ML20217Q134
| ML20217Q134 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/05/1998 |
| From: | Crocker G AFFILIATION NOT ASSIGNED |
| To: | Miraglia F NRC (Affiliation Not Assigned) |
| Shared Package | |
| ML20217Q114 | List: |
| References | |
| DD-98-02, DD-98-2, NUDOCS 9804100310 | |
| Download: ML20217Q134 (3) | |
Text
f P.O. Box 174 - IAe Elmo, MN 55042 - Phone: 612 770-3861 FAX 770-3976 l
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hiarch 5,1998 Frank J. hiiraglia, Acting Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D.C. 20553-0001 RE:
Comments of the Prairie Island Coalition Regarding the United States Nuclear Regulatory Commission Docket Nos. 50-282,50-306 and 72-10 Northern States Power Company Prairie Island Nuclear Plant and Prairie Island Independent Spent Fuel Storage Installation Issuance of Director's Decision Under 10 CFR 2.206 Dated at Rockville, hiaryland on February 11,1998 DD-98-02
Dear Acting Director Afiraglia:
In August,1997, we petitioned the NRC for serious deliberation of potentially catastrophic physical and technological problems with dry cask storage ofirradiated fuel.
Six months later, you share your belief system with us. Your decision in the above
{
captioned matter is nothing more than the catechism of an ignorant, arrogant priest bound by superstition to a doomed and barbarous religion.
Take your religion, Frank, and shove it. Your obligation is to make your decisions based on the principles of science, and to provide your industry and the public with the scientific basis for those decisions. This, you have categorically failed to do.
Your refusal to take the action requested by the Prairie Island Coalition rests entirely on the assertion at page10 ofyour February 11,1998 Decision, which states that the NRC has, "(R)easonable confidence that the licensee could, if necessary, safely unload a TN-40 cask.
However, you offer nothing but a circuitous litany of NRC staff " determinations," "fmdings," " conclusions," " beliefs," "judgements" and
" expectations" that pretend tojustify your " reasonable confidence." This is like the Pope reciting Bible verses tojustify his reasonable confidence that God exists. Do such recitations really mean anything in terms of the actua! state of the Universe? Well, the Pope is infallible and gets rewarced for pontificating. But you're not the Pope, Frank.
You're supposed to use science.
1 9804100310 900403 PDR ADOCK 05000282 P
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Acting Director Frank Miraglia March 5,1998 Page two In our situation here, Frank, " science" means that when you use terms like
" reasonable confidence," you are obligated to identify the boundaries ofyour confidence, which means that you must specify the degree of probability that events actually will
. occur as you expect them to occur. At a minimum, this requires that you identify the data that you think defines the situation, the methodology you used to obtain the data, the analytical model(s) you used to process it into a rational set of facts, and the analysis that assessed the probability of this set of facts. Tlien and only then are you entitled to form your conclusions and decision.
Ifyou had provided information in this manner, it would be possible for society to engage in a reasoned discussion about the risks, costs and benefits of dry cask storage.
' Through societal decision-making processes, an informed decision could then be made regarding the prudence of pursuing the dry cask storage option, considering other options available for nuclear waste management and the various options available for providing electric utility services. But you short-circut that process. You recite bible verses. You force society to participate in your religion because you believe in it.
"Although the staff acknowledged the potential difficulties in retrieving fuel from dry-storage casks if significant fuel degradation has occurred, the NRC staff concluded that licensees need not be required to incorporate specific guidance into the normal unloading procedure to address this unlikely situation." Decision, p. 8-9. Where is the data that supports your assertion that fuel degradation during storage is "unlikely?" You admit (p.19) that there is no actual experience unloading a storage cask after a storage
. period. And as your colleague Charles Haughney acknowledged during the NRC's 1995 Public Meeting in Red Wing, MN, regarding dry cask issues, the only data attempting to define fuel degradation is extrapolated from placebo material in a proxy environment for a short time period. But this data provides no more of a basis for confidence, than the irrelevant experiences you list on page 19.
"(T)he NRC staff does not believe that the process ofrefilling a cask with water and returning it to the spent fuel pool will cause fuel degradation or operational safety j
problems." Decision, p.14. Here, you come right out and directly admit that your judgement is based on your beliefs. Belief, Frank, is a low level of consciousness. You provide no reason or analysis that demonstrates that refilling a cask with water will not cause fuel degradation. And the only procedure you relate for refilling a cask with water ensures that we will not find out how the fuel reacts until it is too late, if your beliefs are mistaken. If your beliefs are mistaken, and thermal shock leads to fuel reactivity with criticality considerations, how are you going to develop and implement special measures to assure adequate safety margins in the blink of an eye? What right do you have to play around with such poorly designed and dangerous experiments?
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Acting Director Frank Miraglia
- March 5,1998
' Page three
"(N)ormal unloading procedures do not need to incorporate contingency actions for failed fuel..." ~(Decision, p.16), and, "... the TS do not include specific requirements for the unloading process. Likewise the TS do not detail maintenance or decommissioning procedures or processes." (Decision, p. 24 - 25). In reality, this means that the licensee will make up unloading, maintenance and decommissioning procedures and processes as best they can when the time comes. In reality, you don't incorporate contingency actions and detailed procedures for cask management because you can't.
You hwe no idea what a " normal" unloading operation entails. For allyou know,
" normal" cask unloading and maintenance will result in criticality situations.
Ifincorporation of contingency actions and detailed procedures were required '
before your licensees could use storage casks, dry cask storage would not be an option because you simply do not know what contingency details to plan for. So, to maintain
- dry cask storage for the industry, your only option is to trot out your religion and pretend that detailed cask unloading and maintenance procedures are not needed What rot.
Reconsider your decision, Frank, or there will be a reckoning for such arrogant ignorance. And you will be held accountable. Believe it.
Sincerely,
- P George Crocker Steering Committee Prairie Island Coalition