you should not tale credit for the function of any system er ccmpenen: that is not qualified for operation during this particular incident.
For 2xample, we think you might take credit for equic-mont not qualified for the post accident containment environment but seismic qualification may very well be required.
Pleass feel free to contact us if further info-mation or assistance is required.
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