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| | number = ML18016A830 | | | number = ML18016A830 |
| | issue date = 01/22/1999 | | | issue date = 01/22/1999 |
| | title = Comment Opposing License Amend Application Dtd 981223 Submitted by Cp&L Involving Spent Storage at Harris NPP & Subsequent Proposed No Significant Hazards Consideration Determination | | | title = Comment Opposing License Amend Application Dtd 981223 Submitted by CP&L Involving Spent Storage at Harris NPP & Subsequent Proposed No Significant Hazards Consideration Determination |
| | author name = LOCHBAUM D A | | | author name = Lochbaum D |
| | author affiliation = UNION OF CONCERNED SCIENTISTS | | | author affiliation = UNION OF CONCERNED SCIENTISTS |
| | addressee name = DIAZ N J, DICUS G J, JACKSON S A, MCGAFFIGAN E, MERRIFIELD J S, THE CHAIRMAN | | | addressee name = Diaz N, Dicus G, Jackson S, Mcgaffigan E, Merrifield J, The Chairman |
| | addressee affiliation = NRC COMMISSION (OCM) | | | addressee affiliation = NRC COMMISSION (OCM) |
| | docket = 05000400 | | | docket = 05000400 |
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| {{#Wiki_filter:r I j 4~I UNION OF CONCERNEO SCIENTISTS January 22, 1999 Chairman Shirley A.Jackson Commissioner Nils J.Diaz Commissioner Greta J.Dicus Commissioner Edward McGafftgan, Jr.Commissioner Jeffrey S.Memfield United States Nuclear Regulatory Commission Washington, DC 20555-0001 SUMECT: CURRENT EXAMPLE OF RISK-DEFORMED REGULATION Dear'Chairman and Commissioners: | | {{#Wiki_filter:I j r ~I 4 |
| During the January 11 Commission briefing on risk-informed regulation and during the January 20 briefing on the proposed reactor oversight process, I'expressed our concern that the NRC and the nuclear industry are making risk decisions using incomplete and inaccurate data.As a current example, I call your attention to the license amendment application dated December 23, 1998, by the Carolina Power&Light Company involving spent fuel storage at the Harris Nuclear Power Plant and the subsequent proposed no significant hazards consideration determination (Federal Register: January 13, 1999, Vol.64, No.8)prepared by the NRC staff.The licensee and the NRC staffkave improperly downplayed the risk associated with the proposed activity.Their risk characterization is wrong.The licensee should be required to resubmit a corrected application and another Federal Register notice issued with a corrected proposed no significant hazards consideration determination. | | UNION OF CONCERNEO SCIENTISTS January 22, 1999 Chairman Shirley A. Jackson Commissioner Nils J. Diaz Commissioner Greta J. Dicus Commissioner Edward McGafftgan, Jr. |
| The error involves the determination made by the licensee and endorsed by the staff regarding the affect of the proposed activity, namely placing storage racks in Spent Fuel Pools'C'nd'D't the Hanis plant, on the probability of a fuel handling accident.From the Federal Register notice: REC'D BY SEC'P., 2t'AM%>>: OS"The probability that any of the accidents in the above list[a spent fuel assembly drop in a spent fuel pool/loss of spent fuel pool cooling low/a seismic event/misloaded fuel assembly]can occur is not significantly affected by the activity itself.... | | Commissioner Jeffrey S. Memfield United States Nuclear Regulatory Commission Washington, DC 20555-0001 SUMECT: CURRENT EXAMPLE OF RISK-DEFORMED REGULATION |
| The probabilities of accidental fuel assembly drops or misloadings are primarily influenced by the methods used to lift and move these loads.The method of handling loads during normal plant operations is not signficantly changed, since the same equipment (i.e., Spent Fuel Handling Machine and tools)and procedures as those in current use in pools'A'nd'B'ill be used in pools'C'nd'D.'ince the methods used to move loads during normal operations remain nearly the same as those used previously, there is no significant increase in the probability of an accident." Washington ONce: 1616 P Street NW Suite 310 e Washington DC 20036-1495 | | |
| ~202.3324900 | | ==Dear'Chairman and Commissioners:== |
| ~FAX: 2024324905 Cambridge Headquarters: | | |
| Two Brattle Square.~Cambridge MA 02238-9105 | | During the January 11 Commission briefing on risk-informed regulation and during the January 20 briefing on the proposed reactor oversight process, I'expressed our concern that the NRC and the nuclear industry are making risk decisions using incomplete and inaccurate data. As a current example, I call your attention to the license amendment application dated December 23, 1998, by the Carolina Power & |
| ~617-547-5552 | | Light Company involving spent fuel storage at the Harris Nuclear Power Plant and the subsequent proposed no significant hazards consideration determination (Federal Register: January 13, 1999, Vol. |
| ~FAX: 617464-9405 | | 64, No. 8) prepared by the NRC staff. |
| ~'.,";-,,'7')ftice: 2397 Shattuck Avenue Suite 203~Berkeley CA 94704-1567 | | The licensee and the NRC staffkave improperly downplayed the risk associated with the proposed activity. Their risk characterization is wrong. The licensee should be required to resubmit a corrected application and another Federal Register notice issued with a corrected proposed no significant hazards consideration determination. |
| ~510.843-1872 | | The error involves the determination made by the licensee and endorsed by the staff regarding the affect of the proposed activity, namely placing storage racks in Spent Fuel Pools 'C'nd 'D't the Hanis plant, on the probability of a fuel handling accident. From the Federal Register notice: |
| ~FAX: 5104434785 | | "The probability that any of the accidents in the above list [a spent fuel assembly drop in a spent REC'D BY SEC'P., fuel pool / loss of spent fuel pool cooling low / a seismic event /misloaded fuel assembly] can occur is not significantly affected by the activity itself.... The probabilities of accidental fuel assembly drops or misloadings are primarily influenced by the methods used to liftand move 2t'AM% >>: OS these loads. The method of handling loads during normal plant operations is not signficantly changed, since the same equipment (i.e., Spent Fuel Handling Machine and tools) and procedures as those in current use in pools 'A'nd 'B'ill be used in pools 'C'nd 'D.'ince the methods used to move loads during normal operations remain nearly the same as those used previously, there is no significant increase in the probability of an accident." |
| ) | | Washington ONce: 1616 P Street NW Suite 310 e Washington DC 20036-1495 ~ 202.3324900 ~ FAX: 2024324905 Cambridge Headquarters: Two Brattle Square. ~ Cambridge MA 02238-9105 ~ 617-547-5552 ~ FAX: 617464-9405 |
| ,rp*>y k A)~~ | | ~'.,"; ,,'7')ftice: 2397 Shattuck Avenue Suite 203 ~ Berkeley CA 94704-1567 ~ 510.843-1872 ~ FAX: 5104434785 |
| January 22, 1999 Page2of2 It is precisely this type of"smoke and mirrors" shenanigans that we decried during the briefings. | | ) |
| The logic seems proper at face value, but it does not take much effort to show that it is wrong.In Enclosure 1 to the license amendment submittal, the licensee reported that the total storage capacity of pools'A'nd'B's 3,669 assemblies and that the proposed activity will add 4,715 storage locations in pools'C'nd'D.'hus, if the amendment is granted, Cp&L will handle-p~ick u and~cue-about twice as many irradiated fuel assemblies as they'1Lif'the amendment is not granted.Consider for a moment the old game of Russian roulette using a six-chamber revolver loaded with a single bullet.CP&L and the NRC staff would apparently conclude that the probability of losing the game are not increased whether one or two turns are taken because, after all, the same method and the same equipment are used each turn.Their logic is simply wrong, The probability of a fuel handling accident at Hams will nearly double if the license amendment request is granted.This material fact contradicts, the conclusion of the licensee and the staff that there will be"no significant increase in the probability." unless doubling the risk is not significant. | | |
| Luckily, there's an opportunity to fix the mistake this time.Unfortunately, it's not the first, and probably won't be the last, time this mistake is made.The NRC staff made this same mistake in April 1998 when it allowed the Paducah facility to continue operating with its risk doubled.We have no intention at this time of formally intervening in this Harris licensing action.We trust that the NRC staff will take the necessary steps to have the licensee fix the fundamental fiaw in the licensing amendment request before granting it.Sincerely, David A.Loch aum Nuclear Safety Engineer 0 4 l~c i~}} | | ,rp |
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| | |
| | January 22, 1999 Page2of2 It is precisely this type of "smoke and mirrors" shenanigans that we decried during the briefings. The logic seems proper at face value, but it does not take much effort to show that it is wrong. In Enclosure 1 to the license amendment submittal, the licensee reported that the total storage capacity of pools 'A'nd |
| | 'B's 3,669 assemblies and that the proposed activity will add 4,715 storage locations in pools 'C'nd if |
| | 'D.'hus, the amendment is granted, Cp&L willhandle -p~ick u and~cue about twice as many irradiated fuel assemblies as they '1Lif'the amendment is not granted. |
| | Consider for a moment the old game of Russian roulette using a six-chamber revolver loaded with a single bullet. CP&L and the NRC staff would apparently conclude that the probability of losing the game are not increased whether one or two turns are taken because, after all, the same method and the same equipment are used each turn. Their logic is simply wrong, The probability of a fuel handling accident at Hams willnearly double ifthe license amendment request is granted. This material fact contradicts, the conclusion of the licensee and the staff that there willbe "no significant increase in the probability." |
| | unless doubling the risk is not significant. |
| | Luckily, there's an opportunity to fix the mistake this time. Unfortunately, it's not the first, and probably won't be the last, time this mistake is made. The NRC staff made this same mistake in April 1998 when it allowed the Paducah facility to continue operating with its risk doubled. |
| | We have no intention at this time of formally intervening in this Harris licensing action. We trust that the NRC staff will take the necessary steps to have the licensee fix the fundamental fiaw in the licensing amendment request before granting it. |
| | Sincerely, David A. Loch aum Nuclear Safety Engineer |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20204F4511999-03-22022 March 1999 Comment Supporting Petition for Rulemaking PRM-50-64 Filed by Atlantic City Electric Co,Austin Energy,Central Maine Power Co,Delmarva Power & Light Co,South Mississippi Electric Power Assoc & Washington Electric Cooperative,Inc ML18016A8071999-02-12012 February 1999 Comment Opposing Significant Hazards Determination & Conditional Request for Stay of Effectiveness Re Proposed License Amend to Permit Expansion of Sf Storage Capacity at Plant NPP ML18016A8031999-02-12012 February 1999 Comment on CP&L Application Dtd 981223.Proposed Finding of No Significant Hazard Wrong & Must Be Rejected for Stated Reasons ML18016A8291999-02-11011 February 1999 Comment Re Proposed Expansion of high-level Radwaste Storage Capacity at CP&L Shearon Harris Npp.Advises NRC to Consider Request from Durham County Board of Commissioners for 30-day Extension of Comment Period ML18016A8151999-02-11011 February 1999 Comment Opposing Expansion of Shearon Harris Facility Re Storage of Spent Nuclear Fuel Rods or Acceptance of Addl Nuclear Waste ML18016A8081999-02-11011 February 1999 Comment on Licensee 981223 Application & NRC 990113 Fr Re NRC Proposed Finding of NSHC ML18016A8161999-02-10010 February 1999 Comment Opposing CP&L Request to Store Spent Fuel Rods from All Three NPPs at Two New Waste Pools at Shearn Harris NPP (Bringing Total Number of Pools to Four) ML18016A8131999-02-10010 February 1999 Comment on Encl Resolution Re Proposed Expansion of high-level Radwaste Storage Facilities at Cp&L,Shearon Harris NPP in Wake County,Nc.Requests 30 Days Extension for Public Comment Period ML18016A8061999-02-10010 February 1999 Comment Regarding Proposed Amend by Util to Increase Sf Storage Capacity at Plant.Believes That Meeting to Help Alleviate Concerns Regarding Protection of Personnel Health & Safety Should Be Scheduled ML18016A8271999-02-0808 February 1999 Comment Opposing Petition from Carolina Power & Light Co to Allow Transport,For Long Term Storage,Spent Fuel Elements Licensee Other Plants to Harris Plant ML18016A8221999-02-0606 February 1999 Comment Opposing Proposal by Shearon Harris to Increase Capacity of High Level Nuclear Waste Storage Pools ML18016A8281999-02-0505 February 1999 Comment Opposing Shearon Harris Nuclear Plant Be Used for Addl Storage of Nuclear Waste ML18016A8311999-02-0505 February 1999 Comment Opposing Shearon Harris NPP Being Used for Addl Storage of Nuclear Waste ML18016A8141999-02-0404 February 1999 Comment Opposing Proposal by Shearon Harris to Increase Capacity of High Level Nuclear Wastes,Publication,Dtd 990113 ML18016A8301999-01-22022 January 1999 Comment Opposing License Amend Application Dtd 981223 Submitted by CP&L Involving Spent Storage at Harris NPP & Subsequent Proposed No Significant Hazards Consideration Determination ML18011A6261994-10-31031 October 1994 Comment Opposing Proposed Amend to Plant Re Relaxation of Requirements to Annual Monitoring ML20150F7561987-02-27027 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning 1999-03-22
[Table view] |
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UNION OF CONCERNEO SCIENTISTS January 22, 1999 Chairman Shirley A. Jackson Commissioner Nils J. Diaz Commissioner Greta J. Dicus Commissioner Edward McGafftgan, Jr.
Commissioner Jeffrey S. Memfield United States Nuclear Regulatory Commission Washington, DC 20555-0001 SUMECT: CURRENT EXAMPLE OF RISK-DEFORMED REGULATION
Dear'Chairman and Commissioners:
During the January 11 Commission briefing on risk-informed regulation and during the January 20 briefing on the proposed reactor oversight process, I'expressed our concern that the NRC and the nuclear industry are making risk decisions using incomplete and inaccurate data. As a current example, I call your attention to the license amendment application dated December 23, 1998, by the Carolina Power &
Light Company involving spent fuel storage at the Harris Nuclear Power Plant and the subsequent proposed no significant hazards consideration determination (Federal Register: January 13, 1999, Vol.
64, No. 8) prepared by the NRC staff.
The licensee and the NRC staffkave improperly downplayed the risk associated with the proposed activity. Their risk characterization is wrong. The licensee should be required to resubmit a corrected application and another Federal Register notice issued with a corrected proposed no significant hazards consideration determination.
The error involves the determination made by the licensee and endorsed by the staff regarding the affect of the proposed activity, namely placing storage racks in Spent Fuel Pools 'C'nd 'D't the Hanis plant, on the probability of a fuel handling accident. From the Federal Register notice:
"The probability that any of the accidents in the above list [a spent fuel assembly drop in a spent REC'D BY SEC'P., fuel pool / loss of spent fuel pool cooling low / a seismic event /misloaded fuel assembly] can occur is not significantly affected by the activity itself.... The probabilities of accidental fuel assembly drops or misloadings are primarily influenced by the methods used to liftand move 2t'AM% >>: OS these loads. The method of handling loads during normal plant operations is not signficantly changed, since the same equipment (i.e., Spent Fuel Handling Machine and tools) and procedures as those in current use in pools 'A'nd 'B'ill be used in pools 'C'nd 'D.'ince the methods used to move loads during normal operations remain nearly the same as those used previously, there is no significant increase in the probability of an accident."
Washington ONce: 1616 P Street NW Suite 310 e Washington DC 20036-1495 ~ 202.3324900 ~ FAX: 2024324905 Cambridge Headquarters: Two Brattle Square. ~ Cambridge MA 02238-9105 ~ 617-547-5552 ~ FAX: 617464-9405
~'.,"; ,,'7')ftice: 2397 Shattuck Avenue Suite 203 ~ Berkeley CA 94704-1567 ~ 510.843-1872 ~ FAX: 5104434785
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January 22, 1999 Page2of2 It is precisely this type of "smoke and mirrors" shenanigans that we decried during the briefings. The logic seems proper at face value, but it does not take much effort to show that it is wrong. In Enclosure 1 to the license amendment submittal, the licensee reported that the total storage capacity of pools 'A'nd
'B's 3,669 assemblies and that the proposed activity will add 4,715 storage locations in pools 'C'nd if
'D.'hus, the amendment is granted, Cp&L willhandle -p~ick u and~cue about twice as many irradiated fuel assemblies as they '1Lif'the amendment is not granted.
Consider for a moment the old game of Russian roulette using a six-chamber revolver loaded with a single bullet. CP&L and the NRC staff would apparently conclude that the probability of losing the game are not increased whether one or two turns are taken because, after all, the same method and the same equipment are used each turn. Their logic is simply wrong, The probability of a fuel handling accident at Hams willnearly double ifthe license amendment request is granted. This material fact contradicts, the conclusion of the licensee and the staff that there willbe "no significant increase in the probability."
unless doubling the risk is not significant.
Luckily, there's an opportunity to fix the mistake this time. Unfortunately, it's not the first, and probably won't be the last, time this mistake is made. The NRC staff made this same mistake in April 1998 when it allowed the Paducah facility to continue operating with its risk doubled.
We have no intention at this time of formally intervening in this Harris licensing action. We trust that the NRC staff will take the necessary steps to have the licensee fix the fundamental fiaw in the licensing amendment request before granting it.
Sincerely, David A. Loch aum Nuclear Safety Engineer
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