ML20154M431
| ML20154M431 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Three Mile Island  |
| Issue date: | 02/27/1986 |
| From: | Palladino N NRC COMMISSION (OCM) |
| To: | Ebersole J AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20154M401 | List: |
| References | |
| NUDOCS 8603140265 | |
| Download: ML20154M431 (10) | |
Text
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,' UNITED STATES
! o NUCLEAR REGULATORY COMMISSION g .t WASHINGTON, D. C. 20555 d
February 27, 1986 CHAIRMAN Mr. Jesse C. Ebersole P. O. Box 1280 Oak Ridge, Tennessee 37831-1280
Dear Mr. Ebersole:
The Commission has reviewed your letter of October 12, 1985, which raises issues and recommendations related to the Indian Point Special Proceeding. Your specific concerns appear to center on three issues: the dense population in the proximity of Indian Point, core melt frequency and containment effectiveness, which we address in the enclosure.
With regard to the broader issue raised by your letter, the general safety of Indian Point, reasonable individuals can have diverse views on technically complicated issues, particularly on those considered in a proceeding that took almost five years to complete and involved highly judgmental factors. Nevertheless, we believe that the Indian Point decision was, in total, consistent with the Severe Accident Policy Statement subsequently approved by the Commission and was consistent with ACRS comments on that policy proposal. As stated in the Commission's conclusion on Question 5 of the Special Proceeding (21 NRC at 1075) we do not consider Indian Point to be a risk outlier, i.e., in a lii gli-r i s k cl a s s oil IL3 uwn. iiowever, we do '
recognize that the plant is in an area of relatively high population density and, as a consequence, warrants continuing effort to assure its safe operation.
The specific technical concerns raised in your letter appear to be consistent with ACRS views expressed on Safety Goals and we will consider them further in that context in the longer term.
Commissioner Asselstine has the following comment:
I believe this response inadequately addresses the matters raised in your and your colleagues letter of October 12, 1985. As indicated in my attached separate views on the Indian Point Special Proceeding, I believe the Commission was wrong in adopting the bottom-line results of probabilistic risk assessments, the Commission was wrong in ignoring the uncertainties in the risks associated with the operation of the Indian Point reactors, the Commission was wrong in rejecting the relatively straightforward safety improvements urged by the staff and the Board, and the Commission was wrong in accepting the risk posed by the Indian Point plants for the long-term. Other countries are 8603140265 227 PDR C CC CORRESP E PDR
l already backfitting additional safety' features at their plants which appear to provide substantial improvements in safety at reasonable costs. It is unfortunate that U.S.
citizens are not afforded similar. protection. I commend
.you and your colleagues for attempting to bring about safety improvements at the Indian Point reactors for the long-term..
Sincerely,
. s t irb skf , f( [ c3 /
Nunzio J. alladino
Enclosures:
As Stated u
i
'O RESPONSE TO SPECIFIC ISSUES RAISED IN OCTOBER 12, 1985 LETTER Issue (1):
Your letter stresses the fact that Indian Point is one of the most highly populated sites in the U.S. and that the NRC should continue to strive for substantial reduction in risks resulting from plant operation. ,
Response
The Commission recognized in its decision that the Indian Point site is unlike most nuclear power plant sites in its proximity to densely populated areas. The Commission also noted that the number of persons and their distribution around the plant are such that the Board in this special proceeding concluded that a severe release of radioactive materials at Indian Point could have more serious consequences than that same release at other NRC-licensed sites. However, the Commission concluded that the record showed that neither the shutdown of Indian Point Units 2
& 3, nor the imposition of additional remedial actions beyond those implemented voluntarily by the licensees, is warranted.
In coming to this conclusion, the Commission agreed with the Board's conclusion that the quantitative estimates of risk to the public resulting from serious accidents at Units 2 and 3 are a small fraction of the competing non-nuclear background risks to which the population around Indian Point is exposed.
Issue (21:
-4 The mean-core-melt frequency should not be larger than 10 per reactor year for all but a few, small, existing nuclear plants and keeping in mind the considerable uncertainties, prudence and judgment will take priority over benefit-cost analysis. For Indian Point, Units 2 and 3, the Commission should require that both the licensee and NRC staff develop a plan to reduce both the estimated core melt frequency and the uncertainty therein.
Also, for sites like Indian Point the NRC should continue to strive for a substantial reduction in both the predicted core melt frequency and the uncertainty therein.
Response
In its Indian Point decision the Commission accepted the Board's recommended quantitative risk estimates, including the estimate of core melt frequency. However, the Commission noted that the specific values were based upon application of the then-existing (circa 1981) state-of-the-art risk assessment techniques.
Therefore, the Commission did not consider the quantitative risk estimates to be a proof that the risk to the public from the operation of Indian FoTnt Units 2 & 3 is acceptably low.
Rather, the Commission believed the estimates showed Indian
l Point risk not to be itnacceptably high. In reaching this judgment the Commission did not place undue emphasis on the quantitative core melt or other risk estimates. The Commission believes that it is not in itself sufficient for probabilistic risk assessments to yield acceptably low estimates. Rather, the Commission believes that a sufficient showing of acceptably low risk must be based as well on engineering judgments of plant safety. For Indian Point, these engineering judgments involved a thorough probing of the units and careful evaluation of the risk-reduction effectiveness of plant safety systems. The Commission believes that in this case there has been such probing and evaluation and, as discussed in other parts of its decision, the safety improvements which were voluntarily implemented by the licensees further assure that the continued operation of the units does not impose an undue risk to public health and safety.
The views expressed in your letter are similar in some respects to ACRS views expressed on safety goals issues and, in the longer term, will be addressed in that context. The Commission is currently considering next steps for safety goals based upon a recent briefing by senior NRC staff.
In addition, the Commission believes that its decision is consistent with the Severe Accident Policy Statement recently approved by the Commission. This statement indicates that the present risk from severe accidents at operating facilities is acceptable. The Commission notes that this position appears to be consistent with pertinent ACRS comments on the Severe Accident Policy. 1/
Issue (3):
Indian Point, Units 2 and 3, were evaluated as having a relatively effective containment in the presence of many, if not T7 In a J Ty 18, 1984 letter the ACRS notes that, "taking into account the results of programs now in progress, and assuming a systematic examination of each plant, the proposed policy provides an acceptable basis for dealing with the severe accident issue for plants now in operation or under construction." Also, there is no current information that Indian Point should be considered a risk outlier in the context of the Commission's Severe Accident Policy Statement. As Mr. Rowsome pointed out in an October 1984 presentation to the Commission on the risk at Indian Point, "the risk to individuals are well within the range of risks posed by other plants" and collective insights suggest that "the societal risk from Indian Point is not outside the spectrum for other plants." Summary of Staff Testimony on the Risk at the Indian Point Special Proceeding, pp. 12.7 and 12.9 attached to the Transcript of the October 2, 1984 NRC Commission meeting, " Continuation of 9/5 Discussion of Indian Point Probabilistic Assessment."
most, severe core accidents. However, the analyses rest on incompletely understood phenomena, on generic rather than detailed examinations of containment behavior, and on an incomplete set of accident scenarios. A detailed containment performance evaluation should be given particular emphasis at sites like Indian Point.
Response
Your letter erroneously indicates that the majority of the ASLB recommended in 'f avor of a filtered venting concept in light of the large uncertainties in the risk assessment. The Board heard testimony on this issue from licensees, the NRC staff, and intervenors. Rather than recommending implementation of this concept at this time, the Board urged reexamination of its recommendation against filtered vented containment in li'ght'of future developments.
The Commission agreed with the Board that the record did not demonstrate that modifications such as filtered vented containment would provide substantial additional r,j s k re d u c ti o n which is required to protect the public health and safety. Both the Board and the NRC Staff found filtered vent containment systems in particular to be a cost-ineffective method of reducing risk. In its decision, the Commission anticipated that NRC's severe accident research program, particularly those elements pertaining to containment aralysis and failure modes, will yield the basic data reouired for further design studies and a realistic evaluation of the risk reduction pctential of both concepts. In addition, the Commission expects the NRC staff to keep abreast of relevant research and engineering experience in other countries and to inform the Commission of significant new developments in containment overpressurization prevention and mitigation.
Finally, in contrast to your suggestion that the containment analyses rested solely on generic examinations, it should be noted that the Staff, in its overall assessment of containment performance, did consider key characteristics and capabilities (e.g. containment structural failure, leakage and coolability) unique to the Indian Point containments and related systems.
Point and on whether the deficiencies identified by the lloard and by the chosen to defer action to address the continuing significant deficiencies ission in this proceeding have been corrected. This Staff report, in emergency preparedness at the Indian Point site.
f Although I would not order the immediate shutdown of the Indian
, outside the context of this special proceeding, as with !
he proceeding. Point plants, I do not believe that the level of protection against serious Com ioner sse s " l accidents now afforded by the plants has been demonst:ated to be ade-this Decision. Ilis dissenting opinion and the addit I f Chairman Palladino and Commis- quate for the remaining operating lives ofIndian Point Units 2 and 3.1 sioners Roberts, Bernt al, an h ua hed. would therefore continue in elTect all of the interim safety improvements It is so ORDERED' ; required by the NRC Staff at the outset of this proceeding. I would re-I quire the additional safety initiatives recommended by the NRC Staff For the Commission i and the Indian Point Board, including: (1) measures to reduce the vul-
! nerability of the plants to steam generator tube rupture accidents and to damage from tornado risk; and (2) the Safety Assurance program. I would also require continued efforts to explore in greater detail further John C. Iloyle alternatives for safety improvements in the plants, including the possible Assistant Secretary of the installation of an additional decay heat removal system, a filtered vented Commission containment or a separate containment system, all of which have the potential to improve either the plants' ability to prevent severe accidents Dated at Washington, D.C.,
or to mitigate their consequences. Finally, I would initiate enforcement this 7th day of May 1985.
action to ensure that the continuing significant deficiencies in emergency preparedness for the Indian Point site are corrected within the near fu-DISSENTING OPINION OF COMMISSIONER ASSELSTINE' propriate enforcement action until the deficiencies are corrected, as our l
regulations require.
When a previous Commission began this proceeding nearly 5 years I could not disagree more with the Commission's decision tcday in ago, it took the unprecedented step ofinitiating the first reexamination the Indian Point Special Proceeding. The severe accident risks dominate of the safety of an operating nuclear power plant, in its May 30,1980 the risk to the public health and safety associated with the operation of order initiating this proceeding, and in subsequent orders defining the the Indian Point plants. By its actions today, the Commission has decid-se pe of the proceeding, the Commission promised a thorough reap-ed to do nothmg further to improve the ability of the Indian Point plants ,
praisal of the risks to the public posed by the two operating Indian Point either to prevent the occurrence of a severe accident which 1:as the ,
units, of the adequacy of emergency preparedness at the Indian Point potential to harm members of the publie surrounding the plants or to site, and of the need for safety improvements in, or shutdown of, the minimize the public health and nfety consequences of such an accident plants.
at the Indian Potat si te. ,
This reappraisal was to consist not only of a technical safety assess-With the exception of the few measures which the Indian Point Licen-ment by the Nuclear Regulatory Commission Staff, but also of a formal sees have agreed to continue on a voluntary basis, the Commissian has ie adjudicatory hearing before an independent Atomic Safety and Licensing now abarefoned the interim measures adopted by the NRC at the outset Board. This hearing was intended to assure a full public airing of the rele-of this proceeding to improve the level of safety of these plants. The .
vant safety issues regarding the risk posed by the Indian Point plants.
Commission has rejected virtually every initiative proposed by the. NRC .
Members of the public were to be given the opportunity to present their Staff and adopted by the Indian Point Board in this proceeding for I, evidence c9 these issues and to test through cross-examination the opin-improsing public .40tection, and the Commission has effectively ended i ns, judgments and analyses of the Licensees and the NRC Staff. The further efTorts to explore any additional accident prevention and riitiga. 'f}.
lion measures for the Indian Point plants. Finaily, the Commission has j Commission was then to reach its judgment on the need for shutdown in01
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i of, or safety improvements in, the Indian Point units based upon this resignation from the NRC of the Chairman of the Indian Point Board hearing record, and resulted in a delay of several months in resumption of the hearings.2
, All of these steps were taken by the Commission with the realization, I The Commission's decision today represents the final step in the m the aftermath of the Three Mile Island accident, that a serious acci- Commission's return to the attilede of complacency towards safety dent at a nuclear power plant which has the potential to harm the health i which prevailed prior to the Three Mile Island accident and which was a and property of the public surrounding the piant can in fact occur. This I significant contributor to that accident. This proceeding has demonstrat-realization, and the Commission's willingness to undertake a public ed that the risks to the public from severe accidents at Indian Point are airing of the risk of such accidents at the plant with the largest number i substantially higher than believed at the time the Commission instituted of people m its vicinity, indicated a possible change in the Commission's the proceeding. In the face of this knowledge, the Commission chooses approach to safety. It seemed that the Commission was at last willing to 1 to reject even the modest safety improvements recommended by the forsake the complacent attitude toward safety that had contributed so NRC Staff and the Indian Point Board, and to end any meaningful effort much to the Three Mile Island accident. It seemed that the Commission to explore more ambitious safety initiatives for the plants. Thus, the was prepared to probe the adequacy of measures both to prevent serious l Commission has elected to ignore the warnings of the President's Com-accidents from occurring and to mitigate the consequences of such acci- mission on the Three Mile Island Accident. This return to complacency dents should they occur. is most unfortunate in the case of the Indian Point plants and the other This change in the Commission's attitude toward safety was welljusti- operating reactors located in densely populated areas of the country.
fied and long overdue, and the dangers associated with the past attitude it is worth noting that the Indian Point site was Grst selected as an ac-of complacency were clear. As the President's Commission on the Acci- ceptable location for nuclear reactors based upon what turned out to be dent at Three Mile Island put it: an erroneous judgment that containments would maintain their integrity given a core meltdown.8 The Commission in its decision, as did the Aher snany years of operation of nuclear power plants. with no evedence that any Atomic Energy Commission in the mid-1960's, refuses forthrightly to u rIenYy te sre n o a on ion On face up to that misjudgment and rejects the adoption or further explora-sr nNei Nnd nd .]
many key steps that could have prevented the accident at Three Male Island were tion of measures that could reduce the risk to the level that was per-not taken. Tne lPressdent's] Commission is convinced that this attitude must be ceived to be acceptable when the site was first selected.
changed to one that says nuclear power as by its very nature potentaally dangerous.
and, therefore. one must continually question whether the safeguards already in place are sumcient to prevent major accidents A comprehensive system as required The Risk Question at Indian Point in which equipment and human beings are treated with equalimportance.3 Although many aspects of the debate concerning the risk to the public posed by the Indian Point plants are quite technical, the central risk The first sign that the Commission s enthusiasm for this inquiry, as well question and the basis for my fundamental difTerences with the Com-as its new questioning attitude toward safety, was waning came shortly mission niajority, can be stated simply. The record of this proceeding es-a er the commencement of the adjudicatory hearings. On July 27,1982, ;
tablishes that a serious nuclear accident at the Indian Point site could the Commission issued an order which redefined the ground rules for result in thousands of near-term fatalities and thousands oflater fatalities the proceeding, restricted the public's opportunity to obtain a hearing on l '
due to cancers caused by the exposure to radiation. Under certain weath-new proposed safety measures for the plant, and erected new barriers to t/ er conditions, delayed fatalities due to cancers caused by the accident i e public s ability to present evidence m the hearing on the risks posed %% appear to be possible as far away from the plant as almost anywhere in y the Indian Point units. The Commission's July 27 order led to the '
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2 8 opposed the Commassion's hJy 27.1982 order, as dad Commessoner Gd nsky. My weems the Commassace's order are piabtashed enth that order. C-hd f.ases Co. at/ Aew Yart
' Point. Unas2).08.1-32-15.16 NRC 27. 39 (1982).
S 3 David otrent. Nweer Asocar sq/erp: Os she Nasery of the Aerdras,yprocess (The Daevenety of
, Report or the Preandens.
s Commisuon on the Acredens at Three Mac Island at 9 l h Wisconasa Press.1988L Ste. a g pp.46.103-35. and 163-74.
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s At the same time, it is cicar that the potential costs to society from New York City. A significant contributor to the potential for this catas-
, dangerous, low-probability accidents increase dramatically at the high-trophic number of early and late fatalities in the case of the Indian Point ,
population-density sites such as indian Point. Id. at 893-94. The central plants is the size of the population living in the vicinity of the plants. ,
question before the Commission in this proceedmg is how to make dect-The Indian Point site has the largest population density of any nuclear sions on whether to require additional safety measures at the Indian power plant site in the country at distances of 10,30, and 50 miles from the plant.* Point plants, and at other high-population-density sites, given the exist-ing large uncertainties in accident probability estimates and the potential-Admittedly, the likelihood of a serious nuclear accident at the Indian
- ly greater costs to society from accidents at such sites. the uncertainties Point riants resulting in thousands of near-term and later fatalities is I are so large that an objective observer could conclude that a severe accf low. Several elements are needed for such an accident to occur. First, '
dent at the Indian Point plants leading to catastrophic consequences is
, there must be a severe accident at the plant dich leads to mehing of credible, or conversely to conclude it is incredible, depending upon how the reactor fuel. Second, there must be a failure in the containment one views the uncertainties.
structure which surrounds the reactor vessel. Such a failure could occur because of some equipment breakdown or human error which violates the integrity of the containment, or because the sequence of events ; The Treatment of Uncertalaties during the accident leads to a radiation release which in some way by-
- passes the plant's containment system. Equipment failures and human The Indian Point Board factored the uncertainties in risk assessment
- k. into its decision in two ways. First, it reviewed and evaluated the Staft's errors leading to the loss of containment integrity occur from time to uncertainty estimates for the accident risk assessments performed r time at nucicar power plants, the most recent one occurring at the San the Indian Point plants. Although the Board adopted the Staft's high esti-Onofre Unit I plant on February 13, 1985. Accident sequences which mate of risk to account for uncertainty, the Board recognized that he can leau to bypass of the containment system have been identified for U Stafi's estimate was an intuitive judgment on the part of one N the Indian Point plants as well as for other plants. third, weather condi- reviewer and noted that there was no basis for believing that reviewer,s tions must permit the transportation of the radioactive releases from the '
intuition was any better or worse than that of other witnesses. Id. at .
plant to areas of population concentration. Weather conditions, such as it also appears that the Board may have relied upon new source term in-severe winter storms, can also increase the consequences of a severe formation, which has yet to be validated based on accepted scienti c accident by preventing early evacuation of the surrounding population j principles, in deciding not to increase the Staft's upper risk limit by a in some accident situations. The low likelihood of an accident resulting in large numbers of fatalities is based in large measure on predictions substantial additional factor.5 Al.
The Board also considered uncertainties in a second way. Both the thit an accident leading to a core meltdown is itself an event of low Board and the Commission's Task Force on Interim Opervion of Indian probability and/or the assumption that the simultaneous occurrence of a Point recommended that where the consequences of a severe acciden core melt accident, the loss of containment integrity and adverse weather conditions is unlikely. appear to be high, as is clearly the case with the Indian Point plants, L
Although it is relatively easy to predict the consequences of a severe Commission consider measures to reduce the severe accident risks.
l simply, the Board recommended that the Commission consider pursuin accident at the Indian Point site given various assumptions concerning i additional safety measures at the Indian Point sne m recognition o the type of accident, containment performance and weather conditions, it is far more difficult to predict with any degree of accuracy the proba- fact that such an accident could result in much more serious cons quences than at sites with lower population density. Id. at 893-94.
bilities of these events occurring. Indeed, the Indian Point Board ex- It s of fundamental importance in this proceeding, as well as in o pressly recognized the large uncertainties involved in efforts to predict Commission regulatory activities, that the Commission factor mto i the hkelihood of core melt accidents, containment performance and w=ther conditions. Opinion,18 NRC at 872,878-81. ,
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" our Advisory Cora- have agreed to continue voluntarily, to be unsupportable. The Commis-Ini tee o Reactor Safes ard ee I d h deep problems involved in the regulatory use of ri sion's decision is particularly ill-advised in the case of the proposed Safety Assurance program and the filtered vented containment.The pro-stonmaking in the face of uncertainty. We recommend th t he C deg:.- "
s on posed Safety Assurance program, which was recommended by both the opt a position on this point and make it clear to the NRC S - NRC Staff and the Indian Point Board, contained a number of elements mmission has adopted a position on uncertaintI in his deci-intended to address the potential for human error and equipment failures sion. Unfortunately, in deciding not to consider th ""' I which can contribute to severe accident risk. The objectives of this pro-society of dangerous, low-probability accidents' and "
those safety improvemems for the Indian Point i C3 CI gram were to bring about improvements in key areas of human perform-n by ance and equipment reliability, to improve and refine our understanding the NRC Staff and the Indian Point Board the C ' " I' of accident risk estimates for the Indian Point plants and to reduce fect, chosen to ignore the large uncertainties inh ' -
m EcAral and in the specific risk assessments considerj '9 where possible areas of existing uncertainty in current risk assessments.
" A significant potential ben: fit from this proposed program was to be that inst. More than anything else, this aspect of the Co the results of the program could be factored into the detailed r;sk assess-f e s a returnperiod,to the unquestioning complacency n ident r s s of ments performed for the Indian Point plants. These nsk assessments c uld then be more than just liled away and used as a justification for
. I simngly support the Board's recommendation that the C .."
give senous consideration to the potential costs to soe
some bottom-line judgment on the accident risks at the Indian Point low-probability accidents at Indian Point. Given th
" plants. Rather, they could become continuing and useful tools for iden-n a potennal areas d safety weakess in the plants.
((; f in ri{k assessment and the serious potential cons ue es of an As a result of the Commission's decision, these benefits will now be lost.
san Point, I beheve it is both rud consider additional improvements which could redu e a agree w e ar s mdush mat a Stered vemed contain-t he ikel ment or a separate containment system should not be required at Indian an consequences of such an accident. ]
i Point Units 2 and 3 at this time. Ilowever, I am concerned that, contrary to the Board's assumption that "the Staff (and the Commission) will
&fety improvements reexamine our conclusion" (18 NRC at 920), specific evaluation of such systems at Indian Point will now be delayed indefinitely. The arguments The Indian Point Board considered a number of 8 dt i
re uce the like! hood and consequences of an ac ide t aga nst the use of a filtered vented containment presented by the Staff 1 " and Licensees in this proceeding were generic and addressed concepts p ants. These included: the measures required 'he "
I1,1980 order by the Director of the Office of Nuclea; rather than specific proposed designs for installation at Indian Poir.s. Be-8 - cause of this, I conclude that such systems have not been explosed suffi-tion; additional mitigative design features; the Safe: A " "
gram; measures to reduce tornado risk; a filtered y P ciently to support a firm decision that they should never be required at d ' " Indian Point. The Board appeared to share this view in its recommenda-system and separate containment structure; and addelional s ""
tor requirements. I agree with the Indian Point Bo d ti n against requiring such systems "at this time."
and Th Staff and Licensees pointed out that the use of a filtered vented elits of, those safety measures which were reco mended y th e ntainment or a separate containment system might reduce latent ition I agree with the Board's judgment that fu cancer fatality risk by as much as a factor of 5 and that the costs of such sideration should be 1,iven to a littered vented contain ent system and separate contain nent structure. I systems would probably be in the tens of millions of dollars. For a site located in densely populated areas, such a reduction in risk might be I find the Commission's decision to reject all of the safe' l ments recommended by the Board, save those few which the worth the costs.The issue should at least be considered furtt.cr.
'8
- Accordingly, I would have directed the Staff to develop a plan for a
' more detailed evaluation of the risk reduction potential and the costs (to C*""'"=== d**d semii n,1,85. Acas c ? NRC and the Licensees) oflittered vented containments or separate con-a O""sNn%"5 "" .. o, ,%
, tainment systems for Indian Point Units 2 and 3. Furthermore, I would P
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4 October 12, l'35 Honorable Nunzio J. Palladino Chairman U. S. Nuclear Regulatory Comission Washington, D. C. 20555
Dear Dr. Palladino:
Subject:
INDIAN POINT SPECIAL PROCEEDING We recognize that the Comission has acted on the Indian Point Special Proceeding but believe that it is worthwhile to provide some coments and recomendations for your further reflection. We shall not go into details of the proceeding but deal only with relatively broad consid-erations, as follows:
- 1. Mr. Rowsome of the NRC Staff testified that Indian Pgint Unit 2, has a median frequency of core melt of roughly 4 x 10~ per reactor year for the "after fix" staff analysis described in the NRC testimony on Comission Question One, with a similar result for Indian Point, Unit 3. If this value were approximately represen-tative of the U. S. light water power reactors, it would suggest a chance of about one in two of a core melt accident by the year 2000 and a likelihood of essentially unity over the life of the current LWRs.
The uncertainties in the estimate for Indiar. Point are clearly large, with some factors pointing to possible overestimate and others to underestimate.
We believe that, especially for a high power nuclear power plant at one of the most highly populated sites in the U. S., the NRC shuuld continue to strive for a substantial reduction in both the pre-dicted core melt frequency and the uncertainty therein.
l Indian Point, Units 2 and 3, are evaluated by the Licensee and the NRC Staff as having a relatively effective containment in the presence of many, if not most, severe core accidents. However, these analyses rest on incompletely understood phenomena, on generic rather than detailed examinations of containment (and plant) behavior, and on an incomplete set of accident scenarios.
Mr. Rowsome stated that he would be only mildly surprised if the .
consequences were a factor of 40 higher (or 200 lower) than the NRC Staff estimates.
Y ,
Honorable Nunzio J. Palladino 2. 'The NRC Staff did not recomend design or operational improvements for the Indian Point units except for a reliability assurance program. However, they stated that, "it is the ensemble of evi-dence and the continued use of the PRA as a risk management tool (the safety assurance program) . . . that supported the staff recomendations." The majority of the ASLB recommended in favor of a filtered venting concept in view of the large uncertainties in the risk assessment and the high surrounding population density.
The Comission itself teok a position less conservative than either the Staff or the majority of the ASLB.
- 3. Since the Staff testimony at the Indian Point hearings, senior members of the NRC Staff have written coments in connection with consideration of the NRC Safety Goals which are possibly at odds with the Indian Point decision. The Safety Goal Task Force, which includes Messrs. Murley, Rowsome, and Ernst, among others, raised the core melt frequency objective to first line status. Mr. Ernst and Mr. Minogue, in memoranda of May 10, 1985 and May 21 both support working toward the core melt safety goal of 10,j985, per reactor year for existing nuclear power plants. Mr. Denton, in his memorandum of June 12, 1985, recomends a still more stringent core melt goal for existing plants.
- 4. In its report to you of July 17, 1985, the ACRS expressed its belief, "that the Comission frequency of not more than 10~ghould state that per reactor yearaismean-core-melt an NRC objec-tive for all but a few, small, existing nuclear plants, and that, keeping in mind the considerable uncertainties, prudence and judgment will tend to take priority over benefit-cost analysis in working toward this goal."
- 5. We strongly support this ACRS position, and median estimate core melt frecuency of 4 x 10~ge perbelieve reactorthat a year (with very large uncertainties?, for a high power plant at one of the most densely populated sites in the U. S., is too large for the long tenn and represents a situation requiring specific attention.
While we agree that it is acceptable for Indian Point Units 2 and 3, to continue to operate, we recommend that the Comission require that both the Licensee and the NRC Staff develop, on some reason-able schedule, a plan for work intended to reduce both the esti-mated core melt frequency and the uncertainty therein. In addi-tion, we believe that detailed containment perfonnance evaluation should be given particular emphasis at sites like Indian Point. It is our belief that Comission policy should reflect prudence and come down on the side of safety, where the uncertainties remain la rge , giving appropriate consideration to both prevention and
1 Honorable Nunzio J. Palladino mitigation. We believe that, particularly if innovative approaches are ;
used, significant improvements in safety are achievable for Indian :
Point. Units 2 and 3, at reasonable costs.
Sincerely,
[Tavid Okrent, University of California Los Angeles, California m . 2-Tse C. Ebersole, Tennessee Valley
[ Authority, retired, Knoxville, Tennessee V h Dade W. Moeller, Harv~ard Tnivers' ty Boston, Massachusetts
. h L s. A J Glenn A. Reed, W'sconsin Electric Power Company, Retired Two Rivers, Wisconsin 4_b [+
Charles J. Ky ie, L
uke r company.
Retired, Cha te, arolina cc: Comissioner Roberts Comissioner Asselstine Comissioner Bernthal Comissioner Zech I Other Members of the Advisory Comittee on Reactor Safeguards