ML20059P053
| ML20059P053 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Zimmer, Crane  |
| Issue date: | 10/15/1990 |
| From: | Sinclair M AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-55FR29043, FRN-56FR64943, RULE-PR-2, RULE-PR-50, RULE-PR-54 55FR29043-00071, 55FR29043-71, AD04-2-124, AD4-2, AD4-2-124, NUDOCS 9010250057 | |
| Download: ML20059P053 (4) | |
Text
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5711Summerset Drive 0
Midland,MI 48640 October 15.1990
'90 DCT W A10:00 l
.l Secretary of the Commission U.S. Nuclear Regulatory Commission
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naAwcu Washington,DC 20555 j
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Attention: Docketing and Service Branch l.
RE: Nuclear Power Plant Licensing Renewal Rulemaking The current plans of the Nuclear Regulatory Commission (NRC)'to promulgate a rule that will extend nuclear plant licenring beyond 40 years can have grave pub!Jc health and safety l
l implications for the country because of the flawed assumptions on which this renewalis i
based: 1) that the current lloensing basis for each operating plant is adequate to provide reasonable assurance of safe operation, and 2) that each operating plant complies with its tioensing basis.
I In regard to the first assumption that the licensing basis is adequate to provide reasonable assurance of safe operation, I would like to point out that in the final days of hearings of the operating license hearings of the now defunct Midland nuclear plant the glaring deficiencies of the licensing process became very clear. All the safety systems of the i
1 Midland plant had been shut down because an inspection team of the NRC had found serious deficiencies in the whole quality control program at the Midland plant. It was going to take 150,000 re inspections to demonstrate that the safety systems were adequate, in spite of l
this state of affairs, the Atomic Safety and Licensing Board for Midland insisted on i
proceeding whh the operating license. The expert witnesses that they brought in were asked if they had direct and personal knowledge that the questions as to whether the !
systems they were describing as adequate were indeed the way they were constructed at the Midland plant. Their response was no", that they could not vouch for this. They were!
asked if they had conversations with the inspectors at the p ant who would have first-hand knowledge of the construction of these safety systems. Their response to that was also that:
they had not had these conversations. It turned out that the expert witnesses for the NRC i
were describing the design of the plant that they had studied in Washington prior to comin i
to Midland and not what was actually constructed at the Midland plant site.
Similarly, the Zim mer plant in Ohio was licensed to operate by the NRC when a whistleblower was able to point out many serious defects in the plant. A specialinspectiof I
team was sent out to explore these allegations and found that they were true. It was i
i subsequently discovered that it would take over a billiM dollars to correct these deficiencies and the utility decided to shut the plant down rather than continue with the repairs j
required.
t These two incidences demonstrate that there is and has been a fundam licensing procedure of the NRC and demolishes their claims that their licensing basis for ea operating plant is adeounte.
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j 6pNT ST.N103 TEL:2-517-835-3891 Oct 15 90 21:11 No.002 P.02 1
4 Another example of the laxness of the NRC's regulations is the situation at the Palisades plant. That plant has been permitted to operate since 1971 on a provisional license because it has been unable to meet the criteria for a full operating license. It has also been allowed i
to operate without meeting the safety requirements that were issued following the Three Mile Island accident. To extend the licensing of such a plant would only prove the extent to j
which the NRCis quite willing to risk the public health and safety and the environment in an i
I effort to keep the nuclear industry going.
The most telling example of the fact that the NRC and the nuclear industry does not understand the effects of aging on nuclear plant components subjected to a highly i
radioactive environment is in the steam generator replacement program that is not goint at Palisades and that has taken place at numerous other pressurised water reactors after only a fraction of their licensed life time has been experienced. The fact that materials i
engineers could not anticipate the effect of aging is clear because the design of these plan such that it cannot accommodate steam generator replacement. A hole must be cut in the i
contalement structure itself,with all the attendant weakening that means in the rebuilt containment design,in order to make this replacement possible. Just how other compone 1
nre being affected by aging cannot be gauged as obviously as that in the failure of the stea generators, but it can hardly be denied that such materials failure in a radioactive environment is continuing in other vitalinternal components of the plant.
There are significant safety questions that have been raised within the NRCitself abo the adequacy of the design and construction of U.S. n-plants.
l High in importance among these issues is the clash of opinions on the safety of t reactor containment such as the one at Fermi 82 and numerous other U been argued for years. It is important to note that even as questions of greatest im and. gravity were in the process of being discussed about safety of the Mark I con with warnings coming from some of the most competent and knowledgeable scientists within the NRC itself, the regulatory branch and the NRC Commissioners gave a fu license to Fermi *2.
The degree to which the U.S. NRC is far more far in its regulation of U.S. nucl than are the requirements and practice for the regulation of the German, $wiss and reactor program has become known. Some previously unpublicised portions of the 19 Reed report prepared by GB were inadvertently disclosed under discovery iri the l over the Zimmer plant in Ohio. Some of the areas disclosed in that report in which and Swiss regulators are far more stringent than their U. S. counterparts are in better redundant safety backup systems; better security requirements to pre in the physicallayout of the plant; and better automation for the unattended react the crew was disabled.
There have also been a series or scandals in the NRC that have i
investigations that indicate the regulators at the highest levels have acted in col the industry they are regulating to forestall significant safety investigations. How c i
nuclear plants have their licenses extended under these conditions?
l The accident at Chernobyl in April,1986, aroused interest in containments in the general g
pub!!c. In the U. S., the NRC completed a draft study in Feb.,1987, of the five different kinds j
of contalnments used in U.S. reactors, including the Mark I, and found that none of the five eystems it studied are foolproof and that some designs are as likely as not to fallin a severe l
accident. Containments are designed to create a barrier against the release of radioactivity to the environment during the worst accident that a nuclear plant is designed to withstand.
The key to understanding the problem is that containments are not required to be designed to remain intact in severe accidents that they were not designed for, such as those involving melting of the fuel. This is what happened at Chernobyl the plant had a containment, one much stronger than many of our nuclear plants,- but the problem was that the accident was more severe than the containment had been designed to withstand, s
Some regulators have raised questions about the Mark I containment since the early 70's.
Because of safety disadvantages, Stephen Hanauer recommended abandonment of thl i
design. However, the chairman of the Commission, Joseph Hendrie, disagreed,--not on the basis of the factual data but because " reversal of this hallowed policy...could well be the end of nuclear power".
Doubts about the Mark I containment continue to this day. Harold Denton, former head of reactor regulation, told an industry trade group in 1986 that the Mark i reactor had a 90%
chance of failure in an accident involving a core meltdown. The NRC staff later developed several recommendations for fixes that would cost in the range of $1 to 3 million per plant.
But the industry argued that the improvements were not justified by the costs, and the NRC has postponed indefinitely a decision on safety improvements. How can the NRC lustify extending the license of nuclear plants under these conditions?
Since the CherNbyl disaster, many European countries have made safety improvements to reduce the chance that a severe accident would breach containment. But the U.S. nuclear industry he: resisted even low-cost safety improvements that the agency itself calculates would reduce severe accident risk by 25 times.
There have been scandals of negligence, laxness, and corruption that we now know are a part of NRC regulatory practices at the highest levels in the U.S. For erample,in 1983,it is now known that important NRC documents relating to quality assurance problems at a nuclear plant were lenked from a Commissioner's office to the licensee. In fact, the licensee distributed the documents to his colleagues with the warning that their further distribution should be limited to " protect the source in the NRC."
l Senator John Glenn has held hearings on this and other violations of regulatory practice.
During those hearings, Julian Greenspan, who has been a federal prosecutor in the U.S.
Department of justice for 15 years made the following statement in regard to NRC regulation:
i
" Based on my extensive experience with the NRC, I can unequivocally state that I know of no other regulatory or investigative agency, where senior agency officials have taken as many blearre and seemingly deliberate actions intended to hamper the investigation and prosecution of individuals and companies in the industry the agency regulates."
At the conclusion of the hearings, Senator Glenn made the following remarks about the 1
Offlee of Inspector and Auditor (OI A), a top level staff created in 1975 to provide
cm o n av v o, o v.r nsrimrsmr. v
- Commissioners with objective information on problems within the Commission: I believe there are serious deficiencies in Ol A's objectivity and investigative practices which have diminshed the effectiveness of the office.... It does not appear that the OIA has been allowed to perform the essential functions of a statutory inspector general office."
Several years ago, when the French government shut down a PWR reactor because of vessel embrittlement problems, a spokesman for the government said, that they would have no problem operating this reactor in the U.S. because American rules on embrittlement are less strict. Embrittlement is an important consequence of the aging of nuclear plants.
Consideration of this one fact alone should preclude the renewal of the licensing of these plants.
In recent years, citizens of the U. S. have finally been informed about how the NRC goes about evaluating its safety problems and how it handles them, so that we now find that there are more safety problems in the U.S. program than there were at the time of TMI. It allis the result of the NRC's own curious definitions. Por example,if an unresolved safety I
system is present in more than one reactor, or in a whole class of reactors, the NRC labels the problem "seneric", By doing so, they can then license that reactor with the idea that the safety problem will be resolved at some future date, but no time table for this is ever set.
As a consequence some of the usost serious safety problems have gone unresolved for years, some for longer than a decade. (UCS, Safety Second, p.15). The mythology soes on--once a problem is termed " resolved", this means only that a solution for the problem has been identified. It does not mean that anything has been installed in the plant to rectify a problem. (UCS, p. 20) And further, when the NRC reports that a generic issue has been
- 1mplemented",lt only means that the utility has agreed to make needed changes, but no actual changes in the plant has been made. (UCS, p. 23)
TWps only a brief summary of the deplorable history of regulation and performance on the part of the Nuclear Regulatory Commission, but it demonstrates why the extension of licenses for U.S. nuclear plants is a threat not only to our public health and safety but to the national security of this country.
Submitted by,
/t e Maryhlacif
_