ML20148F721
| ML20148F721 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/03/1977 |
| From: | Pollard R UNION OF CONCERNED SCIENTISTS |
| To: | Gilinsky V NRC COMMISSION (OCM) |
| Shared Package | |
| ML20148F710 | List: |
| References | |
| NUDOCS 8011060710 | |
| Download: ML20148F721 (2) | |
Text
-
j m
l 4
(WJ M UNION OF CONCERNED SCIENTISTS January 3, 1977 1
Conmissioner Victor Gilinsky U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Dear Comissioner We received the enclesod document fren an individ'ial who sishes to remain anewymous. We are sending it to you in the he7e thet ths Nuclear Regulatory Cerenission will take 3renst action to protect the health and safety of the iublic from the knemi risks discussed in the docunent.
The docunent eerrectly indicates that the consequences of a fuel handling accident inside the reacter containment building are not eensiured by the NRC in deciding whether a nuclear power plant should receive a license. In addition, the document indleates that Westinghouse believes that a fuel handling accident inside centain-ment eeuld result in radiation deses to the sublic in excess of 10 CFit Part 100 limits, i.e., in excess of 25 rem to the whole body and 3CO rem to the thyroid.
In view of these statements, it an, sears that a fuel handling accident inside
'contaiment is am "unreviewed safety questiem" an1 a "significant safety hazard "
We recenend that the imC review the design and wrecedures of each emerating nuclear newer nlant to detemine whether a fuel handling accident inside contain-ment will result in deses that "are well within the guideline values of 10 CFR Part 100," as asecified in Section 15.7.h of the Standard Review Flam. Until such nyiews are ew.nleted, we believe that the NRC should issue orders to halt all refueling owerations in uregress and to wrehibit all future refueling emera-tiens. In addition, we believe that it is assrepriate fer the tac to initiate investigations to detemime whether Section 206 of the sergy Reorganization Act of 197h has been violated by individual dineters er responsible officers of Westinghouse and other firms which received the enclosed document.
We would anreciate hearing fren you prematly regarding the action that ?aC will take te resolve this matter. We also would like an expl.aation of t he reasons for NRC not wreviously requiring analysis of a fuel handling accident inside containment and the stess that will be taken to correct this deficiency in the licensing.erecess.
By coey of this letter, we are also sending the enclosed decunerd to the chairmen of the Advisory Committee on Reacter Safeguards, the Atomic Safety and Licensing Beard 7anel and the Atomie Safety and Licensing Apneal ? acel.
Sincerely, y
f, tv
/
Robert D. Pollard 1208 Massachusetts Avenue. Cambridge, Massachusetts 02138
- Telephone (617) 547-5552 8011oc o 7/ o
As you are aware, a.fuc. h.tndling accident in the spent uci storage ouilding is. analyzed in plant Safety Analysis Reports.
The assumpti'ons utili:cd for-this analysis arc outlined in Regulatory Guide.1.25. Assumotions Used fop e
Evaluating the Potential Consequences of a Fuel liandling Accident in the Fb'tel llandling and Storage Facility."
The off-site' consequences of this accident are conipared to 10CTR100 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.
1However, a fuel handling accident inside the containment is not addressed in the i
Safety Analysis' Reports, other than1 ndirectly, in Standard Tech Specs.. W is not aware of the. tiRC bases for not addrcssing a fuel handling' accident insidicon-tainment, the bases may include:
1.
The assumption that tne. containment will be isolated during refueling operations ;
2.
that the containment could be isolated quickly enough to-limit off-site
.I Consequences
- ot*
3.
that filtration capability comparable to that in fuel storage building exhausts exists in the containment purge exhaust.
These bases are.similar to the bases used to address the fuel handling accident in the fucl handling building.
Information available te us, including results of scoping analyses using very conservative-assumptions based upon Regulatory Guide l.25, indicates that site boundary doses in excess of exposure guidelines set forth in 10CFR100 could j
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 exangle, it.vas assumed thatra push-pull tycc or exhaust only sweep ventila-tion system is in operation over the refueling canal so that act.ivity releases
.are routed im.:ediately to the purge exhaust.
Much of the information required to do an evaluation for specific plants is not available to us.
We do recommend, newever, that you' evaluate the consequences of this potential incident to assure that unacceptable doses.are not a probable result.
Since the NRC regulations do not require the analysis, v.e do not believe this situation rcquires reporting to the NRC unless your engineering evaluation i
shows unaccostable resul ts.
In accomplishing tne evaluation for yo,'r plant, we recctrend t"at you use Regulatory Guide 1.25 assureptions or othcc con.*ervative
+
justiff acic paramaters.
We also believe that yuu should not td e credit for'the function of any system or component that is not qualified for operation during i
this particular incident.
For example, we think you might take credit for equip-ment not qualified for the post accident containment environment but seismic qualification may very well be required.
Please feel free to contact us if further information or assistance is required.
L
,u.
0
-(
..,