Agenda - 04-07-1999 - Laserfiche WebLink

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Chairman Shirley A. Jackson Commissioner Nils J. Diaz Commissioner Greta J. Dicus Commissioner. Edward McGaffigan, Jr. Commissioner Jeffrey S. Merrifield United States Nuclear Regulatory Commission Washington, DC 20555-0001 SUBJECT: CURRENT EXAiN17PLE OF.RISK-DEFORMED REGULATION Dear Chairman and Commissioners: During the January 1 l~' 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 staff.have 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' and `D' at the Harris 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 fuel pool /loss of spent fuel pool cooling flow / 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 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' and `B' will be used in pools `C' and `D.' Since 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 Office: 1616 P Street NW Suite 310 . Washington [)C 20036-1495 .202-332-0900 .FAX: 202-332-0905 Cambridge Headquarters: Two Brattle Square .Cambridge MA 02238-9105 .617-547-5552 . FAX: 617-864-9405 California Office: 2397 Shattuck Avenue Suite 203 .Berkeley CA 94704-1567 .510-843-1872 .FAX: 510-843-3785