Agenda - 11-17-1998 - 5a - Laserfiche WebLink

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28 Nuclear Wasie Orsposal Cnsrs Iv, the usability of the SSES containment .vstrms to limit the release of radiuachve material following an accident invoh•ing fuel damage. These systems fail due to design deficiendes associated with the coolinn of the spent fuel pools as described in Chapter 9. The NRC reyie«~ed the Susquehanna concerns and concluded that although the SSES design did nut conform to numerous federal regulations in effect at the time the plant vas designed and constructed, these safety regulations no longer applied to this facility since both the o~~'ner of the plant and the NRC had failed to detect the nun-conformance at that time. Apparently, in the \RC's eves, igno- ranee of the la~.• is an excuse---e'en though the ~iRC cited noncompliance with safety regulatiuru as a contributor to the wont accident in nuclear power histo- rv: "The evidence from the accident suggests that Chernobyl [;nit 4 vas nut in compliance with ... specific requirements in the 1982 regulations."' The NRC further concluded that nonconfurmances at SSES represented re!- atiyely minor safety significance. The NRC based its safety conclusion on a risk assessment indicating a very low probability of SSES encountering a boiling spent fuel pool. Hu~•~ever, this risk assessment ~.•as predominately biased tu~vards the SSES configuration after numerous plant modifications, analyses, procedure changes, and retraining had been implemented addressing the defi- ciencies. The NRC's evaluation significantly underestimated the risk at the time of discovery. The NRC's bias is important because it misrepresents the risk from the design deficiencies-problems that may remain uncorrected at numerous other operating nuclear power plants similar to SSES. The NRC essentially determined that satisri~ing only the first two defense- in-depth principles is adequate; apparently the public and the environment no longer warrant protection from the release of radioactive material following an accident with fuel damage. However, this determination conflicts v`~ith the stan- dard American defense-in-depth risk management philusophv and more closely resembles the Chernobyl design philosophy: Suyiet safety analysis tends to place greater emphasis un prevention and early mitigation of selected design-basis accidents than it dues on the con- sequernes and mitigation of se~•ere accidents beyond the design basis of the plant= The Chernobyl design philusophv was roundly criticized in the west lincluding critical ~vurds by the \P.C). vet it nu~~• seems that ~~•e are embracing it. The Chernobyl design philosophy isn"t cup~'righted, so at least we won't pay extra fur less protection. (ndicidual Plant Examinations ([PEs) provide further evidence that the ~RL is neglecting the third defense-in-depth principle. [PEs are plant-=peck probabilistic nsk assessments ~~t the cure damage frequencies from design bast r~. ents. IPEs evaluate the plant's response to postulated initiatins; e~'ents, factor- in~ in r~lwpment failure r;~tes and uperah~r rrn~n ' (i~7