ML20046B376
| ML20046B376 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/27/1993 |
| From: | Ochs R MARYLAND SAFE ENERGY COALITION |
| To: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9308040133 | |
| Download: ML20046B376 (3) | |
Text
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Maryland Safe Energy Coalition P.O. Box 33111 Baltimore, MD 21218 410 243-2077 July 27, 1993 Robert M.
Bernero office of Nuclear Safety and Safeguards Nuclear Regulatory Commission Washington, D.C.
20555 Re: Docket No. 72-8 (50-317/318)
Dear Mr. Bernero:
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On March 15 and April 26, 1993, attorneys for the Baltimore Gas &
Electric Company (Shaw, Pittman, Potts & Towbridge) submitted the licensee's responses to our petition to the NRC of December 21, 1992.
In these responses, BG&E claims that they have studied every possible hazard of the LNG facility to Calvert Cliffs, which they have summarized in four scenarios of possibility.
They: conclude that either there is no serious LNG hazard to Calvert Cliffs or the probability of a serious hazard is one.in a million, hence allowable.
We disagree.
The four scenarios of possible hazards posited by l
BG&E have serious weaknesses, especially Scenario III, which is l
totally unrealistic.
It is unrealistic because BG&E studied the failure of only one of the four LNG tanks on shore.
The reality is that if one of these 375,000 barrel tanks exploded, all of them would explode.
A more realistic scenario would beHas follows:
One LNG tank would explode by any one of several-possible causes.
A plane could crash into it.
A tornado could pierce it with a heavy-object.
A projectile could hit it by accident or-design.
The exploding tank would immediately set off explosions in the other three tanks, causing up to a combined 1.5 million barrel i
explosion of LNG.
The concussion to the' nuclear power plant from such a concentration of fuel has not been analyzed by BG&E.
In East St. Louis, the concussion of one exploding rail car containing LNG broke windows on the.other side of.the Mississippi River.
BG&E has failed to report any evidence that the plant and equipment at Calvert Cliffs could withstand a shock wave from Cove Point which would be thousands of times greater in' magnitude.
Would the shock cause' sensitive instruments malfunction?
How much shock can they withstand?
Could safety-backup systems be rendered dysfunctional?
If so, a-loss-of-coolant accident:or reactor moderator control malfunction could cause a' meltdown and explode dangerous' radiation into the atmosphere.
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The f~orce of a 1.5 million barrel LNG explosion would no doubt rip out trees to the southeast of the ISFSI and hurl them onto the ISFSI vaults.
This timber would be in flames.
The forest surrounding the ISFSI would also be ignited by the blast.
The burning timber on top of and next to the vaults would cause the temperature of the canisters to raise above the maximum safe 1
design temperature of the spent fuel and its containers.
This in turn would effect the integrity of the contents, the internal pressure and the longevity of the safe storage of the spent fuel.
The fires would not be able to be quickly extinguished because the more serious urgency of a damaged power plant would require priority attention from emergency personnel.
A variation of this scenario would be if the natural gas leaked from one 375,000 barrel tank but did not explode until it was ignited by something at the power plant.
In this case, the explosion would approximate the characteristics of a fuel-air bomb, which was tested on the Iraqis in the recent Gulf War.
A fuel-air bomb creates great heat and concussion, but it also creates a fire storm which removes all the oxygen from the effected area.
In the Gulf War, Iraqi troops who were not killed by the heat or shock were suffocated in their underground bunkers because the oxygen was sucked out.
At Calvert Cliffs, the oxygen could be sucked out of all but sealed containments.
In this case, personnel could be suffocated to death if not killed by heat or shock.
If automatic scram systems and emergency systems malfunctioned, the reactor could melt down and explode its containment.
We also have questions about the validity of BG&E's other three scenarios.
Scenario I posits that " neutral atmospheric conditions" and a wind speed of 5 miles per hour could lead to a l
flammable concentration up to a maximum of 1.14 miles from a damaged LNG ship.
BG&E failed to say what the situation would be if atmospheric conditions were other than " neutral" (BG&E failed i
to define this term) or if the wind was other than 5 miles per hour toward the power plant.
BG&E concludes in Scenario I that no " overpressure from LNG water reactions" would impact on Calvert Cliffs.
This is a tricky and misleading statement.
Of course, overpressure from vaporization of LNG when it touches the warmer water is no danger.
The
" overpressure" we are worried about is the concussion from a gas explosion.
Statements like the above cause us to wonder about the objectivity and sincerity of BG&E safety studies.
Why doesn't BG&E tell us what the blast impact would be at various distances from a possible explosion?
None of BG&E's four scenarios mention blast imnact.
The NRC's SER of November 1992 states: "The blast pressure due to a potential explosion associated with the Cove Point LNG facility will be part of the analysis performed by BG&E, which is to be submitted 60 days prior to the startup of the Cove Point facility" (page 2-18), now planned for 1994 or 1995.
What kind of regulation is this?
How can the NRC maintain credibility with
.such lax standards?
Common sense dictates that the blast pressure analysis must be done before the ISFSI is loaded, not afterwards!
3 Scenario II analyzes the effect of an explosion of 25,000 cubic meters of LNG.
How many cubic meters of LNG does a ship hold?
i BG&E fails to mention that it may hold more than 25,000 cubic meters.
This amount is only a seventh to a ninth of the total contents of the tanks on shore (174,000 to 235,800 cubic meters, depending on the size of barrels: 31 to 42 gallons per barrel).
This scenario claims that a 25,000 cubic meter explosion "would not cause any fire hazards" but again ignores blast impact.
Scenario IV claims that a release of 25,000 cubic meters of LNG from a ship crash in the main channel 5.7 miles from Calvert Cliffs would allow a vapor cloud to travel 4.8 miles, again "under neutral atmospheric conditions."
They claim that NRC agrees with this assessment.
How far would the vapor cloud go if more than 25,000 cubic meters were released?
They do not say.
The BG&E probability study of a main channel ship crash was concluded to be a chance of one in a million.
This reminds us of similar probability studies of a meltdown at Three Mile Island before the accident.
What if a plane crashes into the LNG ship or shore tanks?
That was not considered in the probability study.
This area is on a major north-south commercial aircraft route.
It is also within 10 miles of three airports.
No probability study was conducted concerning the four LNG tanks on shore.
Who is going to credibly assign probabilities on whether an agent would deliberately fire a projectile into these tanks in order to cause a reactor accident when the wind is southeast in order to force the evacuation of the nation's capitol, possibly during an international crisis?
After the World Trade Center bombing and other conspiracies, who is going to accept such risks?
Now that the United States is unequaled on any battlefield in the world, we should expect attacks at the most vulnerable points, that is, at nuclear facilities, especially near strategic centers.
Motivations are plentiful.
Even agents hoping to advance a ally's cause might conspire to blame others for such an attack, hoping to draw the U.S.
into a war against their enemies.
A pyromaniac or deranged person can also be a threat.
The BG&E study, mandated by the NRC, is incomplete.
The petitioners of December 21, 1992, request that all the safety questions concerning the ISFSI at Calvert Cliffs be studied completely before any spent fuel is transferred to the vaults.
For the Petitioners, ct~r o
Richard Ochs Director, MSEC j
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