ML20214P796
| ML20214P796 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/19/1986 |
| From: | Davis P NRC COMMISSION (OCM) |
| To: | Clements W NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#386-777 OL, NUDOCS 8609240060 | |
| Download: ML20214P796 (34) | |
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%.',Y,.* SEVED SEP 1.9 1986 OFFICE OF THE . e6 SEP 19 A10:51 CommissiONsa September 19, 1986 0FFL . .. r 00CXE W , J ,cf.
BRANCH MEM0 T0: William L. Clements, Chief Docketing and Service Branch FROM: Patricia R. Davis, Legal Assistant 3 h Office of Commissioner Asselstine
SUBJECT:
SEABROOK PROCEEDING Please serve the attached package of materials on the parties to the Seabrook proceeding.
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Embargoed for release Sunday, O August 24.
press contact:
Stephen B. Comley The Sheraton Grand (202) 628-2100, ext.1517 (Attention editors: The statement below was issued in Washington today by Stephen B. Comley, a leading opponent of the Seabrook, N.H., Nuclear Power Plant, following his meeting with dissident NRC commissioner James K. Asselstine
~
and other Washington officials critical of decisions made by.
the NRC commission majority. Comley feels an obligation to share the conclusions he has reached from these meetings, some public but most private.) -
I
. "It is time to give up on nuclear power plants -
building them is too costly, operating them is too dangerous and disposing of their waste is too problematic "At the 100 nuclear power plants licensed in America, we have not yet suffered our first death despite many accidents ..
- most minor, some scary such as the announced ' incident' at the Three Mile Island plant in Pennsylvania.
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EMBARGOED FOR RELEASE .
"After two weeks in Washington to relay the concerns of ,
my neighbors in northeast . Massachusetts about the nearby Seabrook, N.H., plant, I have become convinced that nuclear poiver plants are a catastrophe waiting to happen.
"We should not wait for our first death, we should not wait for our first catastrophe; we should close our nuclear plants now.
"I have spoken with experts at the Nuclear Regulatory Agency as well as administrative and congressional aides. ,
' Privately, they have shared their concerns with me; publicly, they have not raised their voices in opposition to the nuclear power industry, leading me to conclude that this industry's power is as much political as it is nuclear.
"One exception is Nuclear Regulatory Commission (NRC) member James K. Asselstine, whose courageous and frequent dissents are the only disconsonant notes heard among the pro-industry harmony from the other commissioners.
"Asselstine, a former attorney for the Senate Environment and Pulic Works Committee, spoke to me of concerns about the '
j chances for 'a severe accident.'
"Asselstine added that 'no U.S. utility at the present time is prepared to commit to build a new nuclear power plant.' That is so because of the exorbitant cbst to build new plants and the catastrophic dangers in operating them.
"Those plants already in operation annually produce 1,500
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metric tons of waste that will remain dangerously radioactive for hundreds and perhaps thousands of years. And nobody knows what to do with it.
"I do. Let's phase out nuclear power plants as the only practical way to phase out the problems - the financial problems of the past and the present, and the horrific potential problems of the future."
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1 Embargoed for release Sunday, Aug. 24 press contact:
Stephen B. Comley The Sheraton Grand (202) 623-2100 WASHINGTON - President Reagan has been invited to join the anti-nuclear power plant movement by a Massachusetts businessman and leading opponent of the controversial Seabrook, N.H., Nuclear Power Plant.
In a letter to the President (editors: see attached),
1 Rowley, Mass., nursing home owner / administrator Stephen B.
Comley asked that the Seabrook not be granted a license and that the 100 licensed plants be phased out.
In releasing the letter, Comley explained to the medias. -
"I am angry.
" Angry that a plant such as Seabrook, or any nuclear power plant, can have such a profound effect on our ,
future and the future of unborn generations. ,
"I am angry that we are offered no say in something that affects us all so greatly."
As an example of the insensitivity that Comley says
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EMBARGOED FOR RELEASE angers him, he points to a letter (see attached) from Carl l Walske, president of the Atomic Industrial Forum. The letter was written to Nuclear Regulatory Commission member James K.
Asselstine, who frequently has criticized the commission majority as a " protector of the nuclear industry."
In the letter, Walske attacks Asselstine for warning of a "possible" nuclear power p!' ant accident in the U.S. of the dimensians of April 26 accident at Chernobyl in the Soviet
. Union. "The press and the layman will not understand the subtle difference between the words 'possible' and
' probable,'" Walske writes Asselstine.
Comtey accuses Walske of insulting the intelligence of the American public, and ca!!s on the President to take sides with the public.
Comley also asks the President to support dissident NRC commissioner Asselstine, who has been is the object of criticism for his opposition to many of the plans of the nuclear power industry. Says Comley:
"I think the people we should be criticizing are the commission majority, which has been responsible for licensing the unsafe nuclear power plants now in operation.
Their irresponsible, inhumane attitude is deplorable."
~~~
Comley asks the President to urge Congress to take the following stepst "1. Take NRC member Asseltine's warnings on the dangers
v I
EMBARGOED FOR RELEASE _
of nuclear power plants seriously.
"2. Order a moratoriun on the licensing of any additional i
nuclear power plants and a study on how the unsafe plants now in operation can be phased out with the least threat of danger and disruption of service.
"3. Create a commission to investigate fully the NRC to determine how the nuclear power industry was able to proceed so far without closer scrutiny." -
~
Comley cbncluded with this statement:
"Mr. President,1 recommend that the will of the people be given back to them.
"All of the information that the NRC has been suppressing must be brought to light so that the American public can make the informed judgments that is their right. "
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We, t a ci+d: ens of acwley, W===A'==tts appeal to you, k:nald Reacan, tFm',
President of the Chited Statas,'toiddress -the fc11cwiizh Ar.s ard r=. - . .a'itiens that we, the undersiepad, have regad.ing /
the NL'elear Regulaterf r-4a4m, a Federal Agency that has the ability,to p*
license the Seahrr:ck
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ta: clear Plant that is located in Seabreck, New Ear:rshime b2t involves varicus .-
tcwn in. F===^'==tts t=m cf the 10 mile radius. ' -
2e reascns fer cur erwer-'= are tbase: ' '
A. Cur <-h41dman ' live twc miles m+=4d= the ten mile radius but attend
. a rag 4 m =1 =^-nl b'=4d- the ten mile radius. We Fmve been told ..
"that we cannet be part of the evac::aticn planning. 'Ihis aisc 2 acplies to the residents of Sea View NL:rsira Ecm who are transfe_W to a bespital 1ccated inside tra ten mile radius.
B. Regarding the P=d4n17 r-=1 anergency Respcnse Plan, Craft 3 4/86 4
Attaa.d.10.2-2 which says "cnly these hespital patients ard ruzrsi.nq bcma residents who are damned ==d4r=11y safe to move are to be evacuated.
tese patients /r==4d=rts which carzet be' evacuated shculd be shaltared in -
place." (a ocpy is e la==d) .
.. - m In our opinien this net only affects razrsing hcme ard hoseital residents but it cculd affect anycna Wm had an operaticn and Pad to be sheltered in place that day. -
C. We feel that the naclear Regulatory th4~4m has been negligent in not making themselves available ard net calling us or haine um en the issues in our tcut. It ===mm that they have represented the nuclear -
irdustry very well but emy have not ere-% 1 the incut of the pecple that may nce be fer nuclear pcwer or Pave a:ncerns fer safety in cur area.-
Cus, we the citizens of Itwley, Pa==^'=etts rarrmerd: -
A. Dat ycu set up a t**"4m to see if th$ M e1==* Regulatcry Ccr.snissicn is acting r=g- a=4Hly in representing and sayir.g that the safety ard cer.cerns are being r w ly addressed fcr tFm pecple of Itwley as well as pecple acms this ccuntry. "
B. tat you ask for a mcratcrium en the start up cf any new nuclear plants awaiting licenses until ycu and we can be assured that we have the full.
infcrmatien back fzzm CPM 1 to make a resper.sible d=^4mi to whether -
we shculd centinue thinking that rn: clear pcwer is a safe alternative. .
C. mat you red.nd the Pv-1==r Pegulat=rf.carmissicn that this is America .
net Russia and tray are hired by tra pecple and are ac=cuntable to z.-
the pecple, not just the pecple in the nuclear M'vf. ..
t We were rer.inded en the 4th cf mily of what this ecuntry was fcunded for and .
we thank ycu fer that. We are seeing that cur .' A cf speech ard LA cf choice is being Emded. ,
I h WIIH 'IEE ABCVE REASCNS AND REC 2 TEE,WICNS..... ~
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- Atomie Indutri t Focuni,Inc.
7101 Wisconsin Avenue Bethesda.Mo 20814 4805 Teleonone:(3011654 9260
' TWX 7108249602 ATOMIC FOR OC cui w.isk e Presces ,
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May 29, 1986 The Honorable James K. Asselstine U.S. Nuclear Regulatory Commission 1717 H Street, N.W., lith Floor Washington, DC 20555
Dear Commissioner Asselstine:
! Your May 22, 1986, testimony before Mr. Markey's House Energy j Conservation and Power Subcommittee has been widely misinter-
! preted in the "
public arena. Specifically, I refer to your
- statement, . . . . given the present level of safety being
! achieved by the operating nuclear power plants in this country, we can expect to see a core meltdown accident within the next
, 20 years, and it is.,possible that such an accident could result in off-site releases of radiation which are as large as, or larger than, the releases estimated to have occurred at Chernobyl." .
We feel this misinterpretation is the result of your loose juxtaposition of an earlier NRC staff.45% core melt estimate by i
the end of the century and your conjecture that larger than Chernobyl releases are "possible."
We feel that the matter is of vital importance. As a senior public official you are certainly aware that your remarks "bg ( vis-a-vis nuclear plant safetywillbewidelydisseminated.) -
[fr yd,(( The pressbetween difference and thethelayman will not understand words "possible" the.,,/subtle and " probable."
f \-) Our own technical position -- predicated on the 5 year, $20
. million IDCOR study -- is that the NRC staff's earlier 45% core
!* melt estimate is conservatively high. The staff has taken historic averages from previous studies and projected them two decades into the future without accounting for improvements
- taking place and others which wi-11 evolve as nuclear technology l improves in the coming years.
1 i
c Commissioner Asselstine May 29, 1986 t
Most importantly, risk is not equivalent to core melt probabil-ity_. It is not technically correct that any core melt accident at'a U.S. reactor would yield Chernobyl-like consequences which your statement implies. The TMI accident is evidence enough to prove that point.
Given a core melt, the probability of a containment bypass release is less than one in two hundred. With our reactors IDCOR does not find any such releases as serious as Chernobyl apparently was. Thus, the implication in your statement exag-gerates the risk from U.S. reactors by at least a factor of two hundred.
The above arguments suggest that nuclear energy is a very safe means of supplying the electricity that the U.S. economy requi res.
Sincerely, a
CW:spg ,
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IMMEDIATE PRESS RELEASE Wed., Aug. 20, 1986-Noon 4
press contact:
Stephen B. Comley The Sheraton Grand (202) 628-2100, ext.1517 .
me WASHINGTON "In some cases, the Nuclear Regulatory Commission (NRC) has acted more as the protector of the nuclear industry than the protector of the public,"
acknowledges NRC commissioner James K. Asselstine, a frequent lone dissenter on the five-member commission.
(Attention editors: on page four, paragraph three of the attached NRC memorandum, Asselstine identifies five such cases.)
Asselstine made the observation in a recent interview with Stephen B. Comley, a Massachusetts businessman visiting Washington to f'ght i the planned preliminary start-up this fall of the Seabrook, N.H., nuclear power plant. The plant is 12 miles from Comley's home in Rowley, one of several .
towns in the area to oppose the plant.
In the interview, Asselstitie praised many members of the NRC staff as "hard-working and dedicated. If given proper policy guidance and direction from the top, the NRC could do
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- Pego 2 of 3 IMMEDIATE PRESS RELEASE
, much to restore public confidence in the agency as a fair 1 '
and objective regulator," he said, in a criticism of his fellow commissioners.
Asselstine, 38, was an attorney for the Senate Environment and Public Works Committee in 1982 when President Reagan appointed him to the NRC; his term expires June 30,1987. .
~
Comley runs a nursing home. Among the reasons he cites for his opposition to the much-debated and often-delayed nuclear plant at Seabrook is that, in case of an accident, the NRC has no plans for persons who must be sheltered because they are too infirm to be evacuated. .
"I am not aware that this question has been faced squarely by the commission," Asselstine agreed.
Comley asked about cost overruns for nuclear power plant construction. At Seabrook, for example, the increases have driven the cost up to $4.6 billion, so far.
"Among the more significant reasons for the cost increases," Asselstine said, "are poor management of plant construction, lack of standardization, a design-as-you-build approach to plant construction and the need to address new .
and unanticipated safety issues."
Comley also asked about safety in light of the recent accident at Soviet Union nuclear plant at Chernobyl.
"Chernobyl has underscored my belief that a severe
a Page 3 of 3 I M MEDIATE PRESS RELEAS E nuclear accident in the U.S. is unacceptable, and that further regulatory initiatives are needed for the future if we are to reduce the long-term risk of nuclear power to an acceptable level," Asselstine said.
"I am not convinced that the public is fully informed of the risk of nuclear power," he added.
After meeting with Asselstine on Friday (Aug.15), Comley centinued his current round of visits with congressional and -
' adminstration aides. He has been gathering support in his campaign to stop Seabrook since April, when the accident at Chernobyl focused attention on the dangers of nuclear power plants.
Comley hopes to meet with the President to present a petition signed, so far, by 65 percent of the 2,200 registered voters in his hometown of Rowley. The petition calls for "a moratorium on the startup of any new nulcear plants" and the creation of "a commission to see if the NRC is acting responsibly."
Comley said his meeting with Asselstine "has reinforced my belief that nuclear power plants should not be built in this country ever again. The risks are too high and the effective monitoring of these risks is almost impossible. .
"As far as the industry is concerned, the attitude seems to be 'what the people don't know won't hurt them.' Well, I believe what the people don't know could kill them."
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, ! o NUCLEAR REGULATORY COMMISSION ,
- WASHINGTON. Di:.20555
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OFFICE OF THE August 19, 198.6 l
' COMMISSIONER 1
MEMORANDUM F0,R: The Files FROM: James K. Asselstine v.
SUBJECT:
DISCUSSION WITH ST HEN B. COMLEY RE NUCLEAR SAFETY AND EMERGENCY PLANNING On Friday, August 15, 1986, I met with Mr. Stephen B. Comley to discuss his i concerns regarding nuclear safety and emergency planning. Mr. Comley is a l
resident of Rowley, Massachusetts. Mr. Comley is interested in the ,
, Seabrook Nuclear Power Plant but is not a party in the Seabrook licensing proceeding. We did not discuss any contested issues in the Seabrook licensing proceeding. The following is a written summary of my responses to Mr. Comley's questions.
Question 1: Do you feel that the people of Rowley should have a voice in evacuation planning as it pertains to the Seabrook power plant?
Answer: As a general matter, I believe that the 10-mile emergency
' planning zone (EPZ) established by the Cemission is a reasonable boundary for planning protective actions, including evacuation, in the event of a nuclear power plant accident. However, the Comission's regulations are flexible in that they allow expansion of the 10-mile EPZ to take into account nearby facilities or features for which emergency planning would be appropriate. An example would c
be a school located just outside the EPZ. In previous L cases, I have supported expanding the size of the EPZ slightly in a particular area where the facts of the case indicate a particular feature, facility or problem area which can affect overall emergency planning for the plant.
. An example of this is the bridge going to Cape Cod, which is j located just beyond the 10-mile EPZ for the Pilgrim plant.
Because the bridge could significantly affect emergency planning for the Pilgrim plant and because it is the principal artery leading to and from Cape Cod, I believe l
that it should be included in the Pilgrim EPZ,,and I have so stated in the past. Whether the town of Rowley should be included in the EPZ for Seabrook would depend upon the facts in that particular case. Although this is not now a contested issue in the Seabrook proceeding, I understand that it may become one. If so, my decision would be based upon the record developed in the case. I have not reviewed
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! the situation for Seabrook, ~and I Itave no opinion on the issue at the pre ~sent time. ,
Question 2: Evacuation issue - people who can't be moved... Do you feel l some means should be provided for people who cannot be l l moved, other than merely being sheltered? ,
i I
Answer:
I am not aware that this question has been faced squarely
- by the Commission in any previous ca'se. As a general i matter, the Comission's regulations require that emergency j planning within the EPZ provide for a range of protective actions. These can include sheltering, but for at least some accident situations evacuation may be necessary for some or all of the people within the EPZ. Thus, emerge.ncy
! planning measures have been required to include needed
. transportation, particularly for those who are unable to l j evacuate themselves. I agree with this element of our -
l emergency planning requirements. For this reason, thd i -
Comission emphasized the need for arrangements for
< ambulances 'and buses if evacuation is needed for a care .
facility for elderly nuns near the Femi-2 reactor. The Comission has also considered the need for sheltering and i evacuation of prisoners in detention facilities located near i nuclear power plants. However, I do not believe that the J Comission has faced the situation in which evacuation is l impossible for some individuals within the EPZ and the only -
,- alternative is sheltering within unprotected facilities.
! Question 3: Location issue - Seabrook. Has the sumer beach population been fully taken into consideration?
('
Answer: I believe that this is a contested issue in the Seabrook i'
proceeding. My opinion on this and other contested issues will be based upon the formal record in the Seabrook case.
I have no opinion on the issue at the present time and I j cannot discuss it with you.
t .
Question 4: As we have yet to receive all of the information on Chernobyl, what are your opinions on reducing the radius from 10 miles to 2 miles?
Answer _: You are quite correct that we have not yet received all of the information needed on the Chernobyl accident to assess
! its potential impact on emergency planning.' It seems to me
! that the Chernobyl accident may well raise questions on
- emergency planning that cut the other way -- that is, is the 1 i
10-mile EPZ 1arge enough and should we consider expanding it? It seems to me that this is an open question until we receive additional information on the causes, sequence of I events and consequences of the Chernobyl accident. Over the ,
past three years, the U.S. nuclear industry has advocated l
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reductions" in the radioactive source term (the estimates of the amounts and types of radi5 active materials which could
- be released during a serious nuclear acciderit). The industry argues that these reduced source terms would i justify relaxations in several NRC regulations. Chief among !
l those is a reduction in the size of the emergency planning I i zone, perhaps td an area as small as two miles. The l American Physical Society and others have identified a number of areas where additional work.is needed to provide a j sound scientific basis for any source term reassessment.
! They have advised that across-the-board reductions in the j source tenn are not yet justified, and that specific numerical reductions are unwarranted. The Comission has not yet taken action to reduce the source tenns, and our technical staff har advised that any across-the-board .
reductions in emergency planning zones are premature. The
! staff has rejected at least one site-specific proposal to reduce the EPZ for the Calvert Cliffs plant on the ground that the request is premature. Of course, any licensee is free to propose a site-specific reduction in the size of the EPZ for the plant and the individual proposal.would be
. considered by the Comission on its merits.
- Question 5
- I understand that the low level licensing requirements have
- been reduced as they pertain to issues of evacuation problems that may arise in a city or town. This change has enabled question not to be resolved before a license is issued. Given the Chernobyl. incident and the problems and
- j questions that surround the Pilgrim Nuclear Plant in '
! Plymouth (which has been branded "the worst-run plant in the US"), do you think we should reverse again and require that
< evaluation issues be re:olved before a low level license is
) granted to any new plants?
l Answer: The Comission's regulations require adequate emergency l planning measures to be in place prior to the issuance of a full-power license, but not prior to the . issuance of a low-power license (these are limited to no more than five 4
percent of full power). This decision was based upon the technical judgment that a plant beginning operation and not going above five percent power fails to generate the j ' quantity of fission products and decay heat which could pose
! a hazard to the public requiring evacuation or other
) protective action. I agree with this technical judgment
! that the risk to the public from low-power operation of a i new plant is very low. Some have questioned whether the
! Chernobyl accident affects this judgment since that accident I apparently occurred at low power levels. However, our s*taff advises that the situation at Chernobyl was quite different j because the plant had been operating at higher power levels
! for some time, with the consequent build-up of fission l products and decay heat. Having said this, I should note l
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that I~ opposed issuance of a low-power operating license for the Shoreham plant on the ground that there appeared to
. exist an outstanding emergency planning issue which might prevent that plant from ever going into full-power operation. In the circumstances of that case, it seemed to me unwise to contaminate the plant until the Comission had j
i resolved the outstanding emergency planning issues. Such i circumstances may well arise in other cases, and I will have i to examine each case individually. But my decision in '
i Shoreham turned on the wisdom of contaminating a plant that
! might never receive a full-power operating license and not 4
on the risk to the public of low-power operation.
Question 6: Do you feel that the NRC has represented the people as well i as it has represented the nuclear industry? .
Answer: I believe that in some cases, the NRC has acted more as the protector of the nuclear industry than the protector of the public. These cases have included the Comission's decision to allow operation of the Indian Point plants in the face of continued significant deficiencies in emergency planning; the Comission's decision to reject the safety improvements recomended by the NRC staff and the hearing board in the
! Indian Point Special Proceeding; the Comission's decision
- to allow the restart of TMI, Unit 1; the Commission's 1 decision to end the search for further reductions in the l risk of severe nuclear accidents in the Severe Accident Policy Statement; and the Comission's decision to restrict the NRC staff's ability to develop needed new safety
- requirements in the Comission's backfit rule. My views are well documented in my dissenting views on each of these decisions, and they have been widely publicized. For the j most part, I am the only member of the current Comission
! who has opposed these actions; however, one other Comissioner opposed the backfit rule. Despite my opposition to these key Comission decisions, I believe that l .the NRC contains many able and dedicated people who are comitted to the regulatory mission of the agency. If given the proper policy direction from the top, I am confident that the agency could pursue its regulatory responsibilities in a manner that would restore public confidence 'in the NRC as an objective and fair regulator that puts the interests of the public foremost.
4 Question 7: Has Chernobyl changed your thinking regarding nuclear power?
~
j Answer: The Chernobyl accident has not dramatically altered my
- views on nuclear power or on the key regulatory issues which 1
are before the NRC. I continue to believe that nuclear I power plants can be operated, built, and designed safely,
) and that they should be a part of our overall energy mix.
In reaching this judgment, I recognize the substantial
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'comitment to nuclear power which we already have in the 1
U.S. The challenge is to ensure that the approximately 125 !
- - plants we have in operation or under construction. are run '
safely. Hence, Chernobyl has underscored my belief that a l 4
. severe nuclear accident in the U.S. is unacceptable, and '
a that further regulatory initiatives are needed for the future if we are to reduce the long-term risk of nuclear power to an acceptable level. In a recent letter to the President of the Atomic Industrial Forum, .I outlined my own assessment of our current understanding of the risks of nuclear power and the steps that I believe are needed to i reduce that risk to acceptable levels. I am pleased to note i that as part of its recent Safety Goals Policy Statement the Comission agreed to a statement that an objective of our
~
regulatory process should be to prevent the occurrence 'of a
! -severe nuclear accident -- that is, an accident causing damage to the reactor core --' at any U.S. nuclear power i plant. This statement, together with the Comission's recent increased attention on the operating performance of U.S. plants, particularly those with a history of poor performance, is an encouraging step in the right direction.
t Question 8: Do you feel that people are really informed about and know of the dangers of nuclear power?
- Answer
- I am not convinced that the public is fully informed of the
- r'isk of nuclear power. The issues are often complex, and l'
the debate on the issues is ' frequently polarized and somewhat distorted. In my recent letter to the AIF, copy
- attached, I attempted to describe my view of the risk of a nuclear accident, including the uncertainties in estimating-that risk. As I noted in my letter, I do not believe that we fully understand that risk, and we should not be afraid to say so.
I Question 9: Cost verus other funds - obsolete?
Answer: As I understand your question, do I believe that nuclear power is obsolete based upon cost considerations? The Comission's regulations focus on health and safety considerations rather than on the overall cost of nuclear l power. It is true that the cost of nuclear power has increased substantially in recent years, particularly for '
the large new plants. The cost of operating and maintaining i the older existing plants has also increased significantly over the past several years. Although there are many
]
- reasons for the cost increases, among the more significant
! are poor management of plant construction, the lack of i standardization, a design-as-you-build approach to plant construction, and the need to address new and unanticipated safety issues, including those arising from the Three Mile Island accident. Whether nuclear power remains competitive 1
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with other alternatives is difficult to say. It appears, 'l 1
however, that due to a combination of factors, including l reduced demand for electricity, financial conditions, and !
uncertainty about costs and safety requirements, that no '
U.S. utility at the present time is prepared to comit to build a new nuclear powerplant.
} Question 10 How Many people were hospitalized in Russia?
Answer: I do not know the answer to this question. We are awaiting
, further details on the Chernobyl accident at the upcoming meeting of the International Atomic Energy Agency late this I
month.
J QUESTION 11. How old was the plant - 3 years? ,
! - Answer: The reactor which had the accident at Chernobyl was the i .
newest unit of the four-unit Chernobyl plant. Although I do
- not know the date on which the unit began operation, I believe that the plant had been in operation no more than three years, and perhaps less.
Question 12_: What are the differences between the Russian plants and our nuclear plants as you see them?
Answer: There clearly are a number of design differences between U.S. nuclear powerplants and the Chernobyl plant. Other Russian plant designs are more similar to ours. I do not believe that we have enough detailed design information about the Chernobyl plant to fully understand their design i or the significance of the differences between their design
! philosophy and ours. We are awaiting more detailed design
- information at the upcoming IAEA meeting later this month.
l However, quite apart from the design differences between the l U.S. and Russian plants, there are some broad lessons with i applicability to the U.S. nuclear program. One of these is l the unacceptability of a severe accident here and the need to ensure that sufficient steps are taken to prevent such an accident from occurring and to limit the potential for a j large offsite release of radiation should one occur. I have
! proposed initiatives, described in my letter to the AIF, l which would accomplish these objectives. Ih addition, there are specific safety areas, such as. hydrogen control, which
! may require additional attention based upon the information obtained from Chernobyl.
i q
l Question 13: Regarding future generations, would you recomend that we
- continue to build nuclear plants?
1 c '3
. . -7= -
I believe that we should retain the nuclear power option Answeri - -
for the future in this country. When I examine other energy alternatives, it appears at the present time that coal and nuclear are the principal means available for providing large central station generating facilities. Conservation
' and other options are having a significant impact; howgver, it is unclear whether they can eliminate the need for new large generating facilities at some point in the future.
But if nuclear power is to remain a viable option for the future, three conditions must be met. First, the existing plants must operate safely and there must not be a severe accident at any of the existing plants for the foreseeable future -- at least the next 20 years. Second, we must restructure the process for designing, constructing and operating future nuclear plants. This restructuring must include greater use of standardized designs; the development of essentially complete designs before the start of construction; better, more centralized management of the.
construction process; greater attention to construction quality assurance; improved designs which emphasize greater margins of safety, simplicity, ease of operation and ease of maintenance; better utility management; and improved operations and maintenance performance. Third, we must make i continued progress toward developing a safe and environmentally acceptable solution to the nuclear waste disposal problem. Each of these areas, in my view, is in need of attention if nuclear power is to remain a viable option for the future.
Ouestion 14: Do you feel that the public would be justified in believing that the NRC is not acting in the public's best interest?
Answer: As I noted in my response to question 6, I believe there i
are some significant Comission decisions in recent years in .
which the Commission has acted more as the protector of the industry than the protector of the public. In such cases, I believe that the public would be justified in concluding I that the NRC is not acting in the public's best interests.
At the sama time, as I noted in my previous response, the
! NRC staff is composed of many hard-working and dedicated j people. If given the proper policy guidance and direction,
! the NRC could do much to restore public confidence in the i agency as a fair and, objective regulator, and in the safety
- of nuclear power as well. -
f j
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AUGUST 19,1966-10:00 A.h press contact:
Stephen B. Comley The Sheraton Grand (202) 628-2100, ext.1517 WASHINGTON - A Massachusetts businessman with a fistful of petitions, press clippings and appointments with high government officials hopes to land a fatal blow on the Seabrook, N.H., nuclear .
power plant. The $4.6 billion plant has been mired in controversy and cost overruns since its inception more than a decade ago.
Stephen B. Comley lives 12 miles from the plant in Rowley, Mass., where he runs a nursing home. He is in the nation's capital to fight the plant with petitions signed by 65 percent of Rowley's 2,200 registered voters.
A petition already has been hand delivered to Mass. Gov.
Michael S. Dukakis and acted upon by the Rowley Board of Selectman. ,
It calls for Rowley to be part of an evacuation plan in case of an j accident at Seabrook.
Comley plans to present, in person, another petition to ,
President Reagan. It calls for the President to:
- "ask for a moratorium on the startup of any new nuclear I plants awaiting licenses until you and we can be assured that we have the full information back from Chernobyl to make a responsible decison to whether we should continue thinking that nuclear power is a safe alternative.
PAGE 1 of 3
h - AUGUST 19,1986-10:00 A.M.
- " set up a commission to see if the Nuclear Regulatory Commission (NRC) is acting responsibly in representing and saying that the safety and concerns are being properly addressed for the people of Rowley as well as people accross this country."
Comley points out that, in case of an accident at Seabrook, the NRC has no plans for hospital patients that cannot be moved and have to be sheltered, including children and our elders. And, among ,
those who would be evacuated, students at a high school within 10 ,
mifes of the plant would be separated from their parents outside the 10-mile evacuation radius. Comley questions whether these oversights are part of a pattern resulting from the NRC's haste to please the nuclear power industry.
At present, the nuclear plant at Seabrook st!!! has not been brought on-stream. The latest delay has come not from the NRC but another federal agency, the Atomic Safety and Licensing Board. It
- ordered fuel loading and low-power testing at the plant delayed for l
I l hearings on concerns over the plant's control room and other safety issues.
In October, shortly after those hearings are expected to be l concluded, hearings on a full-power license for the plant tentatively are scheduled to begin.
Comley's press clippings from area newspapers show continuing, widespread opposition to the plant. For instance, five of the six Massachusetts communities within the 10-mile evacuation zone
( around the plant are seeking to delay further the plant's start-up by PAGE 2 cf 3
& =
e hse AUGUST 19,1986-10 00 A.M.
refusing to take part in NRC-mandated evacuation planning.
Communities outside the 10-mile evacuation radius, such as Rowley, while seeking to delay or kill the plant through petitions, have asked to be part of any evacuation plan.
On Friday, Aug.15, Comley met with NRC commissioner James K.
Asseltine. Since then, he has met with other NRC officials and White -
House aides. Comley hopes to meet with the President to present the petitions.
Comley says that he wants the President to understand that the campaign to halt Seabrook is for all of the American people. "Because we care . . . about Rowley, about you," is the campaign's motto.
PAGE 3 of 3
4 UNITED STATES D
NUCLEAR REGULATORY COMMISSION "E
k W ASHINGTON,0.C. 20555 3g
+
July 15, 1986 OFFICE OF THE COMMIS510NER Mr. Carl Walske, President
- Atomic Industrial Forum, Inc.
7101 Wisconsin Avenue Bethesda, Maryland 20814-4805
Dear Mr. Walske:
Thank you for your letter of May 29, 1986, regarding my May 22, 1986 testimony before the Energy Conservation and Power Subcommittee of the House Committee on Energy and Commerce. In your letter, you expressed.
concern that my statement may have been misinterpreted in the public arena.
In particular, you point to my statement that "... given the present level of safety being achieved by the operating nuclear power plants in this country, we can expect to see a core meltdown accident 'within the next' 20
' years, and it is possible that such an accident could result in off-site releases of radiation which are as large as, or larger than, the releases estimated to have occurred at Chernobyl." You state that the Atomic Industrial Forum does not agree with my characterization of the likelihood of a core meltdown in this country within the next 20 years, and it is the position of the AIF that, even if .there were to be a core meltdown, the probabi.lity of a substantial release of radioactive materials is very low '
(i.e., one substantial release in 200 core meltdowns).
I stand by my statement before the Energy Conservation and Power Subcom-mittee. I believe that it represents.an accurate and balanced assessment of the risk posed by the 100 operating nuclear powerplants in this country.
I have provided my rationale' for the views contained in my statement before the Subcomittee in various forums in the past. However, since you have taken issue with my statement I want to take this opportunity to explain my i position in detail.
I I share your concern for accuracy. I recall reading in the newspapers in recent months statements by senior officials within the nuclear industry that our plants are " perfectly safe" and we "will not have a Chernobyl-type plant accident here." Apparently, such absolute statements are thought to be needed to counter-balance arguments from the other side that there is an immediate threat to the public which requires the shutdown of our nuclear plants. In my view, neither position is accurate. To convey an impression that Chernobyl-type releases are impossible in this country is as inaccurate as conveying an. impression that a similar disaster is a l certainty. I attempted to take the middle read in my opening statement before the Subcommittee. We do not fully understand the risks of nuclear power, and we should not be fearful of saying so.
Your letter contained a number of specific criticisms of my statement. "
First, you stated that the NRC staff's 45 percent core meltdown estimate over the next 20 years does not take into account safety inprovements now l -
. ,l l
l being developed and others which will be forthcoming. I agree. However, that estimate also does not include all contributors to the probability of a core meltdown. For example, it does not accurately reflect the contributions to risk from external events such as earthquakes and floods.
More importantly, it does not properly account for human errors or
', degradation in the material condition of the plant. The performance of '
existing plants demonstrates that these weaknesses in probabilistic studies i may result in a significant underestimate of the actual risk. Specifi-cally, we are learning that the plants often react in ways we do not expect. As Harold Denton, the Commission's chief safety officer, wrote:
"I believe that the recent Davis-Besse event illustrates that, in the real world, system and component reliabilities can degrade below those we and the industry routinely assume in estimating core melt frequencies." (See, Memorandum from Harold R. Denton to William J. Dircks, dated June 27, 1985.) Thus, my views do 'not rest only on the 45 percent estimate or on the theoretical calculations of IDCOR which you reference. Neither takes into account the large uncertainties in these theoretical estimates and neither accurately reflects the actual operation of the plants in the real world.
Recent operating experience, including the several serious operating events at U.S. nuclear powerplants in 1985, indicates that inadequate or improper maintenance, surveillance testing errors, equipment failures, design inadequacies, and operator and other personnel errors are occurring at U.S.
plants at an unacceptably high rate and that they are significant contributors to operating events that can lead to severe accidents. This operating experience shows that these contributors are causing the total loss of one or more safety systems and multiple equipment failures at plants that can substantially erode defense-in-depth and lead to accident ,
conditions beyond the design basis of the plant.
One would hope that we are aggressively pursuing the root causes of thes'e L occurrences. Unfortunately, it does not appear that all U.S. nuclear utilities are learning the lessons of experience. Our Office for Analysis and Evaluation of Operational Data (AEOD) conducted a survey in the fall of 1984 to determine how well licensees were learning the lessons of experi-ence. AE00 concluded: "Most plants are making moderate, not extensive, use of their in-house operating experience, and in general are making less use of the large body of knowledge associated with events and concerns that originate elsewhere in the industry." (See, "1985 Annual Report /AE00 5601," April 1986, p. S.) This reinforces a. previous AE00 report which found that our licensees often repeat the same mistakes, even at the same plant. The actual operating experience of our existing plants and the industry's failure to heed the lessons of experience indicate, in my judgment, that we can expect to see another serious accident in this country during the next 20 years.
In your letter, you emphasized that risk is not equivalent to core melt probability. I agree. You went on to state that it is not technically correct to say that any core melt accident at a U.S. reactor would yield Chernobyl-like consequences, which you said my statement implies. However,-
- e e
you quoted only a part of my statement. What I said just before the statement quoted in your letter was:
Third, although we believe that all of our reactors have some capability to withstand severe core meltdown accidents, the extent to which they can withstand such accidents depends upon the sequence of events during the accident, the individual plant designs While and the we hope manner in which each plant is operated and maintained.
that their occurrence is unlikely, there are accident sequences for U.S. plants that can lead to rupture or bypassing of the containment in U.S. reactors which would result in the off-site release of fission products comparable to or worse than the releases estimatedThat by the NRC is why staff to have taken place during the Chernobyl accident.
the Comission told the Congress recently that it could not rule out a comercial nuclear power plant accident in the United States resulting in tens of billions of dollars in property losses and injuries to the public.
Thus, my statement made the point that not all core meltdown accidents can be expected to result in large offsite releases of radiation which can harm the public and contaminate large areas of land and property. The central questions, of course, are: how likely is such an accident, what are the uncertainties in estimating the probabilities, and how well do we under-stand this risk? Your letter can be interpreted very easily by the uninitiated to say that the reactor risks are well understood and that an accident involving substantial and harmful releases of r.adioactivity to the environment is all but impossible in this country. That clearly is not an accurate representation of the facts.
Your letter stated that "With our reactors IDCOR does not find any such releases as serious as Chernobyl apparently was." I question whether there is a sound sci.entific basis for this conclusion. The 1975 Reactor Safety Study (WASH-1400), which the industry and the NRC touted as an objective assessment of reactor risk, contains several release categories associated with core meltdowns that are equal to or greater than our estimates of the releases at Chernobyl. The NRC staff has recently advised the Comission that the best available information suggests that some changes in specific radionuclide group releases to the atmosphere are justified; however, the overall consequences are not significantly different from those using source terms contained in the Reactor Safety Study. Thus, the best available information indicates that severe accidents with Chernobyl-type
.* releases, or worse, can occur at U.S. plants.
The question then becomes: how likely are such accidents and'what are the uncertainties in estimating their probabilities? In my view, two con-clusions regarding the Reactor Safety Study are germane to this question.
First, the uncertainties in reactor risks are much larger than estimated in that 1975 report, even with all of the research and analyses that have been completed since then. Second, the bottom-li.ne results of quantitative probabilistic risk assessments are not reliable. I thought there was a general recognition of these conclusions, but your letter seems to indicate a belief that we can now make sweeping generalizations about the low n--.-* r,- - - - - . - .m- $ _ - . . _ . 9
~
likelihood of a large-scale radiation release for all U.S. plants. In doing so, you seem to give no weight to the American Physical Society Study Group on Radionuclide Release from Severe Accidents at Nuclear Power Plants
" It is impossible to make the sweeping generalization which concluded:
that the calculated source term for any accident sequence involving any reactor plant would always be a small fraction of the fission product inventory at reactor shutdown." (See, R. Wilson et al., Reviews of 4
Modern Physics, Vol . 57 No. 3, Part 11, July 1985-~~p. 5128.) The funda-i mental issues raised in that report have not been resolved in a scien-tifically defensible way. Those issues involve factors such as the chemical form of iodine during a severe accident, variations in containment performance due to design and construction differences, and the potential
^
for steam explosion, both within the reactor vessel and within the containment. The resolution of each of these issues has a direct bearing on the potential for a large-scale early release of fission products in the '
event of -6 severe accident.
With regard to the chemical form of iodine, the industry has argued that during a severe accident iodine can be expected to join with cesium to fonn-cesium iodide, which reduces the potential for harmful releases of volatile iodine. Yet, recent experiments. have resulted in the production of 1
For volatile iodine and have not shown extensive cesium " iodideon Based formation.
the experi-this reason, the NRC staff has recently written:
mental evidence available today, a definitive position regarding the chemical form of iodine would be premature. At this time, it is not (See, obvious what phenomena are causing specific experimental results."
Letter from R.B. Minogue to John J. Taylor of EPRI dated May 22,1986.)
With regard to containment performance, there is considerable evidence that containment strength may vary substantially from plant'to plant based upon' differences in design and construction. These differences effectively rule out broad generalizations regarding containment performance. As senior members of the NRC's Office of Nuclear" Regulatory Research put it in describing a recent series of tests: The lessons learned from the steel tests was that even minor details of stiffening ring attachment made a large difference in ultimate capacity. This means that individual construction details could lead to a large variation, site-to-site, in
' Rules of Thumb' are probably out ultimate capacity (of the containments).
of the question." (See, Trip Report from D.F. Ross, G.H. Marcus, and C.N.
Kelber to Robert B. Minogue dated February 3,1986.)
- With regard to s' team explosions, the industry has argued that there is little potential that such explosions could lead to substantial releases based on predictions of fragmentation of the molten core upon emersion in water. However, our researchers at Sandia National Laboratories have not agreed with these predictions, noting, among other things:
A detailed examination of FIST data to date shows no. match between the fragmentation predictions of Fauske, Corradini, or Saito-Theofanus, with regard to debris size or distribution. Mismatch is at least an order of magnitude, showing these theories are missing some key ingredients." (Id.) For these and '
other reasons, our researchers have not ruled out steam explosions as a potentially significant phenomenon which could lead to substantial e
- ' '- --- -' W - *-' *b -
,o radiation releases. Given the best available scientific information to date and recognizing the substantial uncertainties which still exist regarding these issues, I believe we are still a long way from making defensible generalizations about releases from core meltdowns.
You stated that the implication of my statement " exaggerates the risk from U.S. reactors by at least a factor of two hundred." However, your assertion fails to take into account all potentially significant contributors to risk, all potentially significant core meltdown phenomena, a reasonable range of technically defensible parametric values for calculating containment performance during core meltdowns, all potentially significant accident sequences, the effects of human error or design and construction errors, the effects of materials degradation with age, and significant operating events, including so-called precursors to core
~
meltdown accidents. .
9 According to WASH-1400, there are many accident scenarios that can lead to substantial releases, including a small break loss of coolant with failure of the containment sprays, an interfaging systems loss of coolant (i.e., an accident involving overpressurization of low pressure piping that is outside .of the containment but is connected to the high pressure primary cooling piping such that the loss of coolant occurs outside of the con-tainment rather than the design basis loss of coolant inside containment), ,
anticipated transients without scram, station blackout, and loss of coolant accidents with failure of emergency core cooling injection. The specific release category that results from these scenarios is dependent on core meltdown phenomena and containment response thereto. While much progress has been made in -understanding these accident scenarios since WASH-1400 was published in 1975, there remain very substantial uncertainties in evalu-ating them. For example, during a core meltdown, theoretical source term calculations include models for plating out of significant quantities of fission products within the primary system. However, the models do not evaluate, or poorly evaluate, the effects of the heating of the primary system by the plated-out fission products to determine whether this As I phenomenon' alters the sequence of events and the release category.
mentioned before, steam explosions and their effects on containment and resuspension of fission products are still in dispute. These are just two examples of the many uncertainties and unknowns regarding the release categories .which could result from various core meltdown sequences. With regard to the likelihood of the various sequences, for the reasons given above, I would s'ay that none of the sequences can be ruled out. A number of precursor events have occurred at U.S. reactors for each of the above scenarios.
The broad conclusions in your letter seem to be based substantially, if not exclusively, on the 10COR program. Unfortunately, that program examined '
only a, few plants. The nuclear industry eschewed standardization in such areas as plant design, construction, operations, maintenance and surveillance testing. Thus, each operating plant has its own unique vulnfrabilities to core meltdown accidents and to substantial releases of radioactivity. This fact,-together with the substantial uncertainties inherent in these types of theoretical analyses and the limited number of
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accident sequences considered, make extrapolation of the IDCOR results to all plants premature at best.
Given the limits of our understanding of severe accident phenomena and the l large uncertainties inherent in attempting to predict the likelihood that a core meltdown will proceed to a large and catastrophic radiation release, I l reach the same. conclusion as did the President's Comission on the Accident at Three Mile Island. In the words of the Kemeny Comission:
Whether in this particular case we came close to a catastrophic accident or not, this accident was too serious.' Accidents as serious as TMI should not be allowed to occur in the future.
The accident got sufficiently out of hand so that those attempting to control it were operating somewhat in the dark. While today the -
causes are well understood, 6 months after the accidenc it is still difficult to know the precise state of the core and what the conditjons are inside the reactor building. Once an accident reaches
_ this stage, one that goes beyond well-understood principles, and puts those controlling the accident into an experimental mode (this happened during the first day), the uncertainty of whether an accident could result in major releases of radioactivity is too high. Adding to this enormous damage to the plant, the expensive and potentially dangerous cleanup process that remains, and the great cost of the accident, we must conclude that -- whatever worse could have happened -- the accident had already gone too far to make it tolerable.
While throughout this entire document we emphasize that fundamental changes are necessary to prevent accidents as serious as TMI, we must not assume that an accident of this or greater seriousness cannot happen again, even if the changes we recommend are made. Therefore, in addition to doing everything to prevent such accidents, we must be fully prepared to minimize the potential impact of such an accident en public health and safety, should one occur in the future.
" Report of the President's Commission on the Accident At Three Mile Island," p. 15.
That is why I have advocated a program of new initiatives aimed at both reducing the likelihood of core meltdown accidents and minimizing the potential for a large offsite release should such an accident occur. These new initiatives would build upon, but would go beyond the NRC's existing regulatory programs and the self-improvement programs undertaken by the industry in recent years. My proposal consists of three new initiatives for the current generation of plants.
First, we should undertake a detailed reexamination of each U.S. plant to identify and correct design weaknesses and vulnerabilities which can initiate or complicate serious accidents. To be effective, this effort must go. beyond the surrogate plant approach advocated by the industry in the IDCOR program. What is needed is a thorough and independent review of the
G o
design of each plant, including a verification of the adequacy of the existing design basis for the plant and a review of all . changes made to the plant after the approval of the plant's original design basis. Given the i
i absence of standardization in the U.S. nuclear program and the lack of good configuration control at some plants, this step is necessary to assure that all significant design problems are identified and corrected.
Second, we should undertake improvement programs in areas of demonstrated weakness in U.S. nuclear powerplant operations, including management, human performance, equipment reliability, and maintenance and surveillance testing. Despite the existence of voluntary industry efforts in several of these areas, we are still seeing U.S. plant performance that is substan-tially below the levels of safety and reliability being achieved in other countries such as Japan, Sweden, and West Germany.' U.S. operating experi-ence demonstrates that existing voluntary efforts simply are not doing'the job. We need expanded efforts in each of these areas sufficient to ensure a level of performance at U.S. plants which is equal to that now being achieved in these other countries. Of these areas, it appears that .
management is the dominant factor in achieving excellence in perfonnance.
~
We need to focus particular attention on those plants with a history of poor operating performance and reliability. The industry's Institute of i
Nuclear Power Operations (INPO) has been in operation now for more than six l
' years. Although INPO has had a positive effect in improving overall industry performance, there are still far too many plants that fail to meet This indicates either that strong acceptable standards of performance.
peer pressure within the industry is still not being applied to the poor performers or that peer pressure alone is not sufficient to bring about effective and lasting improvement. In either case, further regulatory initiatives are needed, especially for the weak performers. In addition, those members of the industry with more expertise and better performance should provide more help to the weaker performers. The industry itself
.must become more aggressive in ensuring exemplary performance of all nuclear utilities. After all, the future ofI want the best managed facility may to emphasize that I am not rest in the hands of the worst managed.
seeking perfection in U.S. nuclear power plant operations. What I am seeking is a level of operational performance by the U.S. plants thR equals the level of performance being routinely achieved by the plants in such countries as Japan, Sweden and West Germany. I am convinced that this is an achievable objective, and we in government and you in the industry should dedicate ourselves to meeting this goal within the next three years.
Third, we should undertake a detailed study of additional design features, such as a dedicated decay heat removal system and a filtering / venting system for containments which have the ability to reduce substantially the likelihood of a core meltdown and the potential for a large off-site release of radioactivity. Such design features have already been installed or are being actively pursued by several European countries with aggressive ,
nuclear programs. These design improvements for existing, as well as for future plants, are being accomplished in a disciplined manner at reasonable cost. We should, therefore, give specific attention to those designs which already exist or are under active development in other countries. Any such L - - ---. _ _ _ _ _ _ _ _ _ , . _ _ _ _ ___ _ _
a l
features would not necessarily have to satisfy all of the Comission's requirements such as the single. failure criterion since they would serve as a final backup for existing plant safety systems.
. In my view, these three initiatives would bring about fundammtal improve-3 ments in the safety of U.S. nuclear powerplants that would enable the optimistic safety performance projections expressed in your letter to be realized. I believe that we both share a comon objective: to assure a safe and reliable nuclear power program in this country. I therefore invite you and the other leaders of the industry to join with me in a new comitment to safety -- a comitment that will ensure the successful, long-term operation of the plants we now have and the continued avail-ability of the nuclear option for the future. That comitment can best be achieved by a cooperative safety approach which takes advantage nf the industry's knowledge and experience but which also recognizes the need for, and legitimate functions of, regulation. I propose an approach whereby the NRC and the industry would work together to define the specific objectives of each of the three safety initiatives I have outlined and the detailes! -
requirements needed to achiese those objectives. Under this approach, the industry would be free to take the initiative in proposing for discussion creative solutions in each of the areas I have identified. However, this joint effort would result in a binding comitment by the industry to meet specific new requirements. Those comitments would then be subject to NRC inspection and enforcement. The approach I am suggesting is quite similar to that used in many foreign countries with successful nuclear programs and builds upon the voluntary self-regulation approach advocated by the Nuclear Utilities Management and Human Resource Comittee (NUMARC).
In the wake of the Chernobyl accident, I believe that nuclear power is at a crossroads in this and other countries. We have the opportunity to learn the lessons of experience', to correct the mistakes of the past, and to bring about lasting improvement that will ensure the accident-free operation of our plants over their remaining operating lives. We had that opportunity following the Three Mile Island accident but we failed to follow through. I sincerely hope that we do not have to wait for another nuclear accident before we come to grips with the root causes of nuclear power risks. The failure to do this during the past twenty years of commercial nuclear experience involving large power reactors is, in my view, the fundamental reason why nuclear power is controversial and will remain controversial until a systematic approach to safety is taken. And, the failure over the last twenty years to come to grips with the root -
causes of the risks is why I hold the views I expressed at the Congressional hearing. An essential first step toward correcting the mistakes of the past is to acknowledge the obvious: that the public and the Congress will not tolerate, and the industry and the NRC cannot allow, another severe accident as serious as the Three Mile Island accident or worse. The second step is to undertake the new initiatives needed to make this objective a reality.
I have attempted in this letter to outline w' hat more we need to do and why I believe we need to do it. I suggest that we use this exchange as a foundation on which'to build a truly effective safety improvement program, s
a
-9 !
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l a program that will assure the long-tenn protection of the public and that will restore public confidence in the NRC and in. nuclear power.
Sincerely, O .4
, /<. .
James K. Asselstine Oh 9
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Ats mis industrirl Ferum, In g.
71o1 Wisconsin Avenue
- Bethesda.MD 20814-4805 Telephone: 001) 654-926o TWX 7108249602 ATOMIC FOR OC Carl Walske President l
May 29, 1986 The Honorable James K. Asselstine U.S. Nuclear Regulatory Commission 1717 H Street, N.W., lith Floor -
Washington,.DC 20555
Dear Commissioner Asselstine:
1 iour May 22, 1986, testimony before Mr. Markey's House Energy 2
Conservation and Power Subcommittee has been widely misinter-preted in the public arena. Specifically, I refer to your statement, " . . . . given the present level of safety being achieved by the operating nuclear power plants in this country, we can expect to see a core meltdown accident within the next 20 year.s, and it is possible that such an accident could result in off-site releases of radiation which are as large as, or larger than, the releases estimated to have occurred at Chernobyl."
We feel this misinterpretation is the result of your_ loose juxtaposition of an earlier NRC staff 45% core melt estimate by the end of the century and your conjecture that larger than Chernobyl, releases are "possible."
We feel that the matter is of vital importance. As a senior public off$.cial you are certainly aware that.your remarks i
vis-a-vis nuclear plant safety will be widely disseminated.
The press and the layman will not understand the subtle difference between the words "possible" and " probable."
Our own technical position -- predicated on the 5 year, $20 million IDCOR study -- is that the NRC staff's earlier 45% core melt estimate is conservatively high. The staff has taken historic averages from previous studies and projected them two decades into the future without accounting f.or improvements taking place and others which will evolve as nuclear technology improves in the coming years.
's Commissioner Asselstine May 29, 1986 k Most importantly, risk is not equivalent to core melt probabil-ity. It is not technically correct that any core melt accident at a U.S. reactor would yield Chernobyl-like consequences which your statement implies. The TMI accident is evidence enough to prove that point.
Given a core melt, the probability of a containment bypass release is less than one in two hundred. With our reactors IDCOR does not find anf such releases as serious as Chernobyl apparently was. Thus, the implication in your statement exag-gerates,the risk from U.S. reactors by at least a factor of two hundred. .
The above arguments suggest that nuclear energy is a very safe means of supplying the electricity that the U.S. economy requires.
Sincerely, CW:spg l
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/ e THE WHITE HOUSE WASHINGTON August 15, 1986
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Detr Mr. Comley:
In accordance with your telephone conver- ., .'
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sation with my office, I am complying with -
your_ request to put into writing the fact that due to the heavy demands on the President's schedule before he leaves for California he will be unable to meet with you.
This is to advise you that the informational packet you sent with your letter has been brought to the attention of the Nuclear Regulatory Commission.
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Sincerely, FREDERICK J. RYAN, JR.
Director, Presidential Appointments and Scheduling
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Mr. Steven B. Comley )
j Suite 1517 i The Sheraton Grand.
525 New Jersey Avenue, N.W.
Washington, DC 20001-1527
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- WASHINGTON D.C. 20001-1527 (202) 628-2100 August 12, 1986 Mr. Frederick J. Ryan, Jr.
Director, Presidential Appointments and Scheduling
'Ibe White House Washington, DC -
Dear Mr. Ryan:
I res s-ilally request a meeting with President Reagan either at the end of the week or sanetime during the beginning of next week. 'Ihis meeting will be nore beneficial to the President than it will be to Fe.
If you need further information please call me at 628-2100, Ext. 1517.
Sincerely, Steven B. Canley Rowley, Massachusetts ,
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