Agenda - 04-07-1999 - Laserfiche WebLink

Browse Search

January 22, 1999 Page 2 of 2 It is precisely this type of "smoke and mirrors"shenanigans that we decried during the briefings. The logic seems proper at face value, but it does not take much effort to show that it is wrong. In Enclosure 1 to the license amendment submittal, the licensee reported that the total storage capacity of pools `A' and `B' is 3,669 assemblies and that the proposed activity will add 4,715 storage locations in pools `C' and `D.' Thus, if the amendment is granted, CP&L will handle -pick up and move -about twice as many irradiated fuel assemblies as they will if the amendment is not granted. Consider for a moment the old game of Russian roulette using asix-chamber revolver loaded with a single bullet. CP&L and the NRC staff would apparently conclude that the probability of losing the game are not increased whether one or two turns are taken because, after all, the same method and the same equipment are used each turn. Their logic is simply wrong. The probability of a fuel handling accident at Harris will nearly double if the license amendment request is granted. This material fact contradicts the conclusion of the licensee and the staff that there will be "no significant increase in the probability," unless doubling the risk is not significant. Luckily, there's an opportunity to fix the mistake this time. Unfortunately, it's not the first, and probably won't be the last, time this mistake is made. The NRC staff made this same mistake in April 1998 when it allowed the Paducah facility to continue operating with its risk doubled. We have no intention at this time of formally intervening in this Harris licensing action. We trust that the NRC staff will take the necessary steps to have the licensee fix the fundamental flaw in the licensing amendment request before granting it. Sincerely, Q ti ~~ ~ ~ ~~~ David A. Loch aum Nuclear Safety Engineer