October 19, 2000
The
Honorable Richard A. Meserve
Chairman
U.S.
Nuclear Regulatory Commission
Washington,
DC 20555-0001
Dear
Chairman Meserve:
We are writing to you in reference
to a serious issue concerning the safety of pressurized-water reactors (PWRs)
with ice condenser containments.
This issue, the high susceptibility of ice condenser
containments to early failure from hydrogen combustion during a severe accident,
has come to our attention through documents released by the NRC in the last
few months. In particular, a new technical
study conducted for the NRC by Sandia National Laboratories (SNL),
Assessment of the DCH Issue for Plants with Ice Condenser Containments (NUREG/CR-6427),
finds that "ice condenser plants are at least two orders of magnitude more
vulnerable to early containment failure than other types of PWRs."
[1]
In view of these alarming new findings, which
call into question the ability of ice condenser containments to provide adequate
protection of the public health and safety, we urge the Commission to take immediate
action to mitigate the risk of catastrophic, loss-of-containment accidents at
the nine U.S. ice condenser units.
The vulnerability of ice condenser plants to early
containment failure in a severe accident is of particular concern in view of
the impending use of mixed plutonium-uranium (MOX) fuel at the McGuire and Catawba
plants, operated by Duke Energy. A study
by the Nuclear Control Institute (NCI), released last year and scheduled for
publication in a peer-reviewed journal, calculates that implementation of Duke
Energy's MOX plan would significantly increase (by 25%) the number of latent
cancer fatalities resulting from a severe accident with early containment failure
at McGuire or Catawba, because of the greater quantities of plutonium and other
actinides that would be released into the environment.
In addition, many issues remain to be resolved regarding the potential
for MOX fuel use to increase the probability of a severe accident.
Given these additional risks and uncertainties, the use of MOX in the
type of PWR that is most vulnerable to early containment failure will make an
already risky situation even worse and should no longer be considered.
The report NUREG/CR-6427 finds that the lower volume and strength of ice condenser containments
render them less resistant than other types of PWR containments to the overpressures
that would be generated by credible hydrogen combustion events.
While the presence of hydrogen control systems (glow plug igniters) can
mitigate this risk, they require AC power supplies and thus would be inoperable
in station blackouts (SBOs). Consequently, the calculations presented in
NUREG/CR-6427 (Tables 4.21, 4.24 and 7.4) indicate that if an SBO occurs, the
early containment failure probability ranges from 27% to 97% for U.S. ice condenser
plants. For Catawba and McGuire, the
probabilities are 34% and 59%, respectively. If an SBO occurs and the vessel ruptures at
high pressure, the failure probabilities are 100% and 98%, respectively. These results indicate that defense-in-depth
is seriously compromised at ice condenser plants.
We are aware that the Commission has recently received
an NRC staff paper that recommends that, as part of a "risk-informed"
revision to the NRC's rule on combustible gas control (10 CFR 50.44), a requirement
should be added for ice condenser plants to maintain a capability for hydrogen
control during all risk-significant core-melt accidents, including SBOs.
[2]
However, since such a requirement would be
voluntary on the part of licensees, we would go further than this recommendation
and urge the NRC to transfer this issue to the generic safety issues (GSI) program
for determining on a high-priority basis the need for imposition of mandatory
backfits at ice condenser plants. There should be a separate determination of
this need for Catawba and McGuire, comprehensively taking into account the additional
safety risks associated with the planned use of MOX fuel at these plants.
It is highly unlikely that the unacceptably large risk
of early containment failure at ice condenser plants can be mitigated merely
by an attempt by licensees to show that the SBO frequency is low, a possibility
that the NRC staff has suggested. SBOs
can result from a wide range of external events, such as seismic events, that
are hard to predict accurately. Moreover,
an important precursor to an SBO, a loss of off-site power, can be caused by
a sabotage attack outside the protected areas of the plant.
Such attacks cannot be prevented with high assurance, and their likelihood
cannot be quantified. In this scenario, a robust containment is the
major line of defense.
Even if the NRC takes action to reduce the risk of
early containment failure at ice condenser plants during SBOs, it remains to
be seen whether the resulting plant risk will be small enough to offset the
increased risk associated with MOX use. The
fact will remain that ice condenser containment buildings are only half as pressure-resistant
as other types of PWR containments. Moreover, the assumption made by NUREG/CR-6427
that the ice condensers themselves will function properly to mitigate the threat
of steam explosions is itself open to question. In our view, these plants will never be safe
enough to accommodate MOX, and we are hopeful that the NRC will eventually reach
a similar conclusion when it faces the challenge of approving license amendments
to permit the use of MOX at Catawba and McGuire.
Since the results of NUREG/CR-6427
clearly constitute significant new information pertaining to the safety of using
MOX fuel in Catawba and McGuire, we have requested that the Department of Energy
(DOE) prepare a supplement to its November 1999 Surplus Plutonium Disposition Final Environmental Impact Statement (EIS)
to
take the new findings into account. The
reactor safety analysis in the Final EIS was based on the Catawba and McGuire
Individual Plant Examinations, the results of which are called into question
by the new SNL analysis. While DOE would
be the lead agency in preparing such a supplement, we expect that the NRC will
play a key role in providing DOE with the most recent technical information
necessary for the analysis.
We urge the NRC to act in a timely manner to address
the critical safety issues posed by the inadequacies of ice condenser containments
and the synergistic impacts of MOX use in such plants. In the event that the NRC fails to do so, we
are reviewing our options for action under the applicable regulations. We look forward to receiving your prompt reply.
Sincerely,
Edwin S. Lyman, PhD
Scientific Director
[1] M. Pilch, K. Bergeron and J. Gregory, Assessment of the DCH Issue for Plants with Ice Condenser Containments, NUREG/CR-6427, SAND99-2553 (Albuquerque, NM: Sandia National Laboratories, April 2000).
[2] U.S. Nuclear Regulatory Commission, Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control), SECY-00-0198, September 14, 2000.