Images de page
PDF
ePub

23

quantitative information on the types of
containment failures and their relative
likelihood and importance will be provided in
the staff report NUREG-1150....

For PWR's with "large, dry" and

"subatmospheric" containment designs [like
Seabrook], early failures to the atmosphere
have been predicted to result from accident
phenomena such as direct heating, steam
explosions, and coincidence of hydrogen burns
and rapid steam generation. For most plants
with a large dry containment, the likelihood
of these events including an early containment
failure is quite small.

The above comments demonstrate that there are no ready answers to questions regarding containment failure. If the NRC is unable to supply any hard numbers and is reduced to citing analytical uncertainties and studies in progess, it is difficult to understand how in three short months PL&G could accomplish an analysis sufficiently well-grounded to warrant a change in emergency planning regulations for the Seabrook plant.

POTENTIAL TECHNICAL PROBLEMS WITH THE UTILITY'S CLAIMS

The utility's consultant has asserted that the pressure at which the containment would fail is significantly higher than for most other similar large dry containment pressurized water reactors. They attribute this greater strength to several factors, including a larger than average containment volume and more steel used in the construction of the containment. The Subcommittee staff questions whether PL&G has failed to consider adequately a number of significant phenomena and possible reactor accident scenarios, several of which could possibly result in outcomes very different from those cited by PL&G. A few examples of these technical questions may be summarized briefly as follows.

(a). The conclusions of the PL&G report depend crucially on the assumption that the containment failure pressure is roughly 225 psig. This value is much higher than the estimated containment failure pressures for other plants, and may not be adequately supported. In addition, containment failures generally may be assumed to occur at points of structural discontinuity

[blocks in formation]

(e.g., where piping enters or exits the containment). Even if the shell of the containment is stronger than average, one does not expect a shell rupture to be the first failure point of the containment.

(b). PL&G examined only one containment bypass scenario; however, other bypass scenarios may well be relevant and could produce releases greater than those estimated in the PL&G study.

(c). PL&G has argued that if noble gases are released from the containment after an accident, the containment will hold them long enough to permit decay to levels low enough to warrant a reduction of the EPZ. However, emergency planning as currently conceived assumes that off-site dose-response relationships must be examined without any protective actions. It appears that if noble gases are released without a significant delay, under various realistic worst-case weather scenarios, the acceptable off-site dose levels might well be exceeded at 10 miles.

(d). Assumptions about the radioactive inventory released under high pressure melt ejection scenarios may not be consistent with recent analyses conducted by Sandia National Laboratory on these phenomena.

(e). The report may not adequately consider the prospects that accident recovery actions could cause steam de-inerting by condensation, leading to hydrogen burns or detonation within the containment.

(f). In examining earthquakes as a contributor to radioactive release scenarios, the report may not adequately consider after-shocks while the containment is pressurized, which adds an impulse pressure load.

(g). The report's conclusions on radioactive releases as a consequence of steam generator tube ruptures may not be consistent with recent analyses conducted by Battelle Columbus Laboratory on steam generator tube rupture scenarios.

In summary, it appears that PL&G may have been selective about their assumptions; if one made other, equally reasonable assumptions, the outcome might be much different.

[merged small][ocr errors]

CHRONOLOGY OF KEY MEETINGS/DISCUSSIONS INVOLVING
NRC AND PSNH AND FEMA STAFF RELATIVE TO REDUCED EPZ

July 30, 1985

September 9, 1985

October 10, 1985

October 11, 1985

October 22, 1985

November 26, 1985

11

NRC/PSNH meeting discussion of SSPSA submittal according to NRC this included "the regulatory process including the reassessment of emergency preparedness requirements"

NRC/PSNH staff and counsel conference call --
Discussion of a possible rulemaking petition and
idea that a 10-mile EPZ is not necessary at
Seabrook -- based on source term research

PSNH counsel, and NRC legal staff discussion
"reduce or eliminate the entire EPZ - Taking
Seabrook PRA applying new source term data

...

Discussion that "once technical analysis is done
subject to peer review group if the peer review
group raves, then sometime in Nov. 1985 will come
in with a package"

-

NRC/PSNH staff conference call NRC staff notes that feedback about the approach Seabrook was taking on demonstrating the ability to reduce the EPZ appeared to be different from what he understood in an earlier discussion (with PSNH staff)

(NRC staff) noted that what he explained to (PSNH staff) in previous discussion was that the approach Seabrook will need to take is to compare the risk of Seabrook to the risk of typical reactor (WASH 1400) used as a basis for the regulation. (NRC staff) suggested Seabrook review NUREG-0396 the comparison it would be good to compare feature by feature"

[ocr errors]

in

"(NRC staff) said Seabrook should not be developing
the case that Seabrook ..." (incomplete note)
Seabrook coordination meeting with FEMA, NHY, NH
and MA state civil defense staffs Includes
discussion of impact of the probabilisitic risk
assessment on emergency planning issues

FEMA staff notes that Brookhaven is reviewing the containment and time-to-failure aspects of the PRA

Discussion of the size of the EPZ and legal
analysis work

Seabrook coordination meeting with FEMA, NHY, NH

[merged small][ocr errors][merged small]

December 1985

February 1986

April 1986

July 9, 1986

July 21, 1986

July 25, 1986

July 29, 1986

CHRONOLOGY 2

and MA state civil defense staffs Further
discussion of the PRA and impact on emergency
planning issues

"Seabrook Station Risk Management and Emergency Planning Study," Pickard, Lowe, and Garrick

NUREG/CR-4540, "A Review of the Seabrook Station
Probabilistic Safety Assessment: Containment
Failure Modes and Radiological Source Terms,"
Brookhaven National Laboratories

"Seabrook Station Emergency Planning Sensitivity
Study," Pickard, Lowe, and Garrick

NRC, PSNH, PL &G meeting to discuss PSA program
PSNH submits the Risk Management and Emergency
Planning Study (RMEPS) and the Seabrook Station
Emergency Planning Sensitivity Study to NRC for
review

11

NRC staff meeting "(PSNH staff) says before they go for it give them a reading by October what are the merits of this piece of work -- does it provide some basis to go forth with exemption"

NRC staff notes "What do we [Emphasis added] have to justify to change EPZ? ... need to consider technical and legal" (emphasis in original)

PSNH requests that NRC expedite the technical
review of RMEPS as follows:

"A future submittal, depending on the results of the technical review, may request a change to the emergency response plan process for Seabrook Station. We cannot, at this time, specify what action such a future request may seek, but it is important that we address as soon as possible what options are available to us relative to full power licensing. This is important in light of the apparent strategy of the State of Massachusetts to delay the process." (emphasis added)

-

July 18 or 29, 1986 NRC staff meeting "(NHY) wants to know if this

could serve as a technical argument. If not, he won't file. Point out which technical arguments are good vs. no"

"Seabrook has thrown away containment failure"

"Did they include any real data vs. generic May have to go back and tidy up PRA, but probably not"

[blocks in formation]

August 5, 1986

August 6, 1986

August 6, 1986

August 11, 1986

August 13, 1986

August 14, 1986

August 27, 1986

NRC Staff and PSNH meeting "NRC is beginning an expedited review of the study to assess the technical adequacy of PSNH's analysis to support the study's conclusions."

Brookhaven National Laboratories (BNL) compiles project description for Review of the Emergency Planning Sensitivity Study for Seabrook

NRC Staff, BNL, and PSNH onsite walk through
"Objective to reexamine emergency planning basis
wanted enhanced mathodology for site specific
planning determine risk impact of different
options"

-

Internal NRC staff memorandum "It is important to decide what direction NRC is going to take on this issue before a detailed technical review can start. A decision chart set up in the form of three questions is attached for your consideration"

NRC staff notes -- PSNH request - "NRC will give them top priority preliminary review in months normally takes

"Sense of urgency
licensing"

...

out of ordinary"

no discussion of it holding up

"There are so many options get rid of Mass. so they don't have to submit" (emph. added)

Meeting at BNL with NRC staff and PSNH NRC staff notes "Do review in short period of time to get positive response or questions needed to get there"

NRC staff - "Unique features of Seabrook containment Let's try to make it more unique show it's better than average" (emphasis added)

-

NRC staff and PSNH meeting "Review group to (NRC
staff), coordinated with the utility, with a list
of goals
We need to think about what this group
can do in 3 months"

...

88

"What are possibilities 3 mile EPZ with plume?

[ocr errors][merged small][merged small]

"Shrinking of planning zone vs. evacuation zone may be able to reduce evacuation zone but not planning zone" (emphasis in original)

...

« PrécédentContinuer »