View source for NRC-2012-0022, Comment (18) of Scott D. Portzline on Behalf of Three Mile Island Alert, on State of the Art Reactor Consequence Analyses (Soarca) Reports

{{Adams
| number = ML12062A076
| issue date = 02/28/2012
| title = Comment (18) of Scott D. Portzline on Behalf of Three Mile Island Alert, on State of the Art Reactor Consequence Analyses (Soarca) Reports
| author name = Portzline S
| author affiliation = Three Mile Island Alert, Inc
| addressee name = Bladey C
| addressee affiliation = NRC/ADM/DAS/RDEB
| docket = 05000171, 05000277, 05000278
| license number = 
| contact person = 
| case reference number = 77FR5281 00018, NRC-2012-0022
| document type = General FR Notice Comment Letter type:NRC, Slides and Viewgraphs
| page count = 27
}}

=Text=
{{#Wiki_filter:Page 1 of 1 As of: February 29, 2012 Received: February 28, 2012 Status: PendingPost PUBLIC SUBMISSION                                           Tracking No. 80fc71 10 Comments Due: March 01, 2012 Submission Type: Web Docket: NRC-2012-0022 State-of-the-Art Reactor Consequence Analyses Reports Comment On: NRC-2012-0022-0005 State-of-the-Art Reactor Consequence Analyses Reports           '7/A            *27 Document: NRC-2012-0022-DRAFT-0021 Comment on FR Doc # 2012-02313 Submitter Information                                                U-1 Name: Scott Portzline                                                     /
Address:
3715 N 3rd Street Harrisburg, PA, 17110 C-,
Submitter's Representative: Scott D. Portzline Organization: Three Mile Island Alert General Comment See attached file(s)
Attachments TMIA soarca comment to NRC 2-28-12
                          /
7'- X/     )-;
https ://fdmserulemaking.net/fdms-web-agency/componentlcontentstreamer?obj ectld=09... 02/29/2012

February 28, 2012 Cindy Bladley Chief Rules, Announcements, Directives (RADB)
Office Administration Mail Stop:TWB-05-B01M U.S. NRC Washington D.C. 20555-0001 Via E-Mail: Carol.GaIlaghcrOcnrc.gov COMMENTS DOCKET ID NRC-2012-0022 STATE-OF-THE-ART-REACTOR CONSEQUENCE ANALSYES (SOARCA) REPORT DRAFT FOR COMMENT
: Cindy, I submit the attached presentation (in pdf format) on behalf of Three Mile Island Alert for consideration by the NRC. We believe that the NRC cannot adopt the SOARCA study and especially cannot continue to misrepresent its conclusions. The NRC has in the past retracted its acceptance of another risk assessment (WASH 1400) and should not deem SOARCA as credible. It appears that the NRC has accepted the study. It is very clear that the NRC is misrepresenting the conclusions to the public, as is the Nuclear Energy Institute.
Scott D. Portzline Three Mile Island Alert Security Consultant

NR' Puli Metn onte*OA     DrfARpr The Mil lsln Alr SeSiyCIS~tn

Summary
: 1. The conclusions as represented by the NRC Office of Public Relations are misleading.
: 2. The NRC has not clearly emphasized that SOARCA limited its simulations to a select group of scenarios.
: 3. SOARCA does not include many aspects of nuclear accidents Which would severely alter the outcomes and conclusions.

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Nuclear accidents pose little risK to neaitn, NRC says,,,.
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                       'The risk to public health from a severe nuclear power plantaccidenU jin the United States IsI"ery small" because reactor operators should have time to prevent core damage and reduce'the release o           .
I 59 Share radloactPve matenals, US. nuclear regulators said In a study on Wednesday:,

Misleadng
    &'SOARCA           1aalyzed the pttial          consequences of severe accidents at theSurry Power Station near Sr, SU     Va.andthe Peach,                         Atomic Power Station near'Delta, n e ,a Pa."        r .      :,     .....~     1.1.
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    .Should haveincluded'the phrase"a few select                     .
    &#xfd;severe accident scenarios"                                          ,     - F, 3, j
No attempts to correct the erroneous head ines as N"RC does for-articlecasting a-bad impression
               ', ,; .  . ., . ": , . "   , - .F              ..

Point 2 RE: Scenarios
   #10 What if all                                                 tOUCtO+P IFtOfir   o~stIrolt sequences that Nnvember 29. 2006 survive the screening            Do'omeot Control Dcah U.S. Nuclear Regutatrym, Commiosion Waah,.gton. DC 20555-000.
process are those               

==SUBJECT:==
Qu"etiot,- Doycloptd by the Industry Relative to NRC's "Stute oftho At Reactor Con-oquence Analysis' Proct that result in an intact         PROJECT NUMBER: 689 This letter tranomitso series of questions developed by industry r]tatico to NRCt
                                      -State of the Act fReactor Consequco A tycis project. These questions %c-tbe containment?                    addrtsced in a piiblic meeting to be hedued in the January 2007 time frame, Pleasu contact me t.yuu haw any questions regardiog this tratsroittal.
Siocreely, Nuclear Energy Institute letter to   Bilf Bradley Enclosure NRC on how SOARCA will handle       c:     Mr. RobortJ. Prato, NRC certain parameters - November 2006         Mr. Jiti T. Yoroktn. NRC Mr. Jason If. Scho.pro. NRC L

Real-World None of these real-World nuclear aCcide"nts", priortto its occurrence, would have been'predicted, or              *.
simulated by MELCOR.
Three Mile Island - Windscale - Chernobyl - Fukushima II

I*
Three Mile Island apparently is the poster child for MELCOR                                                         I J
                                ,     MELCOR 138.5 i'A Computer Code for Analyzing -
                                    - Severe Accidents InNuclear Powe~rPlanits 0'    ."andOther Facilities The MELCOR code Isdeveloped at Sandia National Laboratories -*
for the United States Nuclear Regulatory Commission MELCOR web page                   sC software PD_&#xfd;.cov*er

"Point 3 The people of TMI knowhthat...
Things don't'happen the way you'd think they would!!
e.g. -- A lone TMI licensee employee, acting on his own, deliberately caused one of the releases. No evacuation order or shelter in place order wa s made.
Confusion prolongs,- mitigation efforts, exacerbates radioa ctive, releases, delays communications, and fosters a reluctance to order an evacuation, ana Tor some citizens, it actuaily creates a reluctance to evacuate.-
* Confusion cannot be accurately modeled by a computer simulation because of its thousands:Of possibilities.- Intelligence,              I may be advanced, but confusion knows no bounds. (bounding is                       I a term used to limit a set of parameters) Operators exacerbated mitigation efforts and interfered with safety equipment at TMI.

Exampoles of unexpected events from TMlI, not accounted for in this study,''
Due to the. falsification of reactor leak rates, the reactor drain tank was already nearly full at the start of the event- early, transport of radioactivity.
Drain lines were already opened to the auxiliary bldg. - early transport of radioactivity.'
Evidence suggests a reactor coolant pump on loop A ran backwards for a time. - unexpected transport...
s team Generator A steam tubes destroyed as the result of the events rather than a triggering event. - alters sequence....
Coolant pump cavitation may contribute to "core hold-up','
causing the additional and prolonged generation of hydrogen and radioactive steam.. - explosive, and source term size
                                                                   + - .
Certain safety systems were disabledprior to the accidentt..
alters sequence of events and expectations

Unexpected Early Release The mitigated and unmitigated accident consequences of SOARCA hasn't account for the aforementioned conditions which could lead to an early release - earlier than SOARCA has indicated.
A small opening or pathway can result in a dangerous release.

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NRCG promised to correct mis-representations on a previous Reactor Safety Study 1/18/79 Accident Probabilities: The Commission accepts the Review Group Report's conclusion that absolute values of the risks presented by WASH-1400 should not be used uncritically either in the regulatory process or for public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate. In particular,  in light of the Review Group conclusions on accident probabilities, the Commission does not regard as reliable the Reactor Safety Study's numerical estimate of the overall risk     L Communication with the Congress and the Public: Commission correspondence and statements Involving WASH-1400 are being reviewed and corrective action as necessary will be taken.
                                                                       ~1

7-Point 6 NRC withdraws a Consequences Report',
Just two months*'prior to the TMI accident the NRC was forced to disavow its accreditation of another Reactor Safety Study` (probability risk analysis) knobwas theb",-
WASH 1400 a/k/a'the Rasmussen Report..
* "The Commission Withdraws any explicit or implicit' past endorsement of.the Executive Summary [of WASH 1400]"
January 18, 1979 NRC Po*icyvStatement The report had stated the probability of an accident was one *in a million per reactor per year. Then came TMI.

NRC withdrawal statement continued "The executive summary of the Reacor Safety Studyis a poor description of the contents of theitself report, toi should use in portrayed  as such, and  has  lent not be the discussion of reactor risks.
The executive. summary does not adequately indicate the full extent of the consequences of reactor accidents and does not sufficiently emphasize:the Vruncertainties.
involved in -the calculations of their probability., -       -
As a result, the reader may be left with a misplaced confidence in the validity of the risk estimates.,

NRC withdrawal statement continued "The press release at the time of publication said that the report is 'the culmination of the most comprehensive risk assessment of nuclear power plants made to date. The objectives of the study were to make a realistic assessment providing an objective and meaningful estimate of the present risks associated with the operation of present day light water reactors in the United States.' "

All~~<    wl isno This study would be analogous to a report on auto0crashes coming out of Detroit where scenarios can be written inwhich al.'safe ty systeims -- the brakes', the headlights, the electrical
 'Systems; the steering and even ,the air bags are rendered inoperabie,( ye' somehow the car ends up crashing into a mountain of pillows and no one s injured.
*The sponsor of such a study can claim that they created scenarios where extremely unlikely failures occur simultaneously, and even then, no one is harmed. That may sound impressive but its dompletely invalidfor real world events.

Point 7         No Timely Evacuations There has never been a timely evacuation or.
a timely evacuation order issued at any of the world's nuclear accidents.,
100% failure rate.
* The evacuation projections are purely               .
wishful thinking.
* Therefore: SOARCA is not based on reality.
Three Mile Island -Windscale - Chernobyl. Fukushima

END}}