ML20236W532
| ML20236W532 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/18/1987 |
| From: | Studds G HOUSE OF REP. |
| To: | Zech L NRC COMMISSION (OCM) |
| Shared Package | |
| ML20236W501 | List: |
| References | |
| NUDOCS 8712080075 | |
| Download: ML20236W532 (3) | |
Text
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, TMt SNVWCNMENT September 18, 1987 i
Dear Chairman Zech:
I am writing to request that the NRC carry out two specific actions with regard to modifications to the containment structure of the Pilgrim Nuclear Power Station being made by the-Boston Edison Company (BECO).
First, an issue which I believe demands further attention is the question of whether these modifications warrant additional environmental evaluation.
As you know, the Atomic Energy Commission performed an environmental review relating' to startup -
of Pilgrim and issued a Final Environmental Impact Statement in May 197 2. - In analyzing the potential environmental impact.of a nuclear accident, the Commission designated nine classes'of-possible accidents, from trivial to severe.
The EIS concluded that since the probability of occurrence of the most severe accidents was'so small, then the environmental risk was extremely low.
As I am sure you are aware, since-1972 a great deal more has
'been learned about the probability of a serious nuclear accident at our nation's nuclear power plants.
Specifically, NRC and industry officials have expressed concern over the capability of the Mark I containment vessel -- used at Pilgrim -
to withstand the effects of a severe accident.
As you know, the Pilgrim plant has been shut down since April 1986 and BECO is spending $30 million to correct design flaws in Pilgrim's containment structure.
No other nuclear plant in the country has experienced modifications of this magnitude, and these actions have nct been subjected to environmental review.
For example, it is my understanding that changes will be made to the venting system that prevents the reactor from exploding if the cooling system fails.
If the system were activatec, radioactive gases would be intentionally allowed to escape into the atmosphere thrcugh pipes in the plant's roof.
The environmental ef fects of such a radiation release have not, to my knowledge, been assessed.
In my' view, federal law and regulations require that an environmental analysis of this and similar modifications to the containment structure be made before'the plant is a]Iowed to resume operations.
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N Page Two Mr. Lando Zech Septemberf18, 1986 I would argue that NRC regulations require, at a minimum, the performance of an environmental assessment (EA) in.conncet' ion l
with an agency cecision to restart the plant.- As you know, 10 CFR s51.21 states that all licensing and regulatory 1 actions
-l subject to the subpart require an EA, except those identified in E51.20(b) as requiring an environmental impact statement (EIS) and those identified in 951.22(c)-as categorical exclusions.
Section 51.20(b) does not require an'EIS for a, reactor restart.
Furthermore, categorical exclusions (1) through (17) do rot involve decisions to restart.
Exclusion (18) does, however, apply to restarts, specifically for
" issuance of amendments or orders authorizing licensees of.
production or utilization facilities to resume operation, i
provided the basis for the authorization rests solely on a determination or redetermination by the Commission that-1 4
applicable emergency planning requirements are met." (emphasis added)
The clear inference is that restart orders that do not rest solely on these grounds are not categorical exclusions and are, therefore, subject to the requirement for an EA.-
Because the NRC's cecision to restart Pilgrim clearly will not rest solely on emergency planning requirements, the decision to restart would, under these regulations, entail the performance of an EA.
Second, it is my understanding that the Office of Nuclear Reactor Regulation (NRR) is presently reevaluating the second revision
,f the Boiling Kater Reactor Owner's Group (BWROG)
Emergen' j Procedure Guidelines (EPG).
It is looking in partic'Aar at the issue of containment venting, the arguments for v.ich were recently presented to the NRR staff by BWR owners.
It
.s my further understanding that this evaluation and Rev. 4 e
the EPGs will not be completed until early 1988.
I urge you
.o _ delay any final decision on whether to approve BECO's venting system until all containment venting issues -- including environmental concerns -- are thoroughly analyzed and resolved through the ongoing review process.
BECC's venting design _may I
'indeed be a safe and appropriate method te prevent core damage or mitigate its consequences in the event of a severe accident.
A decision to apprcve this system at thds time would, however, be p remat ure and u r.wlse.
In summary, I strorgly urge you to perf orm an environmental review of modificaticr.s to the Pilgrim
- containment, as required e
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- Page Three-if Mr. Lando t Zech September 18, 1987 by NRC regulations, and ask that you withhold-judgment on'BECO's venting system until the revisions to the BWROG EPGs havelbeen completed.
'I appreci' ate your. attention to thi, matter and look forward to working with you, i;
With kind regards.
Sir e el
,I rrf E.
Stu ds Mr. Lando W.
Zech, Jr.
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Chairman United States Nuclear Regulatory. Commission 1717 H Street, N.W.
- Washington,:D.C. 20555 0
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