ML11279A119
| ML11279A119 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/15/2011 |
| From: | Harris W - No Known Affiliation |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 76FR47612 00008 | |
| Download: ML11279A119 (6) | |
Text
I , ENVIRONMENTAL RISK MANAGEMENT AND MITIGATION ISSUES THAT ARE ESSENTIAL FOR NRC TO ANALYZE IN THE FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT FOR RELICENSING OF SEABROOK STATION NO. 1 Submitted by William R. Harris at a Public Hearing of the Nuclear Regulatory Commission September 15, 2011 Hampton, NH 03842 652~/~e9J
~Z-~ //DD Ti1 F]C-)1 C-)C/:).,t.L~5Y5"E 7_D)5 ::-/4. Z --/ -William R. Harris Summary of Severe Accident Mitigation Alternatives Requiring NRC Analysis within Final SEIS to NUREG-1437 Supplement 46 of Seabrook Station No. 1 Relicensing, September 15, 2011 2 ENVIRONMENTAL RISK MANAGEMENT AND MITIGATION ISSUES RISK MANAGEMENT/
ENVIRONMENTAL SIGNIFICANCE REFERENCE DOCUMENTS MITIGATION ISSUES 1. On-site backup power for Solar geomagnetic disturbances Thomas Popik, Foundation for spent fuel pool cooling in event constitute highest risk of Resilient Societies, NRC of LOOP during & after solar common mode failures:
Proposed Rulemaking March geomagnetic disturbances extended LOOP; on site 14, 2011, including electromagnetic pulse. transformer fire; dysfunction of backup diesel generators to William R. Harris Comments on Mitigation measures are highly electro- magnetic pulse (EMP). Proposed Rulemaking, July 20 cost-effective.
PRA Type III 2011.analysis indicates Benefit-to-Site specific risks to Seabrook cost ratio of about 110. Station No. 1 are 2 orders of magnitude greater than all NUREG-1437 Supplement 46, other SAMA risks analyzed in Seabrook Station Draft SEIS Draft SEIS. Long term LOOP probability 2011-2030:
17.4%Probab. Water boil off 8.7%Probab. Zirconium fire 4.3%.With 20 year license renewal, See Harris Comments on Popik Probability of zirconium fire(s) Proposed Rulemaking, July 20, at Seabrook Station No. 1 about 2011.1 in 12 (period 2011 -2050).East-West 345kV transmission lines + end of line at plant +ocean proximity
+ geology of New Hampshire result in above average EMP vulnerabilities requiring site specific 2. Retrofit for on-site backup Reduce dependence on outside Calvert Cliffs MD reactor is a AC power for Seabrook reactor power, especially during events prototype for generation of control & emergency functions triggering common mode station power onsite. Also during long term LOOP -failures, such as solar coronal review European nuclear power including options to retrofit mass ejections causing risks to plants designed to generate heat exchangers to convert the U.S. transmission grid and power from on-site thermal reactor-related thermal energy station power from onsite energy in event of loss of into backup AC power for backup sources. outside power (LOOP).station power.3. On-site backup diesel Reduce risks of zirconium fires if NRC Miller Task Force Report generator operability extension backup onsite generators fail July 11, 2011 from 7 days to longer and spent fuel pools are not (parametric) periods, continuously cooled Harris Comments of July 20, 2011.William R. Harris Summary of Severe Accident Mitigation Alternatives Requiring NRC Analysis within Final SEIS to NUREG-1437 Supplement 46 of Seabrook Station No. 1 Relicensing, September 15, 2011 I .., 0 .3 4. Reduce reactor trip and fire Reduce risks of fires dispersing Thomas Popik, Presentation to risk due to solar geomagnetic sulfur hexafluoride (SF6), 2300 North American Electric disturbance damage to times C02 impacts on global Reliability Corp. Atlanta, GA Generator Step Up transformer.
warming August 30-31, 2011.Reduction can be accomplished Credible Reports of with neutral current blocking Reduce risk of loss of onsite Geomagnetic Disturbance device, power Impacts 5. Installation of remote Allow remote command & NRC Miller Task Force Report of readout & SCADA system triage to restore backup power July 12, 2011.command capabilities, including in event of station blackout.
Harris Rulemaking Comments protection of satellite relays July 20, 2011 from system generated Marginal cost per nuclear power electromagnetic pulse during plant reduced if nationwide adverse solar weather access to EMP-protected Comsat and commo links 6. Extend coverage & duration Existing 22 regional sensor sites C-10 Foundation for C-10 Foundation regional (n (northeast Massachusetts only)= 22) radiation monitors & utilize back-up batteries with remote readouts by (a) adding short duration.
Extended-30 sites in Southeast New reporting capacity would enable Hampshire; and (b) extending better-staged evacuation of battery life for monitoring sites radiation hot spots, reduce loss to > 14 days. of life.7. Utilize U.S. Dept. of Transportation modeling systems to plan staged Avert evacuation congestion, contraflow evacuations with & e.g., region of Three Mile Island w/o upgrades to MA Route 110 (1979), when randomized 2 lane on-ramps & off-ramps at evacuation impaired evacuation 1-95 and 1-495, and other flow rates.evacuation route connectors.
- 8. Deploy "intelligent" remote Reduce energy consumption
& U.S. Department of SCADA controlled signal system's air pollution in day to day use; Transportation Emergency for unmanned evacuation signal protect emergency personnel Evacuation DOT websites.management for relevant traffic from radiation exposure in corridors, event of spent fuel zirconium fires'9. Shelter on-site AC Battery Reduce risks of loss of on-site Appendix F at page F-41 to Chargers & Diesel Generator to capability to cool spent fuel NUREG 1437 Supp. 46, July recharge on station batteries, pools. Avert zirconium fires. 2011.Variant of SAMA 157 See EMP Commission Report on Critical Infrastructure, April 2008, for vulnerabilities of*_battery chargers and switches.William R. Harris Summary of Severe Accident Mitigation Alternatives Requiring NRC Analysis within Final SEIS to NUREG-1437 Supplement 46 of Seabrook Station No. 1 Relicensing, September 15, 2011
/Probability of Zirconium Fire at Spent Fuel Pools Estimates Over Remaining Reactor Operation Probability of No Outside Assistance Probability of Spontaneous Zirconium Ignition 50%50%Within Area of Probable Power System Collapse yes yes yes yes yes no no no no no no yes yes yes yes yes yes yes no no no no no no no yes yes yes yes yes State Illinois Illinois Illinois Illinois Illinois Illinois Illinois Iowa Kansas Louisiana Louisiana Maryland Maryland Massachusetts Michigan Michigan Michigan Michigan Minnesota Minnesota Minnesota Mississippi Missouri Nebraska Nebraska New Hampshire New Jersey New Jersey New Jersey New Jersey Plant Clinton Dresden 2 Dresden 3 La Salle 1 La Salle 2 Quad Cities 1 Quad Cities 2 Duane Arnold Wolf Creek River Bend Waterford Calvert Cliffs 1 Calvert Cliffs 2 Pilgrim Cook 1 Cook 2 Enrico Fermi 2 Palisades Monticello Prairie Island 1 Prairie Island 2 Grand Gulf Callaway Cooper Fort Calhoun Seabrook Hope Creek Oyster Creek Salem 1 Salem 2 Years Remaining in Reactor Operation 15 18 20 11 12 21 21 3 34 14 13 23 25 1 23 26 14 20 19 2 3 13 13 3 22 19 15 18 5 9 Long-Term LOOP Probability 14.0%16.5%18.2%10.5%11.4%0.0%0.0%0.0%0.0%0.0%0.0%20.6%22.2%1.0%20.6%23.0%13.1%18.2%0.0%0.0%0.0%0.0%0.0%0.0%0.0%17.4%14.0%16.5%4.9%8.6%Probability of Water Boil-Off 7.0%8.3%9.1%5.2%5.7%0.0%0.0%0.0%0.0%0.0%0.0%10.3%11.1%0.5%10.3%11.5%6.6%9.1%0.0%0.0%0.0%0.0%0.0%0.0%0.0%8.7%7.0%8.3%2.5%4.3%Zirconium Fire Probability 3.5%4.1%4.6%2.6%2.8%0.0%0.0%0.0%0.0%0.0%0.0%5.2%5.6%0.3%5.2%5.7%3.3%4.6%0.0%0.0%0.0%0.0%0.0%0.0%0.0%4.3%3.5%4.1%1.2%2.2%
Probability of Zirconium Fire at Spent Fuel Pools Estimates Over Remaining Reactor Operation Probability of No Outside Assistance Probability of Spontaneous Zirconium Ignition 50%50%Within Area of Probable Power System Collapse yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes yes State New York New York New York New York New York New York North Carolina North Carolina North Carolina North Carolina North Carolina Ohio Ohio Pennsylvania Pennsylvania Pennsylvania Pennsylvania Pennsylvania Pennsylvania Pennsylvania Pennsylvania Pennsylvania South Carolina South Carolina South Carolina South Carolina South Carolina South Carolina South Carolina Plant FitzPatrick Ginna Indian Point 2 Indian Point 3 Nine Mile Point 1 Nine Mile Point 2 Brunswick 1 Brunswick 2 Harris McGuire 1 McGuire 2 Davis-Bessie Perry Beaver Valley 1 Beaver Valley 2 Limerick 1 Limerick 2 Peach Bottom 2 Peach Bottom 3 Susquehanna 1 Susquehanna 2 Three Mile Island Catawba 1 Catawba 2 Oconee 1 Oconee 2 Oconee 3 Robinson Summer Years Remaining in Reactor Operation 23 18 2 4 18 35 25 23 35 30 32 6 15 5 16 13 18 22 23 11 13 23 32 32 22 22 23 19 31 Long-Term LOOP Probability 20.6%16.5%2.0%3.9%16.5%29.7%22.2%20.6%29.7%26.0%27.5%5.9%14.0%4.9%14.9%12.2%16.5%19.8%20.6%10.5%12.2%20.6%27.5%27.5%19.8%19.8%20.6%17.4%26.8%Probability of Water Boil-Off 10.3%8.3%1.0%2.0%8.3%14.8%11.1%10.3%14.8%13.0%13.8%2.9%7.0%2.5%7.4%6.1%8.3%9.9%10.3%5.2%6.1%10.3%13.8%13.8%9.9%9.9%10.3%8.7%13.4%Zirconium Fire Probability 5.2%4.1%0.5%1.0%4.1%7.4%5.6%5.2%7.4%6.5%6.9%1.5%3.5%1.2%3.7%3.1%4.1%5.0%5.2%2.6%3.1%5.2%6.9%6.9%5.0%5.0%5.2%4.3%6.7%
3 Probability of Zirconium Fire at Spent Fuel Pools Estimates Over Remaining Reactor Operation Probability of No Outside Assistance 50%Probability of Spontaneous Zirconium Ignition 50%Within Area of Probable Years Power Remaining Long-Term Probability Zirconium Sysem in Reactor LOOP of Water Fire Collapse State Plant Operation Probability Boil-Off Probability yes Tennessee Sequoyah 1 9 8.6% 4.3% 2.2%yes Tennessee Sequoyah 2 10 9.6% 4.8% 2.4%yes Tennessee Watts Bar 24 21.4% 10.7% 5.4%no Texas Comanche Peak 1 19 0.0% 0.0% 0.0%no Texas Comanche Peak 2 22 0.0% 0.0% 0.0%no Texas South Texas 1 16 0.0% 0.0% 0.0%no Texas South Texas 2 17 0.0% 0.0% 0.0%yes Vermont Vermont Yankee 1 1.0% 0.5% 0.3%yes Virginia North Anna 1 27 23.8% 11.9% 5.9%yes Virginia North Anna 2 29 25.3% 12.6% 6.3%yes Virginia Surry 1 21 19.0% 9.5% 4.8%yes Virginia Surry 2 22 19.8% 9.9% 5.0%yes Washington Columbia 12 11.4% 5.7% 2.8%yes Wisconsin Kewaunee 2 2.0% 1.0% 0.5%yes Wisconsin Point Beach 1 19 17.4% 8.7% 4.3%yes Wisconsin Point Beach 2 22 19.8% 9.9% 5.0%