ML20247R600
| ML20247R600 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/15/1989 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-2642, NUDOCS 8908080065 | |
| Download: ML20247R600 (24) | |
Text
.f.T CERTIFIED DATE ISSUED: S/15/89 f$$ ~~0b' ACRS MEETING
SUMMARY
/ MINUTES OF THE LIMERICK UNIT 2 SUBCOMMITTEE FDA d,'fggp APRIL 25, 1989 i'HILADELPHI A, PA PURPOSE The Limerick Unit 2 Subcommittee met on April 25, 1989, at the Quality Inn, near the Philadelphia, PA, Airport. The Subcotrnittee 1
met to the discuss the application of Philadelphia Electric Company's (PECO) application for an Operating License for Limerick Unit 2.
The meeting started at 1:10 am. The entire meeting was open to members j
of the public. There were six oral and written statements presented by members of the public.
l ATTENDEES l
ACRS William Kerr Chairman Forrest J. Red ck, Member Chester P. Siess, Member l
Gary R. Quittschreiber, Staff MEETING HIGHLIGHTS, AGREEMENTS AND REQUESTS 1.
Opening Remarks Dr. Kerr opened the meeting and noted that time would be set aside after the break to hear from members of the public.
I 2.
NRC Staff Presentatioris l
l 2.a Status of Staffs Review, Open Items, Outstanding Issues, and Recommendations Mr. Richard Clark, NRC Project Manager for Limerick 2, discussed 3
the schedule for the Limerick 2 licensing process and status, noting that the review has not been completed for some residual i
issues, but that no significant disagreements have developed and gp; G
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E ithat resolution of all items is expected prior t'o licensing. 'He discussed the Readiness Assessner.t Program noting that, based.on manyNRCreviewsandinspections',thereishighconfidencet!!at the plant is ready for safe ' operation and that the quality of Limerick 2 construction is among the best of the nuclear power facilities.-
. In response to a question concerning the staff's criteria used for making the statement that " quality of Limerick 2 construction is among the best for nuclear power facilities,"
Clark said this was based on their experience in performing many similar inspections.
With regard to a question from Dr. Remick concerning drug testing with regard to fitness for duty, Mr. McNeill said that their annual random testing coverage is over 100 percent.
With regard to a question from Dr. Remick concerning an open l
item on.the extension of time for operating with inerted con-tainment, Clark said this is for the initic.i start-up program and that it is granted to all BWRs since none have been able to stay within the 6 months requirement of Appendix J without being l'
inerted.
Mr. Clark noted that with regard to the conduct of operations, the Limerick Station does have exceptional site management and supervision which provide strong leadership to support continued performance with good morale and a strong safety perspective.
He cdded that the performance of the site organization has demonstrated that they are capable and qualified to safely operate Limerick 2.
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Limerick'2 Meeting Minutes April 25, 1989-L Mr. Clark stated that subject to the satisfactory resolution of pending issues, the staff concludes'that' Limerick 2 can be operated safely by PECO, without any undue risk to the health and safety of the public.
2.b Region I Inspections ard Conclusions Regarding Readiness fg Startup'
- Mr. Jim Linville, Division of Reactor Projects in Region I, discussed the Region I inspection history at Limerick, noting that their inspection activity is in line with other comparable well designed plants, and that they find tne construction program quality at Limerick to be effective. The'NRC Region I review does provide the confidence that PEC0, its architectural engineer constructor (Bechtel) and subcontractors are committed to and capable of building a quality nuclear plant.
In response to questions from Dr. Kerr concerning whether there is a serious problem with regard to the fuel, Clark said that PECO has made a number of commitments subsequent to the Draft SSER 7, and that a lot more is now known about the problems than was known at the time the Draft was written. This new informa-tion is provided in the new version of SSER 7.
Dr. Kerr questioned the staff on the qualifications of the personnel who performed the Stone and Webster independent design review and what criteria was used to verify the job was well done. Mr. Linville seid Stone and Webster spent about 70,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> reviewing both the design and construction to verify that q
j Limerick 2 was built to the required codes and standards. He said the criteria for judging their work is described in several
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team inspection reports that document the NRC review activities.
In addition, the NRC people assigned have done this sort of work at a number of other plants and have developed criteria on a m____
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' Limerick 2 Meeting Minutes April 25, 1989 comparative basis. Mr. Sam Collins, NRC Staff, added that the pOticular inspection conducted at Limerick indicated very few p' programmatic hardware deficiencies and that the results of these inspections are in fact better than what they have seen at other plants. He added that the specific details.are in the reports.
In response to questions from Dr. Kerr concerning the ATWS issue at Limerick, Mr. McNeill said it is still under discussion but that there has been a disagreement on the interpretation of diversity of the equipment. He said that if the new interpretation stands they will have to make changes to the
-plant.
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In response to a question concerning whether the staff.could assure the Subcommittee of a low likelihood of there being any counterfeit equipment in Limerick 2, Mr. Clark assured the Subcommittee that PECO has responded appropriately to the staff bulletins concerning this matter.
3.
Philadelphia Electric Co. Presentations 3.a Introduction and Corporate Readiness Mr. Corbin McNeil, Executive Vice President at PEC0, provided an overview of the day', agenda, and discussed the nuclear organi-(
zation structure at PECO for the Limerick Station. He stated there was a lack of adequate leadership and management skills on the nrt of senior PEC.0 management which led to the' shutdown at the Peach Bottom Station.
These problems did not occur at Limerick, which developed in a culture of engineering and 4
research rather than electric production.
He added that Limerick is a newer plant, and key Peach Bottom personnel had l
previously transferred to Limerick.
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l Limerick 2 Meeting Minutes April 25, 1989 l
3.b Limerick 2 Construction Mr. John Keraper, Senior Vice President of Nuclear Construction at PEC0, discussed the history of Limerick 2 construction.
i Construction was stopped in January 1284 due to a Public Utility Commission Order.
Limerick 1 started comercial operation in February 1986 and Limerick 2 construction restarted at that time.
Limerick 2 fuel load is scheduled for June 1989 with commercial operation scheduled for December 1989.
i Mr. Kemper noted that PEC0's design and construction philosophy has been to minimize the differences between the Limerick units.
In addition, due to the stoppage of construction on Limerick 2 in 1984, they were able to complete the design prior to restart-ing construction. These actions minimized the construction interface problems and resulted in a minimum amount of rework probler:s and high productivity with construction ccmpletion ahead of schedule and below target cost.
3.c Limerick 2 Pre-Op/Startup Power Ascension Test Status Mr. Ted Vilrich, Startup Manager at PECO, provided Limerick 2 design information and listed the major shared systems with Limerick 1.
Significant design differences included changes due to the snubber and hanger optimization program and reduction of pipe whip restraints due to elimination of arbitrary interme-aiate break criteria. Stellite was also removed from the ccntrol rod blades in Limerick 2.
There were numerous operator changes which assist in operation. These include physical layout and different equipment and valving.
The pre-criticality test program is going well, with the hardware to support the program installed, and with NRC Region I review of procedures about 2/3 complete. The scope is more
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2 Limerick 2' Meeting Minutes April 25, 1989 extensive than other programs approved for recent BWRs, but less extensive than that for Limerick 1.
PEC0 has found some of the-tests performed on Limerick I not necessary to repeat. The present schedule for testing and commercial operation is still ahead of the original schedule developed at the time con-struction was restarted in 1986.
3.d Limerick 1 Operating History and Limerick I and Peach Bottom Lessons-Learned Mr. Graham Leitch, Vice Pres'ident at Limerick, said that the PECO vision, is to be the " leader in the nuclear power industry" with its mission to provide " safe, economical, reliable power."
PECO has demonstrated its ability to manage Limerick at or better than INP0's first quartile with regard to radiological l
control, safety, safety system performance, forced outage rate
- 19 months without a forced outage and none in 1988) and number of scrams.
Mr. Graham discussed the fuel performance problem at Limerick I noting that the initial core and first reload fuel were susceptible to crud-induced localized corrosion (CILC). The contributing factors which led to this problem have been corrected for the short-term, and long-term preventative measures are being implemented.
Mr. Graham discussed the 3 previous SALP Reports for Limerick 1 operations and the general. direction of the improvements. He stated that the major problem at Peach Bottom was lack of leadership at the site. A major basic difference between Peach Bottom and Limerick was that Peach Bottom required the shift managers to have an educational degree but only required limited experience.
The policy at Limerick has been no requirement for a degree, but long on experience. The shift superintendents 1
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have been at timerick for a minimum of 8 years and have at least
- 20. years of power plant experience.
Limerick does require the Shift Technical Advisor to be a degreed engineer and to receive special training in accident management, and in mitigation of core damage..
Mr.- Graham discussed the operator staffing problem at Peach Bottom which caused a shortage of operators. Limerick does have staffing for six shift teams for two-unit operation such that scheduled overtime is not required to fill positions.
Entry-level requirements at Limerick have increased to require a two-year degree or navy nuclear experience. There are now enough personnel in the pipeline to provide for a planned flow to off-shift assignments.
Mr. Graham discusst 'he cultural enhancement at Limerick, e.g.
a site newsletter, frequent meetings, face-to-face performance evateation, self-assessment of personnel practices with regard to professionalism. He feels that Limerick has good intergroup communications and does have a commitment to excellence for nuclear operations.
3.e Readiness for Two-Unit Operation at Limerick Station Mr. Marty McCormick, Plant Manager, discussed the Limerick organization and the operator staffing. He noted that all 60 license holders did pass the special NRC exam given for the Limerick 1 and 2 differences. All differences have been incorporated in the continuing training program.
He discussed' the numbers of licenses required versus available and projected, indicating proper staffing is anticipated.
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Limerick 2 Meeting Minutes'. April 25,1989
Mr. McCormick discussed'a Maintenance /I'&C Readiness Program J'
which trends. equipment failures and: predicts maintenance re-quirements. This has resulted in a low corrective maintenance backlog. By using vibration' analysis, oil analysis and thermo-graphy they can decide whether equipment is running as well as -
~it was to begin with.
-The maintenance division is s'affed and organized for two unit t
operation, is INP0. accredited, and is verified by NRC
~ inspection.
4.
Public Stateme g Oral and written public statements were received from the following individuals and groups at the meeting. The written statements provided at the meeting are attached.
a.
Marvin I, Lewis --Limerick Ecology Action b.
Richard Myers - Citizens League for Energy Awareness and Resources (CLEAR) c.
Ruth Miner - Citizens for Environmental Rights d.
Emanuel Mendelson - Citizens for Environmental Rights e.
Phyllis Gilbert - Sierra Club f.,
Margaret Dardis - Concerned Member of the Public.
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A Limerick 2' Meeting Minutes April 25, 1989
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Philadelphia Electric Co. Presentations 1[,
W 5.a' Limerick 2-Self-Assessment Mr. David Helwig. Assistant to Frecytive Vice president Neamgr, discussed the Limerick.2 self assessment activities involving a readiness program assessment, an organizational readiness assessment and a readiness verification. program. These constituted a thorough process of self-assessment which did identify items for action. The process provided an effective L
confirmation of readiness for operation.
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5.b Status of PRA and Related Issues Mr. Alan J. Marie, Probabilistic Risk Assessment Branch Head, discussed the PRA program at PECO. The group is made up of several full-time personnel. There is also a Technical Advisory Panel, comprised of three industry PRA experts, which provides l
l technical reviews and advice to assure that PRA activities utilize up-to-date methods and information, and which reviews PRA activities at the request of the PRA Branch.
The PRA Program at PECO was developed in 1988 by a task force representing all organization in the nuclear group.to develop and maintain models for nuclear stations and apply models to provide insights on ways to improve performance.
It also L
disseminates PRA information and provides PRA training.
The Limerick Generating Station PRA was developed in 1980 through 1983. The PRA was updated in 1986 through 1988 and will be updated to support the IPE and to include external events.
The original PRA showed a total core damage frequency of 1.45 E-5 and the latest 1988 update shows a frequency of 6.69E-6.
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a L'imerick 2 Meet'ing Minutes April 25, 1989
- Mr. Marie noted that the o'riginal PRA did influence the final Limerick design in the areas of the standby liquid control, the 3.
MSIV and ADS air supplies, and the fire propagation barriers.
PRA.is, being used to prioritize modifications.
PRA information is being disseminated through training of over 600 personnel. to date. along with a quarterly ~ PRA newsletter and distribution of PRA update summaries.
l 5.c. Status of licensing Mr. David Honan, Limerick 2 Licensing Branch Head, discussed the licensing activities remaining for Limerick 2 and discussed the PECO actions taken with regard to ACRS recommendations in previous letters. These recommendations were in the areas of severe accident mitigation features, systems interactions, and seismic risk. Limerick has installed specific features for accident mitigation and the IPE will be the basis for future work in these areas.
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Concluding Remarks Mr. Corbin McNeill, Executive Vice President for Nuclear, discussed the challenges for the PECO nuclear group for 1989, noting that Peach Bottom 2 restart will occur in April 1989, Limerick I will return from refueling in May 1989, Limerick 2 fuel load will occur in June 1989, and Peach Bottom 3 restart will) occur in September 1989.
FUTURE ACRS ACTION
,Dr. Kerr suggested that the Limerick 2 operating license review be discussed at the May 1989 ACRS meeting.
He noted that the meeting was scheduled for the afternoon of May 4, 1989, and a detailed schedule would be provided by the ACRS staff engineer.
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Limerick 2 Meeting Minutes April 25, 1989 The meeting was adjourned at 6:45 p.m.
NOTE:
Additional meeting details can be obtained from a tran-script of this meeting available in the NRC Public Document Room, 2120 L Street, N.W., Washington, D.C. 20006,(202) 634-3273, or can be purchased from Heritage Reporting Corporation, 1220 L Street, N.W., Suite 600, Weshington, D.C. 20005, (202) 628-4888.
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9 S T A T E MEf 4T OF lit 1ERICK ECOL OGV ACTION Before the Nuclear Regulatory Commission's Advisory Committee for Reactor Safeguards.
in the matter of The Operat2ng License for Limerick II Limerick Ecology Action respectfully submits the following Otstement in opposition to the granting of the operating 12 cense for the Limerick II nuclear power plant. We request that the Advisory Comm1ttee for Reactor Safeguards recommend to the Nucleer Regulatory Commission that the operating license for Limer2ck be withheld from the L2censee for the reasons stated h2 rein.
Synops2s.
Retent developments on the international and national scene have 2molved incidents with nuclear reactois of sam 21er or the sar-csions as the Limer2ck II reactor. These incidents have deemons tr a t ed dangerously def a c 2 ent design and unanticipated failure modes. Recent publication of several studies have also cost a cloud over the edequacy of the Lin,erick Mark II containment, the design of the nuclear steam supply engineered cafety systems and quality assurance of materials and components.
The developments on the international scene include the rccent withholding of information of a precursor accidant in a 12-15-88 and 4-10-89.) The G rman reactor. (Inside NRC 12-5-88,
Gernan reactor wrs of similar design to the Limerick II reactor in that the comparable valve configuration would lead to a cimilar accident.
The other accident on the internat2cnal scene was Chernobyl.
Th2 unexpected information from the Chernobyl accident was that Otoam explosions are likely. The design of the Limerick II plant unos assumptions that steam explosions are highly unlikely and that designing for steam explosions is unnecessary. The Limerick II reactor has a dangerous similarity to the Chernobyl reactor in
.that both reactor s were designed using the assumptions that steam fixplosions are unlikely and that designing for steam explosions 10 unnecessary II is plagued with many more problems:
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Limer ick
- 1. Continuing management incompetence as displayed in the
" sleeping" incidence which caused tSe order to shut doun another plant operated by the same licensee.
- 2. Poor morale caused by layoffs at L icerick II, and subsequent vandalism and poor quality.
- 3. An inadequate containment admitted
.n the " Reed" report.
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, Immediacy of interfacing systems loss of coolant accident.
The term," interfacing system LOCA" (ISL), refers to a class of nuclear' plant loss-of-coolant accidents in which the Reactor Cnolant System (RCS) pressure boundary (isolation valve, piping wall, etc.) interfacing with a supporting system of lower design pressure is breached. The interfacing LOCA has a long history of
. concer n to the NRC. ISLs were looked at in the Rasmussen Report-(Wash 1400, Reacto. Safety Study, August 1974) and the update (NUREG 1150.)
Wash 1400 and NUREG 1150 refer to ISLs as an accident 2nitistano esent, "V."
"V" or I SL is defined as unisolatable rupture of a low pressure coolant injection caused by failure of the set.of valves that normally isolate the RCS from the low pressitre. system.
The ISL core damage frequency based on previous assumptions mny vary from 10E 4 to 10E-8 per reactor year. The exponential numbers te mslate toto one reactor accident.every ten thousand to t e r-
} !:: a reactor vears of operation. One reactor accident every Leo t hou s,a nd pars seems very comforting to the statistically uninitiated. The one accident every ten thousano years is based upon previous assump tions and outdated data. The chance of an ISL appears much greater than the present estimate.
A orobabili ty o f o..e ISL_ Der reactor v g may be closer to
.roality than one every ten thousand years.
j The emerging body of knowledoe about ISLs in BURS is cufficient to cause concern about protecting the health and cafety of the public by allowing Limerick II to operate.
(NUREG/CR5124) Adding to the concern about the ISL, the emerging concerns about he 11merick II management puts this reactor in a
- vory unfavorable light.
The Limerick II licensee has a system Overburdened with ac i no p l a_nt ( NLIREG/ CR-4747 ), new cons t ruc t i o_n,
and management incompetency. This is the very mi:: of concerns tehich lead operatois into making the mistakes wh2ch cause ISL s
.cnd other accidents.
Human beings display a learning curve. Many m2 stakes are made Mhen new information is first used. In nuclear plant operation,
'f.,this learning cui ve surf aces in many transients when a plant comes on line. Considering the newness of the information on
[ interfacing LOCAs, caution is required before allowing a new 7 plant as Limerick II on line.
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replications of the unpublicized German reactor accident.
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- a. German'PWR, suffered a precursor accident which' could'have proceeded to an interfacing systemsEloss of coolant-
' accident..The Nuclear L'gulatoryx commission har, reported the
,, likelihood of,.inte, facing lots of coolant. accident'for boiling
' wster L reactor s of ; Limerick : design. J (Inter f acing Systems LOCA:
Boiling' Water Reactors,, February-1989.) The history of-consideration of interfacing LOCAsLis long. The sequence was
-considered tu the Rasmussen; Report (Wash.1400, Reactor Safety Study. August J974) and.itsa: update NUREG 1150.
LAs-ser iousl as the' Biblis A precursor acc2 dent 2 2.
the full Erami f i c a ti ons. of the incident contain a-certain mystery.
Some'ofLthe elements,~uh2ch produce'this mystery include 1.:The Bib 11sLA.acci' dent ir. formation took several months to get torthe NRC.
2.:These was'a' release of radioactivity outside of. containment.
- 3. How close did.this precursor entend tov'ard a major accident is unknown.
- 4. teu wlaer +ble si e US commerc2a1 reac toi s to an interfac2nq 4
.LOCA may have been grossly underestimated.
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' 5J Th2 s mishandla no o ff information parallels the mishandling of information preceding the.TMI#2 accident, and the lack of timely
.informa t2on was cons 2dered 'a cause-of the TM1#P acc 2 dent l
LThis last' question concerning timeliness of information is l
portscularly tooubling..Both the' Tt11#2 accident and the Chernobyl accident ~ appear the result'of untimely receipt of information.
-After.the Tf11#2 accident, the L2censee filed a lausu2t partsally
- en the basis that information on a precursor accident had been withheld until aften the accident. In the Chernobyl acc2 dent, one
- chift did not properly inform the following shift of valve
.clignments.
Valve alignments-are a critical cons 2deration in su y
interfacing-loss of coolant accident.
An interfacing LOCa needs ool v tuo valve misalignments to produce Jan accident. AJthough the NRC has attempted to answer some of thase questions on the interfac2ng LOCA uith the publication of H
NUREG/CR 5124, many considerations still are outstanding and rcquire caution befoie allowing a new plant ~into operation.
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'New information from the Chernobyl accident.-
The Chernobyl accident is the worst o.i record. Just as in the TMI;462 accident, the lesson will be lost if we do not accept the nsw'information surfacing from this accident. This new information bear s directly upon the probability and consequences ofJa severe accident at the Limerick II nuclear power plant.
The new information is that the accident at Chernobyl involved a s team e::plosion and not the core meltdown scenarios presentJy assumed in the design of light. water reactors. (Soviet 1repoi t presented. a t the meeting of the Inte national Association of Atomic Energy (IAEA): in Vienna, August 1986.)
ihe war that steam e); plosions progress is different from the scenat ios-for core meltdowns used in the documents for Limerick II. Steam explosions casi occur seconds.after'a core is uncovered.
The core meltdown scenarios used in the design. documents for Limerick II assume that a core meltdoun will tal e many minutes or hours to progress to a core meltdown. Credit is taken that an
op3rator will initiate actions to avoid a major accident in the long time that.is required for a core to melt down. 4 steam esp:
!J not provide en operator sufficient time to act to avoid an acc 3 rient. tWash 1400. NUREG'1150. NUREG/CR 5124, Earth Island Journal. James Harding, Page 21,. Fall 1986.)
Since the design of Limerich II is bassd upon a dangerously flaued assumption, the design will eiot piotect the health and safetv of the public adequately. The as2:1mption is that the core meltdown sceiscio uill predominate and that steam explosions see co unlikely that the design need not consider the possibility of steam explosions. The Chernobyl accident was a steam explosion.
thowing thatl steam enplosions are likely and that present assump tions are flawed.
Steam eeplosions are veiy lilely and the d25ign must cor. sider steam enplosions to protect the health and Gafety of the public adaquately.
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4 D$ficientimanagement. displayed by Licensee.
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'The'12censee foi Limerick II has had asiother. plant in his
'cystcm ordered shutdown for a." sleeping": incident directly.
related'to deficient management..The deficient. management
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' idisplayed in the"" sleeping" incident continues and worsens' throuchout the licensee service area. The licensee has been
.cccused.of many. actions which fall.below any reasonable standard of business conduct.
Some of these. actions which cause suspicion of the licensce:
'go bact' year s.. and. son.e ere recent. Pc>nosv1vania. Public.Utilaty Commission Administrative Law Judge Metusthek fined the licensee Lfor' improper 1v.chargina ratepayers for cost-of' surveillance of
! protesters ageinst'Lin.erick. Several char 3 ties accused,the licensee of forcina'them out'of a communit,' charitable organi zat 2 on by ~ unf ai rly using its position on the board of that orgeosration. The. morale a t L2 morict: II is dangerously lou due to
.. lay-ofis and an attitude that licensce is toc worried about the
- bottom line to cons 2 der safety.
The sum is that-the. progress on Limerich 11 is highly suspect and;p.ote *. a ficient. Allowing a reactor w2th the many problems of.Limer:ch 11 to operate fails to protect the health and safety
'.cf the public.
.l Respectfully subm2tted, Marvin 1. Iewis, R. P. E.
7801 Roosevelt Boulevaid l
Suite 62-Phila., PA 19158 1
(215) 624 1574 4-25-89 l
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CLEAR Citizens League for Energy Awareness and Resources 740 CATHARINE ST.
PHILADELPHIA, PA 19147 (215) 925-5435 TESTIMONY PRESENTED TO THE NUCLEAR REGULATORY COMMISSION SAFETY ADVISORY GROUP PHILADELPHIA, PA APRIL 25, 1989 BY RICHARD MYERS, DIRECTOR, C1. EAR As the Nuclear Regulatory Commission considers the potential operation of the Limerick II reactor, we encourage you to heed the concerns of citizens throughout this area.
These concerns focus on placement of the Limerick reactors, design of containment, evacuation issues, monitoring of releases, and the reliability of the operator, Philadelphia Electric Company.
Limerick I was found to be one of the most hazardous resctors in the United States according to a Sandia Laboratories study entitled " Technical Guidance for Siting Criteria Development." The study's estimates, released by Congressman Edward Markey, show Limerick to be the nation's third worst reactor for risks of early radiation deaths, fifth worst for cancer deaths, and the wnt for early radiation injuries requiring medical attention.
Containment design could contribute significantly to any serious accident at Limtrick. The General Electric series of Mark reactors has drawn criticism from many quarters. A pressure suppression system, as vas the containment at Chernobyl, the Mark I has been studied and found seriously deficient. According to the NRC itself, there is approximately a 90 percent chance that a Mark I system vill fail in the event of an accident. The Mark II systems at Limerick appear to be but a slight improvement, if at all, over the Mark I system.
An NRC task force, confirming the failure rate of the Mark I reactors, noted that containment failure could occur as early as forty minutes into an accident--thus leaving little time for emergency evacuation.
The whole issue of evacuation has convinced many area residents that neither the utility in charge nor the governmental agencies with oversight power place a high priority on residents' well-being in case of an emergency. Current NRC rules prohibit construction of a nuclear reactor on a site where more than 2.1 million live within a thrity mile radius. More than 3.6 million people now live within that distance of Limerick. Common sense and honest concern for the safety.and health of these citizens require that, at the very least, thorough emergency plans are developed. Existing plans do not meet any but the most minimal legalistic concerns, thus pitting an industry and government against the citizens. Whether there ever is a major accident at Limerick or not, the purpose of emergency planning is to plan as if there will be.
Efforts by Philadelphia Electric and the NRC to discount the possibilities of an accident are irrelevant, misleading and, quite simply, wrong.
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I Existing emergency plans for Chester, Montgomery, Berks, Bucks and Lehigh Counties do not adequately address the impact of the emergency responses by Philadelphia or other populated areas lying outside the ten mile emergency 1
planning zone on these counties' own emergency plans.
The use of highways, medical facilities, shelters and other resources will inevitably be even further strained by the movement of large numbers of people who are not included in the official plans. When large urban concentrations, such as Philadelphia, are deliberately excluded from emergency planning, it is impossible to have me&ningful plans for anyone in the affected area.
1 CLEAR is also very concerned about the citizens of Philadelphia itself. We are now approximately 25 miles southwest of the Limerick reactors; the wind blows from Limerick to the southwest almost one-third of the time; and the citys emergency response director has stated that Philadelphia could not be evacuated in event of a major emergency such as a reactor accident. We know that citizens up to fifty miles distant in " radioactive hot spots" around Chernobyl were evacuated, as well as the official evacuations to a radius of 18 miles. We also know from experience of the Three Mile Island disaster and surveys at other U.S. reactor areas, that significant numbers of citizens living up to 25 miles from reactor sites have said they would evacuate during a declared emergency. Responsible emergency planning would face this issue honestly by including the city of Philadelphia in the planning process. But once again, industry and government reliance on the most minimal legalistic methods have pitted them against a citizenry asking only that its safety and health be honestly considered.
The lack of candor and concern from the industry and regulatory community has r-*+', climate of distrust among many citizens of this area.
Can we count i.. n.da try to monitor releases from its own plants? We believe not and thus strongly encourage the establishment of an independent citizens' monitoring network so that the residents of the area will know when they are being exposed to the releases known to come from General Electric designed reactors, let alone during an emergency condition.
Can residents trust Philadelphia Electric to manage its operations safely? The evidence of Peach Bottom speaks loudly to this question.
Only after severe threats and fines did management make minimal concessions to safe operations. Unfortunately the problem of operators drugged out or asleep at the switch is again only the tip of the iceberg as far as the real safety issues are concerned.
But, as we have seen, this minimalist approach pervades the climate of nuclear operations in this,
nation.
Will the utility and the NRC seriously and conscientiously address the problems raised by Limerick Ecology Action's court suit? Or will they seek the
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minimalist response once again? Can we trust the industry and government on the issue of nuclear power today? As much as we citizens would like to believe
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we could and as much as we like the situation to be so, unfortunately that is not the case today. What is required is a real and honest effort to develop a safe, healthy and economical energy system for our nation, rather than an effort to keep a dinosauer industry from extinction. We do not live in the Soviet Union af ter Chernobyl. We Americans can and do demand a say in the vital issue of energy production and we are, hopefully, intelligent enough to learn from the past and to create a safe and democratic energy future. We encourage government and industry to join us.
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1 STATEMENT OF RUTH MINER AT QUALITY INN HEARING 4/25/89 re Reactor Safety Hearing in Regard to Limerick II l
Greetings to officials and employees of the Advisory Commission on Nuclear Safety and the Philadelphia Electric Company! Possibly this will be our (the citizens')
last opportunity for public comment on the licensing of a nuclear reactor, since, following the advice of Forbes Magazine and the example of France, the government's energy plannere have briskly proceeded to bypass, supercede and countermand even the inadequate regulations related to safety and health that they previously adopted under pressure of past emergencies.
j Precautions are now limited to warning utilities and their personnel of any lapse of vigilance or laxity of procedure in attending to the multitudinous details of operating their experitnental reactors, which now represer.t some 60 different 1
designs.
We won't bore you by rehearsing in detail the design shortcomings of these 57+
varieties--even if we, or anyone else, could do so--but we do want you to know that we are well aware of the perils of the General Electric Boiling Water Reactors the government is licensing in our backyards.
We know that you know the pressure suppression containment systems of General Electric Boiling Water Reactors are inadequate as acknowledged back in the 70's by Mr. Hanauer, and that General Electric has been sued by four utilities at least for concealing known flaws from the public.
- u......a t you are aware of the inferior materials sold to the government and the utilities by suppliers, bolts that can break, valves that can fail (for example in the example cited in today's paper at PSE6G's Salem I reactor, for which PSE6C have been fined $50,000), 0-rings that are in questionable condition, and pipes liable to crack (and we know that in the case of the steam condenser that dripped copper on the claddings of Limerick I and cracked the pipes, releasing radioactivity into the plant, The Philadelphia Electric Company has not replaced the steam condensers in Limerick I and II and in Peach Bottom 2 and 3, as Mr.
McNeill said the company would have to do--even though three of those plants were shut down and problens should and probably must be repaired while they are not in operation--but instead the operators have settled for a patch job and extra monitoring, probably because the stockholders need their $80 million more than the workers in the reactor plant need safe working conditions.)
We know it is of no concern to industry or the NRC that, to quote Ralph Nader's latest Public Citizen safety report on nuclear reactors, "The problem of worker exposure to radiation is most acute at the nation's 32 Boiling; Water Reactors.
On the average, workers at BRRs received nearly 30 percent more radiation than those at other reactors." But we want you to know that we are aware of that.
We know it is of small concern to nuclear proponents that, to quote the December 1986 report from the Council on Economic Priorities, "the greatest adverse change in infant and fetal mortality rates was registered by those counties close to Boiling Water Reactors." It may seem like a fluke to you, but we want you to know that we are aware of the growing evidence f rom such statistics.
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l Minet iestimony 4/25/89 We know that from a practical viewpoint it.is pointless to point out to you
,(even though you are a group supposedly concerned with reactor; safety) that Philadelphia is situated within 25 miles distance of the two Limerick reactors, 4
'both'of them of General Electric Mark II design, and'that this city's director of emergency services has verified that Philadelphia cannot be evacuated--even within two. days, a critical time--in a~ nuclear emergency.
Although we want you to know that we are aware of that fact, we realize that it' E
makes little difference to those who countenanced the licensing and operation of Seabrook and Pilgrim and Shoreham--all adjacent to areas with large populations that cannot be evacuated.
And that fact brings us finally to the growing public recognition of a fact just as ominous in its uay as the physical and biological threats. inherent in the nation's nuclear f acilities and our government's nucleer folly, which you are in the business of trying to make legitimate: That is the United States public's
-loss of political freedom, the erosion of states' rights--overriding of the authority of state governors in Massachusetts and New York and Pennsylvania and the defiance of our Pennsylvania Department of Environmental Resources--the violation of the citizens' right to choose a source of energy.that will not contaminate our environment. irreparably for thousands of years. We are losing, and may have. permanently lost, the human.right to a clean environment with recourse to elected officials who would be responsive to our plight.
The NRC says it has the authority to decide what is safe. We say the NRC has proved to be unworthy of public trust.
But we are aware that it is merely symptomatic'of a government that is run by the power of greed, and the NRC is merelv its agent, and the media are half asleep, intent on entertaining.
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Nevertheless, the Nurenburg Principles apply here. We are servh t notice that because we are aware of these truths we will continue to witnest o them.
In the latest Harris poll, citizens all across the nation have expressoa their abhorrence of nuclear power. They will not always remain passive, and we will remember all these events. When disaster strikes, the bought public officials and the toadying government workers will be called to account.
Let them look out when the great unconscious public finally wakes up.
It is fashionable these days for utilities to call in Navy nuclear submarine admirals to Beef up morale in power plants. Admiral Rickover, the father of the nuclear Navy, has had close connections with nuclear power in our state. He supervised the construction of the first civilian reactor at Shippingport and he was used by the industry to okay the restart of Three Mile Island operations, for which he was promised funding for a special project of his. The funding was terminated after the reactor went on line.
Near the end of his life he issued a warning, which I am quoting from this book, At Work in the Fields of_t_he Bomb.
Rickover told us, "Every time you produce radiation, you produce son 6 thing that has a certain half-Ilfe, in some ce es for billions of years.
I think the human race is going to wreck itself, and 2:'s important that we get control of this horrible force and try to eliminate it."
In this nuclear game we are playing, the same question can be addressed to the unwary general puolic and the corrupt and indifferent officials:
i WOULir YOU RATHER BE WARNED BEFORE OR AFTER ITS TOO LATE?
Ruth Allan Miner Citizens for Environmental
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g.ril 2L, 1939 4 Drael 'wndelson, CITwi6 for t WIR0hNTAL RIGHTS.,
It is a sad day when I have to stand up and express g uncompt ordsing onesition to the licensing of Limerick II. As a retired scientist utf"b has con acted. serious research in a numbar of biological and medical fieTda, it is iror.ie for me to recall that in earlier times I tried to advise members of the nucIsar corr. unity about a simfle method to separate atomic isotopes which had cons to Mcht in some of n;yi oE work. Although I addressed severa.1 avenues in this high1)r classified connunity, I rever received ary feedback. In all Hkelihood, g
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prop osec methodology had already been inaugurated, because years later I learned that it was Deirt put to use.
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At pesent, in ry opinion, the p roposed licensing of Linerick II is both a tareat and an insult. We do not reed thiI specious energy output thzt PE proposes.
Energy conservation an2 PL's efforts to reduce our need for gao&}ine are far more e
carrencable. Nuclear power gereration involves the transmutation of elements, whier. irevitably results in both short term and long term threats to hungn life.
We have already seen some of the worst of these in Hiroshima, Magosaki, ihree-F.ile Island, and Chernobyl, and we can expect far more devastating than ary of these in the future because of our technological advancements for military insanities.
Our survival and wellbeing hang in the balanco. Is it going to be stoc'dohders' berefits or mankind's health that determines the issue ?
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O EASTERN PENNSYLVANIA GROUP 1207 CHESTNUT STREET
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TESTIMONY BEFORE ADVISORY COMMITTEE ON. REACTOR SAFEGUARDS APRIL 25, 1989 Thank you for this opportunity to express National Sierra Club views regarding nuclear power f.n general and the local Club's concerns about Limerick.
II.
Since the 70's the National Sierra Club has urged that no new nuclear I
power plants be constructed, fearing their destructiveness to the environment and human health. As an alternative the Sierra Club promotes the increased use of renewable energy and widespread implementation of conservation.
In that policy framework, I will speak for the Pennsylvania Chapter's Sierra Committee on Radiation and the Environment (CORE). Our almost 16,000 members are concerned at their vulnerability to this ever present nuclear power plant, Limerick II.
Because of short notice of this meeting, I would like to point up a few main problems in general terms and follow with details in due time.
Sierra Club, being an aveved advocate for the environment and public safety in our democratic society, takes issue with Philadelphia Electric Company (PECO)'s
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=ctr influence with the United Way to eliminate the Sierra Club and other environmental groups from their Donor Option Support Program. The second deals with PECO's hiding a report on reactor safeguards from the public.
Specifically, the Reed Report disclosed General Electric's findings that their Mark 1. II, and III containment designs within boiling water reactors are likely to fail. Tomorrow is the third anniversary of Chernobyl. We must learn from that tragedy and be overly cautious, certainly not clandestine when the public safety is at stake.
At least the Mark II containment at Limerick II should be corrected.
In addition to Limerick II management's apparent disregard for public safety,
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the Sierra Club is concerned at the plant's history of construction and opera-l tional problems. These range from huge gaps in cooling tower concrete work to faulty valve installations to recently reported leaks from reactor fuel rods.
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Can we trust PECO to correct such problems? Even so, Philadelphia's Water
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Department predicts a dought by early summer. We are presently at 2/3's storage capacity. Limerick I's water flow rate is 476 thousand gallons per minute from which 12 thousand gallons per minute are evaporated per minute./ Now multiply that huge consumption by two. Must we continue this dangerous drain on our precious water supply?
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"Not blin opposition t progress, t oppo ition to blindprogress" l
Ponted on Recyced Paper Jp !/
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';Fo23cwing ic a statement to the Sub-Committee on Reactor Safeguards,
=ceting held at Quality Inn (philadelphia Airport) April 25, 1989,
- 3 by. MARGARET M. DARDIS, of'Newtown, PA.
(Thic' general statement is backed by appropriate documentation which, however, is not at hand to submit copies to the Sub-Committee becauce of an accident to my residence which resulted in most of my papers 4
being stored for safekeeping.
I chall duly cubmit the material within 30 days after this keeting.)
l STATEMENT l
Changes in Nuc2 car Regulatory Commiccion rules and procedures has not removed their primary moral and technical responsibility to'public cafety and the environment. Indeed, the conflation of licencing and evacuation procedurec p2 aces an even greater burden upon them. Now, more than ever, it ic important, not occasiona12y to ALLOW the public to cpeak, but to LISTEN to the public. Recent events in Alacka in a different inductry nevertheleco point to the principle that cocineco between industry and regu2atory officia2c 2eads finally to irreversible disaster. A2though today's meeting is billed ac being concerned with PRA'c, we must guard againct itc being nothing more than PR's.
Over several years of attendance at drf22c, workchops, proceed-ings before the AS&LB, meetings with the inductry and/or NRC Staff, as well ac reading a Mount Ruch= ore worth of =sterial, ! feel que11-fied to accert that, with regard to Limerick II,.2icencing will on2y ce= pound an a2 ready unreco2ved safety iccue-- unreco2ved in the
..Le ef actua2 fact, not bureaucratic word-twicting.
That iccue is that, in its statement on the 2eccone of Chernobyl, the ACRS acknowledged that, although-- as we all know-- a reactor accident in the U.S. would occur frcm different pr:nimate cauces, it (a) could occur and'(b) could occur in the came magnitude.
In fact, I would observe that an accident of 2escer =mgnitude, with a lower rice of plume, could cauce greater local effects than at chernoby2, though with comewhat 2ecc !==ediate dispercion into the world's enviren=ent.9h' The iccue is, additionally, that Environmental Protection Agency guide-2ines.for protective recponce for the pub 2ic could require relocation of people at considerable dictances beyond the official evacuation eene. Projecting the statistically = cot probable direc-tion of a plume, it is poccible that portions of Philadelphia would be relocated.
In the pact, however, Philade2phia City Council and othe.
i city officials have stated ci= ply that prompt re2ocation of people from the city is an i=poccibility.
Despite accertions that NRC and FEMA are capable of acccccing the
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adequacy of emergency p2anning, neither agency has accepted the duty s,f of providing relocatfor p2anc. Indeed, tectimony by NRC Staff before the AS&LB hac made clear that a22 recponse beyond 10 milec ic ad hoc which is another word for non-existent.
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I call the sub-com=$ttee's attention to the fact that within the
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pact ten days, varicus local government and emergency cervices carried
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E out a drill of a major disaster (not nue2 car) in the Delaware R*ver
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area.
They had prepared for the dr 22 for tec yearc, nChiPtbr ph'/ ((
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t coretica33y ab3e to hand 3e come.250 casua3 ties, a far cry from-I
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rc3ocating.the popu3aton.around the.cecond-most densely populated l
' reactor cite in the nation, j
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It has been stated again and again,. including in the NRC'c'own I
l' citing criteria, that thic cite, if Limerick I came up for construc-tion approva2Ltoday, it would De' turned down.
Why,-then, having made one mistake does the Commiccion contemplate doubling it? Ignoring the evacuation /rcelocation question as part of the over-all cafety status of Limerick:II ignorec' rationality, morality, and the NRC's Congreccional mandate to protect the pub 3de.
Thic Sub-Committee oughtLto deny licensing to Limerick II until.
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.re3ocation plans for Philadelphia and the suburban countdec within a Chernobyl cited radiuc~(18 to 38 miles) have been developed or, as ic more l'!kely, found to be impracticable to fabricate.
Copies of.documento to. follow within 30 days
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