ML051120239

Comment (3) of Mary Lampert, Deborah Katz, Rochelle Becker, Brendan Hoffman, David Agnew, Jed Thorp and Jim Warren on Federal Register Notice Dated 02/28/2005 Re Station Blackout Risk Evaluation for Nuclear Power Plants (Draft), January 200

ML051120239
Person / Time
Site:	Davis Besse, Pilgrim, Vogtle
Issue date:	04/15/2005
From:	Agnew D, Becker R, Hoffman B, Katz D, Lampert M, Thorp J, Warren J Alliance for Nuclear Responsibility, Cape Cod Downwinders, Citizens Awareness Network, Clean Water Action, Massachusetts, North Carolina Waste Awareness & Reduction Network (NC WARN), Pilgrim Watch, Public Citizen
To:	Lesar M NRC/ADM/DAS/RDB
References
70FR9682 00003
Download: ML051120239 (5)

Text

U PL 6zDre Wp_ ql.51/65 Michael Lesar, Chief Rules and Directives Branch Division of Administrative Services Office of Administration United States Nuclear Regulatory Commission Washington, DC 20555-0001 70 Fa- 9 C Submitted Via Email NRCREP© nrc.gov April 15, 2005 RE: COMMENTS ON FEDERAL REGISTER NOTICE DATED FEBRUARY 28, 2005 (VOLUME 70, NUMBER 38) PAGE 9682 "Station Blackout Risk Evaluation for Nuclear Power Plants (Draft)", January 2005 Overview - why a final evaluation is important Station Black-out Nuclear Reactors need electricity to operate - without a supply their safety.A;.; ^

systems would be disabled. They do not generate their own electricity. Like;.:.  ; : :

all of us, they depend on the grid - offsite power. If offsite power fails, they: .;  ;-

depend on back up generators (EDGs). If the EDGs fail, the chance of an , -;

accident approaches certainty. m Consequence - -- .i Depending on circumstances, the station blackout reactor accident can be particularly dangerous to public health and safety - with a core melt and/or spent fuel pool fire large amounts of radioactivity will be dispersed far and wide within a few hours

1. Draft Study - Scope - inadequate Executive Summary, page 9, states that, "Risk (from station blackout) was evaluated for internal events during critical operation; risk from shutdown operation and external events was not discussed."

A. Omission: External Events neither studied, nor defined:

On August 14, 2003 there was a serious transmission grid blackout that affected 9 U.S. nuclear reactors and states. As a result of that blackout (external event), NRC initiated a program to examine loss-of-offsite-power events and station blackout. This study, we are told in the Executive Summary, page 9, is part of that initiative. However, external events such as deregulation of the electric market and its effects on grid reliability, terrorism, global warming, and consequent increased frequency and severity Else Xw t,) 5X r 1 EPoLnS ADS -63 Teof = ADo -6 13 lj D. AD & ( P )

of storms are not discussed or studied. External events are half the equation and exceedingly important.

B. Omission: Internal Events Studied Only During Critical Operation:

Problems can occur, and be more severe, when the reactor is shut down.

Therefore this should have been analyzed.

Examples: Davis-Besse NPS was shut down during the August 14, 2003 black-out. It experienced more complications than most reactors operating at the time - see analysis by the Union of Concerned Scientists comments. The worst black-out event in the United States occurred at Vogtle NPS when the reactor was shut down.

C. Omission: Spent Fuel Pools not studied It is a serious omission not to analyze station blackout risk to spent fuel during refueling. Station black out can contribute to the loss-of-pool coolant event and/or prevent proper mitigation of the event. During refueling, there are fewer barriers and backup systems than when the reactor is operating.

Thus, both the chances of a station blackout and the consequences from a station blackout are increased. . .. ., , I.

. . . 1- .

The National 'Academy of Science, Safety and Security' of Commercial Spent . . f .. : -;-.-

Fuel Storage Public Report (April2005;-p.57) stated that the offloading of  ! . :I:. - ."

the reactor core into the spent fuel pool during reactor outages substantially raises the decay-heat load of the pool and increases the risk of a zirconium cladding fire in a loss-of-pool coolant event.

Analyzing risk to spent fuel storage pools is especially important now because pools are densely packed; accident or sabotage can cause loss-of-coolant; followed by a zirconium fire and radioactive release capable of contaminating hundreds of miles downwind.

Omission: Internal Events Studied Generically Spar models do not use site specific values; spar models simply used industry average values for component unreliability. This does not account for the fact that reactors are not stamped out by "cookie cutters." Plant data may well be outside norm and such deviation must be accounted for. This is especially important now because, for example: The decrease in NRC oversight; industry use of substandard and counterfeit parts; current and varied age of reactors, and components in those reactors, and their expected degradation along what is referred to as the "bathtub curve." At the end of the life-cycle of mechanical components, they will start to wear out and mechanical and safety problems dramatically increase --- whether they are in a toaster or in a nuclear reactor. This is not accounted for or analyzed - to properly do so would require site- specific analysis.

2

2. Problem: Core Damage Frequency report figures differ considerably from figures in NUREG-1776, issued August 2003.

There is no explanation for the wide disparity in the numbers --- numbers in the Draft are far lower.

3. Problem: INPO used as Source Data for SPAR Models NRC's SPAR models were updated using data from INPO's Equipment Performance and Information Exchange database, Section 2.1, page 3.

INPO is not a NRC licensee. Therefore they are not under NRC requirements for accuracy and are not audited by NRC. Therefore NRC is improperly relying on unverified, secret data to base regulatory analysis.

Respectfully submitted by, Mary Lampert, Pilgrim Watch 148 Washington Street, Duxbury MA 02332

-Deborah Katz Citizens Awareness Network Box 83 Shelburne Falls, MA 01379 Rochelle Becker '

Alliance for Nuclear Responsibility-San Luis-Obispo CA 93406-1328 .: ..

Brendan Hoffman Public Citizen Washington, D.C.

David Agnew Cape Downwinders 173 Morton Rd.,

S. Chatham, MA 02659-1334 Jed Thorp Clean Water Action 262 Washington St., Suite 301 Boston, MA 02108 Jim Warren NC WARN - North Carolina Waste Awareness & Reduction Network PO Box 61051, Durham, NC 27715-1051 3

ic:\temp)\GW100001 .TMP Paged1 c:\temrAGWlOOOOl .TMP Paae 1 U Mail Envelope Properties (425FF5B7.050: 6: 24656)

Subject:

COMMENTS ON FEDERAL REGISTER NOTICE DATED FEBRUARY 28, 2005 (VOLUME 70, NUMBER 38) PAGE 9682 Creation Date: Fri, Apr 15, 2005 1:10 PM From: "lampert" <lampert@adelphia.net>

Created By: lampert@adelphia.net Recipients nrc.gov twf2-po.TWFNDO NRCREP comcast.net d-agnew CC (David Agnew) ncwarn.org jim CC (Jim Warren(ncwam))

nukebusters.org can CC (can) citizen.org bhoffman CC (Brendan Hoffman) thegrid.net beckers CC cleanwater.org jthorp CC (Jed Thorp(CWA))

Post Office Route twf2_po.TWFN_DO nrc.gov comcast.net ncwam.org nukebusters.org citizen.org thegrid.net cleanwater.org Files Size Date & ITime MESSAGE 5858 Friday, April 15, 2005 1:10 PM TEXT.htm 26334 station blackout comment by alril 15th federal register .05.doc 40960

,c:\ternp\GW)OOOO1 .TMP _Page 24 Mime.822 93092 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

Subject:

No Security: Standard